Authorized packagings for airbags

This is in response to your November 15, 2006 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packagings for air bag modules. Specifically, you ask if shrink wrapping 11 fiberboard boxes of air bag modules to a pallet constitutes a single packaging under the HMR. According to your letter, each box measures 96" Lx 41" W x 4" and the palletized unit measures 96" Lx 41" W x 48". Also, you indicate that a representative of tie Department suggested that if a shroud were placed over the palletized unit, it may meet the criteria for a 50G design.

Authorized packagings for air bag modules are provided in § 173.166(e). The palletized configuration described in you letter is not an acceptable packaging for air bag modules. A 4G box that meets the general packaging requirements in Part 173 and the performance oriented packaging requirements in Part 178 at the Packing Group III performance level is an authorized packaging. To utilize the packaging configuration described in your letter, the individual boxes must be authorized 4G packagings and the shrink wrapped pallet must be treated as an overpack in accordance with § 173.25. A 50G packaging is not in authorized packaging for air bag modules.