PHMSA Inspection Series Volume 4

Recently, the Texas Propane Gas Association hosted inspectors from the Pipeline Hazardous Materials & Safety Administration (PHMSA) of the U.S. Department of Transportation (U.S. DOT) for training for the propane industry, and they shared some excellent information that we are passing on to the entire membership through a series each week on DOT inspections. This is week 3, part 4, and the last in the series.

During your inspection, the following documents will be viewed:

The following documentation will be reviewed

- Hazmat Training records

- Security plan

- PVIK documentation

- Written emergency shutdown procedures

- Cylinder records

- ASME Tank records

- Monthly hose documentation

- Cargo Tank Birth Certificates

What Happens Next?

After the completion of the inspection, one of two things will happen:

1) No probable violations noted at this time or

2) If probable violations are found, then you must provide comprehensive corrective action within 30 days.

After addressing any violations identified during the inspection, PHMSA in Houston will review both the violations and the corrective actions you've taken. There are three possible outcomes:

1) You may receive a warning letter - slap on wrist.

2) You might be issued a ticket; or

3) In cases where PHMSA deems the infraction as severe, such as refilling an expired bottle, it will be referred to the legal department in Washington, D.C., for a determination of the appropriate penalty.

Most Common PHMSA Inspection Violations

Here is a list of the most violations that PHMSA finds during its inspection of propane facilities:

- PVIK inspections/markings up-to-date on cargo tanks

49 CFR 180.407 & 180.415

- Security Plan/review it annually/49 CFR 172.800

- Moving ASME tanks/49 CFR 173.315(j)

- Filling cylinder that is out of test/ 49 CFR 173.301

- Written emergency shutdown procedures/49 CFR 177.840(l)

- Remote Shut-off/ 49 CFR 177.840(O)

- Unserviceable Placards 49 CFR 172.500

- Documenting monthly hose inspection/piping/ 49 CFR 180.416(d)

- DOT registration/carry in truck/ 49 CFR 107.620/107.608

- Train hazmat employees 49 CFR 172.700

- Maintain cargo tank birth certificates 49 CFR 180.417

- RIN Approval letter/cylinder records/condemnation letters/CGA

- Not Having Cylinder Requalification Pamphlets

49 CFR 180.205/180.209/180.215

Click here for Volumes 1-3 in the PHMSA inspection series.