On Monday, March 26, 2012 Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a notice of proposed rulemaking (NPRM) to roll some special permits (exemptions) being used with success to be added into the regulations.

This will save time for the shippers and PHMSA in processing the ongoing applications. The amendments in the NPRM, if approved address the safe transportation being utilized in the special permits. The air bag modules and seat belt pretensioners get evaluated by approved DOT inspectors to determine the qualification for explosives, 1.4G or lower hazard, Class 9. The articles defined as explosives continue to require an EX numbers. Class 9 exceptions per the special provision details may be utilized for the non-explosive ones. The item 173.166 will be added to the regulations and the evaluation test in 172.56(b)(1) continues the level of safety and saving in reduces the paperwork burdens and facilitates commerce. The parts of the regulatory system affected parts 106, 107, and 171-180.

This NPRM was issued in response to a petition from the North American Automotive Hazmat Action Committee (NAAHAC). This committee represents automotive manufacturers and component suppliers in North America, Asia, and Europe. Current automotive manufacturers install accident air bag and seat assemblies. These parts are activated in a crash. There is a sensor that sends an electrical signal once the crash happens to the air bag inflator. The inflator receives the signal to activate the igniter that causes the part to generate nitrogen gas that inflates the bag. This happens faster than 200 milliseconds. The bag is made with holes to allow the impact of a person force the nitrogen to disperse as the person’s impact is reduced.

These automotive manufacturers transport the components using special permits. These special permits set forth details to achieve a safety level that is at the least corresponds to or exceeds the safety level required under the regulations which is consistent with public interest. NAAHAC requests these permits be incorporated into the regulations to reduce paperwork burdens and facilitate commerce while maintaining acceptable level of safety.

The NPRM would incorporate provisions of the special permits into the regulations. The PHMSA proposes to revise the current approval and documentation requirements for a material appropriately classified as a Class 9 (UN 3268) air bag inflator, air bag module, or seat-belt pretensioner. There are to be definitions in 49 CFR 173.166 along with the requirement to have the air bag inflator, air bag module, or seat-belt pretensioner examined and successfully tested to determine if it meets the requirements to be classified as explosives Division 1.4G by a person or agency (authorized testing agency) who is authorized by the Associate Administrator to perform such examination and testing under 173.56 of this subchapter. These meeting this classification can be shipped using UN0431, Articles, pyrotechnic for technical purposes as specified in Special Provision 161 (see 172.102). The NPRM covers the details to roll these special permits into the current regulations to improve commerce.

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