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
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.
Mr. Tutrone advises multinational corporations, trade associations, and transportation intermediaries on domestic and international matters involving logistics services and transportation. These matters include: regulatory compliance; regulatory enforcement; agency rulemaking; legislative concerns; service issues; loss and damage claims; transportation security; contract drafting and negotiation; and rate disputes before the Surface Transportation Board (STB). His practice is multimodal, involving air, motor, ocean and rail transportation, and encompasses a wide variety of logistics services, such as warehousing and terminal services.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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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
A. US Transport regulations pertain to hazardous materials “in commerce”
B. What is “in commerce” and what isn’t?
C. What problem was Walmart hoping to solve?
II. PHMSA regulations for last mile delivery of certain common goods
A. What does fully-regulated look like?
B. What has changed in the way hazardous materials are transported to lead to a new way of doing business?
III. Special Permits
A. What is a special permit?
B. How do you apply for a special permit?
C. What is the process that the USDOT follows to review and approve special permits
IV. Party Status applications and approvals
A. What is the difference between special permits and approvals?
B. What is “Party Status” and how do you get it?
V. Pitfalls to avoid
A. Hazmat employee training
B. Incident reporting
C. Following the SP
VI. Case study: Walmart's SP
A. What problem was Walmart hoping to solve?
B. How will Walmart ensure that the SP is complied with?
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?
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