How long must you keep SPCC inspection records? (Three years, and the free-tier problem)

Short answer: 40 CFR 112.7(e) requires that records of SPCC inspections and tests, signed by the appropriate supervisor or inspector, be kept with the plan or at the facility for three years. That is far longer than many free software plans keep your data at all, and the gap between those two numbers is where facilities lose inspections.

What the rule actually requires

Three requirements travel together in 112.7(e):

1. Written procedures. Inspections and tests are conducted in accordance with written procedures developed for your facility. Records kept under usual and customary business practices suffice: you don't need a special format, you need consistency.
2. Signatures. Each record of inspections and tests is signed by the appropriate supervisor or inspector. An unsigned checklist is a worksheet, not a compliance record.
3. Retention. The signed records are kept at the facility or with the SPCC plan for three years.

The three-year habit extends across the rule's other logs as well: inspection schedules and logs, dike drainage records where applicable, and oil-handling personnel training and briefing logs. All of it is the evidence base an inspector reads as "this facility operates its plan."

The full record set an inspector expects

Inspection records rarely get examined alone. Expect the surrounding documentation to be requested in the same visit:

• the plan itself, with its container list and capacity calculations matching the tank farm in front of the inspector;
• the self-certification statement (or PE certification);
• three years of signed monthly inspection records;
• the annual training and briefing log (112.7(f));
• the technical amendment log, covering facility changes (112.5(a));
• the five-year review statement (112.5(b)).

A facility that has the inspections but can't produce the briefing log, or has the plan but its container list is two tanks out of date, has a gap, and gaps are what get counted.

The trap: records that outlive the tool they were born in

Most facilities now record inspections in an app or a spreadsheet rather than a paper binder. That's fine under the rule; electronic records with signatures are accepted business practice. The problem is the tool's own retention policy.

Several popular inspection platforms delete submission data after three months on their free plans; paid tiers remove the limit but store records as raw data, disconnected from your plan, your container list, and any regulatory structure. Do the arithmetic: an inspection recorded in March on a free plan is gone by June. An inspector asking in April for last year's monthly records gets a hole in the pattern, and "no documented monthly inspections" is among the most frequently cited SPCC violations.

The same trap wears a second costume: records scattered across a camera roll, a messaging thread, and a laptop that left with a former employee. Technically recorded, practically unretrievable.

What audit-ready looks like

• Every inspection record: date, inspector, per-item results, photos of findings, signature;
• Records tied to the facility and its container registry, not floating files;
• Retained the full three years, and beyond, since older records demonstrate the pattern;
• Assemblable into one package in the structure an inspector expects: plan, container list, inspection logs, training briefings, amendment log, five-year review statement.

That last point is the difference between a folder of PDFs and a defense. PlanKeep is built around it: signed inspection records, photos, and logs live with the plan for the full retention cycle, and the audit package exports as a single structured bundle. If your history currently lives in scattered files and phone galleries, the Inspection Readiness Report is the fastest way to see the gap before someone else finds it for you.

FAQ

Can SPCC records be electronic? Yes. The rule accepts records kept under usual and customary business practices; electronic records with signatures qualify. What matters is that they're retrievable, signed, and complete for three years.

Three years from when? From the date of the inspection. The window rolls: last March's record can be retired next March, once it has aged out, though keeping it longer costs nothing and strengthens the pattern.

Do I need to keep records for tanks I removed? The inspection records for the period they existed, yes; they're part of the facility's history and feed the amendment trail when containers change.

What's the penalty for missing records? Records failures are cited as documentation violations under the rule, and civil penalties under CWA §309(d) run up to $68,445 per day, per violation at the inflation-adjusted maximum (2025 level, 40 CFR 19.4). Compared to that, recordkeeping software is rounding error.