DOT does not ask a propane company for one big safety manual. It names specific papers: a hazmat security plan, hazmat training records, shipping papers, written emergency discharge steps for the truck, cargo tank test records and driver files. Which ones you need depends on what you haul, your trucks and your drivers.
By Bill Stomp · Last updated:
Propane Safety Pro (PSP) writes safety manuals and plans from the facts you send on our intake form.
Most owners first ask whether a small bobtail needs a security plan; the answer is in the questions below.
Which written items does DOT name?
| Document | Rule | Who usually needs it | Where to keep it (the rule sets how long) |
|---|---|---|---|
| Hazmat security plan | 49 CFR 172.800(b)(3), 172.802 | Persons offering or transporting propane in commerce in a quantity greater than 3,000 liters (792 gallons) in one packaging, subject to 49 CFR 172.800 | Office, with employees trained on their part |
| Hazmat training records | 49 CFR 172.704(d) | Every hazmat employee | The hazmat employer keeps the current record covering the preceding three years while the person is employed as a hazmat employee and for 90 days afterward, under 172.704(d). |
| Shipping papers and emergency response information | 49 CFR 172.200, 172.602 and 177.817(a), (d)–(e) | Shipments subject to the applicable shipping-paper and emergency-information requirements; check any claimed exception under 172.200(b). | Carry required papers and emergency information as the rules specify. Shipping papers must meet the driver-access and placement requirements of 177.817(e). |
| Written emergency discharge procedures | 49 CFR 177.840(l) | Cargo tanks subject to 173.315(n) | On or within the truck |
| Cargo tank test and inspection records | 49 CFR 180.407 and 180.417 | Cargo tank owners and motor carriers | Keep the applicable certificates and test reports as required by 180.417; check its location and retention rules for the particular record. |
| Driver qualification file | 49 CFR 391.51 | Drivers subject to Part 391 | Office |
Hazmat registration under 49 CFR 107.601 is a filing, not a manual, but a DOT investigator may ask for the certificate. Rules change; check the current eCFR 172.800 before you rely on any page.
How do you check your DOT file?
- Record the quantity of propane offered or transported in commerce in each single packaging. Compare it with 49 CFR 172.800(b)(3); tank water capacity alone does not decide whether a security plan is required.
- Pull a training record for every hazmat employee and check the dates against 172.704.
- Open one cab and check the shipping paper, emergency response information and discharge procedure.
- Check one driver file against the 391.51 list and one cargo tank file against its last test.
How do DOT and plant-code documents fit together?
Your plant O&M manual and fire safety analysis answer to the fire code; DOT records cover transportation. DOT rules can also apply to covered loading, unloading and other transportation-related work at a plant under 49 CFR 171.1. A required security plan includes site-specific transportation security risks under 49 CFR 172.802(a). Check both sets of requirements for your operation. See what a propane company must have in writing for the full map.
What else should you know?
Is a DOT hazmat security plan a safety manual?
It is a transportation security plan under 49 CFR 172.802(a)–(d), including personnel, unauthorized access, applicable facility and en-route risks. It does not replace a complete operating-procedures manual or the operating, maintenance or emergency discharge procedures required for the operation.
Does a small bobtail need a security plan?
It does if that truck ever ships or hauls more than 3,000 liters (792 gallons) of propane in its tank. That line is in 49 CFR 172.800(b)(3). Count the propane offered or transported in one packaging, not tank water capacity alone.
Who keeps the training records?
You do, as the hazmat employer. Keep each person’s record while they do hazmat work for you and for 90 days after they stop. It covers their last three years of training (49 CFR 172.704(d)).
Can Propane Safety Pro write the security plan?
Yes. Propane Safety Pro writes the DOT hazmat security plan from your intake form. A purchased manual does not certify compliance. Your team still trains on the plan and keeps the records.
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 DOT Hazmat Security Plan.
General information, not legal advice.