E9791 use permit

[oxyhacker]

I will indeed, if you will read my last post again.

While the permit doesn't allow new manufacture, it is still a mark-and-sale and not a use permit. Paradoxical, perhaps, but a good thing for all the 9791 tanks out there since otherwise they would not be covered by it.

Again look at page 13 article K, it allows for NO NEW CONSTRUCTION.

 

[pescador775]

The Special Permit appears to be an interim document which allows the new company to, stamp, finish, galvanize, hydro test and sell remaining stock under SP9791. In order to obtain the exemption to apply to new construction under SP9791, or any construction, it would be necessary for a separate application and for new product to pass the various test criteria. After all, PST LLC would be legally regarded as a separate entity with new management, plant location and people. The "E" designation is no more. In order to be consistent with terminology used in the Hazardous Materials Safety and Security Reauthorization Act of 2005 it appears that the jargon has been permanently changed to Special Permit (SP).

 

[oxyhacker]

Just a jargon change. After going from calling them special Permits to Exemptions many years back the DOT recently decided to go back to calling them Special Permits. So when an exemption is up for renewal or revision the new version is prefixed SP rather than E.

The Special Permit appears to be an interim document which allows the new company to, stamp, finish, galvanize, hydro test and sell remaining stock under SP9791. In order to obtain the exemption to apply to new construction under E9791, or any construction, it would be necessary for a separate application and for new product to pass the various test criteria. After all, PST LLC would be legally regarded as a separate entity with new management, plant location and people. Unless DOT HAZMAT has changed their jargon again, I don't know how else to explain the use of "special permit" in this regard.

 

[pescador775]

Thanks, I checked it out and confirmed. Edited the referenced post.