Section 80.600(a)(10) says, Any refiner or importer shall maintain copies of all product transfer documents required under §80.590. If all information required in paragraph (a)(6) of this section is on the product transfer document for a batch, then the provisions of this paragraph (a)(10) shall satisfy the requirements of paragraph (a)(6) of this section for that batch.” Does that mean that if a refiner or importer has a PTD containing the information no other record is required? That seems unneeded. Does that paragraph mean something else?

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Section 80.600(a)(10) first requires that product transfer documents under § 80.590 be maintained by refiners and importers. It then states that if such product transfer documents contain all the information required under paragraph (a)(6) of § 80.600 for each batch, then no other separate recordkeeping is required for that batch in order to satisfy the requirements of paragraph (a)(6).

Question and Answer was originally posted at Questions and Answers on the Clean Diesel Fuel Rules (pdf) (135 pp, 888 KB, EPA420-B-06-010, July 2006)