A terminal acting merely as a distributor or carrier is not required to wait for lab results before shipping diesel fuel. The regulations provide that, like other downstream parties, to establish a defense to presumptive liability a terminal must have a quality assurance program that includes sampling and testing, as one element of its defense to presumptive liability.

Question and Answer was originally posted at Questions and Answers on the Clean Diesel Fuel Rules (PDF)(135 pp, 888 K, EPA420-B-06-010, July 2006, About PDF)