Texas Propane Training Requirements Under PEP — 2026 Guide

Texas regulates LP-gas through the Railroad Commission of Texas — Alternative Fuels Safety (AFS) department, under the Texas Natural Resources Code and Texas Administrative Code, Title 16, Chapter 9 (LP-Gas Safety Rules). The RRC issues its own certifications and runs its own courses and exams — it does not rely on PERC's CETP or PEP for state compliance.

RRC certification categories (per rrc.texas.gov) include:

• Bobtail Driver — Course 2.3 Bobtail Operations (8-hour, instructor-conducted)
• Service and Installation — Course 3.2 Residential System Installation (8-hour)
• Appliance Service & Installation — Courses 3.2 + 3.3 (Appliance Conversion, Installation and Venting)
• DOT Cylinder Filler and Motor/Mobile Fuel Filler — Course 2.1 Dispenser Operations
• Categories F, G, I, J — 16-hour courses
• Category E (Underground Storage) — 80-hour course

Company licensing: a company must hold an active RRC license and have at least one management-level certification holder for each license category it operates. Licenses are valid one year and renewed annually.

The plain-language read: the RRC built and runs its own curriculum, exams, and credentials, and a Texas license is issued against them. Whatever PERC does nationally with CETP and PEP, it does not change what the RRC requires to license a company or certify a management-level holder.

One naming caution — and one real, narrow exception. The RRC's site lists a "PERC Dispenser Operations Exemption," and there is a live PERC pathway behind that label. Under 16 TAC §9.55, AFS "may award training and certification or continuing education credit to DOT cylinder filling or motor/mobile fuel filler employee-level applicants and certificate holders for PERC-based courses administered by an approved company." The course has to be consistent with the guidelines of PERC's *Dispensing Propane Safely*; the company administering it files a PERC-Based Training Application with a non-refundable $300 registration fee and submits its curriculum, exam materials, and any videos to AFS for review; AFS answers in writing within 14 business days. An LP-gas licensee may run the course for its own employees. On the certification side, 16 TAC §9.52(a)(2)(C)(iv) is where it lands: a DOT Cylinder Filler applicant completes the 2.1 Dispenser Operations course *unless* the individual is issued a Dispenser Operations certificate exemption.

That is the full reach of it. The §9.55 pathway covers two employee-level filler categories and stops there — no bobtail, no service and installation, no appliance, no RV, and no management-level category. Anyone reading the label as a general back door to PEP for Texas compliance has read it too far. The continuing-education credit named in §9.55 is that same two-filler-category pathway; it is a different rule from the general continuing-education credit under §9.52(g) discussed below.

For your Texas state licensing — nothing. CETP being phased out and PEP coming online is a PERC program change; the RRC's system is independent of both. Your Texas certifications, courses, exams, and company license requirements are unchanged by the national transition.

Two things *are* worth knowing:

• Voluntary PEP is fine, but it doesn't replace RRC licensing — with a nuance on continuing education. A Texas employer can put staff through PEP for the training value, but PEP does not satisfy any RRC certification or *licensing* requirement — the license still runs through the RRC's own courses and exams. Continuing education is where PERC coursework does count: 16 TAC §9.52(g) governs credit for CETP courses, and it names CETP specifically, listing the eligible courses for employee-level CE credit. PEP is not named anywhere in the rule. As PERC retires CETP modules, whether a PEP course earns RRC continuing-education credit depends on the RRC updating §9.52(g) — ask the RRC before you count on it. Confirm with the RRC how it treats PEP specifically for CE, since the rule is written around the CETP course list.
• The RRC is migrating platforms. As of June 2026, the RRC was moving from its CERTS system to a new internal platform called AFOS, and warned of "extended wait times and processing delays." If you're registering for classes or exams or verifying an employee's certification status, build in extra time during the transition.

1. Train and certify through the RRC for every category you operate — bobtail, service/installation, cylinder/mobile filling, underground storage, etc.
2. Confirm your company license covers each category you run, with a management-level certificate holder for each.
3. Plan around AFOS delays. Register early; don't assume same-week scheduling while the platform migration is underway.
4. Don't substitute PEP for RRC requirements. If a vendor or national program implies PEP "covers" Texas, verify with the RRC before relying on it — outside the narrow §9.55 filler pathway and §9.52(g) CE credit, PERC coursework does not satisfy an RRC requirement.

• The RRC certification category and date for each certified employee.
• Your company RRC license and the management-level certificate holder on file for each category.
• Renewal and continuing-education dates, which run on different clocks. The company RRC license renews annually. An individual certificate holder's continuing education is a four-year cycle: under 16 TAC §9.52, the next CE deadline falls four years after the May 31 following the most recent course completed. The RRC prints the CE due date on the certification card — pull it from the card rather than assuming a yearly class.
• Registration confirmations during the CERTS → AFOS transition, in case of processing delays.
• If you run PEP voluntarily, keep its Learning Center transcript separate from your RRC compliance records so the two are never confused.
• If you use the §9.55 PERC-based course for fillers, keep the AFS approval letter for the administering company with those employees' records.