When the Railroad Commission of Texas (RRC) adopted the 2017 NFPA 58 in 2020, RRC adopted the Fire Safety Analysis requirements found in Section 18.104.22.168 of NFPA 58 with a compliance date of September 1, 2022, which was clarified in the most recent RRC rulemaking this past summer.
While NFPA requires fire safety analysis for installations for 4,000 gallons and over, the RRC will only require a fire safety analysis for new and existing installations with an aggregate water capacity of 10,000 gallons or more.
What is a fire safety analysis? A fire safety analysis is an evaluation of the total product control system, such as the emergency shutoff and internal valves equipped for remote closure and automatic shutoff using thermal (fire) actuation, pull away protection where installed, and the optional requirements of Section 6.30. for underground and mounded containers over 10,000 gallons (if applicable).
The Railroad Commission has been in the process of updating the PERC Fire Safety Analysis forms to Texas standards to help propane retailers to comply.
Until RRC provides this template, TPGA believes there should not be any enforcement of this requirement.
As soon as RRC releases these documents, TPGA will provide them to our membership.
Please report any Fire Safety Analysis enforcement to TPGA.
Once available and completed, the fire safety analysis shall be submitted by the owner, operator, or their designee to the authority having jurisdiction, upon request, and local emergency responders.