The only parties who are required to meet the independent sampling and testing requirements are refiners and importers. A party that meets the definition of distributor or reseller, such as a terminal, therefore, is not required to meet the independent sampling and testing requirements.
In order to establish a defense to violations of the RFG standards for which it may be presumptively liable, however, a distributor must conduct a quality assurance program of sampling and testing. This quality assurance sampling and testing program could be conducted by an independent lab, but an independent lab is not required. The quality assurance sampling and testing defense provisions are discussed in the Liability/Defenses Section of this document.(7/1/94)
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)