Four groups ask a propane company for safety papers in writing: DOT, the fire marshal, OSHA and your insurer. Each wants different papers. Which ones you need depends on what you haul, your plant, your crew and your insurance carrier. The table shows who asks, what they ask for and the rule behind it.
By Bill Stomp · Last updated:
Propane Safety Pro (PSP) writes safety manuals and plans from the facts you send on our intake form.
Many small, family-owned propane companies find out about these papers one at a time: from the insurer at renewal, the fire marshal at a plant expansion, or DOT at a roadside stop. Here they are on one list.
Who asks for which document?
| Who asks | Document | Rule cited | Answer |
|---|---|---|---|
| DOT (PHMSA) | Hazmat security plan | 49 CFR 172.800(b)(3) and 172.802: more than 3,000 liters (792 gallons) of Division 2.1 offered or transported in commerce in one packaging | Do I need a DOT hazmat security plan? |
| DOT (PHMSA) | Hazmat employee training records | 49 CFR 172.704(d) | Hazmat training records |
| DOT (PHMSA) | Written emergency discharge procedures on the truck | 49 CFR 177.840(l), for trucks under 173.315(n) | Emergency discharge procedures |
| DOT (FMCSA) | Driver qualification file | 49 CFR 391.51, for drivers subject to Part 391 | Driver qualification file |
| Fire marshal | Fire safety analysis | NFPA 58 (2024), §6.30.3; 2020: §§6.29.3.1–6.29.3.3 | What is a fire safety analysis? |
| Fire marshal | Written operating and maintenance procedures | NFPA 58 (2024), §§15.2–15.5 (operating, as applicable) and §§15.6–15.7 (maintenance) | What goes in an O&M manual? |
| Fire marshal | Training documentation | NFPA 58 (2020), §§4.4.1–4.4.4 | NFPA 58 in plain English |
| OSHA | Written hazard communication program and SDS access | 29 CFR 1910.1200(e) and (g) | What is an SDS / HazCom program? |
| OSHA | Emergency action plan when another OSHA standard requires one; an employer with 10 or fewer employees may communicate it orally | 29 CFR 1910.38(a)–(b); check applicable state-plan requirements | What is an emergency action plan? |
| Insurer | Underwriting and renewal file | Carrier- and policy-specific; ask your agent for the current list. | Documents underwriters ask for |
| Your company | Policies and procedures manual | No single rule; it ties the day-to-day work together | What is a P&P manual? |
Federal rules are published in the eCFR (DOT) and in OSHA’s standards. NFPA 58 section numbers change between editions; your fire official decides which edition and amendments apply.
Which questions do propane company owners ask?
- What safety manuals does DOT require of a propane company?
- Do I need a DOT hazmat security plan?
- Does NFPA 58 require a fire safety analysis?
- What does the fire marshal look for?
- What safety documents do insurers ask propane companies for?
- What is an SDS binder / HazCom program, and do I need one?
- What goes in a propane O&M manual?
- What is a propane policies and procedures manual?
How do you build your document list?
- List what you ship and haul, who does hazmat work, and your trucks and drivers. Check each against the DOT rows in the table; tank size alone does not settle the list.
- Write down your plant’s tank sizes and layout. Ask your fire official which NFPA 58 edition and amendments apply, then check each fire-marshal row.
- Review workplace chemical exposure under 29 CFR 1910.1200(b), (e) and (g). Then check whether you need an emergency action plan; with 10 or fewer employees you may give it by word of mouth (1910.38(a)–(b)).
- Ask your agent which of these the carrier wants at renewal, then mark which ones you already have.
What else should you know?
Is there one manual that covers all four?
No. DOT, the fire marshal, OSHA and your insurer each name different documents. A policies and procedures manual can point to the others, but it does not replace a security plan, a fire safety analysis or a HazCom program.
Does every propane company need every document?
No. It depends on your work. DOT duties depend on what you ship and haul, your trucks and your employees. Fire-code duties depend on the adopted code, local amendments and your plant. OSHA programs depend on the hazards your crew works around.
Does an insurer require these documents?
You may need loss runs, driver lists, training records or written safety programs for underwriting or renewal. Requirements vary by carrier and program. Ask your agent for the current list; a manual does not guarantee acceptance or coverage.
Does buying a manual make my company compliant?
No. A purchased manual does not certify compliance. Your people still have to be trained on it, follow it and keep the records it calls for.
Who built Propane Safety Pro?
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.
How can you get started?
See the safety manuals Propane Safety Pro writes.
General information, not legal advice.