Todd:
 
My comment about testing was taken from a conversation with Dr. Charles 
Peterson, Director of the BioFuel Lab at U of Idaho, Moscow.  Dr. Peterson 
flatly stated that the key issue for small biofuel producers was the need to 
test each batch, that small producers could not, typically, afford such tests.  
He recommended that the small producers join forces and create a "central" lab 
to test each batch made by each producer if that fuel is to be sold.  If anyone 
is attempting to sell untested biofuel, there is a risk that such fuel -- 
off-spec fuel --could foul a diesel engine, its injectors and filters.  
 
Further, if a producer sought product liability insurance, I am reasonably 
certain that the carrier would insist on the testing of each batch.
 
As to labeling, how would anyone label non-tested, off-spec biodiesel?  The 
term, "biodiesel" has a correct and scientific meaning, that is a compound 
which has passed ASTM D 6751.  It is not "biodiesel" unless it has been tested 
and has passed the test.  Petro diesel also has to pass its tests.  I 
understand that the B20 may have its own test.
 
Testing, in my opinion, is critical to the success of the entire biodiesel 
industry.  We need to be on par with the big producers of diesel fuels.  We 
must be able to assure the buying public that "our" biodiesel meets the 
standard of D6751.  The problem lies in the cost of testing each batch.  Dr. 
Peterson's conclusion is that testing could become economical if enough of the 
small producers form a "coop" or some other business arrangement so that a 
sample of each batch can be tested.  I agree with Dr. Peterson.
 
Jim Miller

Appal Energy <[EMAIL PROTECTED]> wrote:
Jim,

>4.  The test profile is there for a reason -- you do not truly have
>biodiesel unless it passes the test.  You may have a compound which
>will burn, but to mis-lable it as "biodiesel" would be illegal.
>Civil liability could follow.

That's a bit of a mis-correlation. I sure wouldn't want to put it in a
storage drum and label it "maple syrup." And labeling it as "A Compound
Which Will Burn" is equally misleading.

Just because a sample may not be subjected to the costly tests and rigors of
ASTM D-6751 doesn't mean that it's not biodiesel. It's just not a fuel that
can be legally sold for road taxable use. And that's only because of
"legislative legalities," not chemical "realities."

Todd Swearingen


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