Transportation Development Group — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 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. Sincerely, Steven Andrews Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews 23-0093 Jones, Jessie Jane CTR (PHMSA) From: INFOCNTR (PHMSA) Sent: Thursday, October 26, 2023 3:27 PM To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Interpretation request special provision 134 Robots as Vehicles Attachments: PHMSA_Interpretation_Request_ROBOTS.pdf Follow Up Flag: Follow up Flag Status: Flagged Hello Alice, Please see the below interpreta on request. Let us know if you need anything. Sincerely, Janaye From: Jim Powell <jim@dgtraining.com> Sent: Wednesday, October 25, 2023 2:37 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Cc: Support <support@dgtraining.com> Subject: Interpretation request special provision 134 Robots as Vehicles CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. A ached is an interpreta on request for the term “vehicles” as defined in 49 CFR 172.102 SP 134, as it relates to “robots” designed to transport/convey cargo. It seems easy to envision that four-wheeled robots scoo ng around a warehouse floor with a tote on top, that it’s clearly a vehicle. But what about a humanoid-looking robot carrying totes or boxes in it’s arms and placing on a conveyer? Seems like that would also meet the defini on of a vehicle. I would just like a wri en interpreta on on this. It will come up again, sooner rather than later as the new UN number 3556 will be in use in 2025. 1#

Page 3Jim Powell Transporta on Development Group LLC 1-808-280-6047 www.dgtraining.com jim@dgtraining.com 2#

Page 4Transportation Development Group LLC 190 W. Continental Rd Ste 216-401 Green Valley, AZ 85622 1-808-280-6047 Direct | 1-800-949-4834 October 25, 2025 Pipeline Standards and Rulemaking U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Email pdf to infocntr@dot.gov Phone: 202-366-8553 Interpretation request – Are lithium battery-powered bipedal robots considered “vehicles?” In 49 CFR 172.102(c)(1) Special Provision 134 it defines a “vehicle” as the following: https://www.ecfr.gov/current/title-49/part-172/section-172.102#p-172.102(c)(1) a. For the purpose of this special provision, vehicles are self-propelled apparatus designed to carry one or more persons or goods… Upon conducting a quick search of the internet for “human shaped bipedal robots in the warehouse” you’ll find numerous examples of robots carrying totes around a warehouse, putting them on a conveyer, etc. Since this battery-powered apparatus is transporting cargo, would it be correct to classify it as a Battery Powered Vehicle? This would be UN3171 or Internationally under the new UN 3556, Vehicle, lithium-ion battery powered as codified in the UN Orange book and ICAO TI for 2025. Sincerely, Jim Powell, DGSA, CDGP President Transportation Development Group LLC jim@dgtraining.com 1-808-280-6047 DOT Interpretation Request from Jim Powell dgtraining.com regarding “Robots” as “Vehicles”#