The Railroad Commission of Texas (RRC) is accepting public comments to proposed revisions to LPG Form 7, Cargo Tank Registration/Re-Registration, and other proposed new forms as the result of the recent “proposed” LP Gas safety rule changes. Previously, cargo tank and container delivery registration, re-registration, and transfers were all in one form, Form 7.
RRC is proposing to split Form 7 into now (3) forms:
1.LPG Form 7 Cargo Tank Registration/Re-Registration
2.LPG Form 7A Container Delivery Unit Registration /Re-registration
3.LPG Form 7T Cargo Tank and Container Delivery Unit Transfer
TPGA supports changes to Form 7 Cargo Tank Registration/Re-Registration will streamline the bobtail registration and renewals. TPGA had several complaints from members on qualifying for the 10-year bobtail requalification period, and RRC has responded with proposed updates for Form 7.
As a reminder, bobtails under 3,500 gallons made of SA-612 steel in dedicated propane service qualify for a more extended requalification period of every 10 years vs. every 5 years.
No longer will marketers have to send separate emails or letters to RRC stating that your bobtail is made out of SA 612 steel and in dedicated service. Once adopted, all this information will be incorporated into form 7.
Additionally, RRC is introducing a new LPG Form 16P that allows an individual that has completed the Propane Education and Research Council (PERC) Dispensing Propane Safely course & exam, and submits the proper documentation, to receive a DOT cylinder filler certification. Also, RRC has introduced PERC Outside Instructor Application to apply with the RRC to administer PERC-based courses that will result in DOT cylinder filler certifications for the attending students.
TPGA believes the proposal of LPG Form 16P and the PERC Outside Instructor form is premature. RRC has just received comments on the “proposed” LP Gas Safety Rules. The final rules have not been adopted, and it seems the Commission is anticipating that the proposed rules on which the association and our members submitted several comments will be adopted “as is.” The Commission should wait until the final Dispensing Propane Safely rules are published before proposing and adopting corresponding forms.