{"operation":"document","citation":"25-0030","title":"Dangerous Goods of America, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-03-12","effective_on":null,"summary":"25-0030 response to Dangerous Goods of America, Inc. concerning 173.185, 173.219.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-03/25-0030.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 12, 2026\nManuel Alejandro\nDangerous Goods of America, Inc.\nDGA Hazmat App LLC\n10400 NW 33rd St, Suite 230\nDoral, FL 33172\nReference No. 25-0030\nDear Mr. Alejandro:\nThis letter is in response to your March 14, 2025 email and subsequent phone conversation\nwith a member of my staff requesting clarification of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) applicable to lithium batteries installed in life‑saving\nappliances. In your email, you describe self-inflating life vests with beacons—each\ncontaining between 1 g and 2 g of lithium metal—offered for transportation by air.\nWe have paraphrased and answered your questions as follows:\nQ1. Is the lithium battery mark—specified in § 173.185(c)(3)(i)—required on an article\ndescribed “UN2990, Life-saving appliances, self-inflating?”\nA1. No. When the article is properly classed, described, packaged, marked, and labeled,\nas “UN2990, Life-saving appliances, self-inflating” the mark specified in\n§ 173.185(c)(3)(i) is not applicable. However, under § 173.219(b)(3) the lithium\nbatteries contained in life-saving appliances must be “packed in accordance with\n§ 173.185,” meaning the packaging requirements in § 173.185 apply when offering\n“UN2990, Life-saving appliances, self--inflating.”\nQ2. When offered for transportation by air, what quantity limitations apply to lithium\nmetal batteries contained in “UN2990, Life-saving appliances, self-inflating?”\nA2. As described in § 173.219(b)(3), lithium batteries included as part of a life-saving\nappliance must be packed in accordance with § 173.185 and Special Provisions A54\nand A101, as applicable. When transported by aircraft, Special Provision A101\n\n<<>>\n\nrestricts the quantity of lithium metal in the batteries contained in any piece of\nequipment to 12 g per cell and 500 g per battery.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nAlexander Wolcott\nActing Chief, Regulatory Review and Reinvention\nBranch Standards and Rulemaking Division\n\n<<>>\n\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps; Baker, Yul (PHMSA)\nSubject: FW: Request of a Letter of Interpretation\nDate: Monday, March 17, 2025 9:46:13\nGood Morning,\nSee the attached interpretation request. Let us know if you need anything else.\nBest,\nAminah\nFrom: Compliance DGA4U \nSent: Friday, March 14, 2025 4:00 PM\nTo: Pfund, Duane (PHMSA) ; INFOCNTR (PHMSA)\n\nCc: Compliance DGA4U \nSubject: Request of a Letter of Interpretation\nSome people who received this message don't often get email from compliance@dga4u.com. Learn why this is\nimportant\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nDear PHMSA;\nWe are a training facility for the safe transport of hazardous material, there are questions\nthat we are not sure about. Therefore, we ask for clarification:\nAs you may be aware many evacuation slides, life rafts and life vests assigned to UN2990,\nLife-saving appliances, self-inflating, in addition to the survival kits hazmat contents in these\nappliances, they also contain beacons that are powered by lithium metal batteries that most\nare activated when in contact with water or by person.\nSome appliances contain more than two and others do not. The size of these lithium metal\nbatteries in the beacon varies.\n· Do these appliances require the lithium battery mark (173.185 Figure 1 to paragraph (c)(3)\n(i) and does,\n· The lithium test summary is required (173.185 (a)(3).\nPlease find below two Examples:\n\n<<>>\n\n1. If we are declaring in a shipping paper a UN2990, Life-saving appliances,\nself-inflating, and this Life-saving appliances contains a lithium metal battery in the\nBeacon that complies with 173.185 (c)(1)(ii).\nDoes the box require to be marked with the lithium battery mark (173.185\nFigure 1 to paragraph (c)(3)(i)?\n2. If we are declaring in a shipping paper a UN2990, Life-saving appliances,\nself-inflating, and this Life-saving appliances contains a lithium metal battery in the\nBeacon that exceeds 1g for a lithium metal cell or 2g for a lithium metal battery.\nDoes the box require to be marked with the Class 9 Label 172.446 or the Class 9\nLabel 172.447?\nIf the Class 9 Label 172.447 applies, will the classification change to UN 3091,\nLithium metal batteries contained in equipment?\nYour kind and prompt reply to this inquiry is very much appreciated.\nThank you,\nManuel Alejandro\nDangerous Goods of America, Inc.\nDGA Hazmat App LLC\n10400 NW 33rd\nSt, Suite 230, Doral, FL 33172\nTel: 305-871-3313 Cell: 786-218-5850| Fax: 305-592-8589 | compliance@dga4u.com","truncated":false,"body_characters":4951}