Common Mistakes Using Special Permits
There are so many nuances to the Hazardous Materials Regulations (HMR) it’s hard to keep up sometimes. This is not helped, at all, by the various DOT Special Permits (DOT SP) sprinkled in that affect how you use, fill, and requalify packaging and transport Hazardous Materials. There is a common misconception that Special Permits are consistently written, but each DOT-SP is truly special.
Adding to the confusion, various DOT-SPs created for a similar purpose, use of compressed gas cylinders for example, will extraneously include existing regulations not exempted anywhere in the document. A common mistake is to confuse these regulations with Operational Controls or Special Provisions.
This becomes a problem when an assumption is made that the regulation isn’t applicable when using a similar Special Permit that does not include a restatement of the rule, when performing the same activity.
Remember that the regulations in 49CFR are always applicable regardless of a rule being re-stated in the SP you’re using, unless the SP expressly exempts you from the rule.
Obviously, the way out of this problem is reading and understanding each line of the Special Permit, most importantly, all references to existing regulations. An in-depth knowledge of the Hazardous Materials Regulations (HMR) as it applies to your operation is the baseline when using DOT Special Permits.
For more compliance information regarding Department of Transportation Special Permits, visit our website: https://tymsllc.com/regulatory-compliance/