This past week I learned that what used to be allowed only under a “special permit” is now part of the regulation for unloading (and loading) HAZMATs. It was very popular during my time as a safety/PSM manager and all my plants applied for and received the DOT Special permit(s) to unload both Railcars and Tanker Trucks of HAZMATs. But now, plants do not have to apply for a special permit as DOT has written all their “special permit” requirements into their “Attendance Requirements”. But as attractive as it may sound, these video monitoring requirements come with some very specific requirements that we almost always find errors/gaps in its implementation. Here is what the regulation says…