MOVING INVENTORY PART 2
The Art of SHIPPING
Standards to ship non-deployed airbags & seat pre-tensioners are specifi c and come with stiff penalties for non-compliance. These highlights of the DOT HazMat rules are also requirements
of the ARA Certifi ed Auto Recyclers (CAR) program. By Sue Schauls T
he Certifi ed Auto Re- cyclers (CAR) program requires documentation of appropriate DOT training for employees associated with the shipping of hazardous materials or dangerous goods. Safety is import-
ant 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 tem- perature materials as defi ned by Title 49 of the Code of Federal Regulations parts 171-173. Identifi cation of a hazardous material is the fi rst step, and frequently the most diffi cult. Of all the shippers’ responsibilities, the requirement to prop- erly classify a hazardous material is very important.
AUTOMOTIVE RECYCLING • July-August 2018
It is from the proper identifi cation of the hazardous materials that the other requirements are based. For automotive recyclers, the hazardous materials in your facilities are: 1) Airbag Infl ators: Consisting of a casting contain- ing an igniter, a booster material and a gas generate. An airbag infl ator is a gas gener- ator used to infl ate an airbag in a supplemental restraint system in a motor vehicle. 2) Airbag Module: Consisting of the airbag infl ator plus an infl at- able 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 batter- ies for electric and hybrid vehicles will be either Nick- el 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 materi- als are documented in the most current edition of 49 CFR Parts 100-185, with specifi c parts of the code that pertain to automotive recycling.
49
Penalties for non-compliance can equal no less than $250 per violation, but can be up to $32,500 and even jail time.
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