A newly published interim final rule on safe management of recalled airbags supplements EPA’s June 2017 and July 2018 memos on the topic is available here. The Nov. 30 rule focuses on parts subject to Takata-related recalls where Espeel has determined that Takata parts are not suitable for onsite deployment.
The upshot of the new interim final rule is this:
1. Non-Takata recalled and non-recalled waste (discarded or no longer suitable for use) airbag modules may be safely deployed onsite if the resulting residue is recycled as scrap metal.
2. Takata-related airbag parts should be managed consistent with vehicle manufacturer instructions as set out in dealer recall notices or elsewhere. Vehicle manufacturers should compensate their dealers for the cost of proper recalled airbag parts management.
3. The interim final rule exempts dealerships from certain hazardous waste management mandates. Specifically:
• Airbags do not count toward a dealership’s monthly hazardous waste quantity;
• A maximum of 250 parts may be accumulated at once, for no more than 180 days;
• Parts shipped offsite must comply with hazmat shipping rules, and be marked “Airbag Waste: Do Not Reuse.” )They must be shipped to a facility under a vehicle manufacturer’s control or otherwise arranged in connection with a recall, or to a permitted hazardous waste treatment, storage or disposal facility; airbag waste shipment records must be kept for at least three years).
Questions on the interim final rule may be directed to firstname.lastname@example.org ,or (703) 821-7040.Download Bulletin PDF