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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0226 ([Groendyke Transport, Inc.] [Mr. Jerry Mahl])

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

Interpretation Response Details

Response Publish Date:

Company Name: Groendyke Transport, Inc.

Individual Name: Mr. Jerry Mahl

Location State: OK Country: US

View the Interpretation Document

Response text:

Mr. Jerry Mahl
Groendyke Transport, Inc.
2510 Rock Island Blvd.
Enid, OK 73701

Ref. No. 12-0226

Dear Mr. Mahl:

This responds to your October 1, 2012 email requesting clarification of the recordkeeping requirements for cargo tank inspections and testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification whether the reports specified in §180.417(b) on the testing and inspection of a cargo tank under §180.407 may be kept in electronic format.

The answer is yes. Unless specifically prohibited in the HMR, electronic methods of recordkeeping are authorized; with the general understanding that a record must be in such a format that it can be made available to a DOT representative upon request. Thus, in accordance with §180.417(b)(3), so long as the owner and the motor carrier, if not the owner, each retain a copy of the test and inspection report until the next test or inspection of the same type is successfully completed, the copy may be in electronic format.

I hope this information is helpful. If you have further questions, please contact this office.

Sincerely,

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks
180.417 Reporting and record retention requirements