What insurance does a Texas oilfield trucking company need?

This page is for Texas trucking companies whose freight is the oilfield: water haulers and vacuum trucks moving produced water and flowback, frac sand haulers running pneumatic trailers or boxes from mines to pads, crude oil transports pulling from lease tanks, and carriers hauling pipe, tubulars and equipment. The Midland and Odessa pages cover the Permian context.

If your company is mainly an oilfield service contractor that also runs trucks, such as a roustabout, well service or construction company, our sister resource at oilfieldserviceinsurance.com covers the full contractor program and operator MSAs in more depth. This page stays on the trucking side.

49 CFR 387.9 sets different minimums based on the commodity, and oilfield carriers can land in different rows of the table depending on the load:

Produced water and other oil and gas waste bring in the Railroad Commission. Under 16 TAC 4.193, a for-hire transporter moving oil and gas waste off the property where it was generated, by any means other than pipeline, needs an oil and gas waste hauler permit. A few rule details that matter in practice:

• Approved vehicles only. The permit covers the vehicles on the Commission-approved list, and each vehicle carries a copy of the permit with the vehicle list.
• Marking. Each vehicle is marked on both sides and the rear with the permittee's name and permit number in letters at least three inches high.
• Design and maintenance. Vehicles must be suited to oil and gas waste and maintained to prevent leakage or spillage.
• What is excluded. The permit does not cover hazardous oil and gas waste under Statewide Rule 98, and inert waste such as sand, concrete and demolition debris does not need a permit.
• Administration. The RRC requires an active Form P-5 organization report, electronic filing, and annual renewal.

The waste hauler permit is not an insurance policy, but operators and their prequalification platforms check it alongside your certificate. A truck that is not on the approved list is a problem whatever your limits are.

Pollution in transit. The business auto and motor carrier forms exclude pollution from the cargo being carried. For a water or crude hauler, that exclusion goes to the core of the operation. The MCS-90 counts "environmental restoration" as part of public liability, so the insurer may have to pay the public for a spill, but the endorsement lets the insurer seek reimbursement from you for anything the policy itself would not have covered. The fix is usually the ISO broadened pollution endorsement for covered autos (CA 99 48) or a separate transportation pollution policy. See truck pollution liability.

Lease roads. Caliche roads, low water crossings, narrow pad entrances and night hauling put physical damage and rollover risk well above highway freight. Underwriters ask about it directly.

Hours of service. 49 CFR 395.1(d) has oilfield provisions: drivers of vehicles used exclusively in oilfield equipment transport and servicing can restart their 8-day period with 24 consecutive hours off, and specially trained drivers of specially constructed well-servicing vehicles can log waiting time at the well site as off duty.

Operator MSAs. Operators usually require auto limits and umbrellas well above the federal minimum, additional insured status, waivers of subrogation on auto and workers comp, and primary and non-contributory wording. Texas also has an oilfield anti-indemnity statute that ties indemnity to insurance; have an attorney review the indemnity section. See shipper contract requirements and primary and non-contributory.

Underwriters weigh commodity (water, sand, crude), trailer and tank type, lease road exposure, driver turnover in boom periods, hours and fatigue controls, and spill history.

Not every oilfield trucker hauls liquids. Frac sand carriers and pipe and equipment haulers have a different risk profile from water and crude haulers, and their programs should reflect it.

• Frac sand. Pneumatic trailers and container (box) systems run high-frequency loads between mines, transload yards and pads. Underwriters focus on mileage, driver fatigue and lease road exposure more than on pollution. Physical damage on newer pneumatic trailers can be a large share of the program.
• Pipe and tubulars. Load securement and loading and unloading at the pipe yard and on location are the questions. Check how your cargo form handles loading and unloading and whether the operator's pipe is cargo or property in your care.
• Equipment moves. Rig components and production equipment often run as oversize loads, which brings in TxDMV permits and escorts. See heavy haul insurance.

Mixed fleets that haul both sand and water under one company need to make sure the auto, pollution and RRC permit details cover every unit that might be dispatched to a waste load, not just the trucks that usually run water.