Must Written Emergency Discharge Procedures Ride on the Bobtail?

Yes, if the truck is subject to the emergency discharge control rules in 49 CFR 173.315(n). Section 177.840(l) requires written procedures on or within the truck for all delivery work. They must describe that truck’s control features. For passive shutdown systems, they must also state the limits within which the system works.

By Bill Stomp · Last updated:

What else must the procedure cover?

49 CFR 177.840(l) also covers use of a facility-provided hose. The procedure must explain that process when the truck has a specially equipped delivery hose under §173.315(n)(2). A generic “shutdown” heading does not show how this truck is equipped.

How would I check the truck’s copy?

Open it with the person who knows the installed discharge system. Compare the document with the truck. Resolve any mismatch. Keep the current copy where the driver can get it. Those are suggested checks to support the written procedure.

Assign one person to replace the copy when the equipment or procedure changes. Note which version is on each truck. Do not leave the office copy as the only current one.

Does the procedure replace the daily device test?

No. Paragraph (o) has a separate rule for trucks with the off-truck remote shut-off equipment it describes. The device must pass a test within 18 hours before the day’s first delivery. A wireless test must be done at least 150 feet from the tank. Have the trainer cover the full rule and equipment instructions.

Questions and answers

Is a copy in the office enough?

No. The rule says on or within the vehicle. Check the truck’s copy and make sure it describes that truck’s equipment.

Can I use another branch’s procedure?

Use it as a prompt for review. The person in charge must check it against the actual truck before treating it as that truck’s procedure.

Next step

Review the copy carried on one truck with the person in charge of its discharge system. Our bobtail operations page explains the manual’s scope.

Related: monthly discharge-system records. Return to the manuals and records questions.

General information, not legal advice. Check what applies with the responsible regulator and a qualified safety or legal reviewer. This page does not replace training or the procedures for your equipment.