Renaldo Sales & Service, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Pipeline and Hazardous Washington, D.C. 20590 Administration Materials Safety AUG 2 1 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, Tern Foste ... T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2Edmongon (80.41716)(2)18) Goodall, Shante CTR (PHMSA) Reporting and Record Retenter tur From: Rivera, Jordan CTR (PHMSA) 16-0114 Sent: Tuesday, June 28, 2016 2:53 PM To: Hazmat Interps Subject: FW: Hazmat Information Center Feedback: Highway (Sections 177.800 – 177.870) Hi Shante/Alice, Please submit this as a letter of interpretation. Kerry Fitzgerald spoke with Eamonn in the Info Center. Please let me know if you have any questions. Thanks, Jordan From: PHMSA Webmaster To: PHMSA HM InfoCenter; PHMSA Webmaster Sent: Friday, June 10, 2016 1:13 PM Subject: Hazmat Information Center Feedback: Highway (Sections 177.800 – 177.870) ormationy Gem Name: Kerry Fitzgerald Organization: Renaldo Sales & Service, Inc. Street: PO Box 820 City: North Collins State: New York Country: Zip: 14111 Email: kerry.fitzgerald@renaldo.org Phone: 716-337-3760 Fax Number: Topic: Hazmat Information Center Feedback: Highway (Sections 177.800 - 177.870)#

Page 3Question/Comment/Details: Is it permissible to use a "rubber stamp" or "digital" signature on reports/records that are required in 180.417 (b)(2)(x), rather than a handwritten signature? Such signatures are allowed in 172.204 (d) for shipping papers. It would streamline the record keeping process if signatures could be digitized. If an official interpretation is necessary for this inquiry, let this email suffice for such a request. Thank you#