What are the requirements for reporting to EPA in the case of an independent lab that conducts sampling and testing that is unrelated to the independent sampling and testing requirements that apply for refiners or importers, such as quality assurance sampling and testing for a downstream pipeline or terminal?
There is no requirement that the results of downstream quality assurance sampling and testing must be reported to EPA. This is true both in the case of quality assurance sampling and testing by downstream parties such as pipelines or terminals, and in the case of quality assurance sampling and testing carried out by branded refiners or importers over their downstream branded operations.
The conduct of quality assurance sampling and testing programs, and the actions that are appropriate when violations are found through such a program, are discussed in the Remedies and Liability/Defenses Sections of this document. (7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)