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Interpretation Response #16-0114 ([Renaldo Sales & Service, Inc.] [Mr. Kerry Fitzgerald])

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

Interpretation Response Details

Response Publish Date:

Company Name: Renaldo Sales & Service, Inc.

Individual Name: Mr. Kerry Fitzgerald

Location State: NY Country: US

View the Interpretation Document

Response text:

August 24, 2016

Mr. Kerry Fitzgerald
Renaldo Sales & Service, Inc.
P.O. Box 820
North Collins, NY  14111

Reference No. 16-0114

Dear Mr. Fitzgerald:

This letter is in response to your June 10, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to whether a mechanical signature is permitted on documents that are issued for vehicle reporting and recordkeeping.  Specifically, you ask whether it is permissible to use a “rubber stamp” or “digital” signature on test or inspection reports required in § 180.417(b)(2)(x), rather than a handwritten signature.  

The answer is yes.  Except in specific instances stipulating that a signature must be handwritten or as permitted under § 172.204(d), the HMR do not specify the methods that may be used to execute prescribed signatures.  It is the opinion of this Office that, except in those instances where the HMR require a handwritten or other specific type of signature, the signature methods permitted in § 172.204(d) may be used to execute signatures required under the HMR provided the signature is legible and verifiable.  Therefore, it is permissible to use rubber stamped and digital signatures that fulfill these conditions when completing the test or inspection reports required in § 180.417(b).  

I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
180.417(b)(2)(x), 172.204(d),

Regulation Sections

Section Subject
172.204 Shipper's certification
180.417 Reporting and record retention requirements