BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month April 7, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Commercial Law
  • schedule 90 minutes

PHMSA Special Permits and Party Status: Strategies for Last-Mile Delivery of Hazardous Materials

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About the Course

Introduction

This CLE webinar will guide transportation attorneys on obtaining Special Permits and Party Status Applications from the U.S. DOT and Pipeline and Hazardous Materials Safety Administration (PHMSA) that allow transportation in commerce of certain hazardous materials as not subject to the Hazardous Materials Regulations (HMR) when transported to their final delivery destination. In particular, the program will benefit attorneys representing transportation or logistics companies competing in the last-mile delivery space or counsel advising businesses looking for efficient ways to provide last-mile delivery.

Description

Using non-asset based carriers, couriers, and rideshare drivers for final or "last-mile" delivery to consumers of goods ordered through e-commerce has become increasingly attractive and necessary. But one problem is that many common consumer goods and many regulated goods are subject to the federal HMR which require special equipment for transport or delivery and special driver training, eliminating delivery by car, bike, or scooter as viable alternatives.

In July 2025, the PHMSA issued Walmart a Special Permit (DOT-SP 21427) that "authorizes the transportation in commerce of certain hazardous materials as not subject to certain HMR when transported to their final destination" if the conditions in the special permit are followed. Other entities, if eligible, can apply for Party Status and, in effect, piggy-back on the Walmart Special Permit

Many in the transportation industry do not understand either the process or the pitfalls of seeking and obtaining Special Permits or Party Status. Missteps can mean unintended violations, fines, and worse. Applicants must expect additional scrutiny of their operations, and those unfamiliar with the process can be fooled if they do not understand how DOT and PHMSA function.

Listen as our expert panel discusses the Walmart breakthrough and the terms of its permit and offers instruction, best practices, and practical tips for obtaining Special Permits and Party Status Applications from the DOT and PHMSA.

Presented By

Ryan Paquet
President
HazMat Safety Consulting

As President of Hazmat Safety Consulting, Mr. Paquet provides clients with extensive experience and perspective he has gained in his 20+ years of experience related to hazardous materials transportation safety. For 10 years, Mr. Paquet was the Director of Approvals and Permits Division for the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the US Department of Transportation. In this role, he led the critical function of processing special permit and approval applications in coordination with other domestic government agencies, foreign governments, and international organizations. Mr. Paquet has led action and government response to the worldwide recall, national disasters, and the introduction of new technologies into the US market. 

Jason D. Tutrone
Partner
Thompson Hine

Mr. Tutrone helps businesses develop and maintain safe, competitive, and efficient transportation capabilities by providing guidance on freight-transportation and aircraft transactions, compliance with transportation regulations, regulatory solutions to transportation challenges, and resolution of transportation-related disputes. His practice is multimodal, involving air, ocean, rail, and truck transportation, and covers domestic (U.S.) and international transportation. Mr. Tutrone's clients are shippers, including chemical manufacturers, fertilizer manufacturers, retailers, automotive manufacturers, and food producers; trade associations representing shippers; transportation intermediaries; aircraft owners and purchasers; and businesses that use or are affected by unmanned aircraft systems (UAS).

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, April 7, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Regulatory and operational challenges of last-mile delivery

II. PHMSA regulations for last mile delivery of certain common goods

III. Special Permits

IV. Party Status applications and approvals

V. Pitfalls to avoid

VI. Case study: Walmart's SP

The panel will review these and other important issues:

  • Why did it take so long for someone to obtain a Special Permit as did Walmart?
  • How is regulatory compliance with last-mile delivery enforced?
  • What are non-asset based carriers?