Compliance
MEETING REGULATORY COMPLIANCE
DOT
DOT Security Plans
Shippers, receivers, or carriers of propane (Division 2.1 flammable gas) are required to have a Department of Transportation (DOT) security plan to protect shipments from security risks, such as theft or sabotage.
Security plan requirements are spelled out in 49 CFR Part 172 Subpart I.
You must develop and implement a security plan if you offer for transportation or transport propane in a cargo tank motor vehicle (bobtail or transport) having a water capacity of 792 gallons or greater.
NFPA
Operations & Maintenance Manuals
Requirements include:
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Operating procedure manuals for all bulk plant storage facilities.
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Written procedures describing actions for operating personnel to take in the event of a release of LP-Gas in the facility.
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Maintenance manuals for all equipment at these facilities.
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Maintenance programs, including record keeping, for plant fire protection equipment.
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NFPA 58 requires that a Written Fire Safety Analysis (WFSA) be completed for all LP gas installations that use ASME containers with an aggregate capacity of more than 4,000 gallons (water capacity).
OSHA
OSHA Hazardous Communications Plans
The Hazard Communication Standard (HCS), 29 CFR 1910.1200 (h), requires all employers to provide information and training to their employees about the hazardous chemicals to which they may be exposed at the time of their initial assignment and whenever a new hazard is introduced into their work area.
Employers must also maintain a written hazard communication program at their facility as required by the HCS, 29 CFR 1910.1200 (e).
Emergency Action Plan
An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees.