Oil Spill Prevention (SPCC) questions for the ASP

Question 1

A bulk oil storage facility documents its tank and valve inspections on the checklist forms used in its normal maintenance program. Each completed checklist is signed by the inspector. The checklists and the written inspection procedures developed by the certifying engineer are filed with the SPCC Plan, and both are kept for three years. During an audit, a reviewer says the facility must recreate all of these records on a separate SPCC-specific log format before they can be accepted. How should the facility respond?

1. AThe reviewer is correct, because inspection records are valid only if they are transcribed into a log created specifically for the SPCC Plan.
2. BThe records are acceptable only if retention is extended beyond three years, because business-practice records need a longer retention period than SPCC-specific records.
3. CThe current records are acceptable, because signed records kept under usual and customary business practices, together with the written procedures, satisfy the requirement when kept with the Plan for three years.
4. DThe records are acceptable only if the certifying Professional Engineer countersigns every checklist.