Aviation

DOT-SP 12726 No More?

On March 27, 2026 the Council on Safe Transportation of Hazardous Articles (COSTHA) submitted a Petition for Rulemaking to incorporate DOT- SP 12726 into the Hazardous Materials Regulations. As a member of COSTHA, Tym’s is thankful for this organization’s efforts and support this proposed rulemaking. Currently, with 18 grantees, DOT-SP 12726 is a commonly used […]

What is a Special Permit?

A Special Permit from DOT PHMSA is defined in 49 CFR 107.1: “a document issued by the Associate Administrator, the Associate Administrator’s designee, or as otherwise prescribed in the HMR, under the authority of 49 U.S.C. 5117 permitting a person to perform a function that is not otherwise permitted under subchapters A or C of […]

Revision to Special Permit 21774

On January 23, 2026 the second revision of DOT SP 21774 was issued by the DOT Pipeline and Hazardous Materials Safety Administration (PHMSA). These changes were requested by American Airlines and thereafter approved by the DOT. Second Revision to DOT SP 21774 Changes in revision 2 include the addition of approved “corrugated plastic boxes,” manufactured […]

Now is a Great Time to Request a DOT Special Permit

On January 12, 2026, the US Department of Transportation, Office of Hazardous Materials Safety (OHMS), stated in writing that it “will refrain from taking any enforcement action against a regulated party who defers the performance of an activity that would otherwise be required under the Federal pipeline or hazardous materials safety regulations” in specific circumstances. […]

Do You Need a Hazardous Materials Security Plan?

Background When communicating with the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT PHMSA) an assumption is often made regarding HazMat Security Plans. The agency tends to assume one is required, catching even experienced personnel off guard when requesting renewals or undergoing an audit by the DOT. Requirements The requirement for a […]

SMS Compliance Date for FAA/EASA Repair Stations

The FAA recently published Information For Operators (InFO) 24007, clarifying the Safety Management System (SMS) compliance date. Existing US Repair Stations with an EASA certificate must implement a SMS by December 31, 2025. Maintenance Annex Guidance (MAG) Change 10, which includes the SMS requirement, must be implemented by October 10, 2025. Therefore, EASA manual supplements […]

Cylinder Overpack Letter of Interpretation 24-0042

Problem On June 4th, 2024 Tym’s LLC formally requested clarification for a Letter of Interpretation (LoI) issued by the US Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding the use of Overpack for compressed gas cylinders. On January 3, 2025 the agency issued a revised Letter of Interpretation, based on our concerns. […]

DOT PHMSA Interpretations Now Open for Comment

Problem On June 4th, 2024 Tym’s LLC formally requested clarification for a Letter of Interpretation (LoI) issued by the US Department of Transportation, Pipeline and Hazardous Materials Safety Administration (DOT PHMSA) regarding the use of Overpack for compressed gas cylinders. A generous portion of our website outlines this engagement here. The back-and-forth on this topic […]