Arrowhead Industrial Services, Inc. — Hazardous Materials Safety Interpretation

Page 1• of Transportation US. Department 400 Seventh Street, S.W. Washington, D.C. 20590 JAN 2 2 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 CER 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 000344#

Page 2• E Boothe 8171:2 ARROWHEAD INDUSTRIAL SERVICES, INC. Applicability CONTAINER SPECIALISTS COMPRESSED GAS 05 December 2000 CA-9804008 IA01 Via Facsimile and Federal Express 3537 South NC 119 Graham, NC 27253 PO Box 1000 Mr. Edward Mazzullo Research Director, DHM-10 Phone: 336.578.2777 USA and Special Programs Administration Email:A101@aol.com Fax: 336.578.2929 United States Department of Transportation Office of Hazardous Materials Standards 400 Seventh Street, sw Washington, DC 20590 Subject: Application Request for Regulatory Interpretation Reference: 49 CFR Parts 106, 107 and 171-180 Riverside, CA 92507 3330 Durahart St Sir, Phone: 909.778.1585 USA Email: AISIWEST@aol.com Fax: 909.778.1581 is located at 3537 South NC 119, PO Box 100, Graham, North ARROWHEAD INDUSTRIAL SERVICES, INC., whose corporate office your office, for a regulatory interpretation of the above Carolina 27253 USA, formally makes application request to referenced parts of the CODE OF FEDERAL REGULATIONS. Specifically, are the generation, acquisition, accumulation, final certification and presentation as well as Victoria House storage of data, information and/or reports, as required High Wycombe Desborough St. within the above referenced document, by electronic methods Buckinghamshire prohibited? HP11 2NF Phone: +44 (0) 1494 601100 UK In an effort to expedite, a response via facsimile transmission will be appreciated. Fax: +44 (0) 1494 601101 Email: AISLMTD@aol.com Respectfully submitted, WHEAD INDUSTRIAL SERVICES, INC. # www.arrowbeadindustrial.com Vice President Co: JP Vassallo File 045 •#