Data control and recording systems should be proposed in the exemption request as part of an overall quality control, record keeping and review plan. All data that is generated for the batch that is intended to form a basis for the RFG certification, must be recorded and retained in a secure manner so that the auditor will be able to review accurate data for the yearly in-line blending audits.
We believe the refiner should provide reasonable security for all the data that is generated so as to retain uncompromised files and to restrict unnecessary and unauthorized access to those files. Limiting the number of persons who have access to the files is as important as who has access.(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)