Does a Propane Company in Michigan Need a Written DOT Hazmat Security Plan?

Use the federal transport test to decide if you need the plan. Michigan adopts NFPA 58–2014 for storage and handling. That state adoption excludes transportation. Use your Michigan site records in the plan review. Check the federal plan rules on their own.

Work from the Bureau of Fire Services installation record

File the permit application at least 30 days before a proposed covered tank setup. R29.6152 covers a tank over 2,000 gallons of water. Total capacity over 4,000 gallons is another trigger. It also covers any place that fills containers. Include the required plot plan, nearby features and separation details. Use that plot to review entrances, loading areas and nearby risks.

Tell the bureau when the installation is complete. Give at least seven calendar days before the planned start of service. That gives the bureau time to inspect and certify. Ask the project owner for the real approval status. A new tank alone does not show approval.

Treat a violation notice as a delivery instruction

Has the bureau told the supplier that a site violates the rules? R29.6151 then bars delivery. Notice can be spoken, written or tagged at the site. Do not tamper with, remove or disregard a written notice fixed to the storage system. Pass the real notice to dispatch and drivers. You choose how to route that office alert.

Keep the instruction tied to the site. Dispatch needs to know if a bureau notice remains open. It also needs to know who can confirm that the restriction was properly resolved.

Keep state approval decisions out of informal exceptions

The Bureau of Fire Services is the authority having jurisdiction. A variance request must explain why you cannot meet the rule. The bureau may approve it under the rule's stated findings. A boss cannot grant that approval. File the bureau's decision with the site record.

Michigan requires advance notice for closing a site for good. Its rule also addresses sites unused for more than 12 months. Update security contacts and access notes when a site closes. Keep the closure records in the site file.

The national plan page explains the federal amount test and required plan contents. Use the Michigan manual page for permits, delivery holds and site records.

Michigan transport-office questions

Does Michigan's NFPA 58 adoption replace the federal test? R29.6102 adopts the 2014 edition for storage and handling. Transport is outside that adoption. Check federal coverage separately.

Can dispatch wait for a letter after the bureau calls? R29.6151 recognizes spoken notice too. Do not deliver after the bureau gives that notice.

Is a small site that fills containers exempt from the application rule? R29.6152 covers any place that fills containers. That trigger is separate from the tank-size tests.

Can a manager waive a state LPG rule? R29.6153 provides a bureau variance process. Explain why you cannot meet the rule. An order from your own office is not bureau approval.

Propane Safety Pro offers a DOT Hazmat Security Plan manual. Use current bureau site records and your real transport work when writing it.

Bill Stomp built Propane Safety Pro. He is a war veteran who personally 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.

Propane Insider is published by the makers of Tank Spotter, Custom Fuel App, Blink Fuel, PIMS and Propane Safety Pro; some links go to advertisers. Propane Safety Pro is published by the makers of the DOT Hazmat Security Plan and the Policies & Procedures manual described on this page.

General information, not legal advice.