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Don’t Keep Your Hazmat Special Permit A Secret

Posted on 4/26/2021 by Roseanne Bottone

Hazardous materials Special Permits (SPs) empower shippers and carriers to use their creativity to solve unique transportation challenges.

When you use a hazmat packaging that is authorized by Special Permit, US DOT requires that you clearly mark the SP number on the packaging. Failure to mark the SP number on the packaging can significantly impact transportation safety, for reasons we cover below.

What is a Hazmat Special Permit (SP)?

A special permit is a document issued by US DOT to allow a person to do something that is not otherwise authorized in the hazardous materials regulations (HMR).

As DOT puts it: “Special permits enable the hazardous materials industry to quickly and safely integrate new products and technologies into the production and transportation stream... A special permit must achieve at least an equivalent level of safety to that specified in the HMR.”

Hazmat Special Permits (SPs) are commonly used to authorize:
  • Packaging construction criteria that differ from a UN Standard or DOT Specification,
  • Alternative means of testing or closure,
  • The reuse of the packaging,
  • Alternative hazard communication requirements (e.g., relief from labeling or the requirement for additional wording),
  • Alternative segregation requirements, or
  • The transportation of normally forbidden materials under certain conditions.

Why Marking the SP Number is Critical for Safety

Communicating the fact that a special permit is being used is essential to keep shippers, carriers, and handlers safe. Without the required marking, those who encounter the package will be unaware of any special considerations that must be taken into account to ensure the safe handling of the package during the cycle of transportation..
 
In a “Safety Notice” published in the Federal Register, the DOT gave this example:
 
“[C]onsider the case of a DOT 3HT cylinder that has been manufactured and re-qualified for service under an SP to be used in a fire suppression system onboard an aircraft. The SP may require the cylinder to be tested more frequently and at a different test pressure than the HMR would otherwise require.

If a cylinder re-qualifier fails to recognize the cylinder's SP markings and apply the more stringent SP requirements, it might wait too long to retest the cylinder or apply the wrong test pressure. These errors put lives and property at risk when defective cylinders are improperly tested and allowed to function as part of an emergency response system, such as a fire suppression system.”

[76 FR 53999, August 30, 2011]

How to Indicate Special Permit Usage on Packagings

In general, the outside of each package authorized by a special permit must be plainly and durably marked “DOT-SP” followed by the special permit number assigned.

Note: Packages authorized by an exemption issued prior to October 1, 2007, may be plainly and durably marked “DOT-E” in lieu of “DOT-SP” followed by the number assigned as specified in the most recent version of that exemption.

Conversion of SPs into the HMR  

Other people can submit a petition to become a party to a hazmat special permit if it better serves their shipping needs. While DOT’s goals for special permits include “reducing the volume and complexity of the HMR by addressing unique or infrequent transportation situations that would be difficult to accommodate in regulations intended for use by a wide range of shippers and carriers…” some special permits become widely used.

As a result of their popularity, longstanding special permits with well-establish safety records have been converted by the Pipeline and Hazardous Materials Administration (PHMSA) into the 49 CFR regulations to facilitate broader applicability and ease of compliance.

In 2016, PHMSA added ninety-six Special Permits to the 49 CFR regulations. 

Using Pre-printed Special Permit Packaging 

As PHMSA adds widely used Special Permits to text of the HMR, you may find that what was once a special accommodation is suddenly not-so-special, but is available for anyone to use, right there in the regulations.

So what about all that pre-printed special permit packaging now that the special permit has been incorporated into the regs and no longer exists? Good news! According to 49 CFR 172.23 (h), a packaging that is permanently marked with a special permit number, “DOT-SP” or “DOT-E,” for which the provisions of the special permit have been incorporated into the regulations may continue to be used for the life of the packaging without obliterating or otherwise removing the special permit number.

In-person Hazmat Workshops Return in 2021

Let’s train together again. Join a Lion instructor for comprehensive, expert-led training to ship hazardous materials by ground, air, and vessel when Lion workshops return to select cities later this year.

These comprehensive workshops cover the latest requirements you must know to offer safe, compliant shipments, and help meet US DOT, IATA DGR, and IMDG Code training mandates for hazardous materials professionals.
 
  49 CFR  IATA DGR  IMDG Code
Charlotte Aug. 10–11 Aug. 12  
Orlando Aug. 16–17 Aug. 18  
Nashville Aug. 24–25 Aug. 26 Aug. 27
Atlanta Aug. 30–31 Sep. 01 Sep. 02
Houston Sep. 14–15 Sep. 16 Sep. 17
Dallas Sep. 20–21 Sep. 22 Sep. 23
San Diego Sep. 28–29 Sep. 30 Oct. 01
Cincinnati Nov. 08–09 Nov. 10  
St. Louis Dec. 01–02 Dec. 03  
Chicago Dec. 06–07 Dec. 08 Dec. 09

Save when you attend all four days! Enroll for the Complete Multimodal Hazmat Shipper Certification Workshops in Nashville, Atlanta, Houston, Dallas, San Diego, or Chicago. 

US DOT requires hazmat training once every 3 years (49 CFR 172.704). 

Tags: hazmat shipping, hazmat special permits

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