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 […]
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 […]
Function Specific Training Requirements Department of Transportation (DOT) training is required in accordance with Subpart H of 49 CFR Part 172. Function Specific training is referenced specifically in § 172.704(a)(2)(i), which clearly states that anyone who performs a regulated function must be trained on the specifics of the Hazardous Materials Regulations, as it relates to […]
Problem Tym’s recently assisted a Department of Transportation (DOT) regulated facility that uses 59 different Special Permits (SP) in 5 different job functions. The company struggled with training compliance based on the complexity that the sheer number of documents and job functions presented. The financial burden of wages paid for training and lost productivity from […]
Tym’s recently sent a letter to the leadership of DOT PHMSA regarding the process of evaluating party status applications for DOT Special Permits. Not long ago, this was a simple administrative procedure by the agency. It was quick, painless, and included reasonable actions to demonstrate compliance related to the specific request. The same was true […]
On August 5, 2024 the Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) granted Tym’s LLC request for emergency special permit (SP) andissued DOT-SP 21774. We are happy to announce that the Tym’s Special Permit will be an effective solution for the entire aviation industry because PHMSA granted the SP with “Party Status.” […]
Our open letter to industry explains the situation in detail and presents facts surrounding the issue. We also included a call to action to industry trade associations, aircraft owner/ operators, (including all major US airlines), and repair stations to pressure the DOT and FAA to offer a reprieve to those who apply for Party Status.
For the first time, many US Repair Stations certified by the FAA and EASA will have a third regulatory agency certification: the UK CAA. Those of us in the USA cannot provide a triple maintenance release with FAA-UK-EU approval but foreign Repair Stations can. This will result in confusion and tough conversations with customers. We have a simple solution
Recently, we contemplated the applicability of the RR-C-901D cleaning and testing requirement found in 49 CFR 173.302(b) for filling aluminum oxygen cylinders. We’re interested to know what you think of our findings and need your comments to help the industry.
If you were happy that the FAA excluded Repair Stations from the requirement to develop and implement a safety management system (SMS) in the recent rule published in the Federal Register, temper your enthusiasm. Part 145 Repair Stations in the US will be required to implement the FAA’s “voluntary” program to remain EASA approved.