Moving Inventory Part 2
Standards to ship non-deployed airbags & seat pre-tensioners are specific and come with stiff penalties for non-compliance. These highlights of the DOT HazMat rules are also requirements of the ARA Certified Auto Recyclers (CAR) program.
By Sue Schauls
The Certified Auto Recyclers (CAR) program requires documentation of appropriate DOT training for employees associated with the shipping of hazardous materials or dangerous goods. Safety is important when packaging hazardous material for shipping.
Identifying Hazardous Materials
A hazardous material (HazMat) designation means a substance or material, which has been determined by the Department of Transportation to be capable of posing an unreasonable risk to health, safety and property when transported in commerce. The term includes hazardous substances, dangerous goods, hazardous waste, marine pollutant and elevated temperature materials as defined by Title 49 of the Code of Federal Regulations parts 171-173.
Identification of a hazardous material is the first step, and frequently the most difficult. Of all the shippers’ responsibilities, the requirement to properly classify a hazardous material is very important. It is from the proper identification of the hazardous materials that the other requirements are based. For automotive recyclers, the hazardous materials in your facilities are:
1) Airbag Inflators: Consisting of a casting containing an igniter, a booster material and a gas generate.
An airbag inflator is a gas generator used to inflate an airbag in a supplemental restraint system in a motor vehicle.
2) Airbag Module: Consisting of the airbag inflator plus an inflatable airbag assembly.
3) Seat belt pre-tensioner: Contains similar hazardous material and is used in the operation of a seat belt restraining system in a motor vehicle.
4) Lithium-ion Batteries: All types of lithium batteries were recently designated as “Dangerous Goods” with shipping restrictions. Automotive large format batteries for electric and hybrid vehicles will be either Nickel Metal Hydride or Lithium-ion batteries.
Training is Required
The general requirements for who needs to be trained and who can train to ship hazardous materials are documented in the most current edition of 49 CFR Parts 100-185, with specific parts of the code that pertain to automotive recycling.
“No person may offer or accept a hazardous material for transportation in commerce unless that person is registered in conformance with the rule as defined in 49 CFR 171.2(a) subpart G of Part 107 of this chapter, if applicable, and the hazardous material is properly classed, described, packaged, marked, labeled, and in condition for shipment as required or authorized.”
As owners, operators, employers and employees of your facility there are certain responsibilities that have to be maintained in order to ship the hazardous materials discussed.
Federal regulations require hazardous material training for every “Hazardous Materials Employee.” The DOT requires every “Hazardous Materials Employer” to provide all the necessary information to hazardous material employees so they can perform their individual job functions in a safe and knowledgeable manner. (Definitions of these roles are included in the Hazardous Materials Guide.)
A Hazardous Materials Employer must be trained to certify Hazardous Materials Employees or provide certification training to those employees responsible for preparing hazardous materials for shipping. The required areas of training include:
General Awareness/Familiarization: General awareness and familiarization training is intended to raise the HazMat employees’ awareness of the regulation and the purpose and meaning of the hazard communication requirements. All HazMat employees must have this training to make sure hazmat employees can identify and recognize that the airbag/modules, seat belt pre-tensioners and Li-ion batteries are hazardous.
Function-Specific Training: Function specific training is intended to teach the necessary knowledge, skills and abilities for an individual’s job function, and specifically to train them to prepare materials for shipment.
Safety Training: This training provides information concerning the hazards posed by materials in the workplace and personal protection measures. The training may include basic emergency response procedures but is not intended to satisfy the requirements of OSHA (29 CFR 1910.120).
Security Training: Each HazMat employee must receive security awareness training of security risks associated with hazardous materials transportation and methods designed to enhance transportation security for facilities with large quantities being shipped.
HazMat employees must receive this training and certification at least once every three years. DOT regulations require that HazMat Employers train, test, and maintain test records for all HazMat Employees in these areas. A new HazMat employee who changes job functions may perform those functions prior to completion of training, provided the employee performs those functions under the direct supervision of a properly trained and knowledgeable HazMat employee; and the training is completed within 90 days after employment or job function. The training documentation must include the HazMat Employees name, completion date and location of training, name and address of the trainer, and a copy of the test and certificate.
Preparing Hazardous Material for Shipping
General requirements for shipping airbags modules or seat belt pre-tensioners are that they must be prepared for shipment in a very specific manner. They must be shipped in what is referred to as “performance UN packaging.” Also there are terms and numbers that must be printed on the shipping papers, shipping boxes, or both. HazMat shipping papers provide information on several things including; shipper/receiver name and address, HazMat description, DOT proper shipping name, quantity, emergency response information and certification and signature. If you ship or deliver HazMat in your own vehicle, such your own pick-up truck or delivery van, then you must comply 100 percent with these regulations. Under this scenario no placards are required on the vehicle.
