Who is the transferee in a custody transfer where the owner of the receiving tank/truck/barge is different than the operator (scheduler) of the tank/truck/barge, who may also be different from the company that provides the employees of the site? Can a company assume that when multiple parties can be the transferee, that one can take on the role of being the designated responsible party?
Regarding transfers of custody, PTDs are intended to be given to the person physically taking custody of the product. Where multiple parties are involved in a physical transfer of the product, and the transferor does not know the name of the person physically taking custody of the product, the name of that person may be omitted from the PTD so long as this information has been recorded on some other document that memorializes the transfer of custody of the product, and this information is available to EPA on request. (5/23/95)
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)