PHMSA's HM-268 Rules Took Effect Sept. 3. Here Is What They Did and Did Not Change

The Situation

*From the publisher. Propane Insider is published by Bill Stomp, who also owns Propane Safety Pro. Links carry tracking tags.*

On Aug. 4, 2026, the Pipeline and Hazardous Materials Safety Administration published 16 final rules, HM-268A through HM-268P, in the Federal Register. Most took effect Sept. 3, 2026. Fourteen of the 16 did. One took effect Aug. 19 and one, HM-268E, takes effect Dec. 2.

A common question is whether the package created a new security-plan requirement for propane retailers. We found nothing in the package that creates one, and the requirement pre-dates it (49 CFR 172.800).

The Facts

What the rules did

HM-268J ("Hazardous Materials: Reduce Training Burdens for America's Farmers") raised the farmer exception to the security plan rule, 49 CFR 172.800(c), from $500,000 to $825,000 in gross agricultural receipts. This is a deregulatory change that applies to farmers.

None of the 16 rule titles puts a new planning duty on retailers. (We read HM-268J in full and the other titles; read the full text if your question turns on a particular rule.)

What the existing rule asks for

A DOT security plan must be reviewed at least annually (49 CFR 172.802(c)) and must be available on request to DOT or DHS officials. A rulemaking package arriving is a sensible moment to open the binder, check the date of the last review, and see whether anything in the plan refers to a section that moved.

Whether your company needs a plan depends on what it hauls and in what quantity. That is a regulatory question for your own counsel or a qualified compliance professional. We do not offer legal advice, and no manual guarantees compliance or the outcome of an inspection.

The documentation angle

An inspector is one reader of a written plan. Another is the insurance carrier. Crum & Forster, a propane insurer, told LP Gas magazine in September 2025 that commercial auto is under pressure and that liability is hit by documentation gaps and a more litigious climate. A third reader is a lawyer. In Q2 2026, umbrella premiums rose 5.3% and commercial auto 4.5% per CIAB, and about 190 jury verdicts of $10 million or more landed in 2025 per Marathon Strategies (a count, across 68 industries, not propane alone).

Bill Stomp's view is that costs, insurance and claims are all rising, and that a company is better placed with a current, dated, written plan than with a verbal one.

Propane Safety Pro builds DOT Hazmat Security Plan manuals around the answers you give on one information form. Questions are welcome through the intake page.