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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #23-0093

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Transportation Development Group

Individual Name: Jim Powell

Location State: AZ Country: US

View the Interpretation Document

Response text:

April 24, 2024

Jim Powell
Transportation Development Group
190 West Continental Road, Suite 216-401
Green Valley, AZ  85622

Reference No. 23-0093

Dear Mr. Powell:

This letter is in response to your October 25, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the application of the term "vehicle" in § 172.102, special provision 134, currently assigned to the proper shipping name "UN3171, Battery-powered vehicle or Battery-powered equipment." You state it is your understanding that the language in special provision 134 would apply to four-wheeled robots as a "vehicle," and ask whether a "humanoid-looking" robot that carries totes or boxes in a warehouse would be applicable to the term "vehicle" as it relates to special provision 134.

In accordance with § 173.22 of the HMR, it is the shipper's responsibility to properly class and describe a hazardous material. This Office does not generally perform that function. However, it is the opinion of this Office that the intent of the term "vehicle" in § 172.102, special provision 134 is to include self-propelled apparatus designed to carry one or more persons or goods. Therefore, humanoid-looking robots powered by lithium ion batteries and designed to carry one or more persons or goods would be consistent with the description of a "vehicle" in § 172.102, special provision 134 and thus be transported as "UN3171, Battery-powered vehicle."

I hope this information helpful. Please contact us if we can be of further assistance.


Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.102, 173.22

Regulation Sections

Section Subject
172.102 Special provisions
173.22 Shipper's responsibility