Welcome to the latest edition of the Monday Morning Messenger! Here's a sneak peek at what's in store for you:

In our first story of the morning, in honor of September being National Preparedness Month, we highlight how you can equip yourselves and emergency responders with essential propane information.

In our second story of the morning, stay updated on the Congressional authorization of the CFATS program and a Congressional proposal to raise the reporting threshold for propane.

In our third story of the morning, the association continues our U.S. DOT PHMSA inspection series. Learn what documents will be reviewed during inspections, what actions are required if violations are found, and also the most common PHMSA inspection violations.

In our last story of the morning, we inform you of a way you can enhance safety on your customers' properties with Propane Tank Locator decals.

Also, don’t forget to check out our Quick Links Section for fast access to resources and industry programs.

Don't miss out on these crucial updates and resources in the propane industry. Stay informed each week with the Monday Morning Messenger!

In this issue

• In Brief
• When Accidents Happen
• Propane Reporting Threshold Legislation
• PHMSA Series: Documents & Most Common Violations
• Tank Locator Decals
• Quick Links

September 2023

National Preparedness Month

September 27, 2023

Fall/Winter Propane Living Deadline

October 7, 2023

National Propane Day

October 9, 2023

15th Annual Pros4Care Golf Tournament

October 10, 2023

Texas Propane magazine Ad Deadline

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October 15, 2023

Propane Emergencies Hotel Deadline

Affinity Partners

Lone Star Energy Group Workers Comp Insurance

&

Basys Credit Card Processing

&

NoCell Technologies

Accidents are an unavoidable part of life, and this reality extends even to our propane industry. Just last week, an incident occurred when the TX DOT accidentally struck a gas main located on TPGA's property, right near our entrance. Fortunately, the Austin Fire Department swiftly responded to contain the leak.

Throughout your propane career, it's likely that you may encounter situations where one of your bobtails or transports experiences a rollover or when one of your commercial warehouse clients faces a fire that could potentially threaten the propane stored on their premises.

The video below depicts just one of the challenges firefighters may encounter. To equip firefighters and emergency responders with greater knowledge and confidence when dealing with propane-related incidents, ProCOT is hosting its Propane Emergency Response Training this coming November.

The Propane Council of Texas' November course serves several essential purposes. Firstly, it provides an opportunity to delve deeper into propane education for your local fire department. Secondly, it imparts crucial insights from an emergency response standpoint, helping propane industry attendees understand what to expect and how to react in propane-related emergencies. Our goal is for the propane industry to leave with a better understanding of potential incidents and valuable resources to apply in their work.

Furthermore, each industry member attending the ProCOT training in November will receive Continuing Education Credits from the Railroad Commission.

Please extend invitations to your local fire departments, and we encourage you to attend if you can.

You can also support the training, by sponsoring. Click here to learn about sponsorship opportunities.

The CFATS program, administered by the U.S. Department of Homeland Security (DHS), is designed to identify and oversee facilities, ensuring they implement security measures to mitigate the risk of certain chemicals, such as propane, falling into the hands of terrorists.

For propane facilities storing a minimum of 60,000 pounds, which is about 14,285 gallons, registration with the CFATS program is mandatory. Depending on the risk assessment of these propane facilities, propane retailers may also be subject to additional requirements.

In recent news, TPGA reported on the expiration of congressional authorization for the Chemical Facility Antiterrorism Standards (CFATS) program. Although the program currently remains expired, it is slated for renewal by the end of the year, if not sooner.

When this renewal transpires, a Congressman from Missouri is already prepared to take action. Today, Congressman Burlison will submit a house bill request aiming to raise the threshold for reporting propane quantities under the federal CFATS program from 60,000 pounds to 126,000 pounds (equivalent to 30,000 gallons).

TPGA hopes that this proposed change will garner support from the broader U.S. Congress, and we commit to keeping you informed of its progress.

Source: Missouri Propane Gas Association.

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.

These Propane Tank Locator decals are available through Propane Service Corporation, TPGA's compliance store.

This 3.5"x5" orange decal is designed to be placed on the electrical box of your customers and identify to emergency responders and contractors that there is a propane tank on their property and, secondly, where it is on the grounds.

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