Confirm that the attester will designate what is required to turn over a tank from one service to another, and how the barrels should be counted; i.e., from RBOB to conventional, or 3.5 wt% RBOB to 2.7 wt% RBOB.
The attester will not designate products for the party subject to the attestation engagement requirement. The function of the attestation engagement is to provide an independent analysis of the designations made by the regulated party. The designation of gasolines and RBOB occurs when product has been produced and shipped by a refiner. The attestation engagement is a year-end review of the production and marketing records of the regulated party, after decisions pertaining to product designations have been made.(7/1/94)
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, About PDF)