What happens if I refuse to allow sampling to occur?
This is your option, but in the Introduction package provided each retailer at the time of sampling, the respective environmental agency provides a letter requesting your participation in the survey. If you choose not to participate, the Federal or state agency will be notified immediately of your option not to participate and will follow-up with you directly concerning your refusal. You may incur additional costs for choosing this option.
Can I get a copy of the 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 member company, the $150 fee partially offsets the costs to sample and test your location.
How do you know the sample came from my location?
The 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 a sales receipt for the fuel purchased at the site for the sample and sign Chain of Custody documents to validate the sample procurement. These documents are verified upon receipt at our laboratory.
The 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?
- RFGSA Programs
- Frank Lenski
- President, RFG Survey Association (RFGSA)
- (703) 279-6434
- Frank.Lenski@rfgsa.org
- SwRI Field operations
- Southwest Research Institute (SwRI)
- Sam DeViney
- (210) 522-3383
- Sam.Deviney@swri.org
- U.S. Environmental Protection Agency (EPA)
- Program Policy:
- Jaimee Dong
- (202) 343-9672
- Dong.Jaimee@epamail.epa.gov
- Enforcement:
- Jeffrey Kimes
- (303) 312-6445
- Kimes.Jeffrey@epamail.epa.gov
- EPA - Clean Air Act: http://www.epa.gov/air/caa/
- Arizona Issues – Policy/Enforcement
- Department of Weights and Measures (AZDWM)
- Michelle Wilson
- (602) 771-4933
- MWilson@azdwm.gov
Frequently Asked Questions
Who is the RFG Survey Association?
We are an independent not-for-profit trade association. Our members (refiners, importers, blenders, fuel suppliers, and fuel marketers) form a consortium of companies who have chosen an industry compliance option to meet their regulatory compliance requirements.
Why are you sampling?
EPA and State Agencies have approved survey plans to allow refiners, importers, blenders and fuel suppliers to meet their required fuel compliance obligations through the Association’s fuel sampling programs. The Association programs are in addition to 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 organization that the Industry utilizes to meet Federal or State environmental requirements for fuel compliance.
How did you pick my station? You recently sampled my location, why are you back?
The regulations require a representative sample of all the stations within the sampling area of interest. The stations are chosen at random. The primary factors that influence the station selection and frequency of selection are market share, station volume 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 specific sampling program (RFG, E15, ULSD, AZ). In addition, he/she will have the Field Origin Report (FOR), which identifies station/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 IC pay for the fuel sample?
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 the survey plans approved by the Federal or State Environmental agencies, whether or not you and/or your supplier participate directly in the RFGSA programs does not impact your selection for sampling under the programs. 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 the plan methodology.