One pipeline has notified all shippers and suppliers that their metering ticket will be the official transfer document for all shipments. This appears to be appropriate for a transfer whereby the pipeline is delivering (or transferring custody to a party) but how can it be appropriate when the pipeline is receiving (or being the transferee) product from a shipper? Isn't the shipper required to provide its own document? Or can we rely on the pipeline's ticket which memorializes the transaction?
EPA does not require that there be an "official" transfer document. While the approach described in the question seems appropriate, the enforcement liability still remains with the transferor. As a result, the transferor should verify that the transferee receives all the PTD information for each batch. (8/29/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)