Someone in the office put last year's fire safety analysis in the same binder as the DOT security plan and labeled the folder "compliance." The two papers are not the same job. One is about the plant. One is about the load on the highway.
We write the shop policies book and the fill-in DOT hazmat security plan. If you run the trucks, this page is for you.
What the fire safety analysis actually is
The Propane Education & Research Council and the National Propane Gas Association publish a Fire Safety Analysis Manual for marketers. The 2020 public copy is keyed to NFPA 58's fire-protection section. Confirm the edition your state fire marshal adopted. The 2020 edition numbers that section 6.29. The 2024 edition numbers it 6.30.
The analysis is a written look at fire protection for a bulk plant. The current code text uses an aggregate water-capacity threshold of more than 4,000 gallons for that written analysis, plus ASME containers on roofs. Parked bobtails and transports are not the plant tanks. Read the current code and the PERC/NPGA manual before you brief the owner. We do not interpret your plant.
The analysis is supposed to reach the authority having jurisdiction and local emergency responders. If yours still sits in a drawer the fire department has never seen, the paper did not do the job.
The analysis also has to match the yard you run today. If you added a tank, moved a transfer point, or changed how product leaves the plant, an old write-up describes a different place.
What the DOT plan is
A transportation security plan is a different file. 49 CFR 172.800 lists who it applies to. That list includes a large bulk quantity of Division 2.1 material. Propane is a Division 2.1 flammable gas. The same section defines a large bulk quantity as more than 3,000 liters, which is 792 gallons, in a single packaging such as a cargo tank. A retail bobtail that holds more than that volume is on the list.
49 CFR 172.802 names the three pieces the written plan covers: personnel security, unauthorized access, and en-route security. Confirm the current wording on the eCFR. That is the load, the people who can reach it, and the route. It is not a plant water-spray discussion. It is not a customer leak flyer.
A printed binder that nobody has opened since the last manager left is not the same as a plan the people on the clock can find.
The shop book is a third file
People mash all three because they all live in binders.
A policies and procedures manual is how the shop actually runs: who fills, who inspects, who calls whom on a leak, how you keep records. It is the book a new dispatcher can read on day one.
Customer smell-gas steps are another file if you count them. PERC publishes inspection and leak guidance for the public on propane.com. That is a customer warning. It is not the fire safety analysis, and it is not the transportation security plan.
If the security plan still names a gate you tore down two summers ago, the file will not hold. If the policies book talks about a fill procedure the yard abandoned, same problem. The shop book has to match the people who did the work last week.
What to pull Monday morning
You do not need a consultant to start.
1. Put three folders on the table: fire safety analysis, DOT security plan, policies and procedures. If one folder is empty, that is the gap.
2. Open the fire safety analysis. Can you see the plant it describes. Does the gallon figure match what is in the yard today.
3. Hand the DOT plan to someone who did not write it. Ask them to find the three pieces 49 CFR 172.802 names. Time how long that takes.
4. Open the policies book. Read the pages on plant access and who rides the bobtail. If last week's crew winces, the book does not match the yard.
If those three folders take more than a few minutes to find, you already know the work.
Get the written shop book and the written security plan
Propane Safety Pro writes the fill-in DOT hazmat security plan and the policies and procedures manual from one intake form, built to how you actually run, print-ready. The security plans page is the transportation document. The policies and procedures page is the shop book. How to choose propane safety manuals walks the rest of the catalog, including fire safety analysis if that folder is the empty one. There is no public price on this site.
Call 610-228-0887 and ask for the written program. Or use the contact page. We sell to people who run the trucks. We do not sell to homeowners.
This page is general information for propane marketers in the United States. It is not legal advice. Confirm the current code, your state's rules, and your insurer's list before you treat any example here as your requirement. Primary text: 49 CFR 172.800 and 49 CFR 172.802 on the eCFR. Fire-protection section numbering is NFPA 58, confirmed against the PERC/NPGA Fire Safety Analysis Manual (2020).