After 10 months of back-and-forth with the US Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding Letter of Interpretation No. 24-0010, we finally have some conclusions regarding the use of Overpack for aviation compressed gas cylinders. Tym’s Request Resulted in Revised Letter of Interpretation On January 3, 2025, the agency issued […]
If you operate a US Repair Station with an EASA Certificate, no doubt you’ve heard about the
new special condition in the forthcoming Maintenance Annex Guidance (MAG) that requires you
to establish, implement, and maintain a Safety Management System (SMS).
There are several great trade associations that assist small and medium-sized businesses with
complex regulatory requirements in their operational domain.
We receive regular requests regarding Safety Management System (SMS) implementation from
domestic FAA repair stations with EASA approval granted via the EU/US bilateral agreement.
We suspect that this will continue, and greatly increase, based on the upcoming deadline to
implement SMS for US repair stations on December 31, 2025 (as published in FAA Information
for Operators (InFO) 24007).
According to a Federal Aviation Administration (FAA) final rule published on December 18, 2024
titled ”Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the
United States,” the FAA announced a formal requirement that international regulatory authorities
and repair stations have been dreading for years.
A Final Rule posted to the Federal Register on 12/30/2024 increased the fines for DOT and FAA violations, including Hazardous Materials transportation laws, again in 2025. The long list of legal citations and penalties can be found here. Remember that findings during FAA and DOT audits can result in a multitude of violations andsome penalties […]
On December 11, 2024, the Department of Government Efficiency (DOGE) on X (formerly Twitter) asked the public to provide examples of “wasteful and burdensome regulations.” We were more than happy to oblige. Below is a snippet of our submittal. We must give credit to the Aeronautical Repair Station Association (ARSA), which so eloquently summarized the […]
Tym’s recently submitted a public comment on Docket No. PHMSA-2024-0041 regarding the development of “general investigative questions” that may be used by PHMSA’s Office of Hazardous Materials Safety (OHMS) field operations personnel when “investigating potential general safety issues.” We asked that the questions not be adopted based on the agency’s false premise that the questions […]
The application process for Special Permit party status is straightforward. However, DOT PHMSA will respond with a request for documentation, such as training records, at a minimum. In the worst case, the process will trigger a full regulatory audit or on-site visit. Typically, the agency asks questions that may be misleading or confusing to the […]
Can you use a Department of Transportation (DOT) Special Permit (SP) that is not your own? An important rule, sometimes not re-stated in an applicable Special Permits, is 49CFR § 173.22a covering “Use of packagings authorized under special permits.” Section a of § 173.22a clearly states that a Special Permit may not be used unless […]