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Special Permit Operators

illustration of plane being loadedThe U.S. Department of Transportation (DOT) Pipeline Hazardous Materials Safety Administration (PHMSA) has the primary responsibility for issuance of Special Permits (DOT-SP), Competent Authority Approvals (CA), and Competent Authority Classification of Explosives (EX approval letters) to the Hazardous Materials Regulations (HMR). A Special Permit or CA approval is a document that authorizes a person, company, or operator to perform a Hazardous Materials function that is not authorized by the HMR.

Federal Hazardous Materials Transportation Law 49 U.S.C. §5117 (PDF) authorizes PHMSA to issue Special Permits and Competent Authority Approvals in a way that reaches a safety level that is equal to the safety level required by the HMR or is consistent with the public interest if a required safety level does not exist. The terms "special permit" and "exemption" have the same meaning.

The Federal Aviation Administration (FAA), Federal Motor Carrier Safety Administration (FMCSA), Federal Railroad Administration (FRA), and the United States Coast Guard (USCG) have designated an Operating Administration (OA) representative point of contact to review DOT-SP and approval applications.

Common examples demonstrating why an entity would apply for a DOT-SP or approval include:

  • An operator who would like to transport dangerous goods forbidden by air;
  • An entity who would like to offer or transport dangerous goods that exceed quantity limitations;
  • Lithium-ion and lithium-metal batteries or cells that have not met sub-section 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1, or any subsequent revision.

For more detailed information, please visit PHMSA Approvals and Permits webpage. The FAA is required to be notified via this notification email address when the special permit grantee intends to use the PHMSA granted special permit to either ship or accept the hazardous materials authorized for the transportation in commerce. The notification is mandatory; failure to meet this requirement could result in the revocation of the granted special permit by the Associate Administrator as provided for in the HMR.

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