DOT PHMSA Issues Special Permit Authorizing Cylinder Requalification

Updated: April 29, 2020

Please Note: U.S. DOT emergency Special Permit 21025 will expire on June 30, 2020.  This Special Permit allows the filling and offering for transport certain DOT specification cylinders in hazard class 2.1 and 2.2 that are up to 12 months overdue for periodic requalification. If your company requested and was granted party status to this Special Permit and you wish to use it beyond the June 30 expiration, you need to request an extension by May 1, 2020, 60 days before the Special Permit expires.  It is not known whether DOT will extend this Special Permit due to their Notice of Enforcement Discretion issued on April 6. The Notice only applies to hazard class 2.2.

On April 1, 2020, the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Special Permit SP 21025, which authorizes the filling and offering for transportation of certain DOT specification cylinders that are up to 12 months overdue for periodic requalification for relief efforts during the COVID-19 Public Health Emergency.

CGA members can request party status to this Special Permit by completing an application for party status and submitting it to DOT. For your convenience, CGA has prepared a party status application template. You may download the template in Microsoft Word format here: Template_Application for Party Status to DOT Special Permit 21025.


  1. Copy the template onto your company letterhead and complete with all requested information; information that needs to be included is [CAPITALIZED AND IN BRACKETS]
  2. Provide as complete a list of locations where this special permit might be used as possible
  3. Email the completed form to:
  4. Wait to receive party status notification

NOTE: The provisions of this Special Permit cannot be used until you have received notification from DOT PHMSA that your request has been granted.