Walmart, SpaceX Request Hazmat Special Permit Mods

Posted on 4/23/2019 by Roger Marks

US DOT PHMSA posted notice of applications to modify existing hazardous materials special permits (SP) and notice of actions taken on existing SP applications on April 15. 
Among the special permit modification requests were a request from Walmart and a very unique, interesting request from Space Exploration Technologies Corp (SpaceX) discussed below.

Typical hazmat special permit applications are requests to:
  • Modify or expand the scope of an existing special permit;
  • Authorize the use of alternative packaging or packaging orientation for hazardous materials;
  • Allow for hazmat to be shipped or transported in ways otherwise prohibited; and more.
Can't make it to a workshop? Find online hazmat training to satisfy 49 CFR, IATA DGR, and IMDG Code mandates. Whether you ship hazmat every day or once a year, these courses cover what you need to know to keep your shipments in full compliance and avoid DOT fines now approaching $80,000 per day, per violation.  
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Reduced Size Limited Quantity Marking 

WALMART INC requested to modify special permit 20801, which allows for use of a reduced size limited quantity marking in place of the 100 mm marking required by 49 CFR 172.315(a)(2), regardless of the size of the package. 
172.315(a)(2) allows shippers to use a reduced size marking (minimum of 50 mm on each side) only when the “packaging size requires a reduced size marking.” 
The permit modification requested would remove requirements for a copy of the special permit to be carried aboard the motor vehicle (by ground mode) and presented to the air carrier before or at the time of shipment (by air mode). 

SpaceX Dragon 2 Capsule 

In a one-of-a-kind special permit request, SpaceX asked PHMSA to allow the display of the DANGEROUS placard only “when transporting the recovered Dragon 2 capsule.” 
Special permit 20474 allows for the Dragon 2 space capsule (and associated support equipment) to be transported in non-DOT specification packagings and provides relief from marking and labeling requirements. 
Shipping the Dragon 2 space capsule after recovery from the Atlantic Ocean will require packaging regulated hazardous materials from six different divisions, including lithium batteries contained in equipment, compressed gas, dinitrogen tetroxide, and methylhydrazine. Under the terms of the special permit, these materials will be shipped in specially designed packagings.
The permit is contingent on operational controls, leak checks on pressure vessels, employee and driver hazmat training, attendance at all times, marking requirements, and other safety, emergency response, and communication measures. 
PHMSA will not grant party status to this special permit. 

Special Permits Granted

PHMSA also posted a notice of special permits granted, denied, and withdrawn in a separate Federal Register notice posted on April 15.
PHMSA officially codified its standard operating procedures for evaluating hazmat special permits in September 2015.

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Tags: 49 CFR, DOT, hazmat shipping, hazmat special permits, PHMSA

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