One would think that an airbag actuator would fall within the definition
of a "propellent actuated device" ("specialized mechanical device or gas
generator system that releases or directs work by means of a propellant
charge"), and as such would be exempt from 27 CFR part 555 "Commerce in
Explosives" by the action of the exemption at 27 CFR 555.141(a)(8): given
the existence of that regulatory language (which was unchanged, except for
a section renumbering, by the "safe explosives act"), I'd say there would
be a formidable "reasonable doubt" barrier between the American motoring
public and any legally-sustainable charge of "Using Unlicensed Explosives"!
Yes, I don't think anyone would get arrested and convicted for this, at least not by itself. But, the code is there. Of course, since they added charcoal briquets to the charges against that guy back East, I guess if they really want you they'd add your airbag to the list (of course it would be listed as an "unlicensed propellent actuated device" or some such).
For reference:
Orange Book, page 57, question 27
"27. How are airbags regulated by AFT?
Unless the product has been classified by AFT as a special explosive device and exempted from regulation under 27 CFR 55.32, an airbag device containing explosive initiators, igniters, or inflators is subject to regulation as containing explosive materials, i.e., low explosives, and must comply with all applicable requirements under 27 CFR Part 55."
My ATF contact says that airbags have NOT be classified as a special explosive device so are not exempt. She is NOT interested in arresting anyone for having an airbag in their car, but if you had several initiators in your house, she'd consider it.
---------- Jerry Durand Durand Interstellar, Inc. 219 Oak Wood Way Los Gatos, California 95032-2523 USA tel: +1 408 356-3886 fax: +1 408 356-4659 web: www.interstellar.com pgp: 45A2 0A52 1D56 70C2 B865 9D5C 83F2 2112 04CE 2B54
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