Applicablity of life saving appliances

This is in response to your June 25, 2007 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to life saving appliances. Specifically, you ask if § 173.219 requires a package that contains a self inflating life-saving appliance and hazardous materials authorized by § 173.219(b) to be marked with both "Life-saving appliances, self inflating" and "Life-saving appliances, not self inflating," or only "Life-saving appliances, self inflating."

A life-saving appliance typically contains small quantities of hazardous materials that are required for the appliance to be effective during use (§ 173.219(b)). For example, a self- inflating life vest used by boaters may contain flares and compressed oxygen; a non-self inflating survival kit used by hikers may contain strike-anywhere matches, electric storage batteries, and bear repellant. Hazardous materials cannot stand alone as life-saving appliances; however, they may be used to supplement an instrument or device that is designed to assist those in distress.

In accordance with the HMR, the description "Life-saving appliances, self inflating, UN2990" applies to self-inflating appliances and "Life-saving appliances, not self inflating, UN3072" applies to life-saving appliances that do not self inflate. The descriptions apply to the overall appliance rather than individual hazardous material used to supplement the appliance, such as those listed in § 173.219(b). Therefore, a life-saving appliance that is self-inflating and contains hazardous materials in addition to those required for self inflation (see above for example of self-inflating life vest) would be assigned the proper shipping name "Life-saving appliances, self inflating."