UN Air Bag Transportation and Classification Committee

Mission Statement - This committee will address issues concerning packaging and shipping of hazardous materials related to automotive occupant restraints.

Items of Recent Interest:

•  United Nations Discussions-"SAFETY DEVICES PROPOSAL" In the U.N. December, 2004 meeting, Germany's petition draft of September 3rd, 2004 was deferred. This proposal by Germany was an attempt to group articles which contain pyrotechnic substances and are used as vehicle safety systems for separation, locking, or release-and-drive systems such as battery disconnects or pedestrian protections to be grouped into Airbag classifications as either UN3268 or UN0503 (Class9 and Class 1.4 respectively). Many delegates noted the term; "Safety Device" is too general in definition and needs to be more specific. Germany is prepared to make these changes and re-submit their proposal at the December, 2005 meeting in Geneva.
•  Certain groupings of the "Safety Devices" being created such as battery disconnect systems do meet certain provision under the Research and Special Programs Administration (RSPA) to be considered as non-hazardous materials if they can be deemed "hand-held safe" A meeting scheduled April 4, 2005 with the RSP A will allow the Department of Transportation (DOT) to explain hand held safe device criteria and how it can be presented to the U.N. Committee of Experts to be possibly adopted as a U.N. Standard.
•  Exemptions: Previously 173.166(e)(4) has only allowed airbags and pre-tensioners to be shipped in a DHD (Dedicated Handling Device), a reusable high strength plastic, or metal container, from the Manufacturing facility to the Assembly facility. NAAHAC has asked RSPA to allow these containers to be shipped to a mid-point location and from the assembly facility back to the manufacturer.
•  Letters of Interpretation: On November 17, 2004, the Standards Office within the Research and Special Programs Administration (RSPA) issued a letter of interpretation allowing seat belt pre-tensioners to be shipped as a non-hazardous device. In their letter, the Standards Office agreed that a finished pre-tensioner is considered a completed vehicle component. This letter is contrary to the regulation which suggests that the device be attached to the vehicle or a large massed object. NAAHAC will be meeting with RSPA to better understand the latest letter of interpretation from U.S. DOT.
•  IA T A Requirements: The air eligibility marking requirement has been removed, however in its place is a new requirement (8.1.6.12.2) which states that a new statement must be added to the certification statement on the Shipper's Declaration for Dangerous Goods Form; "I declare that all of the applicable air transport requirements have been met." This is effective January 1, 2005.
•  Section 8.1.4.1 now allows "(consolidators, freight forwarders and lATA cargo agents) employed by the shipper to act on their behalf to undertake the shipper's responsibilities in the preparation of the consignment" to sign the Shipper's Declaration for Dangerous Goods Form. The caveat to this is that the individual signing the form must go through Hazmat training.
•  The sequence of information on the basic description of dangerous goods has been changed. The new sequence has the UN#, Proper Shipping Name, and Hazard Class listed in that order. The old sequence with the Proper Shipping Name appearing first may be used for 2005 and 2006. In 2007 the new sequence must be used.
•  Transport Security Administration: The Transport Security Administration has extended their deadline for implementing fingerprinting requirements from January 31, 2005 until May 31, 2005. This requirement mandates that all holders of a Commercial Driver's License (CDL) with a hazmat endorsement must be fingerprinted.