Section 172.802(a)(1) does not call for fingerprints or criminal checks for every worker. It requires checks of information from applicants hired for covered jobs. Those jobs involve access to and handling of materials covered by the plan. §172.802(a)(1)
Start with the positions covered by the rule
Read this paragraph against the jobs at your company. It concerns applicants hired for the covered positions. It sets no one screening method for all staff. This is a reading of this paragraph only. Separate hiring or credential laws may apply. §172.802(a)(1)
The same paragraph sets limits on the checking system. It must meet federal and state employment-practice and privacy rules that apply. Have the process reviewed before you choose checks. Do that before you collect private information too. §172.802(a)(1)
For a planning note, we suggest naming the covered jobs. List the information to check and who will check it. Keep applicant details in the proper personnel file. A blank written procedure can explain the steps. It need not copy private records.
Put responsibility in the written plan
The plan must name the senior manager in charge by job title. That role covers the plan’s overall development and use. The plan must also describe security duties. Name the roles or departments that carry them out. §172.802(b)(1), (2)
Assign the personnel-security task to a clear role. We suggest asking that person to explain the steps. When should they raise a problem? Who reviews the process?
Screening is one part of personnel security
The plan must assess transport security risks. It must include measures suited to those risks. Personnel security is one part of that plan. It is not the whole plan. §172.802(a)
Covered staff also need in-depth training on the plan. It must include their own security duties. It must teach what to do in a breach. Checking applicant details does not replace those lessons. §172.704(a)(5)
Keep the question narrow when requesting a plan
Ask how the written process will fit your covered jobs. Check that it fits your lawful hiring process too. This page does not settle checks under other rules. A license or credential may have separate terms.
Propane Safety Pro lists personnel security and training pages in its plan scope. Use that scope to discuss the written steps. Have any screening service reviewed on its own.
About Bill Stomp
Bill Stomp ran 87+ propane branches in 12 states and helped 200+ propane companies. He was VP of sales and marketing for a multi-state fuel company.
Put it in writing
See the DOT Hazmat Security Plan. The published plan covers personnel security and includes training pages and sign-off sheets. Discuss your covered positions when requesting it.
General information, not legal advice. Sources read October 17, 2026. This answer addresses the federal hazardous materials transportation rules; check separate state and other applicable requirements.