Assistance With Competent Authority Approvals & Special Permits
Bringing a new product to market? Currie Associates can help you determine which regulatory codes apply and guide you through the process of obtaining Competent Authority Approvals (CAA) and Special Permits (SP).
Expert Support for Obtaining Approvals & Permits
Identifying and classifying regulated products can be complex. Our experienced consultants help you:
- Classify new products that are subject to hazardous materials regulations
- Clarify which regulations apply to your products and operations
- Provide guidance in identifying the appropriate regulatory relief requested from PHMSA
- Complete applications with relevant information
- Navigate the approval or renewal process efficiently
We’ve worked across a range of industries and can tailor support to meet your specific business needs.
What is a Competent Authority Approval?
A Competent Authority Approval (CAA) is a formal authorization issued by a regulatory body, like PHMSA in the U.S., that allow for specific actions under dangerous goods regulations. They’re sometimes required when you’re doing something that falls outside the standard regulatory framework – like transporting a new type of product, using a non-standard packaging configuration, or operating in a unique way that still maintains an equivalent level of safety.
This process is common when launching a new product that may not clearly fit into existing hazard classes or descriptions. One of the first challenges is determining whether a CAA is even needed, and if so, which regulations apply.
That’s where Currie Associates provides support. We help identify the correct product classification, determine regulatory applicability, and walk you through the steps to apply for a CAA.
These approvals don’t just check a regulatory box – they’re often critical for getting a product to market without delays or compliance issues. Similar to Special Permits, we can also help develop the documentation or work instructions that accompany the approval and support training if necessary.
What is a Special Permit?
A Special Permit is an official authorization from PHMSA (under 49 CFR) that allows a company to perform a function not otherwise permitted by regulation- such as using non-standard packaging or alternative shipping methods.
Key points about Special Permits:
- Include specific terms and additional requirements
- Must be followed exactly – noncompliance may result in penalties or revocation
- May require copies to be kept onsite or accompany the shipment
- Often specify marking, labeling, packaging, and approved transport modes
- Permits have expiration dates and must be renewed at least 60 days in advance
- Employees must be trained on all conditions of the permit
Using a US DOT 49 CFR Special Permit?
If your company holds – or reoffers packages under – a Special Permit, employees must be trained on the specific terms and conditions. This includes:
- Details of what is being exempted or authorized
- Any limitations on the use of the permit
- UN number and Proper Shipping Names that are covered under the permit
- Any packaging requirements
- Marking and labeling requirements
- Modes of transport authorized
Just like with all required training under 49 CFR, the training must be documented, and a training record must be maintained. Recurrent training is required every three years and / or whenever there is a change to the special permit requirements. This training is in addition to the training required in accordance with §172.700 through §172.704.
Currie Associates offers customized instructor-led training (onsite and webinar) or computer-based training which will incorporate the terms and conditions of your special permits. We can also develop a customized guide / work instruction to help your employees understand the nuances of your special permit.
Contact Currie Associates at 518-761-0668 or complete our online contact form for more information.