Since the Environmental Protection Agency (EPA) issued a memo in June 2017 regarding the regulatory status of recalled Takata airbags stored in warehouses, there has been a great deal of concern in the recycling industry as to whether not airbags were considered hazardous materials. Auto recyclers, shredder operators, and other airbag stakeholders were left with a number of regulatory questions about both Takata and non-Takata airbags that still remained in vehicles destined for recycling.
Through a number of outreach efforts, including a face-to-face meeting, ISRI raised these concerns with the EPA. On behalf of its members, ISRI advocated for the EPA to issue a clarifying memo with much-needed guidance for recyclers that routinely recycle vehicles containing airbags. These efforts proved successful when the EPA recently issued such a memo dated July 19. Among other items, the memo confirms that airbags remaining installed in vehicles are considered part of the vehicle being recycling and are therefore exempt scrap metal under the Resource Conservation and Recovery Act (RCRA). The full memo which includes a summary of regulatory interpretations is available for ISRI members.
For more information about airbags or this memo, please contact David Wagger or Billy Johnson.