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Fuel Regulations

 

Advocacy with government agencies: Government agencies often look to fuel regulations to address environmental or political priorities.  But their approach may not encompass considerations critical within the fuel distribution system. We have been successful in leading advocacy efforts with the regulators to craft regulatory language which is practical and minimally problematic to implement.

Compliance Plans: As regulations are finalized, it is imperative that a well thought out compliance plan be developed.  It is often too late to attain compliance at the point the new regulation is published.  We track regulatory changes and understand the implications of those regulations throughout the system.  From that understanding, effective and efficient plans can be developed.

Training of key personnel: One of the key steps in any quality management system is the training of personnel in the understanding of the importance of quality principles and the specific operations required to protect the fuel and brand reputation.  We have trained personnel in all of these areas as well as when new fuels have been introduced, fuels like E10, Biodiesel blends and ULSD.

EPA Reporting
      • Detergent VARs
      • Quarterly additive usage
      • Annual fuel manufacturer reports

Within the many EPA regulations are requirements for reports.  The detergent rule requires that a Volumetric Additive Reconciliation report be generated monthly. If additives are being added to fuels, whether at refineries or downstream of them, there are requirements to submit quarterly additive usage reports to the agency. And annual reports are required for fuel manufacturers an importers. We are familiar with all of these requirements, and more, and can facilitate report generation and submission.

Dispenser Labels: Dispenser labels are required by a number of federal government agencies as well as many states.  While the federal requirements are consistent across the nation, those from the states are not.  We have a thorough knowledge of the requirements and can offer advice that can avoid NOVs.

Product Transfer Document Messages: The EPA considers any document which memorializes fuel custody or title transfer to be a product transfer document (PTD).  This includes Bills of Lading, Pipeline tickets, Invoices, Monthly Statements and more.  All of these documents are required to contain messages applicable to the fuel products involved.  The regulations pertaining to the detergent rule, RFG, Renewable Fuels Standard, ULSD, and E15.  Additionally, a number of states have their own PTD requirements.  We  understand the various rules and can formulate a practical approach to compliance.