What happens if I refuse to allow my facility to be sampled?
This is your option; but in the Introduction package provided each facility at the time of sampling, the respective governmental environmental agency provides a letter requesting your participation in the survey. In most cases a refusal to participate in the survey is a violation of the applicable regulations. You may incur additional costs if you choose this option.
If you choose not to participate, the Federal or State agency and your fuel manufacturer/supplier will be notified immediately of your option not to participate in the sampling event and will follow-up with you directly concerning your refusal.
Can I get a copy of the retail sampling results? Why is there a fee to obtain the results of the sampling analysis at my location?
Yes. In most cases if your supplier is a member of the Association, they will receive your sample analysis. If there is a problem, they will contact you. If your supplier is not a RFGSA member or participating company, there is a $150 fee which partially offsets the costs to sample and test your location. Instructions to request a sample are provided in the Introductory package.
How do you know the sample came from my retail service station?
Approved chain of custody (COC) procedures by program will ensure samples are properly identified and managed throughout the procurement, testing and reporting process. In many cases sample containers have pre-affixed location tags which identify your location and the samples to be taken. You are free to examine the labels. In addition, the sampler is required to obtain proper COC documentation based on the facility. For example: a sales receipt for the fuel purchased or signed Chain of Custody documents to validate the sample procurement. These documents are further verified upon receipt at our laboratories.
The retail fuel sample obtained by RFGSA is quite small. Does it really represent the fuel (product) you are sampling?
Yes. All official product sampling will be done in a manner that meets or exceeds industry standards. Please note that our sample collection procedure disposes of the hose residual which allows us to procure a valid sample without pumping a large volume.
If I have additional questions or concerns about the RFGSA programs, who do I contact?
- RFG Survey Association Inc. (RFGSA) – Overall program operations
- Frank Lenski, President
- (540) 404-4437
- Frank.Lenski@rfgsa.org
- SwRI Field operations – Retail Sampling Programs
- Southwest Research Institute (SwRI)
- Jamie Pollock
- (210) 522-5853
- Jamie.Pollock@swri.org
- U.S. Environmental Protection Agency (EPA)
- Program Policy:
- Enforcement:
- TBA
- EPA Regulations
- EPA - Clean Air Act: http://www.epa.gov/air/caa/
- Arizona Issues – Policy/Enforcement
- AZ Department of Agriculture, Weights and Measures Services Division
- Michelle Wilson
- (602) 771-4933
- MWilson@azda.gov
Frequently Asked Questions
Who is the RFG Survey Association?
We are an independent not-for-profit trade association. Our members and program participants (refiners, producers, importers, blenders) participate in a consortium of companies who have chosen an industry compliance option to meet their regulatory compliance requirements.
Why are you sampling?
EPA and some State Agencies have approved regulations and RFGSA survey plans to allow refiners, producers, importers and blenders to meet their required fuel compliance obligations through the Association’s fuel compliance programs. The Association programs are in addition to any other Federal and State sampling programs.
Are the Association programs approved by EPA or State Environmental Agencies?
Yes. All RFGSA programs have been approved and authorized by their respective environmental authorities.
Does the RFGSA or its contractors work for EPA or State?
No. We are not employed or affiliated with the EPA or any State environmental agency. We are an independent organization that the Industry has chosen to meet Federal or State environmental requirements for fuels compliance.
How did you pick my station? You recently sampled my location, why are you back?
The motor fuels compliance regulations for which the RFGSA supplies services, have a number of specific requirements. Locations are chosen based on an EPA approved statistical survey designs and, in some cases, specified with certainty. The primary factors that influence the facility selection and frequency are the program requirements, volumes and overall market representation.
What identification should the sampler provide before sampling my location?
The independent contractor (IC) should present letters from; (1) the RFG Survey Association; and (2) the respective governmental agency (EPA/State) requesting your participation in the sampling programs (Gasoline/Diesel, AZ). In addition, he/she will have the Field Origin Report (FOR), which identifies station/facility/product(s) to be sampled and the name of the IC sampling the site. You may request to see the IC driver’s license to verify his/her identity.
Will the RFGSA pay for the retail fuel sample(s)?
Yes. The contractor will request a receipt showing location address, product and quantity purchased.
I am an unbranded retail outlet, who authorized you to sample my location?
Under most survey plans approved by the Federal or State Environmental agencies, whether or not you and/or your supplier participates directly in the RFGSA programs does not impact your selection for sampling under the National Fuel Survey Program. The survey plans require a representative sample of all the fuel sold in a specific area. All locations in the specific sampling area are eligible for sampling based on regulations and the survey plan methodology.