In the case of a refiner or importer using the 100% independent analysis option, must the refiner or importer conduct any sampling or testing of RFG in addition to that performed by the independent lab?

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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.

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