Frequent Questions

Section 80.77 states that product transfer documents should include the name and address of the transferor and transferee. In the interest of keeping the PTD's as a single document, would it be permissible to retain the addresses of the transferees in a p

Under § 80.77(a) and (b), the product transfer documents for each transfer of title or custody must include both the name and address of the transferor and the transferee. However, EPA will consider this requirement to be met in a case where only the names of the transferor and/or the transferee are listed in the documents that are provided at the time of the transfer of title or custody, provided:

1) The normal business practice of the parties is to list only the names of the transferor and/or the transferee;
2) Both the transferor and the transferee know and have records of the required addresses; and
3) The addresses are provided to EPA upon request. (10/17/94)

This question and answer is posted at http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf. The original was posted in the Q&A posted on 10/17/94 which can found at http://www.epa.gov/otaq/rfg_qa.htm" See Question ID 3857 for RFG (Taken from the first question on http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf)
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