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ASP question for October 25, 2026

The ASP question of the day for Sunday, October 25, 2026, on oil spill prevention (SPCC). Pick an answer to see the explanation and its source.

ASP Domain 7: Environmental Management

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?

Show answer and source: 40 CFR 112.7(e)

Answer: C. Acceptable, because signed usual and customary records plus written procedures kept with the Plan for three years suffice.

Section 112.7(e) of the general requirements for Spill Prevention, Control, and Countermeasure (SPCC) Plans accepts inspection records kept under usual and customary business practices. The records must be signed by the inspector or supervisor and kept, with the written procedures, alongside the Plan for three years. The rule does not require a separate SPCC log, retention beyond three years, or a certifying engineer's countersignature on each checklist.

On the job

A plant engineer at a chemical blending site reviews a regulator's questions about tank-farm records. The weekly tank and valve walk-down sheets come from the maintenance system, each signed by the inspector, and sit in the SPCC binder next to the written inspection procedures. Since signed records kept under usual and customary business practices suffice, the engineer keeps both with the Plan for three years and does not build a duplicate SPCC log.

Study aid, not site-specific safety advice. The official rule controls.

Answer C comes from

40 CFR 112.7(e)(opens ecfr.gov in a new tab)
“You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.”

Where it appears on the exam

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