In our interaction with a number of employers in the group, we have encountered a potential problem relating to the Air Bag Recall program which is applicable to all dealers carrying out work on replacing them. This information is provided after we have consulted with SafeWork NSW and focuses on an area which is very technical in nature but is extremely important because of the potential of fatalities if any malfunction occurs.

Air Bags have a small explosive charge in them which acts as the actuator of the bag providing the means by which it is inflated. As has been publicised recently, a person in Australia was actually killed by a faulty air bag, so the potential for fatalities exists in their handling. So the correct handling and storage of these items is very important.

Licensing

The advice we have received in relation to the explosives quantity within each module is that it is only a matter of grams, therefore the quantity of units to be stored would have to be extremely large to reach the 10kg NEQ threshold for any licensing requirements under the Explosives Regulations 2013 to come into consideration. However, it may be relevant to large dealers and should not be overlooked.

Packaging Requirements

The Dangerous Goods classification for an airbag is determined by the manufacturer. The Manufacturer can either classify airbags as a Class 1 (Explosive) or Class 9 (Miscellaneous).

The manufacturer is to package the airbags in approved packing which includes the UN Number. The modules we have seen have been classified as Class 9 and have the correct UN number and labelling, however, it is important to be sure that this is the case which may change according to each manufacturer’s classification.

Storage Requirements

In terms of storage in designated storage areas, it needs to be a :

  • Well ventilated area
  • Stored away from any ignition sources
  • There should be restricted access to the storage area

Notwithstanding that the quantity is unlikely to infringe the amount from a licencing aspect, the risk is still great enough to cause a fatality and therefore from a best practice perspective, we encourage all participants in the recall program to consider developing a procedure and practice that:

  1. introduces a quantity threshold for storage of removed faulty airbag modules and a defined period of time these are stored in the workshop environment before these are transported back to the supplier or parts warehouse; and
  2. introduces a quantity threshold for segregated storage of both new and faulty airbag modules in the parts warehouse and any other location with large quantities of modules i.e. no more than 30 units in one storage location with designated storage areas segregated by more than 20 metres.

Signage

Dependant on the classification the below signage is required

Hazard labels

As the manufacturers appear to have classified these units as Class 9, Miscellaneous Dangerous Goods 9 signs should be displayed in an easily visible location in all areas where there is storage of these airbag modules.

Transportation

There is no placarding required for trucks carrying airbags.

As these units are all imported by car manufacturers that are large corporations, we would be surprised if they did not have material relating to processes and procedures relating to these matters and therefore suggest that it would be a good idea to approach them for any information they can provide relating to the safe storage and handling of these items.


Should you require any further information, please do not hesitate to contact us on 1300 287 872 or 0414567122.