For a refinery with an in-line gasoline blending exemption, can the annual in-line blending audit be conducted by the same attestation auditor as outlined under Subpart F of the RFG and Anti-dumping regulations? Must the auditor for an in-line blending op
An in-line blending exemption exempts a refiner from the independent sampling and testing requirements of § 80.65(f). As one of the conditions of the exemption, the refiner must carry out an independent audit program of its in-line blending operation.
Attestation engagements are different than, and do not take the place of, the in-line blending audits. Attestation engagements cover a broad range of records required under the reformulated gasoline and anti-dumping programs, as specified in Subpart F. They deal with production volumes, fuel properties reported for those volumes, and shipment documentation. The independent audits required for in-line blending operations, on the other hand, are narrowly focused on individual in-line blending systems that are unique for each location. Basically, the in-line blending audit must verify that for each batch, the reported batch properties are supported by secondary sources of test data; that in-line blending control and recordkeeping systems are being carried out as represented to the Agency in the petition for the exemption; and that the testing, cross checks and quality control being exercised over the operation allow the refiners to accurately predict the property values and volumes being reported for each batch.
Auditors who conduct in-line blending audits must meet the criteria specified in § 80.125(a) and/or (d), which require the auditor to be an independent certified public accountant, or, alternatively, an employee of the refiner, provided that such employee is an internal auditor certified by the Institute of Internal Auditors, Inc. ("CIA") and completes the internal audits in accordance with the Codification of Standards for the Professional Practice of Internal Auditing. However, because of the complexity of on-line measurements and estimates, many auditors who qualify for the attestation engagements may not have the technical qualifications to conduct in-line blending audits. The audit program for an in-line blending operation will require the refiner to use an auditor who both fulfills the requirements under § 80.125(a) and/or (d), and has expertise with in-line blending operations. (8/15/95)
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)