ECAR Fact Sheet for New York
Air Bag Cartridges

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

Air bags are compromises.  Cars are equipped with them in order to try to make the best of a very bad situation (a collision).  But the air bag cartridges contain an explosive chemical, sodium azide.  If the air bag has not been deployed, the material is dangerous to handle.  It can explode, it can cause burns if it gets on unprotected skin, and it can severely irritate the lungs if inhaled.  You don't want undeployed cartridges going through your crusher.

If the air bags have been deployed, the material is no longer dangerous, and you will not have to take special precautions.  But many vehicles now contain multiple air bags (side air bags, for example).  Any undeployed air bags must be removed from the vehicle.

Once you have removed the intact cartridges, you can send them to a reclamation facility.  If you do, you will not have to treat them as a hazardous waste.  However, if you send them off-site for disposal, you will have to follow the hazardous waste rules.

Regulations

Air bag cartridges that have not been deployed are a hazardous waste unless they are reclaimed. If they are reclaimed, they are not a hazardous waste.

If you plan to dispose of air bag cartridges, follow the storage, transportation, recordkeeping and reporting rules for hazardous waste.

If a vehicle contains a deployed air bag, the air bag does not need to be removed prior to crushing.

Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste.

New York Conservation Rules and Regulations on Hazardous Waste Management (NYCRR 373)

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your procedures for air bag handling procedures.

1. If the air bag or air bag cartridge will be sent off-site to a reclamation facility, verify that:
   • The air bag/cartridge was sent to a facility capable of reclaiming the items.
2. If the air bag or air bag cartridge will be sent off-site for disposal, verify that:
   • The air bags/cartridges were managed on-site as hazardous waste, which includes proper storage.
   • The air bags/cartridges were sent to an approved landfill using the appropriate procedures.
   • Hazardous waste recordkeeping and reporting requirements have been satisfied.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don't explain how to do it. That's where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there.

The following BMPs are recommended for the management and recycling of air bags:

• Leave deployed air bag units in vehicles since deployed air bags do not pose a risk to human health or the environment.
• Store non-deployed air bags indoors, protected from the weather until they can be resold.
• If you send air bags, have retained shipping papers that indicate the name of the declaimer, the date of transfer, and the quantity of air bags/cartridges shipped.

Contacts

1. For general questions, contact DEC Solid and Hazardous Materials Program at 518-402-8651.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Automobile Recycling home page
2. New Requirements for Vehicle Dismantlers
3. A Quick Look at Your Automobile Recycling Facility
4. Forms for Auto Recyclers
5. Summary of Laws, Rules and Regs Relating to Auto Recyclers
6. Resource Guide for Auto Recyclers

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