AIRBAGS

MANAGEMENT of NON-DEPLOYED OEM AIRBAGS
FOR AUTOMOTIVE RECYCLERS

Position/Issue

The Automotive Recyclers Association (ARA) states that reusing nondeployed original equipment manufactured (OEM) airbags is a viable, environmentally –friendly, economical, and safe alternative to using new, more costly OEM airbags when the recycled airbags are properly matched, handled, and installed. The National Highway and Traffic Safety Agency (NHTSA) agrees that the key to the safety of recycled airbags is the proper matching, handling and installation of the recycled airbags.

Federal and State Regulations

The Federal Motor Vehicle Safety Act directs the US Transportation Secretary “to prescribe safety performance standards for used motor vehicles, in order to encourage and strengthen state motor vehicle inspection programs.”

http://www.gao.gov/new.items/d01225.pdf This provision gives NHTSA the authority to develop safety standards for occupant restraint systems, which might incorporate airbags. NHTSA however, has not developed such standards because it has not identified significant problems with occupant restraint systems that could be addressed by state motor vehicle inspection programs. The agency has, however, determined that water damage can undermine the performance of airbag systems. http://www.a-r-a.org/files/gao_report.pdf

States are also involved in the regulation of aftermarket crash parts and recycled airbags. According to the Automotive Service Association (ASA), forty-four states currently have laws governing the use of replacement crash parts. Specifically ASA found that thirty-six states require notice to consumers when aftermarket crash parts are used, seven require notice and consent of the consumer and eight states do not require any notice or consent. http://www.asashop.org/takingthehill/replacement.htm New York is the only state that has enacted a law restricting the sale and installation of recycled airbags.

Also, the National Conference of Insurance Legislators (NCOIL) recently approved an airbag fraud model, which would make it a felony to possess or sell a stolen airbag or to fraudulently install an airbag. The model bill also requires that labels be placed on the dashboard of cars if non-deployed OEM airbags are used in the car.

Practice

As a proactive measure to ensure safety standards are met, ARA launched ARAPro™ in 2006. The ARA’s Airbag Protocol (www.airbagresources.com) was developed as a national standard to ensure best management practices (bmps) are applied to the process of extracting, handling, inspecting, and storing recycled OEM non-deployed airbags from salvaged vehicles. Using the Vehicle Identification Number (VIN) as well as other interchange reference sources, ARAPro™ enables the repairer to accurately match the make, model, and year of the replacement component to the vehicle under repair.

ARAPro™ Airbags, the brand name that applies to recycled OEM non-deployed airbags complying with the Airbag Protocol, are supplied with a certificate that can ultimately be used by a state DMV’s to verify that a Protocol compliant OEM non-deployed airbag has been used in the repair.

When managing the airbag component system, the dismantler/recycler needs to be familiar with the basic contents of an airbag.

Description of Airbag Components

There are three parts to an airbag.

• The bag itself is made of a thin, nylon fabric, which is folded into the steering wheel or dashboard or, more recently, the seat, door and/or headliner.

• The sensor is the device that tells the bag to inflate. Inflation happens when there is a collision force equal to running into a brick wall at 10 to 15 miles per hour (16 to 24 km per hour). A mechanical switch is flipped when there is a mass shift that closes an electrical contact, telling the sensors that a crash has occurred. The sensors receive information from an accelerometer built into a microchip

• The airbag's inflation system uses a propellant to inflate the airbag.
  

For a more complete description of airbag content and use, see:

http://auto.howstuffworks.com/car-driving-safety/safety-regulatory-devices/airbag1.htm

Airbag Inflators

It is the content of the inflators that dictate safe handling and disposal practices. Specifically, environmental regulators and automotive recyclers alike are concerned about whether and when the contents of the airbag inflators are defined as hazardous waste.

