Managing Hazardous Waste

We protect the environment and communities by ensuring compliance with hazardous waste laws

Airbag Waste Management

Conditional Exemption for Undeployed Airbags Emergency Regulations Expired

DTSC’s emergency regulations for the conditional exemption for undeployed airbags expired on March 6, 2025. Under the emergency regulations, generators of undeployed airbag waste (airbag waste handlers) were exempt from hazardous waste management requirements if they met the conditions of the exemption. DTSC is currently working to permanently adopt the conditional exemption provisions through a regular rulemaking, which is projected to be completed in the summer of 2025.

There is currently a lapsed period between the expiration of the emergency regulations and before the permanent adoption of the conditional exemption provisions. During the lapsed period, undeployed airbag waste that are hazardous are no longer exempt from hazardous waste management requirements and are to be managed under full hazardous waste management standards.

Public Workshop to Finalize Emergency Regulations for Conditional Exemption of Undeployed Airbags

The Department of Toxic Substances Control (DTSC) held a virtual public workshop and presented information on the current emergency regulations on Conditional Exemption of Undeployed Airbags and the proposal to finalize these regulations through a regular rulemaking process on June 5, 2024.

This webinar was intended to familiarize people with current regulations and offers the opportunity for public comments. DTSC is working to public notice the regular rulemaking package to permanently adopt the U.S. EPA’s Interim Final Rule in the spring 2025, which will begin the formal rulemaking process.

Conditional Exemption for Undeployed Airbags Regulation Approval

DTSC’s emergency regulation for conditional exemption of undeployed airbags was recently approved by Office of Administrative Law (OAL) and is effective starting March 15, 2024. The exemption provided by the emergency regulation relaxes the hazardous waste requirements for the generation and accumulation of airbag waste at the airbag waste handler location and during transport, as long as the conditions of the exemption are met. Airbag waste must be managed as hazardous waste once it is received at a designated facility for proper management.

DTSC Reference Number: R-2023-11R

OAL Reference Number: 2024-0305-02E

Please visit the Conditional Exemption for Undeployed Airbags webpage to access the rulemaking information.

Please be sure to check the website for more information as DTSC continues to update this website.

Airbags and Airbag Waste

Airbags are safety devices installed in vehicles to protect passengers in the event of a collision by a cushion that is rapidly inflated at impact.

Airbag module – Is a fully assembled unit including both the airbag inflator, fabric cushion, and is commonly housed in the steering wheel boss and dashboard of a vehicle. The airbag module is typically the form of the device when packaged and shipped to vehicle manufacturers.
Airbag inflator- a small metal canister containing an igniter, a booster material, and a gas generator. On impact an electronic pulse is sent to the inflator which initiates the chemical reaction that releases the gases into the cushion causing it to expand.

When a collision occurs, an electronic signal is sent to the inflator which triggers the igniter and booster material to react and generate an inert nitrogen gas which deploys the cushion being held within the airbag module. Once the bag has been inflated, the gas begins to dissipate through holes in the bag. Deployment of the airbag module consumes the propellant and removes the hazardous characteristics in the airbag inflator. Once an airbag has been deployed the entire airbag module cannot be reused and must be replaced.

Airbag Waste

Undeployed airbag inflators and airbag modules exhibit the hazardous waste characteristics of reactivity (D003) and ignitability (D001) under the federal Resource Conservation and Recovery Act (RCRA) due to the propellants contained in the inflator. Common propellants used in airbag inflators are:

Sodium azide (many manufactures have stopped using as propellant)
Ammonium nitrate
Guanidine nitrate
Potassium nitrate

Deployment of the airbag fully consumes the propellant and removes the hazardous waste characteristics of reactivity and ignitability.

Frequently Asked Questions

DTSC has gathered questions that have been asked regarding the management of airbag waste. The following questions and answers are provided for guidance on the new provisions. The questions and answers will be periodically updated as needed.

What is airbag waste?

“Airbag waste” is any hazardous waste airbag inflator or hazardous waste airbag module. An airbag inflator consists of a metal casing containing an igniter, a booster material, and a gas generant. An “airbag module” is the airbag inflator plus the inflatable bag assembly.

Undeployed airbag inflators and airbag modules are generally reactive (D003) and/or ignitable (D001) due to the propellant contained in the inflator, and therefore considered hazardous wastes when discarded. Deployment of the airbag module consumes the propellant and removes the reactivity and ignitability characteristics.

What is NOT “airbag waste”?

Deployed airbags that do not contain any hazardous chemicals are not airbag waste under division 4.5, title 22 of California Code of Regulations. Non-recalled undeployed airbags that are repurposed for reuse are not considered discarded and therefore not airbag waste.

Who is considered an airbag waste handler, and what must they do to manage their airbag waste under the exemption?

An “airbag waste handler” is an entity that generates airbag waste under the conditional exemption and can include auto manufacturers, auto dealers, repair facilities, auto dismantlers, and scrap metal facilities. To be conditionally exempt from hazardous waste generator requirements, an airbag waste handler must:

Accumulate no more than 250 airbag modules and airbag inflators (combined) at one time;
Accumulate their airbag waste for no longer than 180 days;
Package their airbag waste in a container designated to address the risk posed by the airbag waste;
Label their airbag waste;
Send their airbag waste directly to either:
1. An airbag collection facility, or
2. A designated facility;
Ensure their airbag waste shipments comply with all applicable U.S. Department of Transportation (DOT) requirements for airbag waste during transit; and
Maintain at the airbag waste handler facility records of all offsite shipments of airbag waste.

What is meant by packaged in a “container designed to address the risk posed by the airbag waste”?

Airbag waste exhibits RCRA hazardous waste characteristics of reactivity and/or ignitability. Containers designed to address these risks posed by airbag waste include containers that meet the DOT requirements for shipping airbag modules or airbag inflators per 49 Code of Federal Regulations (CFR) part 173.

What is an airbag waste collection facility?

An “airbag waste collection facility” receives airbag waste from airbag waste handlers and accumulates the waste for more than ten days. An airbag waste facility must be under the control of a vehicle manufacturer or their authorized representative (e.g., a certified auto parts dealer), or under the control of an authorized party administering a remedy program in response to a recall (for example, Takata) under the National Highway Traffic Safety Administration.

Once the airbag waste arrives at an airbag waste collection facility, it becomes subject to all applicable hazardous waste regulations, and the facility receiving the airbag waste is considered the hazardous waste generator.

Do shipments of airbag waste need a hazardous waste manifest when traveling from the airbag waste handler to a designated facility or the airbag waste collection facility?

Airbag waste managed under the exemption does not need a hazardous waste manifest when being transported from an airbag waste handler to a designated facility or an airbag collection facility. However, the airbag waste remains subject to all applicable DOT hazardous materials regulations in 49 CFR part 171 through 180.

What is a designated facility?

A “designated facility” is authorized to accept hazardous waste for treatment, storage, disposal or recycling. Under the airbag waste conditional exemption, the designated facility would be considered the hazardous waste generator for any airbag waste received from airbag waste handlers.

More information about management of airbag waste and transboundary transport of the waste may be found at U.S. EPA website.

If you have any further questions, please email us at chosu.khin@dtsc.ca.gov.