GOLD SEAL Recall Certification Checklist

Sep 1, 2022 | Safety

Certification is increasingly important. Here is a look at the facility standards for the Gold Seal program’s recall protocols. Find out where you rank!

From the ARA Certification Committee

The Gold Seal certified facility conducts a VIN check for safety system recalls when the vehicle is inventoried.

If a recall exists, then the part is struck as not saleable in the inventory system and processed for scrap or factory authorized collection methods assuring documented OEM-approved destruction techniques.

An ARA Gold Seal certified facility does not sell Recycled Original Equipment (ROE) auto parts that have safety recalls issued by an Original Equipment Manufacturer (OEM) for re-use or repair of another vehicle.

Safety recall parts are only sold to factory authorized collectors assuring a documented OEM approved destruction. An ARA certified facility conducts a VIN check for safety system recalls when the vehicle is inventoried. If recalled safety items are found, the recalled part is not entered in inventory for sale or is assigned a recall code and/or is struck as not saleable for reason of recall in the inventory management system. Recalled parts are removed (or destroyed) from the vehicle and processed for scrap or bounty collection.

Safety parts known to have recalls, such as airbags, are also VIN checked for recall at point-of-sale. If a recall exists, then the part is struck as not saleable in the inventory system and processed for scrap or factory authorized collection methods assuring documented OEM-approved destruction techniques. Standards would include:

o Written Recall Policy with source VIN attached to stock number and a recall notification procedure.

o Airbag Handling Protocol implemented.

o Point-of-sale VIN check on safety components such as airbags.

Learn more at https://aracertification.com/recalls

The following sample written recall policy may be modified to reflect the facility’s policies that go beyond the minimum requirement of the Gold Seal program.

Written Recall Policy – Sample

This Gold Seal certified facility does not sell Recycled Original Equipment (ROE) auto parts that have safety recalls issued by an Original Equipment Manufacturer (OEM) for re-use or repair of another vehicle. Safety recall parts are only sold to factory authorized collectors assuring a documented OEM approved destruction. Recalled parts may also be sold for litigation purposes.

This Gold Seal certified facility conducts a VIN check for safety system recalls when the vehicle is inventoried. If recalled safety items are found, the recalled part is not entered in inventory for sale or is assigned a recall code and/or is struck as not saleable for reason of recall in the inventory management system. Recalled parts are removed (or destroyed) from the vehicle and processed for scrap or bounty collection.

Safety parts known to have recalls such as airbags are also VIN checked for recall at point-of-sale. If a recall exists, then the part is struck as not saleable in the inventory system and processed for scrap or factory authorized collection methods assuring documented OEM-approved destruction techniques. Deployed airbags do not need to be removed to be checked in using the factory authorized collectors.

The point-of-sale recall check must be made at the government website:

https://vinrcl.safercar.gov/vin/

https://www.nhtsa.gov/recalls

For ARA Members with login:

https://ararecalllookup.nsvrp.org/

This Gold Seal certified facility enters each ROE part into the Inventory Management System with a unique ID that provides traceability for the source and sales destination. Parts, including brokered parts, are listed on invoices with the source VIN.

Upon direct notification from the manufacturer, this Gold Seal certified facility processes recalled parts by correlating the manufacturers recall by VIN to the facility’s stock number. All unsold parts are struck from inventory and removed from online listings such as eBay Motors and/or third-party broker sites.

Upon direct notification from the manufacturer, recalled parts that were sold are flagged for a notification letter to the buyer, as identified by stock number in the sales record. 

The recall notification letter sent to the customer will be mailed with a delivery confirmation receipt. Delivery receipts will be logged. If a notification letter is returned as undeliverable, an attempt to call the customer at the phone number from the invoice and/or account will be made. This call will be logged. Customer reimbursement and parts replacement will follow the guidelines provided by the vendor for the recalled parts.

This Gold Seal certified facility has documentation, within the past three years of DOT certification training for hazardous materials and dangerous goods shipping for all employees associated with the shipping of airbags, seatbelt pretensioners and hybrid batteries. Even facilities that do not sell airbag or other designated dangerous goods to retail customers must be HazMat certified to ship these parts to recyclers, remanufacturers, and factory authorized collectors.

ARA Certification program has developed SAMPLE written procedures to assists members seeking to become Certified Auto Recyclers in developing the required written policies aligned with the standard of excellence set forth in the CAR and Gold Seal certification program. Gold Seal downloadable sample for a written recall policy (as seen here) can be found at https://aracertification.com/recalls.

Recall Certification Questionnaire

Here are evaluation questions to determine where you stand in this protocol.

6.01 Is each ROE part entered into the Inventory Management System with a unique ID that provides traceability for the source and sales destination if sold?

The Gold Seal certified facility should enter each ROE part into the Inventory Management System with a unique ID that provides traceability for the source vehicle and sales destination. Parts, including brokered parts, are listed on invoices with the source VIN.

o Yes

o No

o N/A Not applicable is only acceptable if the facility is not seeking Gold Seal certification.

