A refiner or importer using the 100% independent analysis option must use the test results from the designated independent lab as the basis for all RFG reports to EPA. The RFG regulations do not prohibit a refiner or importer using the 100% independent analysis option from also performing other sampling and testing, nor from having other sampling and testing performed by another lab. #15 Such other test results may not be used by the refiner or importer to show compliance with the RFG standards, however.(7/1/94)

#15 The testing requirement at § 80.65(e)(2), that includes provisions for reconciling testing "conducted by the refiner or importer and by an independent laboratory..." refers to refiner or importer testing conducted under the 10% independent analysis option, and not to the 100% independent analysis option.

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)