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2020 MEMBERSHIP DIRECTORY & SERVICES GUIDE HOT TOPICS

MANAGEMENT OF AIRBAGS - NYSDEC ENFORCEMENT LETTER

In 2019, the New York State Department of Environmental Conservation (NYSDEC) issued an enforcement discretion letter regarding the management of waste airbags. This letter impacts how GYNADA members must handle them because NYSDEC considers dealers to be “airbag waste handlers”. Airbags become “waste airbags” when they are removed from a vehicle and waste airbags cannot be sold or reused. Undeployed airbags that are removed fromany vehicle are a hazardous waste and subject to the applicable hazardous waste regulations in New York State. However, NYSDEC requirements differ depending on the recall status of the airbag.

Defective Air Bags If auto dealers are handling defective airbags as per the NYSDEC enforcement letter, and as long as the defective airbags are managed within New York State, they can be considered non-hazardous, and therefore are not subject to the NYS Hazardous Waste Management regulations. Non- Defective Air Bags (ND Airbags) Auto dealers must follow the provision on the NYSDEC letter to manage non-defective air bags.

Call Walden Environmental Engineering, a GNYADA Allied Member, at 516.624.7200 or visit Walden Environmental Engineering for more information regarding the correct management of waste airbags or any other hazardous or non-hazardous waste.

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