"Evaluating The Criteria For AS uccessful Fuel Marking Program"
Evaluating the Criteria for a Successful Fuel Marking Program 1. The Objectives of a Successful Program are to identify and control adulteration, not just to provide markers. This process involves: Consultation to determine the nature of the problem as well as to determine the supply chain dynamics and operational needs Determining a Marking Strategy and technology choice Ensuring a Robust Operation for marking, inspection and enforcement 2. Critical Success Factors for an Effective Program To achieve this there are some key factors that need to be considered. There is a need for a: Defined Program Marking Inspection Control Integrated Management System Infrastructure Resources and the ability to Implement Country-vide Programs Co-operation of all players (Ministry, OMCs, SGS/Autheniix) Database Experience of Running Large Country-wide Programs Management Training and Ongoing Support Program and Operations Audit Highest Standards of Quality Integrity and Ethics Appropriate Flexible Marking System Multiple Markers Propriety Field Test Lab Back up using a different technology to field test 2.1 Defining the Program: It is critical to define the programs objectives. operations and the penalties for illegal activity. Strategic Marking Objectives To Identify fuel that is illegal or has been adulterated Demonstrating that action will be taken if illegal activity is detected Operational Defining a suitable marker/test system Determining secure storage and distribution of the marker Determining how to mark the fuel or solvents Measure for marker in market place Defining an appropriate sampling, inspection regime Defining a field test Defining the lab test for back-up Having a Number of Markers and layered technology to Combat any operational difficulties to: Ensure marker solubility in different Fuels Provide layered technology with robust combinations of forensic, field Quickscan, field verification and Iaboratory analysis Prevent attempts to remove or launder the marker system Keep the identification of the markers secret Controlling the Malpractice Penalise malpractice Certify and reward good practice 2.2 Integrated Management The various elements of the operator can involve: controlled marking linking terminal deliveries to retail site receipts managing an active surveillance 'testing program providing data for management control/action on both an individual company basis and for the industry and Government as a whole. For Success, this necessitates: Full coordinated operational control through Standard Operating Procedures. This needs to be backed by an effective audit structure with timely upgrading of operating strategies to maximise the effect of the program Full operator training with Manuals A management information system to back-up the operational activities Having a comprehensive data control and information system will ensure that: o Security or failure alerts are sen : in a near "real-time" fashion to imitiate remediation and enforcement o Raw data from whatever source will be entered into a prescribed format o This will be used to prepare table/graphs o These will be use in turn to writs reports o Data correlation o Being able to write specific reports 2.3 Experience and Credentials in a Number of Countries is Vital It is vital that the company providing the solution has valid credential and expertise from implementing programs of like size. The amount of best practice learned from previous implementations can be applied which will reduce the overall launch time and speed the recovery of revenue. 2.4 Chain of Evidence It is critical that the full chain of evidence is maintained. It also essential to maximize the use of data by tracking parcels of product as well as confirming actual malpractice by field sampling and results. This information is used both for taking action against malpractice as well as to compare results of individual companies to the industry as a whole. 3. Choosing the Right Marker 3.1 Marking Strategy Depending on the nature of the problem, it will be important to determine whether to mark: he fuel that is being adulterated /replaced or the potential adulterant (or in the case of export dumping the export fuel). The arguments are summarised below. In general quantitative marking is suitable when dilution is an issue, through for example smuggling and "Yes/No" marking when adulteration is an issue. Marketing Positive Draw backs Approach Mark All Road All relevant fuel Level of detection is limited to 5-10% fuel to 100% marked and can to identified Theft and illegal use of the marker is a major issue Laundering is not an issue Mark potential It is possible to This second option is valid only when it is Adulterants detect__ low levels possible to mark all product that is likely to be of adulterant used illegally. If solvents have been Some markers can be laundered. imported illegally they can be detected (they will have to marker 3.2 The Criteria for Marking Technology. The main attributs of any marker system are summarised below - Stable and Robust - Unique and protected by patents etc. - Suite of more than one marker to distinguish between neighbouring countries - No effect on product Specification - Works in all fuels (includes biofuels) - Detected at Low Levels and specific - Quick to test and confirmed in Lab - Can be identified after" aundering" - Will stand up in court (to mistakes) Keeping information on the markers confidential is also key a) Stability: The markers must be stable: a. In all fuels (e.g. kerosene diesel and gasoline. b. In additives or dyes if the marker is to be added via this route b) Unique, Secret and Patent Protected. a. Uniqueness is critical to prevent mis-identification of adulterated fuel in the market b. Secrecy is critical to prevent abuse of the system by adulterators and the adulterators marking below the level of detection c. Patent protection is desirable