Common Pitfalls of DOT Special Permit Party Status Applications
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 layman, such as “Please send your Security Plan,” even though the facility may not require one. They may also ask for written “policies and procedures” that aren’t required by law.
However, if they do exist, these internal policies could include details that do not align with federal law, which may result in enforcement action.
It is imperative that your facility is up to date on all regulatory requirements, including training, before submitting a party status request. Training records must include function-specific training on the details of the Special Permit, in addition to all other training required by 49CFR Part 172 Subpart H. Tyms can assist by reviewing these records and offering supplemental training, as needed.
For more information, visit our website: https://tymsllc.com/training
Additionally, you should expect additional scrutiny from the DOT’s “modal partners,” such as the Federal Aviation Administration (FAA), depending on how you ship or transport these items. For example, if you ship by air (e.g. FedEx Express) your information will also be reviewed by the FAA Office of Hazardous Materials Safety. Sometimes these agents look for unexpected things, based on their agency’s oversight goals or individual agent’s biases.
After your application is granted, you will receive a Special Permit Authorization letter with your company’s information listed as a Grantee. This document, in addition to the Special Permit, will be used together throughout the transportation process. The Special Permit Authorization will also have an expiration date. A renewal request must be filed at least 60 days prior to expiration. If you do not meet this timeframe, it is highly unlikely that the renewal will be granted in time. If you request renewal before this date, a Timely Filing letter is typically sent. This letter normally allows your company to continue using the Special Permit until the agency completes a new evaluation and issues an updated Authorization Letter.
You can easily offload this entire regulatory burden to Tym’s by using our low-cost, flat-rate compliance services, which include DOT-SP party status requests and renewals.
Find more information on our website: https://tymsllc.com/regulatory-compliance