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Document Record Detail

Full Document:
RCRA Online Number:14893
To:RCRA Division Directors, Regional Enforcement Division Directors, Regional RCRA Branch Chiefs
Organization of Recipient:NA
Description: This memorandum discusses how RCRA regulations apply to recalled Takata airbag inflators that are subject to the 2015 Preservation Order issued by the US DOT. The Takata airbag inflators are not subject to RCRA Subtitle C regulatory requirements while they are being held under the 2015 DOT Preservation Order because EPA does not consider airbag inflators or other explosives to be “discarded” and therefore subject to the hazardous waste regulations while they are being stored pending judicial proceedings or investigations. At the point the inflators are released from the Preservation Order and other legal action related to the recall, the inflators would be considered solid waste and subject to a hazardous waste determination and any applicable RCRA regulations. EPA considers discarded gas-generating-propellant airbag inflators to exhibit the characteristic of reactivity, waste code D003 (40 CFR 261.23(a)(6)) and airbag inflators containing an oxidizer to exhibit the characteristic of ignitability, waste code D001 (40 CFR 261.21(a)(4)). Deployment of airbag inflators is considered treatment of a hazardous waste and may require a permit if RCRA exemptions and exclusions do not apply. For example, incineration requires a RCRA permit regardless of future materials reclamation.
Regulatory Citation(s) : 261.2(c)(3), 261.21, 261.23, 262.1 EXIT disclaimer
Statutory Citation(s):3007, 3013, 7003 Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Characteristic Wastes; Combustion; Combustion of Hazardous Waste; Compliance; Disposal; Exclusions (RCRA); Generators; Hazardous Waste; Hazardous Waste Recycling; Identification of Hazardous Waste; Incineration; Large Quantity Generators (LQG); Permits and Permitting; Reactive Wastes; Recycling; Scrap Metal; Small Quantity Generators (SQG); Solid Waste; Storage; Treatment; TSDFs
Approximate Number of Hardcopy Pages:3
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:Yes


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