PA refers to cyclists as drivers.
http://safety.fhwa.dot.gov/ped_bike/docs/pamanual.pdf

[QUOTE][Bicyclists do not have special privileges on a roadway’s shoulder. Indeed, a bicycle rider is directed to ride on the furthest right hand side of the roadway, not on the roadway’s shoulder. The Motor Vehicle Code does not designate the roadway’s shoulder as a bicycle lane./QUOTE]

Yes, you are assuming certain liabilities by riding on the berm.