Seventy Feet From the Nozzle at 10:15 p.m.
It is 22:15 at a 24-hour fuel station on a state highway near Jackson, Michigan. You are delivering 4,200 gallons of UN 1203, Gasoline, 3, PG II, from a cargo tank into the station's underground tanks using the truck's PTO-driven pump. The transfer is about half complete. You need the signed delivery ticket from the office, roughly 70 feet away and around the corner of the building, and you also need a restroom. While you are gone, the station attendant tells a waiting customer he can pull around to the diesel island by driving past your truck. Separately, the station manager says you can leave the truck running during the transfer because 'the pump needs it,' and offers to 'keep an eye on it' while you are inside. Your next delivery is 40 minutes away.
1. What rule governs this situation, and what exactly does it require of you during the transfer?
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The attendance rule for cargo tanks, and it is being broken the moment you leave the nozzle area.
A cargo tank must be attended by a qualified person at all times while it is being loaded or unloaded. In practice that means the qualified person must:
- remain within roughly 25 feet of the tank,
- have the tank and the transfer connection in clear view, and
- be physically able to shut off the flow - at the pump controls or the emergency shutdown - without delay.
Why your 70-foot walk fails all three: you are out of the 25-foot envelope, you have lost line of sight around the corner, and you cannot close a valve you cannot see. If a hose lets go, gasoline is pouring at pump rate for however long it takes you to walk back around a building.
Two things this rule is not: it is not about paperwork, and it is not satisfied by having someone nearby. The station manager offering to 'keep an eye on it' is not relief - he has not been trained by your carrier, does not know the shutdown sequence, and is not the qualified person for this operation. He is also a bystander you would be putting into a flammable-liquid hazard.
The correct move: finish or shut down the transfer, secure the connection, then get the ticket. If the restroom will not wait, stop the transfer, disconnect the hose properly, and restart when you return. The delivery ticket is not worth a 4,200-gallon release.
2. The engine is running to drive the pump. Is that acceptable, and does it change the attendance analysis?
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Running the engine to power an onboard PTO pump can be within the rules; running the engine while you walk away cannot.
The engine allowance exists because many cargo tanks unload with a pump driven off the truck's own powertrain. Where that is the only way to move the product, the engine runs during the transfer, subject to the carrier's procedures and the facility's requirements. The permission is tied to the operation, not a license to leave the vehicle.
The attendance analysis does not soften because the engine is running. If anything it tightens:
- An attended transfer with a running engine means you are at the controls, within about 25 feet, able to shut down the pump and kill the engine with one motion if a hose fails or a spill starts.
- An unattended transfer with a running engine is the worst version of this scenario: a running ignition source at a gasoline spill, with the only person who knows the shutdown sequence around the corner of a building.
What to verify before you start the transfer, and re-verify at the end: parking brake set, wheels chocked, engine status consistent with the plan, hose connections tight and not kinked or chafed, the station's emergency shutdown within reach and known to you, and no smoking or open flame in the area - including a customer idling at the diesel island next door.
If the pump will not run safely without someone watching the engine and someone watching the nozzle, the load is over-staffed for one driver. That is a dispatch conversation, not a workaround.
3. How do you handle the customer who wants to drive past your truck, and what does 'attendance' require before you consider the delivery complete?
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The customer waits, and you do not move a connected truck for convenience.
On the customer: a gasoline transfer with a hose connected and product moving is not a traffic-management problem to be solved by a waving hand. If the customer's path would take a vehicle within the isolation area around the truck and the fill connections, the attendant needs to hold that vehicle until the transfer is complete. Do not reposition a loaded cargo tank with a hose connected to a fill point, and do not drive over your own hose. If the route truly can only be cleared by moving the truck, the correct sequence is: shut down the pump, close the valves, disconnect and stow the hose, cap the connections, and only then move.
Attendance is continuous, through the end:
- Product stops flowing; pump shut down; valves closed in the proper order.
- Hose disconnected and drained per procedure, capped, and stowed - not dragged over a curb.
- Fill connections secured and the station's caps replaced.
- Spill checked at the connection point before you sign anything.
- Chocks pulled, compartments and hatches confirmed closed, placards and paperwork verified, then departure.
Framing: the exam keeps returning to the same judgment. A cargo tank transfer is a continuous attended operation with one accountable person. The moment that person leaves the 25-foot envelope, the operation is unattended regardless of who is standing nearby, and every other convenience - the ticket, the restroom, the waiting customer, the 40-minute next stop - queues behind that fact.