6.02 Are ROE Parts listed on invoices with the source VIN?

The Gold Seal certified facility enters each ROE part into the Inventory Management System with a unique ID that provides traceability for the source vehicle and sales destination. Parts, including brokered parts, are listed on invoices with the source VIN.

6.03 Are brokered ROE Parts traceable back to their source VIN?

The Gold Seal certified facility enters each ROE part into the Inventory Management System with a unique ID that provides traceability for the source vehicle and sales destination. Parts, including brokered parts, are listed on invoices with the source VIN.

6.04 Does the facility written RECALL policy require that recalled Parts may not be sold, other than to factory authorized collectors, or for litigation purposes?

The Gold Seal certified facility does not sell Recycled Original Equipment (ROE) auto parts that have safety recalls issued by an Original Equipment Manufacturer (OEM) for re-use or repair of another vehicle. Safety recall parts are only sold to factory authorized collectors assuring a documented OEM approved destruction. Recalled parts may also be sold for litigation purposes.

6.05 Does the facility written RECALL policy address how to handle recall notifications from manufacturers?

The Gold Seal certified facility conducts a VIN check for safety system recalls when the vehicle is inventoried. If recalled safety items are found, the recalled part is not entered in inventory for sale or is assigned a recall code and/or is struck as not saleable for reason of recall in the inventory management system. Recalled parts are removed (or destroyed) from the vehicle and processed for scrap or bounty collection.

Safety parts known to have recalls such as airbags are also VIN checked for recall at point-of-sale. If a recall exists, then the part is struck as not saleable in the inventory system and processed for scrap or factory authorized collection methods assuring documented OEM-approved destruction techniques. Deployed airbags do not need to be removed to be checked in using the factory authorized collectors. The point-of-sale recall check must be made at the government website: https://vinrcl.safercar.gov/vin/ OR https://www.nhtsa.gov/recalls

6.06 Does the facility written RECALL policy address how to notify any buyers of recalled Parts?

Upon direct notification from the manufacturer, recalled parts that were sold are flagged for a notification letter to the buyer, as identified by stock number in the sales record. 

The recall notification letter sent to the customer will be mailed with a delivery confirmation receipt. Delivery receipts will be logged. If a notification letter is returned as undeliverable, an attempt to call the customer at the phone number from the invoice and/or account will be made. This call will be logged. Customer reimbursement and parts replacement will follow the guidelines provided by the vendor for the recalled parts.

6.07 Does the facility written RECALL policy address when to destroy or remove in stock inventory?

The Gold Seal certified facility conducts a VIN check for safety system recalls when the vehicle is inventoried. If recalled safety items are found, the recalled part is not entered in inventory for sale or is assigned a recall code and/or is struck as not saleable for reason of recall in the inventory management system. Recalled parts are removed (or destroyed) from the vehicle and processed for scrap or bounty collection.

6.08 Does the facility maintain a written record of all handled recalls and actions taken?

Upon direct notification from the manufacturer, recalled parts that were sold are flagged for a notification letter to the buyer, as identified by stock number in the sales record. 

The recall notification letter sent to the customer will be mailed with a delivery confirmation receipt. Delivery receipts will be logged. If a notification letter is returned as undeliverable, an attempt to call the customer at the phone number from the invoice and/or account will be made. This call will be logged. Customer reimbursement and parts replacement will follow the guidelines provided by the vendor for the recalled parts.

6.09 Is the ARA Airbag Protocol signed by all Employees responsible for airbag handling at the facility? Document Verification Required

Airbag Handling Protocol should be reviewed, implemented and the document signed by each employee that handles airbags at the facility.  A copy of the policy can be downloaded from https://aracertification.com/

6.10 Regulatory Review – DOT Training – Shipping of Airbags – Does the site have documentation of DOT Certification Training for Dangerous Goods shipping provided within the past three years for all employees associated with the shipping of airbags/seatbelt pretensioners/hybrid batteries or DO NOT ship HazMat from facility? Verification Required

This Gold Seal certified facility has documentation, within the past three years of DOT certification training for hazardous materials and dangerous goods shipping for all employees associated with the shipping of airbags, seatbelt pretensioners and hybrid batteries. Even facilities that do not sell airbag or other designated dangerous goods to retail customers must be HazMat certified to ship these parts to recyclers, remanufacturers, and factory authorized collectors.

ARA University (https://arauniversity.org/) has a module available: Airbag & Explosive Pretensioners Safety

ARA University (https://arauniversity.org/) has a module available: DOT Hazardous Material Training

o Yes, documentation of training within three years for shipping staff

o No, documentation of training not current within three years for all shipping staff

o No airbags or HVV batteries are shipped even for recall bounty processing

6.11 Does the facility perform point-of-sales recall check for all safety parts such as airbags?

Safety parts known to have recalls such as airbags must be VIN checked for recall at point-of-sale. If a recall exists, then the part is struck as not saleable in the inventory system and processed for scrap or factory authorized collection methods assuring documented OEM-approved destruction techniques. Deployed airbags do not need to be removed to be checked in using the factory authorized collectors. The point-of-sale recall check must be made at the government website: https://vinrcl.safercar.gov/vin/  or  https://www.nhtsa.gov/recalls

For ARA Members with login: https://ararecalllookup.nsvrp.org/

o Yes, point-of-sale recall check is performed.

o No, point-of-sale recall check is not performed.

