Restraints/Keyless Entry - Perchlorate Material Disposal

Model: All Model

Group: General Information(10)

Number: KT2006122001

Date: Wednesday, December 20, 2006

Area: N. America

Subject
Disposal/Handling of Perchlorate Containing
Materials under California Law (General
Information - 015)

Description

For California Dealers Only.

This bulletin is intended to clarify your responsibilities under California law regarding the disposal requirements for perchlorate-containing materials in light of the recent passage of Title 22 of the California Code of Regulations Section 67384.10.

Perchlorate is a chemical that has been found to contaminate drinking water, ground water, surface water, soil and create various health problems. In an effort to decrease the amount of perchlorate released into the environment, California is regulating the disposal of materials containing perchlorate such as airbags, seat belt pre-tensioner initiators, and batteries for keyless entry systems.

You should be aware that once an airbag or a seat belt pretensioner is deployed, the perchlorate is used up in the burn process and is no longer regulated. The Department of Toxic Substance Control has advised manufacturers that deployed airbags and pretensioners are exempt pursuant to section 67384.2(b)(6) from the Perchlorate BMP (Best Management Practices) regulations. Thus, you can handle those items as you have handled them in the past, with the additional knowledge that the perchlorate has been used up.

In the event that you replace an undeployed airbag or pretensioner, you may use such parts during training of dealer personnel regarding the functioning of those items. KMA recommends dealers to periodically demonstrate airbag and seat belt pretensioner deployment as part of a dealer training program on how the airbag system operates and the consequences of deployment.

If undeployed airbags and seat belt pretensioners are not deployed as part of dealer employee education, they are considered hazardous waste and you should follow the normal procedures for the disposal of such materials in accordance with California's hazardous waste regulations.

Lastly, we want to remind you of a recent change in California law that waste batteries from keyless entry remote systems may not be discarded in the trash. See California Universal Waste Rule, 22 CCR in section 66273.13.

Waste batteries must be taken to a local recycle collection center. A center near you can be found at http://www.earth911 org.

If you have any questions regarding your implementation obligations under California law, please consult with the legal counsel you regularly consult with on waste issues.