Who Is Responsible for a Propane Company's DOT Hazmat Security Plan?
Direct answer:
Under 49 CFR 172.802(b), the plan must name, by job title, the senior management official responsible for developing and carrying it out. It must also list security duties for each position or department involved, and include a plan for training hazmat employees. The rule asks for a job title, not a person's name.
Start with the number: who needs a plan at all
A propane company needs a written transportation security plan when it offers for transport, or transports, a large bulk quantity of Division 2.1 material. The rule (49 CFR 172.800(b)(3)) defines that as more than 3,000 liters (792 gallons) in a single packaging such as a cargo tank motor vehicle. Check the actual quantity in each packaging against that threshold. The full test is on our page Do I need a DOT hazmat security plan?.
The three things 172.802(b) adds
Section 172.802(a) lists the risk assessment and the three core measures (personnel security, unauthorized access, en route security). Paragraph (b) adds who is in charge:
- A senior management official, named by job title. The plan identifies the title of the person responsible for the overall development and carrying out of the plan. For a small company that is often the owner or general manager. The rule leaves the choice to you.
- Security duties for each position or department. Every position or department with a part in the plan gets its duties written down, plus the process for telling employees when specific parts of the plan must be put in place.
- A training plan. The plan must include a plan for training hazmat employees under 49 CFR 172.704(a)(4) and (a)(5).
An example layout (a way to organize it, not a legal form)
| Position or department | Security duty to write down |
|---|---|
| Owner or general manager | Named senior management official; signs the annual review |
| Dispatch / office | Who tells drivers when a specific security measure starts, and how |
| Drivers | En route measures; what to report and to whom |
| Plant / yard crew | Access to trucks, keys and the plant; who is allowed in |
| Whoever hires | Confirming information job applicants give, within federal and state employment and privacy law |
Who is allowed to read the plan
The most recent version, or the parts that matter to them, must be available to the employees responsible for carrying it out, consistent with any clearance or background-check limits and a demonstrated need to know. When you revise the plan, everyone responsible for it must be told, and every copy must show the date of the latest revision (49 CFR 172.802(c)).
A copy, or an electronic file of it, must be reachable at or through your principal place of business. On request, at a reasonable time and place, you show it to an authorized official of the Department of Transportation or the Department of Homeland Security (172.802(d)).
Review it every year
The plan must be in writing, kept for as long as it is in effect, and reviewed at least annually (49 CFR 172.802(c)). Update it when things change: a new driver, a new truck, a moved plant, a new security manager. Each of those can change who is responsible for what.
Straight answers
Does the plan have to name a person? The rule says to identify the senior management official by job title.
Does every employee get the whole plan? No. It must be available to the employees responsible for carrying it out, subject to need to know.
Can we keep it electronically? 172.802(d) allows a copy or an electronic file, accessible at or through your principal place of business.
How often is it reviewed? At least annually, and updated as needed when circumstances change.
Want it written for your trucks?
We write the DOT Hazmat Security Plan around your operation from one intake form, about an hour on your side. See the DOT Hazmat Security Plan or call 610-228-0887 and ask for Bill.
Book a 30-minute demo It costs nothing, and you leave with a plain answer.