Airbag Handling Protocol

Introduction – The purpose of this document is to provide guidelines for the practice of removing an original equipment non-deployed airbag from a salvaged vehicle for installation in another vehicle. The guidelines are provided in sections, and the rationale, additional explanation and examples are noted in italics.

Definition – These guidelines cover the use of Original Equipment Manufactured non-deployed airbags. OEM non-deployed airbags must be original equipment that have been removed from a donor vehicle and installed in another vehicle for which they are correct replacement parts. These guidelines do not include rebuilt, re-manufactured, or non-original equipment airbag or airbag system components. They do not include any airbag or airbag system component that has been disassembled, altered, repaired, or had any parts removed or replaced.

Owner Notification – If an OEM non-deployed airbag is to be installed by a third party, the vehicle owner must be made aware of the intended use of such air bag(s) prior to its installation. In repairing a vehicle, the use of OEM non-deployed airbags may save the consumer several hundred dollars and in some instances be the difference between the vehicle being declared a total loss rather than being repaired.

Air Bag Suitability – There should be no modifications to the OEM non-deployed airbag including finish and color. Refinishing an airbag such as painting the exterior cover to match the interior color of the vehicle may degrade the material thereby adversely affecting deployment or cause paint to flake off during deployment, which could cause severe injuries to the occupants.

Airbag system components that have suffered water damage must not be re-used. Airbag modules are sealed to repel moisture under normal vehicle operating conditions. However, airbag system components that have been submerged or suffered flood damage must not be reused. Long-term exposure to the elements may also cause water contamination.

Applications – The supplier must ensure that any OEM non-deployed airbag supplied is an exact interchange for the recipient vehicle. Fitment must be ensured through confirmation with published, recognized and approved interchange data. Physical fit and similarity is not a guarantee of correct interchange.

OEM Non-Deployed Air Bag Training – OEM non-deployed airbags shall ensure that any staff member who is engaged in dismantling, handling, inspecting, storing or shipping of airbags complete a training course. Such training course must be meet the shipper certification rules set forth by the Department of Transportation (DOT) in 49CFR 171-173. Persons involved in shipping and transporting of airbags (both OEM non-deployed and OEM new) must follow procedures appropriate for the shipping consistent with DOT Regulations. Training must be repeated so that all HazMat employees have been certified or re-certified within the last three (3) years.

Documentation – Upon sale, each OEM non-deployed airbag must be accompanied by a supplier issued document including the following information:

• Identification of the supplier of the unit.

• Identification of the airbag module cover color (and color code if available).

• Identification of the donor vehicle, including VIN, year, make and model.

• Suppliers internal stock number or locator number.

• Indication of source of fitment information (i.e. Interchange manual/part number, OEM info, etc.).

Recalls – Prior to sale, the NHTSA complaint, defect, and recall database shall be searched to confirm that the OEM nondeployed airbag(s) are not the subject of investigation. If there is evidence of complaints, defects, and/or recalls, the airbag system shall be destroyed.

The point-of-sale recall check must be made at the government website:

https://vinrcl.safercar.gov/vin/

https://www.nhtsa.gov/recalls

Storage – Once removed from the donor vehicle, airbag modules should be stored in a cool dry location with appropriate fire protection, stored cover side up and not stacked. OEM non-deployed airbags shall be protected from the elements both in the salvage vehicle and in storage facilities to avoid exposure to water or other contaminants. Storage of airbags shall be on a secure flat surface away from high heat source and free of oil, grease, detergent or water. Suppliers of OEM non-deployed airbags shall comply with all relevant procedures.

o Inspection Protocol

Suppliers of OEM non-deployed airbags must use an established protocol for inspection of an OEM non-deployed airbag and must perform such inspections on all units prior to sale/installation. Only units that successfully meet all the requirements may be sold or installed. Inspections must include at a minimum the following:

1) The OEM non-deployed airbag supplier must identify, record, and report the donor vehicle information including vehicle year, make, model, VIN and airbag trim color if applicable.

2) Airbag module cover must be visually inspected and show no damage including nicks, scrapes, scratches, or outer flaws which might lead to the refinishing of the module.

3) Airbag system components must be visually inspected and show no signs of water contamination – including mold, mildew, or water residue. OEM non-deployed airbag use is not recommended if the donor vehicle sustained flood damage and/or any airbag system components exhibit signs of water contamination.

4) The airbag module must be inspected and be free of loose parts or foreign objects.

5) Visual inspection of mechanical fasteners for damage.

6) Attached wiring and electrical connectors must be visually inspected and show no corroded, damaged, or abraded wires, terminals or connectors.

7) The shorting bar, if included, must be visually inspected.

For more information https://aracertification.com/gold-seal or contact the ARA at (571) 208-0428 to get started today!  

Visit the aracertification.com website for more information on being Gold Seal certified.

ara roe logo
Centercaps_Ad_2.25x5-6.4.19-PRINT