Airbags need propellants to deploy. Propellants containing sodium azide (NaN3) were common in early inflator designs, however, sodium azide is highly toxic and considered as hazardous waste. Propellants containing this compound were phased out during the 1990s. More efficient, less expensive and less toxic alternatives are now used that are not considered hazardous waste. For example, many inflators now use canisters with compressed air. http://www.aorc.org/airbag.asp.

Many states however, continue to promote airbag deployment best management practices that only apply to those bags with the sodium azide propellant. These bmps recommend deploying airbags with inflators containing sodium azide before a vehicle is crushed or dismantled because once deployed, the inflator material is no longer considered dangerous. In fact, five states (VT, OR, MN, DE and NY) have enacted legislation that mandates that airbags with sodium azide be deployed or removed from a vehicle before it is wrecked or dismantled (see links to each of the 5 states’ policies below). No federal mandate however, exists regarding inflator content/deployment policy.

Airbag Management During Dismantling/Recycling Process

Specific steps should be taken to safely manage airbags during the dismantling and recycling process of end of life vehicles.

When recovering intact airbags for reuse, first check the airbag manufacturer specifications to determine the content of the airbag inflator. If the inflator contains sodium azide then follow your state guidelines for handling. If sodium azide is not present, then follow these best management practices:

1. All employees involved in extracting, inspecting, handling units should be trained & certified. (e.g. for CAR certification, facilities need to have documentation that a trained employee is available to ship air bags and has completed or been trained by a certified trainer in hazardous materials shipments. You should be able to show a certificate for each employee involved. Most training will probably be from an industry-led or internet training course.)
2. Store non-deployed air bag units indoors, protected from the weather until they can be resold or disposed of properly. Non-deployed air bags are valuable, so do not deploy unless necessary.
3. If the air bags have been deployed, the material is no longer dangerous, and you will not have to take special precautions.
4. All shipping employees must also be trained and certified & comply with all DOT/state or local rules regarding airbag shipments. For each approved air bag inflator, air bag module and seat-belt pretensioner, the shipping paper description must conform to the requirements in §173.166(c) of this subchapter - http://hazmat.dot.gov/sp_app/special_permits/docs/14000/SP14281.pdf
5. If airbags are being sold for reuse, maintain the shipping papers on-site that indicate the name of the reclaimer, the date of transfer, and the quantity of air bags/cartridges.

Other Resources

1. Background: Airbag Use in Cars – Key Dates
   http://www.consumeraffairs.com/news04/2006/airbags/airbags_invented.html#ixzz0j9r0NqzI
   
2. ARA Protocol for use of Original Equipment Non Deployed Air Bags
   http://www.airbagresources.com/downloads/guidelines_and_standards/sc_airbagprotocol_ver1.4_may_2007.pdf
3. Airbag Training & Certification, Hazardous Materials Training & Certification and Airbag Inspection. www.airbagresources.com
   
4. Links to the 5 states that mandate deployment of sodium azide filled cartridges before crushing.

   Delaware
   http://www.dnrec.state.de.us/DNREC2000/Divisions/AWM/hw/hw/pdf/salvage2.pdf - pg. 2

   Minnesota
   http://www.pca.state.mn.us/publications/manuals/salvageyard-manual.pdf - page 45
   

   New York
   http://www.dec.ny.gov/chemical/28650.html, Section 5E

   Oregon
   http://www.deq.state.or.us/lq/pubs/factsheets/hw/AirBagManagement.pdf
   

   Vermont
   http://www.anr.state.vt.us/dec/ead/sbcap/salvage/PDF/FS_AirBags.pdf
   

  5. Airbag Systems Manufacturers

Autoliv, Inc. http://www.autoliv.com/wps/wcm/connect/autoliv/Home

Delphi Automotive Systems http://delphi.com/

Key Safety Systems, Inc. http://www.keysafetyinc.com/

Takata http://www.takata.com/Company/Company_Home.aspx

TRW Automotive http://www.trw.com/system/occupant_safety_systems

Approved June 2010 ARA Technical Advisory Committee