When Does a Special Permit Serve as a Competent Authority Approval? Comments Based On PHMSA letter of Interpretation 19-0055

摘要

Just as SP 20600 does not constitute a CAA under the ICAO TI, it also does not under the IMDG Code, the ADR and RID, or other national regulations implementing the UN Recommendations. There is really no practical way to obtain worldwide acceptance of provisions such as those in SP 20600 without incorporating them in the international regulations. Only those holding Special Permits where the relief is specifically tied to a specific ICAO TI provision allowing competent authority discretion should consider their SP as constituting a CAA. In the past, SPs and approvals issued by RSPA/PHMSA identified whether the provisions of an SP constituted a CAA and holders found this to be valuable customer service.