ATF EXEMPTIONS FOR AIRBAG INFLATORS AND MODULES

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ATF EXEMPTIONS FOR AIRBAG INFLATORS AND MODULES

• September 24, 2003
• Presented by Dave Nichols
• PowerPoint by Scott Detwiler, TRW

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REGULATORY BACKGROUND

• BUREAU OF ALCOHOL, TOBACCO, FIREARMS AND
  EXPLOSIVES REGULATES EXPLOSIVES IN COMMERCE
• EXPLOSIVES INCLUDE
• Materials on the List of Explosive Materials,
  including mixtures containing these materials
• Other Explosives
• THIS INCLUDES AIRBAG PROPELLANTS

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REGULATORY BACKGROUND

• SINCE PROPELLANTS ARE REGULATED AS EXPLOSIVES,
  AIRBAG INFLATORS ARE ALSO CONSIDERED EXPLOSIVES.
• ATF REGULATIONS REQUIRE ALL PERSONS WHO HANDLE
  EXPLOSIVES TO HAVE A LICENSE OR PERMIT.
  THEREFORE, EACH ENTITY HANDLING AN INFLATOR WOULD
  HAVE TO BE LICENSED OR PERMITTED BY ATF

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ATF EXEMPTIONS

• SPECIAL EXPLOSIVE DEVICE EXEMPTION
• AT 555.32 (FORMERLY 55.32), THE AGENCY ALLOWS FOR
  CERTAIN EXPLOSIVE ACTUATED DEVICES, TOOLS OR
  SIMILAR DEVICES TO BE EXEMPTED FROM REGULATION.
• A WRITTEN REQUEST MUST BE SUBMITTED TO THE
  ADMINISTRATOR FOR REVIEW.

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ATF EXEMPTIONS

• INFORMATION REQUIRED
• COMPLETE AND ACCURATE DESCRIPTION OF THE DEVICE
• NAME AND ADDRESS OF THE MANUFACTURER/IMPORTER
• PURPOSE AND USE FOR WHICH IT IS INTENDED
• PHOTOGRAPHS/DIAGRAMS/DRAWINGS OR A SAMPLE OF THE
  DEVICE
• DOT CLASSIFICATION (OPTIONAL BUT USEFUL)

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ATF EXEMPTIONS

• INFORMATION REQUIRED (CONTINUED)
• SUBMIT REQUEST TO THE PUBLIC SAFETY OFFICE
• Ms. Gail Davis, Chief
• Public Safety
• Bureau of Alcohol, Tobacco, Firearms and
  Explosives
• 800 K Street, N.W., Room 710
• Washington, D.C. 20001
• TURNAROUND TIME 2-5 MONTHS

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ATF EXEMPTIONS

• SUGGESTIONS
• BE CLEAR IN YOUR LETTER WHAT EXEMPTION YOU ARE
  REQUESTING DONT BE OVERLY GENERAL OR
  NON-SPECIFIC. ATF WILL NORMALLY REFERENCE YOUR
  REQUEST IN THE EXEMPTION
• ATF LIKES TO GRANT AN EXEMPTION BY PART , ETC.
  IF YOU ARE LOOKING FOR AN APPROVAL FOR A FAMILY
  OF DEVICES, MAKE THAT CLEAR AND PROVIDE MAXIMUM
  PARAMETER INFORMATION FOR THE FAMILY