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A New Look at SRS/Airbag Disposal & Deployment Practices

Toyota has previously outlined specific airbag deployment procedures and safe airbag handling practices in service publications. Because of changes in the way in which some state regulatory agencies now view the pre-disposal deployment of airbag and seat belt pretensioner assemblies, Toyota is re-visiting the subject in this article.

Toyota has also issued TSB SS004-07 (Toyota), SS005-07 (Scion) and TSIB SS005-07 (Lexus) to further support this new perspective.

This article focuses on the proper handling and disposal of Supplemental Restraint System components including all types of airbags and seat belt pretensioner assemblies, both deployed and undeployed, that have been removed from a vehicle in a service or collision repair operation.

Is An Undeployed Airbag a Hazardous Waste?

Generally speaking, the short answer to this question is, “Yes.” The U.S. Environmental Protection Agency (EPA) has deferred the responsibility to each individual state of determining if airbags, whether deployed or undeployed, constitute hazardous waste. For this reason, dealerships need to stay informed of state and/or local regulations that may affect them. In the absence of such policies, all airbags and seat belt pretensioners should be considered hazardous material (HazMat) for purposes of shipping and hazardous waste for purposes of disposal.

CCAR-GreenLink®, the National Environmental Compliance Assistance Center for Auto Repair and a service of the Coordinating Committee For Automotive Repair (CCAR), has surveyed environmental regulatory agencies in all fifty states, plus the District of Columbia and Puerto Rico, to determine their policies in place regarding airbags and related issues. The survey found that a large majority of states regard undeployed airbags as hazardous waste because the inflating device contains reactive and explosive materials.

Follow this link to see CCAR-GreenLink’s research results and your state’s position.

NOTE: The information contained in this link is for general reference only and subject to change. It should not be considered definitive compliance information. Check with your state agency for the most current regulations in effect in your area.

Does the pre-disposal deployment of an airbag render the device non-hazardous?

Again, the short answer to this question is – generally – “Yes.” But while most states consider a deployed airbag to be non-hazardous waste, some regulations at the state level now define the pre-disposal deployment of airbag and pretensioner assemblies as “treatment” of a hazardous waste.

Is this “treatment” subject to permit requirements at the state level?

The short answer to this question is – “Sometimes.” The CCAR survey found the states divided on the issue. Consequently, the manual deployment of airbag components for disposal purposes may not be a “best practice” in certain states, and other methods of disposal must be considered.

Even in those states where deployment is acceptable treatment to render the component “non-hazardous,” special training, certification or licensing may be required. TMS recommends that dealership risk management personnel carefully review local and state regulations, train personnel to follow consistent and compliant practices and, where appropriate, contract a licensed hazardous waste transporter, disposal facility or recycler to manage undeployed airbag and seat belt pretensioner disposal. Requirements for HazMat treatment licenses and permits vary from state to state. Follow the links at the end of this article for more information.

Why are airbag handling procedures changing?

As mentioned in the opening paragraph of this article, this change in practice has come about for the following reasons:

  • Previously, deployed airbags were considered to be non-hazardous waste, and manual airbag deployment was an acceptable, non-regulated practice when performed safely by properly-equipped service facilities. In today’s regulatory climate, in which states decide if airbags – deployed or undeployed – constitute hazardous waste, it is impossible to have a single “best practice” for a majority of dealers.
  • Within the past several years, a number of states have ruled that the deployment of an airbag does, in fact, constitute “treatment” of hazardous waste, requiring practicing dealerships to obtain a treatment facility permit. This requirement is a “moving target,” because airbag disposal practices and protocols vary from state to state and are continually evolving.

Moving forward, Toyota service publications will continue to explain, in detail, the procedures for pre-disposal deployment of airbag and pretensioner assemblies. These practices however, should only be used by dealership technicians if allowed by state and local regulations, and by the dealership’s risk management policies.

NOTE: Special Service Tools (SSTs) for airbag and pretensioner deployment are no longer classified as essential SSTs. These tools will continue to be available through the SST program for repair shops choosing to continue airbag deployment in compliance with state and local governance. Tools may be ordered by contacting SPX/OTC at 800-933-8335.

Disposal of Undeployed Airbags

In determining what to do with undeployed airbags and seat belt pretensioner assemblies, dealership service departments and collision repair shops need to determine:

  • whether their state considers undeployed airbags to be hazardous waste (most states do),
  • whether deploying the unit constitutes “acceptable treatment” of the hazard, rendering the component “non-hazardous” (most states do), and
  • whether their state considers airbag deployment a HazMat treatment practice that requires a permit (many states do).

Dealerships must also understand that undeployed airbags and pretensioners are considered HazMat for purposes of shipping and handling, and that HazMat-specific training is required for all shipping and handling personnel identified as “hazmat employees”.

Toyota does not allow returns of any hazardous material, including any type of airbag or seat belt pretensioner assembly at the present time; therefore, there are several important points to keep in mind in determining how to dispose of your undeployed airbags and seat belt pretensioner assemblies:

  • Never discard undeployed airbags in the trash. Most states consider undeployed airbag assemblies to be hazardous waste, and these components are considered an extreme hazard by solid waste transporters and landfills.
  • Understand and follow all prescribed warranty return procedures; Toyota/Lexus/Scion dealers are subject to return exclusions for certain parts like airbags and pretensioners.
  • Use the services of reputable, licensed haulers for pick up and proper disposal. (See the list of resources at the end of this article for more information.)

Are Deployed Airbags a Hazardous Waste?

The short answer to this question is, “Sometimes.” While forty-one states, plus Puerto Rico and the District of Columbia, currently consider a deployed airbag not to be a hazardous waste, and five states (Florida, Michigan, Missouri, Ohio and Washington) deem deployed airbags not to be hazardous waste only if they are recycled, one state (Virginia) considers deployed airbags to be a hazardous waste. In Nevada, they may be hazardous waste depending upon the amount of metals it contains. Since all of these regulations are subject to change, it is in the dealership’s best interests to stay apprised of the laws governing these issues.

Can Airbags Be Recycled?

Everything can be recycled, including airbags. The make-up of airbag modules includes aluminum, stainless steel or mild steel, nylon and plastic.

Some airbag manufacturers have recycling facilities. Autoliv, an airbag manufacturer, has a recycling facility in Promontory, Utah, where the company cites the ability to recycle 98% of the materials in individual units. Autoliv will process airbags of any manufacture; there is a fee for this service.

Generally speaking, there is a cost to dealerships that chose to recycle their airbags. There are also costs associated with other means of undeployed airbag disposal; however, if your dealership is not in a position to deploy an airbag and dispose of it as non-hazardous waste, these are your only other options.

Finally, it is important to note that, even when using reputable haulers and recyclers, your “hazmat employees” must have the appropriate training in HazMat shipping and handling, as mandated by the U.S. Department of Transportation (DOT), to legally transfer these items to a carrier for shipment. Look for more information on this subject in an AWARE article later this year.

Conclusion

In the absence of national standards governing the handling and disposal of deployed or undeployed airbag modules and seat belt pretensioner assemblies, dealerships need to stay informed of state and local rules.

The following are helpful related resources:

U.S. EPA –

Information for Hazardous Waste Generators

U.S. DOT –

Overview of Hazardous Materials Regulations

Other information –

CCAR-GreenLink® State-by-State Research Results

RCRA/Hazardous Waste State Resource Locator

Online Databases of Hazardous Waste Transporters