Hazardous Class or Division refers to the category of hazard assigned to a hazardous material under the definitional criteria of part 173 of the CFR. Air bag modules, air bag inflators and seatbelt pre-tensioners can be classified as Class 9 or 2.2 Hazardous Materials depending on the ignitor material. Lithium-ion batteries can be classified as Class 9.
Pyrotechnic air bag modules, air bag inflators, and seat-belt pre-tensioners are classified as CLASS 9 MISCELLANEOUS HAZARDOUS MATERIALS.
Compressed gas air bag modules, air bag inflators, and seat-belt pre-tensioners are classified as DIVISION 2.2 NON-FLAMMABLE COMPRESSED GAS HAZARDOUS MATERIALS.
Lithium-ion batteries are classified as CLASS 9 MISCELLANEOUS HAZARDOUS MATERIALS.
UN Number: UN stands for United Nations. The UN number contains 4 digits and refers to packaging conforming to standards in the United Nation Recommendations on the Transport of Dangerous Goods. For Class 9 airbag modules and seat-belt pre-tensioners the UN Number is UN3268. For 2.2 Hazardous materials the UN Number is UN3353. Li Battery the UN UMBER is UN3090 or UN3091 if packed with or contained in equipment.
Packaging Groups: A grouping according to the degree of danger presented by hazardous materials. Packaging Group I indicates great danger, while Packaging Group II indicates medium danger. Packaging Group III indicates minor danger. For air bag modules and seat-belt pre-tensioners are Packaging Group III. Lithium batteries are Packaging Group II.
EX Number or Product Code: When offered for domestic transportation by highway, rail freight, cargo vessel or cargo aircraft only, a serviceable airbag module or seat-belt pre-tensioner that has been removed from a motor vehicle and manufactured as required for use in the U.S. may be offered for transportation without marking the EX Number or product code on the shipping paper. Instead, the word “Recycled” must be entered on the shipping paper.
DOT Proper Shipping Name: The official name that DOT has determined must be written exactly.
24-Hour Response Telephone Number: Any person or company that ships a hazardous material must provide a 24-hour emergency response telephone number including area code; in case the transportation company has an emergency involving the hazardous material that was shipped. There are businesses that provide these services for a fee. INFOTRAC is one such business, and is a ARA Member Benefit Provider.
Retention of Shipping Papers: Shippers and carriers are required to retain shipping papers or electronic images thereof for a period of one year to be accessible through their respective principal places of business.
Box or Container Requirements
In order to ship airbag modules or seat-belt pre-tensioners, UN specification packaging must be used. The UN specification marking must not be covered by labels or attachments, such as packing slips or tape.
1) Strength: The packaging that is needed is a 4G fiberboard box. Regular cardboard boxes will not work.
2) Dunnage: This refers to the cushioning that must be inside the box surrounding the hazardous material. It must be sufficient enough to secure the material to prevent movement during transportation.
3) Weight: The total of the package cannot exceed the weight allowed on a UN specification package. Only one airbag module or one seat-belt pre-tensioner per box is allowed.
4) Labeling: Hazardous materials markings must meet the following qualifications. It must be durable, in English, and printed on or affixed to the surface of a package or on a label, tag or sign; be on a background of sharply contrasting color; and not be covered by labels or attachments, like packing slips or tape. It also must be located away from any other markings that could substantially reduce its effectiveness.
Safe Packaging Practices
Some safe packaging practices for lithium metal batteries and lithium ion batteries include:
They should be packaged in combination packagings conforming Packing Group II performance level. The lithium battery or cell must be packed in inner packagings in such a manner as to prevent short circuits, including movement which could lead to short circuits. The inner packaging must be packed within one of the following outer packagings: metal boxes (4A or 4B); wooden boxes (4C1, 4C2, 4D, or 4F); fiberboard boxes (4G); solid plastic boxes (4H2); fiber drums (1G); metal drums (1A2 or 1B2); plywood drums (1D); plastic jerricans (3H2); or metal jerricans (3A2 or 3B2), and be equipped with an effective means of preventing external short circuits.
A lithium cell or battery offered for transportation or transported by motor vehicle to a permitted storage facility, disposal site or for purposes of recycling is excepted from the specification packaging requirements when protected against short circuits and packed in a strong outer packaging conforming to the general packaging requirements.
Batteries employing a strong, impact-resistant outer casing and exceeding a gross weight of 12 kg (26.5 lbs.), and assemblies of such batteries, may be packed in strong outer packagings, in protective enclosures (for example, in fully enclosed wooden slatted crates) or on pallets. Batteries must be secured to prevent inadvertent movement, and the terminals may not support the weight of other superimposed elements. Batteries packaged in this manner are not permitted for transportation by passenger aircraft, and may be transported by cargo aircraft only if approved by the Associate Administrator prior to transportation. n
This article has been edited for publishing. Download the complete CAR standards document at www.a-r-a.org.
Sue Schauls, a environmental, safety and compliance expert, is currently the Executive Director of the Iowa Automotive Recyclers. Sue can be reached at Sue.Schauls@gmail.com.