Yes, if you offer or transport propane in commerce above the federal size limit. The test is more than 3,000 liters (792 gallons) in one packaging. Your Texas company license serves a different purpose. Check both rules.
Put the AFS file beside the transportation plan
The Railroad Commission's Alternative Fuels Safety department runs the state LP-gas program. Its rules are in 16 TAC chapter 9. Texas adopts NFPA 58–2017 and NFPA 54–2018, with state changes. Put those editions in your branch file.
Link yard access to those who oversee licensed work. RRC says the company representative must be in charge. That person must actively supervise licensed LP-gas work. The Category P exception applies. You can name that person in your contact list. Still assign the federal plan's duties clearly.
Check driver records before dispatch. RRC lists a Bobtail Driver certification. New certification uses the eight-hour 2.3 Bobtail Operations course. RRC also lists a continuing-education course. Check those state credentials. Also check each driver's jobs under the plan.
Build the state incident call into your escalation sheet
A covered event can trigger a call to AFS. Section 9.36 says to call at the earliest practical moment or within two hours after discovery. Listed triggers include death or hospitalization. They include an unintended ignition that needs an emergency response. An event reportable to another state or federal agency also counts. LPG Form 20 must follow.
Do not hold up the leak procedure for a plan review. Section 9.35 requires a written procedure for possible-leak notices. Employees must know it. They must have authority to use it without management oversight. Link it to the plan's incident contacts.
Keep the federal document focused
Tie the plan to your real security risks. Cover staff risks. Address access by people who lack permission. Cover risks en route. Section 172.802 calls for someone to be in charge. Review the plan at least once a year. Use the state license, training and incident files to help assign the work.
Texas questions from the dispatch desk
Can our RRC representative also be a security contact? You can list that person. RRC's role means main authority and active supervision. The Category P exception applies. Assign the federal plan's duties as well.
Does Bobtail Driver certification settle the plan question? That is a state credential. The federal test still applies when you offer or transport the gas. It includes the large-bulk Division 2.1 amount test.
Does a federal incident report replace the AFS call? Section 9.36 includes events reportable to another state or federal agency. Keep the Texas call on your incident checklist.
Should staff wait for a manager on a possible-leak call? The licensee must authorize staff to use its written leak procedure without management oversight. Train office staff before the call comes.
Have the branch details ready
Bring your license categories, representative, driver credentials and incident contacts to a plan discussion. Use the Texas manual guide for the daily work behind those records.
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General information, not legal advice.