The 792-gallon test counts what is in one container, not your yearly gallons. For Division 2.1 material, the trigger is more than 3,000 liters (792 gallons) in a single packaging, such as a cargo tank, when you offer it or haul it in commerce.
Reviewed October 17, 2026
Read the test against the real shipment
The rule covers a person who offers covered hazmat for transport, as well as a person who hauls it. §172.800(b)
For Division 2.1 material, the trigger is a "large bulk quantity." The rule defines that as more than 3,000 liters (792 gallons) of liquid or gas in a single packaging. §172.800(b), (b)(3)
Single packagings in that definition include a cargo tank motor vehicle, portable tank, tank car or other bulk container. §172.800(b)
Bring three facts to your review: what the material is, how much is in each container, and whether you offer it, haul it or both. Do not use yearly gallons sold in place of those facts. This is a suggested list, not a ruling on whether the rule applies to you.
What happens if it applies
Once your operation is covered, the plan must include a written risk assessment. It must also include steps for personnel, for unauthorized access and for security on the road. §172.802(a), (c)
Ask your reviewer to write down which part of the rule applies and why. The quantity test is only one part of the rule. If it does not settle your case, have the reviewer check the other criteria and exceptions. This page is not a blanket exemption.
Questions and answers
Does adding up all our customer tanks answer this test?
No. The test looks at the amount in one packaging. Give your reviewer the real shipment details, not the total gallons your customers store.
About Bill Stomp
Bill Stomp built Propane Safety Pro. He is a war veteran who ran over 87 propane branch offices across 12 states, and he has helped more than 200 propane companies improve their profits, sales, safety and operations.
Next step
Got your shipment examples? Take them to the DOT Hazmat Security Plan page for propane companies.
General information, not legal advice.