Greenville, South Carolina
HRP on behalf of a private healthcare corporation, obtained a Department of Transportation (DOT) Special Permit which facilitated the transport of hazardous secondary material with improved logistical feasibility for the client.
The Special Permit allowed relief from specific DOT Hazardous Materials regulations through alternate methods which were proven through the application to be equally safe. These regulations are as follows:
- Packaging Requirements (49 CFR 173.213)
- Shipper’s Responsibility (49 CFR 173.22)
- Placarding Requirements (49 CFR 172 Subpart F)
- Training Requirements (49 CFR Subpart H)
HRP worked with technical representatives of the Department of Transportation to facilitate processing of the application. This involved significant communication with the agency, including providing clarification and additional requested information.
Within the application and through processing, HRP negotiated on behalf of the client for permit conditions which were compatible to normal operations but also satisfied the Department’s standards for safe transportation. This required a review of technical data of the material to be transported, evaluation of the proposed packaging materials, and preparation of a Standard Operating Procedure (SOP) for the safe and compliant packaging, labeling, and shipment of the material.
The application for this permit was drafted directly from the Department of Transportation regulations. This required diligent research of the Hazardous Material Regulations as well as review of the process and submission options. International Air Transport Association (IATA) regulations were also included in this review as the material would also be shipped via air. HRP initiated communication with multiple divisions of the Pipeline and Hazardous Material Safety Administration (PHMSA) to ensure that the application was submitted correctly and processing was conducted expediently.
Working with the Department of Transportation at the federal level proved challenging, yet HRP was able to quickly respond to any information requests and successfully negotiate conditions on behalf of the client. The client was issued a Special Permit which accurately reflected those allowances requested in the initial application, allowing the company to ship the material in a manner that was logistically preferable to existing business operations.