Latest DOT Updates on Hazmat Special Permit Requests

On March 26 and April 7, US DOT PHMSA announced details about hazardous materials special permits that have been requested, approved, denied, or withdrawn recently. 

DOT Hazmat Special Permit Updates

March 26, 2025:

• Actions on Hazmat Special Permits
• Applications for New Special Permits 
• Applications to Modify Special Permits 

April 7, 2025:

• Actions on Hazmat Special Permits
• Applications for New Special Permits 
• Applications to Modify Special Permits 

What is a DOT Hazmat Special Permit?

A hazmat special permit is a document issued by US DOT that can allow a person to do something that is normally not allowed by the Hazardous Materials Regulations (HMR). These permits often demonstrate creative solutions to challenges that shippers, carriers, and other stakeholders in the hazardous materials supply chain face. 

Typical hazmat special permit applications are requests to:

• Allow an alternative packaging or packaging orientation to be used; 
• Allow shipping or transportation of hazmat in ways normally prohibited; or
• Modify or expand on an existing special permit, e.g., to add a material, packaging type, or mode of transportation.

DOT Special Permit Applications 

Requirements for special permit applications are listed in 49 CFR 107.105. The application for a special permit must be submitted at least 120 days before the requested effective date. Any supporting documents that are included must be sent by mail, fax, or email, or submitted online. 

A shipper may utilize a special permit on a regular or semi-regular basis to streamline their day-to-day processes. In other situations, a special permit can provide a solution when something out-of-the-ordinary happens. PHMSA’s recent announcements list a few requests that illustrate this kind of "narrow scope," including applications for special permits:  

• "To authorize the one-time, one-way transportation of two containers packed with ammonium nitrate back to the shipper,” and 
• "To authorize the transportation… of lithium ion cells which were burned in an accident and deactivated prior to transportation.” 

In both cases, it appears that an unexpected issue put someone suddenly in the position of being the “shipper” of the hazardous materials involved. In these situations, special permits can allow for safe transportation of the materials without placing an undue burden on the company that finds itself stuck with hazmat to ship following some unsual, unexpected event. 

Conditions for Hazmat Special Permit Use

PHMSA approves special permit applications only when the applicant demonstrates that the alternative(s) they propose will not negatively affect on transportation safety. Once PHMSA grants a special permit, the permit will specify the conditions and actions required for compliance.

One very common condition on special permits, for example, is that employees who handle the relevant shipments must receive training that addresses the permit’s requirements and limits. Special permits often include a list of “operational controls” that special permits holders must follow when preparing and offering the shipments. 

Read More: Required Marking for Hazmat Special Permit Packages

Upcoming Hazmat Training Workshops

Come out for Lion's Hazmat Ground Shipper Certification Workshop near you for two days of expert-led training to simplify you responsibilities for hazmat shipping compliance. From classifying materials and shipping names, to UN packaging, labels and placards, shipping papers, training employees, registration and reporting, and more—return to work feeling more confident about compliance with the US Hazardous Materials Regulations (HMR) in 49 CFR.

Upcoming workshop locations include St. Louis on April 24–25 and Cincinnati on April 30–May 1. This two-day workshops provides general awareness, security awareness, and function-specific training required for "hazmat employees" on initial hiring and at least every 3 years thereafter (49 CFR 172.704).