Introduction
Although using off-road diesel where appropriate can result in significant cost savings for businesses, it’s essential for companies using off-road, or dyed, diesel to maintain proper documentation and follow specific procedures to ensure compliance with federal and state regulations.
While enforcement may be rare, the penalties for non-compliance can be severe, making proper management essential when you’re using dyed diesel. Here, we review some of the best compliance practices for companies to follow when using off-road diesel.
Required Documentation and Record Keeping
Companies using off-road diesel should maintain the following documentation and keep records for the last three years on hand:
- Fuel receipts and invoices
- Delivery tickets from fuel trucks
- Relevant permits (required in states like Texas and Alaska)
- Documentation of employee training
- Records of internal audits and compliance checks
Storage and Labeling Requirements
Proper storage and identification are crucial for compliance when using off-road diesel. All storage tanks must have clear placards identifying them as diesel fuel tanks, and separate storage tanks should be maintained for on-road and off-road diesel. Proper labeling helps prevent accidental misuse by employees, while secure and properly maintained storage areas ensure safety and compliance.
Employee Training and Management
For maximum compliance and safety, companies should implement the following training measures:
- Establish comprehensive training programs for proper fuel usage
- Create clear protocols for handling accidental misuse
- Develop specific procedures for equipment movement between job sites
- Document all training sessions and attendees
- Conduct regular refresher courses on proper use and storage
Using Technology to Maintain Compliance
For larger operations, implementing fuel management systems like Tecalemit or Gasboy can help control and monitor fuel dispensing. These systems often use key fobs or PIN systems to track usage and prevent unauthorized access. Regular auditing of fuel usage and storage practices helps identify potential issues before they become problems that could lead to fines or penalties.
Regular Auditing Practices
Companies can and should conduct internal audits to verify the proper fuel type in all equipment and storage tanks, review fuel usage patterns, and ensure all documentation is properly maintained. These audits provide opportunities to assess employee compliance with fueling procedures and identify areas for improvement in fuel management practices. They can also catch problems early and prevent regulatory issues.
Identifying Cost-Saving Opportunities
While maintaining compliance, businesses should consider whether their equipment could benefit from off-road diesel use. For example, refrigeration units on trailers can legally use off-road diesel even when attached to vehicles that require on-road diesel. Understanding these distinctions can lead to significant cost savings while maintaining full compliance.
Emergency Response Procedures
Having clear protocols for handling accidental misuse is crucial. If dyed diesel is accidentally used in on-road equipment, immediate action is required, including proper tank and line flushing procedures. All incidents should be documented, and appropriate corrective actions should be taken to prevent future occurrences.
Working With Suppliers
Maintaining strong relationships with fuel suppliers is crucial for compliance. Clear communication about fuel type requirements and regular verification of correct fuel delivery helps prevent mistakes. Companies should maintain detailed records of all deliveries to ensure ongoing compliance.
Partner With Fuel Delivery Experts
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