This week your safety lead still cannot find the leak-check sheet after an out-of-gas call. The tank inspection photos and the written procedure are missing too, even though the field work already happened. Your office needs one file it can open when the inspector walks in.
What a leak check covers after service is interrupted
Leak-check timing after an interruption of service lives in NFPA 54, the National Fuel Gas Code. NFPA 54, 2024 edition, Tentative Interim Amendment 24-1 prints §8.2.3.1: "Immediately after the gas is turned on into a new system or into a system that has been initially restored after an interruption of service, the piping system shall be checked for leakage."
Section 8.2.3.2 says that where leakage is indicated, the gas supply shall be shut off until the necessary repairs have been made.
Mississippi builds on that NFPA-54 leak-check duty in Title 19, Part 7, Chapter 14 (effective July 1, 2021). Rule 14.02 defines an interruption of service as any time any part of the system has a loss of pressure. The same rule states that all "out of gas" situations are interruptions of service. An out of gas situation occurs "both when a tank is completely out of gas, or when the pressure becomes so low that appliances, heaters, etc., cannot operate and/or shut off, even though there may technically be some gas in the tank."
Rule 14.04 requires a leak check on any interruption of service to an existing system. It also requires a leak check on first-time service of a new customer. In occupied dwellings, the check includes an interior inspection of the propane system and appliances, and reigniting pilots and appliances. If a leak will not be immediately repaired, that rule requires a lockout at the service valve.
Rule 14.04 requires documentation of leak checks, including the items checked and the results. That file "shall be kept on file at the branch or office serving the customer" and must be made available to Mississippi LC Gas Inspectors upon request.
That board's file rule is one state's answer. Confirm the matching duty with your own LP-gas board before you change forms.
What Florida puts on paper before an out-of-gas fill
Florida Administrative Code Rule 5J-20.044 sets out-of-gas, leak-call, and interrupted-service steps. Those steps apply to licensed LP-gas dealers. Before filling a container in an out-of-gas situation, the dealer shall close all container valves. The dealer shall physically check appliances and outlets, and look for appliance changes and open or uncapped lines.
If the customer is not present or appliances are inaccessible, the dealer closes the container valves and leaves adequate written notice. That notice is adequate when it includes the company name and phone number. It also needs a description of the work performed and any unsafe conditions found. It needs a telephone contact for restoration of service and a warning against reactivation of service by unauthorized persons. When gas supply to a system is interrupted, Rule 5J-20.044 also requires a leak test. Use the method prescribed in Annex C of NFPA 54. The results must be documented before the system goes back into service.
A short exception covers minor repairs the license holder stays on site to monitor. Those repairs still get a combustible-gas-detector or leak-detector-solution check.
Florida's written-notice list and documented leak-test result are concrete fields your CSR can match on the ticket.
How long Texas keeps pressure and leakage tests on file
16 Texas Administrative Code §9.4 tells each LP-gas licensee, registered manufacturer, or other registrant what to retain. Pressure-test, leakage-test, and customer records stay on file for at least five years. During normal business hours, an authorized Commission representative may inspect the files and facilities to verify compliance. On request, the licensee's officer, employee, or representative shall provide copies.
§9.35 adds the written leak procedure that sits under NFPA 58 plant duty. Each licensee shall maintain a written procedure "to be followed when any employee receives notification of a possible leak." That procedure includes leak-grade classification and the action criteria for each grade.
The licensee shall ensure that all employees are familiar with the procedure and shall authorize employees to implement it without management oversight. The written procedure shall be available to emergency response agencies as specified in NFPA 58, §6.29.2.
The Railroad Commission of Texas Fire Safety Analysis Manual quotes NFPA 58, 2017 Edition, §6.29. That quote covers fire protection at industrial plants, bulk plants, and dispensing systems with an aggregate water capacity greater than 4,000 gallons. §6.29.2.1 says planning for an inadvertent release of LP-Gas, fire, or security breach "shall be coordinated with local emergency response agencies."
One place for inspections, leak checks, and the written book
The TankSpotter safety page lists four paper failures. Those failures are illegible handwriting, lost or damaged sheets, incomplete forms, and years with no trail. When an LC Gas Inspector or a Commission representative asks for the file, the office needs one record. That record holds the same stop's photos, GPS, timestamps, signatures, and check details.
