Do I need a DOT hazmat security plan?
If you offer or haul propane in a cargo tank that holds more than 792 gallons (3,000 liters) in that one tank, yes — you need a written transportation security plan. That is the live rule in 49 CFR 172.800(b), not a sales line. A bobtail is a cargo tank motor vehicle. The rule names that kind of tank as a “single packaging.”
People mix two numbers. 792 gallons is the security-plan trigger. Placards are a different rule. The old 3,500-gallon figure is not the current 172.800(b) line. The table below keeps them apart.
Ask for the intake form — one form, about an hour Or call 610-228-0887 and ask for Bill.
What does 49 CFR 172.800(b) actually say?
The opening of 172.800(b) says each person who “offers for transportation in commerce or transports in commerce” one of the listed materials “must develop and adhere to a transportation security plan.” Propane is a Division 2.1 flammable gas. Paragraph (b)(3) lists “A large bulk quantity of Division 2.1 material.”
The same paragraph defines that phrase: “large bulk quantity” means “a quantity greater than 3,000 kg (6,614 pounds) for solids or 3,000 liters (792 gallons) for liquids and gases in a single packaging such as a cargo tank motor vehicle, portable tank, tank car, or other bulk container.” That is the number that applies to a propane bobtail or transport.
Read the current text at 49 CFR 172.800 on eCFR. If you are cylinder-only and never hit that bulk line, say so on the form. We would rather tell you that you do not need this book than sell you one.
Which number is which — 792 gallons, placards, and the old 3,500-gallon line?
Keep these in separate buckets. They are not the same test.
| Question | Live rule | What it means for a propane dealer |
|---|---|---|
| Do I need a written security plan? | 49 CFR 172.800(b) — more than 3,000 liters (792 gallons) of Division 2.1 in a single packaging | A bobtail cargo tank is that single packaging. If the tank is over 792 gallons, the plan is required. |
| When is a tank “bulk”? | 49 CFR 171.8, “Bulk packaging” (3) — water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas | That is the bulk-packaging definition for gas. It is not the security-plan gallon line. |
| When do I need FLAMMABLE GAS placards? | 49 CFR 172.504(a) and Table 2 (Division 2.1). The 454 kg (1,001 pounds) exception in 172.504(c) does not apply to bulk packagings. | A loaded bobtail is a bulk packaging. Placards are the highway mark. They are not the 792-gallon security-plan test. |
| What about 3,500 gallons (13,248 liters)? | That capacity line was in the older security-plan rule and the 2010 NPRM. It is not in current 172.800(b). | Do not use 3,500 gallons as today’s trigger. The current text uses 792 gallons in a single packaging. |
Code text moves. Confirm the current eCFR before you treat any marketing page as the last word.
What must the plan contain under 49 CFR 172.802?
172.802(a) says the plan “must include an assessment of transportation security risks” for the listed materials, “including site-specific or location-specific risks” at places where those materials are prepared, stored, or unloaded incidental to movement. Then, “at a minimum,” it must include three elements:
- Personnel security — “Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous materials covered by the security plan.”
- Unauthorized access — “Measures to address the assessed risk that unauthorized persons may gain access” to those materials or the conveyances being prepared to move them.
- En route security — “Measures to address the assessed security risks of shipments … en route from origin to destination, including shipments stored incidental to movement.”
172.802(b) adds three more pieces that have to be in the writing: the senior management official responsible for the plan, identified by job title; security duties for each position or department that carries the plan; and “a plan for training hazmat employees in accordance with § 172.704 (a)(4) and (a)(5).”
172.802(c) is the annual-review line, not (b). It says the plan, including that risk assessment, “must be in writing” and “must be reviewed at least annually and revised and/or updated as necessary to reflect changing circumstances.” The section does not use the words “signed” or “dated.” Operators still keep a dated copy so they can show when the last review happened. We will not hang “signed and dated” on a section number the text does not carry.
Current text: 49 CFR 172.802 on eCFR.
What training does 49 CFR 172.704(a)(4) and (a)(5) require?
172.704(a)(4) is security-awareness training: each hazmat employee “must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security,” including how to recognize and respond to possible security threats. New hazmat employees must get it within 90 days after employment.
172.704(a)(5) is in-depth security training. It applies to each hazmat employee of a person required to have a security plan “who handles hazardous materials covered by the plan, performs a regulated function related to” those materials, “or is responsible for implementing the plan.” That training must cover the plan and how it is run — objectives, structure, procedures, duties, and what to do if there is a breach.
172.704(c)(2) says a hazmat employee must receive the required training “at least once every three years.” For in-depth security training, it is every three years, or within 90 days after a revised plan is put in place. Current text: 49 CFR 172.704 on eCFR.
We write the plan, including the pages that say how you will document that training. We do not deliver the training, sit the class, or sign the employee file. That work stays yours, or your trainer’s.
How do you get the plan written?
You fill one intake form about your plant, trucks, keys, gates, hiring practice, and routes. We write the plan from our fixed template to your operation. Built within a week of your completed form. You get a print-ready plan. We do not inspect the yard and we do not train the crew.
Most operators buy this with the Policies & Procedures manual. They get asked for together. See what an auditor asks for and ask for a redacted sample if you want to see the shape of the pages first.
Ask for the intake form — one form, about an hour
Or call 610-228-0887 and ask for Bill.
Last reviewed: September 11, 2026. Author: The Propane Safety Pro team. General information for propane dealers, not legal advice. Confirm the current Code of Federal Regulations and your own obligations with counsel.