Written Programs When the Inspector, the Carrier and the Court Ask

Published by Propane Insider. The publisher, Bill Stomp, also owns Propane Safety Pro. This paper is the publisher's view and is not legal advice.

Summary

Three readers ask a propane company for its written safety program: the regulator, the insurance carrier and, rarely, a court. This paper sets out what each asks for, why the ask is firmer, and what a written program can and cannot do.

1. Why the ask is firmer

In Q2 2026 commercial auto premiums rose 4.5% and umbrella 5.3%; umbrella has risen 35 quarters in a row. Overall commercial premiums fell 2% (CIAB Q2 2026 survey, ciab.com/resources/q2-2026-pc-market-survey). That is a squeeze on two lines, not a rise in all of them.

Crum & Forster, one propane insurer, said in an LP Gas article (Sept. 18, 2025) that commercial auto is under pressure and that general liability is increasingly affected by inadequate documentation and a more litigious environment. Marathon Strategies counted about 190 jury verdicts of $10 million or more in 2025, up 40.7% from 135 in 2024, across 68 industries. That is a count, not dollars, and not a propane figure.

2. What each reader asks

The Propane Safety Pro Policies and Procedures manual states it plainly: "Regulators, the insurance carrier, and — if it ever comes to it — a court will ask what the company's written program said and whether it was followed."

The DOT security plan. A DOT security plan is reviewed at least annually and must be available on request to DOT or DHS officials (49 CFR 172.802(c), (d)). PHMSA's HM-268 package, published Aug. 4, 2026, mostly took effect Sept. 3, 2026 (14 of 16 rules). From the package's 16 rule titles and the full text of HM-268J, we found nothing that creates a retailer security-plan requirement, and the requirement pre-dates it (49 CFR 172.800).

Training records. An inspector who asks for "the training records" will expect the full set of records the manual lists, in one place.

3. Fire Safety Analysis timing

A Fire Safety Analysis done end to end typically takes four to six weeks. Some states require a licensed engineer to prepare or sign it, so check your state before planning.

4. What a written program does

A written, dated program gives an owner something to show. It is a starting point for the owner and the owner's counsel. It does not by itself make a company compliant, and it does not guarantee any outcome of an inspection, a premium or a claim.

5. Where Propane Safety Pro fits

The company completes one information form, and PSP builds the manuals and plans around its trucks, yard and people. See the DOT Hazmat Security Plan and Policies and Procedures pages, or book 30 minutes with Bill.

Sources

ClaimSource
Auto +4.5%, umbrella +5.3%, 35 quarters, overall -2%CIAB Q2 2026
Crum & ForsterLP Gas 2025-09-18
~190 verdicts, +40.7%, 68 industriesMarathon Strategies 2026
HM-268: 14 of 16 effective Sept. 3, 2026Federal Register 2026-08-04 (HM-268J, 91 FR 49329)
P&P manual quoteP&P manual v1.5
Security plan annual review, DOT/DHS on requestDOT security plan manual v1.5
"All five ... one place"Propane Safety Pro manual
Four to six weeks; licensed engineer caveatFSA service page