Interpretation Response #00-0344 ([Arrowhead Industrial Services, Inc.] [Mr. RG Wilson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 01/22/2001

Company Name: Arrowhead Industrial Services, Inc.

Individual Name: Mr. RG Wilson

Location State: NC Country: US

View the Interpretation Document

Response text:

January 22, 2001

Mr. RG Wilson                           Ref.  No. 00-0344
Vice President
Arrowhead Industrial Services, Inc.
P.O. Box 1000
Graham, North Carolina 27253

Dear Mr. Wilson:

This responds to your December 5, 2000 letter requesting clarification on whether electronic methods of recordkeeping are permitted under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- ­180) and Parts 106 and 107.  Specifically, you ask whether the generation, acquisition, accumulation, transfer, final certification and presentation, as well as storage of data, information and/or reports, as required under 49 CFR by electronic methods is prohibited.

Unless specifically prohibited in the HMR, electronic methods of submitting reports, paperwork, and recordkeeping is authorized.  For example, the HMR requires that a hard copy of the shipping paper/manifest be carried on the transport vehicle when transporting hazardous material; however, electronic retention of a shipping paper/manifest is authorized.  Other forms of paperwork, reports, certifications, etc. required under the HMR are permitted to be submitted and maintained electronically.

I hope this answers your inquiry.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

171.2

Regulation Sections