[Sqg-program] FW: Treating Auto Airbags and Seatbelt Pretensioners

Fri Jul 7 10:54:19 EDT 2006

Hi All

Attached is FDEP guidance based on email correspondence on how to properly
manage vehicular air bags. Is it or is it not a hazardous waste? Well, that
depends on if the air bag is recycled or disposed. Read the attached emails
for more detailed discussion on this topic.

Also included are discussions on how other states are dealing with this. Hope
this helps.

Glen Perrigan
Florida Department of Environmental Protection
Hazardous Waste Management Section
2600 Blair Stone Road  MS-4555
Tallahassee, Florida 32399-2400
850-245-8749 Fax:  850-412-0528
E-mail: glen.perrigan at dep.state.fl.us  Website: www.dep.state.fl.us/waste
Please Note:  Florida has a very broad public records law.  Most written
communications to or from state officials regarding state business are public
records available to the public and media upon request.  Your e-mail is
communications and may therefore be subject to public disclosure.

-----Original Message-----
From: Redig, Michael 
Sent: Thursday, June 01, 2006 11:00 AM
To: Perrigan, Glen
Subject: RE: Treating Auto Airbags and Seatbelt Pretensioners

Glenn,
	See attached e-mail correspondence on same with Ms. Davis form
January 2006. 

Thanks
Mike

Please note: Florida has a very broad public records law. Most written
communications to or from state officials are public records and may be made
available to the public or media upon request. This e-mail communication,
your reply, and future e-mails to my attention may therefore be subject to
public disclosure.  

-----Original Message-----
From: Perrigan, Glen 
Sent: Thursday, June 01, 2006 10:01 AM
To: Redig, Michael
Subject: FW: Treating Auto Airbags and Seatbelt Pretensioners

Mike

Please read the message below. Has this issue been discussed in Florida? Does
it need to be discussed? Thanks.

Glen Perrigan
Florida Department of Environmental Protection Hazardous Waste Management
Section 2600 Blair Stone Road  MS-4555 Tallahassee, Florida 32399-2400
850-245-8749 Fax:  850-412-0528
E-mail: glen.perrigan at dep.state.fl.us  Website: www.dep.state.fl.us/waste
Please Note:  Florida has a very broad public records law.  Most written
communications to or from state officials regarding state business are public
records available to the public and media upon request.  Your e-mail is
communications and may therefore be subject to public disclosure.

-----Original Message-----
From: Gleason, Irene
Sent: Thursday, May 25, 2006 5:00 PM
To: Perrigan, Glen
Cc: Clarke, Raoul
Subject: FW: Treating Auto Airbags and Seatbelt Pretensioners

Sounds like something for the SQG folks to think about... 

-----Original Message-----
From: Michael Stepaniak [mailto:michaels at ccicenter.org]
Sent: Thursday, May 25, 2006 4:54 PM
To: Mailing list for HHW professionals.
Subject: Treating Auto Airbags and Seatbelt Pretensioners

Hello all,

Recently received this letter and don't have a response. Any advice would be
appreciated. Thanks.

Regards,

Michael 

To Whom It May Concern,

I am writing in regards of treating airbags and seatbelt pretensioners as a
hazardous waste. The air bag's inflation system reacts sodium azide (NaN3)
with potassium nitrate (KNO3) to produce nitrogen gas. Hot blasts of the
nitrogen inflate the air bag. The air bag system ignites a solid propellant,
which burns extremely rapidly to create a large volume of gas to inflate the
bag. The bag then literally bursts from its storage site at up to 200 mph.
Like airbags, pretensioners are triggered by sensors in the car's body, and
most pretensioners use explosively expanding gas to drive a piston that
retracts the belt. Pretensioners also lower the risk of "submarining", which
is when a passenger slides forward under a loosely worn seat belt.

I am aware an airbag module is considered as hazardous waste so my question
is this: If an individual deploys an airbag (without a permit) on his own
watch would this be considered as treating a hazardous waste? We are a
hazardous waste disposal facility and this concept varies from state to state
due to the interpretation of the hazardous waste regulations. To give an
example: if an auto dealer receives a automobile that is to be repaired under
warranty replacement and the old airbag module is removed. A new module is
put in the automobile. The dealership is not allowed to just throw the airbag
away in the trash or elsewhere. So if the mechanic deploys the airbag and
then discards it, would this be considered as though the dealer has treated a
hazardous waste? I understand that once the airbag module is deployed it is
no longer considered as a hazardous waste that is why the airbag is deployed
by the individuals before discarding the equipment. The alternative to the
mechanic deploying the airbag is to send the airbag as is to a hazardous
waste disposal company and let them properly dispose of them. The same
question for seat belt pretensioners as far as deactivating them and at that
point throwing them away also. 

Any assistance with clarifying what treatment is considered for these devices
would be greatly appreciated. If you are unable to provide an answer please
guide me in the direction to resolve the question. Thank you for taking the
time in assisting me.

Best Regards,

Tara Davis
Business Development Specialist
EBV Explosives Environmental Company
tara.davis at ebveec.com

Michael Stepaniak
Program Coordinator
PA Resources Council
phone: 412.431.4449 ext. 213
fax: 412.488.7492
michaels at ccicenter.org

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