Safety By Mike James Airbag Disposal in the Language of My Father S
ome really good stuff for the recycler has happened in recent months per- taining to how to handle airbags. This is one of those subjects that I really wish I could claim some responsibility for helping to make happen. The credit for all of this great solution on airbag disposal goes to a group of the senior leadership of the Insti- tute of Scrap Recycling Industries (ISRI) from across the country that met multiple times with the U.S. Environmental Pro- tection Agency (EPA) in Washington D.C. They deserve a big thanks. All I get to do is help explain this good stuff to those of you dealing with end-of-life vehicles. Please bear with me as I put this in the language of my father – simple. A couple of articles have been published recently pertaining to what you should do with an airbag that you are not going to be selling. The problem with these articles and the Guidance document that came out from the EPA are that you really needed a master’s degree in environmental engi- neering or some other form of the environ- mental sciences to be able to read them. Well, I have one of those, and it is still a pretty complicated document.
Two Real Choices
When you have a vehicle sitting in front of you and you ask yourself what to do with the airbags, please take the easy route. Very simply, you have two options, 1) Leave the airbag in the car all the way to the crushing and shredding operation, or 2) Pull the airbag out of the car for poten- tial sale. Once pulled, if by chance it is a defective Takata airbag, then you may want to consider the RAS buyback program. This gets really simple if the airbag is still attached and installed in the car as you received it. If you make the choice to leave the airbag in the car then you have made the easiest decision. You can crush the car and the airbag can ultimately go through
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the shredder as a part of the scrap metal recycling process. You can avoid getting yourself into trouble with this very simple solution. But please note, if you put a few extra airbags in the trunk of the car before you crush it, then you have committed what might be considered a criminal act with improper disposal of a solid waste. Now, let’s discuss option 2, which is taking the airbag out of the car. Please, before you ever take an airbag out of a car, make sure you have a verified market or a verified buyer for that specific airbag (see the comment on the Takata air- bags). Whatever your choice, do not stock- pile airbags, period. End of discussion. Do not stockpile airbags.
Disposal Protocol
Once the airbag is removed from the car, and you do not have a buyer, then you have to decide on how to dispose of it and this is where things get complicated. The disposal of an uninflated airbag must be handled under the rules of the Resource Conserva- tion and Recovery Act (RCRA). These are the rules that cover Hazardous Waste. I am not even going to try to explain this com- plicated set of rules. Simply – do not stock- pile airbags; do not send undeployed air- bags to the landfill; and do not stuff them in the trunk of a car before crushing. There is another option, but again I do not recommend this for standard practice. A deployed airbag that you are holding in your hands can be placed in the scrap metal waste stream as a part of the car. Obviously, if you are selling to a shredder, some shredding companies may have their own corporate policies that are more restrictive, but at least the EPA has made it very clear in their smoky and convoluted way of writing that the deployed airbag can go with the cars through the shredder. Make sure you consider the shredder’s
rules and those rules associated with Solid Waste/Hazardous Waste for the states in which you do business. So, you may give some thought to building a process to deploy that ware- house of airbags that you have been accu- mulating over the years. I hope not, but if you do, then let me encourage you to con- sider the safety of your employee that will be doing this work. It is not a simple thing to deploy a bunch of airbags in a manner that is cost-effective.
Let Me Be Clear Again, only pull the airbag if you have a confirmed and ready buyer for that airbag. Otherwise, leave it in the vehicle and crush the vehicle at the time that works for your business. Remember above that I said do not pull the airbag unless you have a con- firmed buyer. The RAS Buy-Back Program could serve you as a confirmed buyer. Please remember the warning. Do not spec- ulate or stockpile airbags. Folks, it really can be as simple as spelled out above, but if you have a question don’t hesitate to give me a call and we will do our best to help. If you want to know more about the Takata Airbag recall, send an email to Paul D’Adamo, at RAS, at
pauldadamo@coresupply.com.
Thoughts and opinions expressed in the Safety column are those of the authors. Readers should seek professional guidance when establishing their systems and processes.
Mike James, James Environmental Management, Inc., has spent more than 45 years building and leading compliance assurance programs in
heavy industrial environments. He and his team created eComply® – a cloud-based compliance assurance and educational tool allowing companies to manage risks in their business.
Automotive Recycling
Caryn Smith
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