Air Bag Packaging

This is in response to your recent inquiry concerning authorized packagings for Air bag inflators. You indicated that you believe the condition or form in which the inflators are packed during the performance of tests conducted under test series 6(c) of the UN Manual of Tests and Criteria, Second Edition, is the only authorized packaging for the articles when subsequently offered for transportation. You further stated that your shipping department personnel maintain that any packaging authorized for air bag inflators in 49 CFR 173.166(e) can be used.

You are correct. Without specific authorization of alternative packagings in your EX-approval letter, your shipping department may not make substitutions in any of the packagings that were examined and classified as for transport under §173.166(b). It was intended that the shipper pre-select from the packagings authorized in §173.166(e), one or more combinations of packagings of the articles to be examined for classification by one of the procedures prescribed. Upon re-application to the Office of Hazardous Materials Approvals with supplemental technical information, alternative packaging combinations other than those originally classified may be authorized. In that case, your EX-Approval letter would be re-issued with the additional authorized packaging noted below the assigned classification.