April 2013 Spray 31 Useful Tips Here are some useful tips to help you plan more effectively: 1. Read the regulatory requirements very carefully. Be thoroughly familiar with the applicable provisions of the U.S. DOT’s Hazardous Materials Regulations (HMR) and the international standards that may apply. If you intend to ship within the U.S. only, you will need a DOT Special Permit. If you intend to ship internationally as well, you will need both a DOT Special Permit and a Competent Authority Approval. There are different application requirements for each. Applicants outside the U.S. must have a U.S. Agent for the service of process. Instructions and online application web app are found on the U.S. DOT website at https://hazmatonline.phmsa.dot. gov/Online%20Approvals/pages/welcome.aspx 2. Thoroughly review the U.S. DOT PHMSA website for letters of interpretation that may exist. You may find that a DOT special permit is not required because there might have been a previous ruling issued on the subject. An approval or special permit search can be made by accessing the following webpage: http://www.phmsa.dot. gov/hazmat/regs/sp-a 3. Carefully review the U.S. DOT PHMSA website for other permits or approvals. You can conduct a search on one or more companies that manufacture or offer similar products. If a special permit or approval exists, you may become a party to that special permit (if it is allowed). Becoming a party to an existing special permit is a lot quicker than applying for a new permit. 4. Read and be thoroughly familiar with the requirements for completing and submitting an application for permit and/or approval. You must submit all relevant information at the same time. 4. (continued) If you fail to submit a complete application, it will generally be denied and you must start the process all over again. Pay careful attention to the requirements for information required for a corporate officer (e.g., President, CEO) and a technical contact. Be certain to include the Dun & Bradstreet (DUNS) number in the application and indicate whether or not the applicant will act as a shipper, carrier or both. 5. Submit the application in writing and via e-mail. Follow-up with a phone call to ensure that your application has been received and that all of the required information was included in the application. Allow at least one week for the Office of Special Permits & Approvals to receive and process the application. Allow at least 4–6 weeks for PHMSA to begin its review of the application. 6. Give careful consideration to using packaging that may already be approved or permitted. This is particularly true of aerosol manufacturers and distributors. Often aerosol manufacturers will seek a permit for a new type of container when an existing container that has already been approved may suffice. Although there might be a modest increase in unit price when selecting a different container, this might be an acceptable alternative given that the applicant may not be able to bring their product to market for six months or more. 7. Do not apply for an emergency application, unless it is actually an emergency, e.g. a matter of life or health, military or national security interest, or significant economic loss. Loss of revenue because a product was not brought to market on time is not economic loss! An example of economic loss would be failure to fulfill a contractual obligation, or where a significant penalty clause might be included in the contract.
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