TankSpotter Safety is built for that field file. The product page states that every inspection generates formal documentation. That file includes photos, GPS latitude and longitude, date and time stamps, tech signatures, and complete check details. The app is built around NFPA 54/58 codebooks, so the record is made at the tank, not typed up later.
The written policies and procedures book is a separate shelf item. Propane Safety Pro's policies and procedures manual covers that book. It is built on 49 CFR, OSHA 29 CFR 1910, and NFPA 58. It includes a table of the code editions your state adopted. That page lists delivery procedures, plant and bulk storage, service and installation, and training documentation. It also lists emergency procedures and leak response. It covers recordkeeping for what you keep, where it lives, and how long you hold it.
It also states that insurers, the AHJ, and a plaintiff's attorney still ask for the written program. They ask even when no single CFR orders every dealer to keep a policies manual. Put the digital inspection and leak-check file next to that written book. Your safety lead should open one drawer to answer one question.
What your safety lead pulls this week
Have your safety lead pull five recent out-of-gas or interrupted-service stops this week. For each stop, confirm the leak-check method and result sit with the account. Confirm any required customer notice fields are filled. Confirm tank or system inspection photos and signatures are attached to the same record.
Have that same safety lead open your written leak-response procedure. Check that every CSR and driver on the board knows where it lives. Check that each person can start it without waiting for a manager. Before Friday, list every stop that still needs a call back to the driver or a missing sheet pulled from the cab.
Common questions
When is a leak check required after an out-of-gas call? NFPA 54 section 8.2.3.1 says to check the piping for leakage right after gas is turned on into a system restored after an interruption of service. Mississippi's Rule 14.02 counts every out-of-gas situation as an interruption. Check the edition and rule your state adopted.
How long does Texas require LP-gas leakage test records? 16 Texas Administrative Code section 9.4 says pressure-test, leakage-test, and customer records stay on file for at least five years.
What does Florida require when the customer is not home on an out-of-gas fill? Rule 5J-20.044 says the dealer closes the container valves and leaves a written notice with the company name and phone, the work done, any unsafe conditions, a contact for restoring service, and a warning against unauthorized reactivation.
Sources
• National Fire Protection Association, NFPA 54 National Fuel Gas Code, 2024 Edition, Tentative Interim Amendment 24-1 (document prints §8.2.3 Leak Check), Issue Date: August 25, 2023; Effective Date: September 14, 2023 — https://docinfofiles.nfpa.org/files/AboutTheCodes/54/TIA_54_24_1.pdf • Railroad Commission of Texas, Fire Safety Analysis Manual for LP-Gas Storage Facilities (quotes NFPA 58, 2017 Edition, §6.29), cover date October 2022 (PDF CreationDate Dec. 16, 2022; read September 26, 2026) — https://www.rrc.texas.gov/media/jpflxayt/rrc-fsa-manual-nfpa-58-2017-12-16.pdf • Mississippi Department of Insurance / State Liquefied Compressed Gas Board, Title 19 Part 7 Chapter 14 — Leak Check Procedures and Requirements; Permitting Procedures, Effective Date: July 1, 2021 — https://www.mid.ms.gov/wp-content/uploads/2023/04/202103reg.pdf • Florida Administrative Code (via Cornell LII), Fla. Admin. Code Ann. R. 5J-20.044 — Out-of-gas, Leak Call, and Interrupted Service Procedure, Amended effective July 10, 2019 — https://www.law.cornell.edu/regulations/florida/Fla-Admin-Code-Ann-R-5J-20-044 • 16 Texas Administrative Code §9.4 Records (via Cornell LII), Amended effective January 6, 2020 — https://www.law.cornell.edu/regulations/texas/16-Tex-Admin-Code-SS-9-4 • 16 Texas Administrative Code §9.35 Written Procedure for LP-Gas Leaks (via Cornell LII), Amended effective January 6, 2020 — https://www.law.cornell.edu/regulations/texas/16-Tex-Admin-Code-SS-9-35
This page is general information for propane operators. It is not legal advice and it does not certify compliance. Confirm the rule text your state has adopted.