to aid prosecution of anyone interfering with the system. c) Having a Number of Markers h vital a. To mark more than one ft :el or for tracking particular parcels of fuel b. To mark in neighbouring countries c. To identify tampering/laundering d. For marker replacement in the existing marker is compromised by laundering d) No Effect on Product Specification a. Added at very low level b. Tested on all products e) Detection - The need to stand up in Court with No Mistakes a. For adulteration,- India's Need - must be detected in-the-field at low levels (less than 1%) in all fuels - including biofuels an gasoline with ethanol b. Specificity is critical and ro other marker must be detected by the field test c. For quantitative measurement must have an accuracy in-thefield of plus or minus 5% d. In both cases, there needs to be a back-up lab tests which confirms the result and is not based on the field test. This will ensure no mistakes. f) Laundering a. The marker needs to be detectable after laundering attempts by such agents as acid, alkali, alcohol, cellite/day b. As with c) above, the marker system needs to be flexible so that the combination and concentration of the markers used can be altered when laundering i) suspected or becomes a problem 3.3 Marking Technology A number of different technologies have been Used in the market place. Traditional Dyes Marking programs originally relied on the relatively high levels of dyes, markers and inorganic tracers (generally greater than 20 ppm) Physical measurements (such as change in density or refractive index) have also been used. Second Generation Dyes Tracing techniques were developed making use of covert chemicals. As with dyes relatively 1igh levels of marker (generally greater than 20 ppm) are needed. The marker is normally analysed by a relatively simple chemical test which gives a colour (it is important that this is not confused with the colour of the fuel itself). The colour development is typical of a particular chemical and this, together with the relatively high concentration used, means that it can be identified relatively quickly. Isotope Technology relies on producing isotopes of different masses and measuring them with expensive sophisticated lab based instruments and highly trained technicians. Infra Red /UV "Direct Read" Technologies A number of companies now offer machine read systems based on IR or UV tracers. This technology is easy to use, but there is a need to calibrate for different fuels. Other Direct Read Technology There are a number of direct read technologies under development. Immunoassay Technology (IAS) relies :m marking with extremely low levels of marker (e.g. 100 ppb as opposed to the 20 ppm generally used for dyes). The marker is then detected by absorption onto an antibody column and analysed by a number of techniques including direct vis Jal observation on the column, fluorometry and HPLC. Antibodies are very specific and one antibody will recognize only one marker chemical. This protects against false positive. The marker chemical is present at too Iowa concentration to be measured by any other technique. It is essential to have the antibody to extract and concentrate the marker. The security of the marker is therefore extremely high. X-Ray Fluorescence, GCMS etc. Good Technologies for quantitative detection which rely on lab or very large analytical equipment The table below compares the attributes of the various technologies. 4. Summary Needs for a Successful Program Whereas, the marker system is critical, on its own it is not enough. It is key to: Understand the Problem and have a Defined Program To have an Integrated Management System run by an Experienced Management Team An Appropriate and Excellent Marking Technology The Link between technology and integrated Management illustrated below. Comprehensive Supply Chain Control Using a Variety of Systems and Technology Consultancy/Technology Infrastructure Inspection Unique Marking Global Network Technology (Local Expertise) Sector Experience System Control Ability to Track and Trace Product Guarantee Chain of Supply/Evidence Sample/ Analyse to Determine Malpractice Report and Control Sectors Petroleum Pharmaceutical Tax Stamps etc. 5. Marking Evaluation System - The criteria (below) need to be determined by the client (Ministry/OMCs etc.) - The competitors should fill in information appropriately - The client can then score competitive bids using the weighted criteria on page 11. 5.1 Experience a. Detail existing programs where Authentix and SGS work together with information .m both implementation and ongoing operations. Provide client references for validation. b. Provide Details of the Infrastructure company listing experience, integrity ethics, financial stability etc. c. Provide Details of Marker Company listing experience, integrity ethics, financial stability etc. 5.2 Operational Ability a. Detail Proposed Operational Strategy in India i. Program Audit Strategy ii. Program Implementation Strategy iii. Marker Manufacture facilities iv. Secure Marker Storage v. Controlled marking vi. Linking terminal deliveries to retail site receipts vii. Sampling/Analysis vii. Providing data for management control/action on both an individual company basis and for the industry and Government as a whole d. Provide Standard Operating Procedures and Operations Manuals to demonstrate Operational competence e. Give Details of training programs for staff f. List Staff with qualifications g. Demonstrate a management information system to back-up the operational activities which will ensure that: Raw data from whatever source will be entered into a prescribed format This will be used to both taking immediate corrective ac ion and to prepare table/graphs These will be use in turn to write reports Data correlation Being able to write specific reports 5.3 Marking Technology Evaluation a) List each marker to be used in system b) Detail Marker stability for each marker: i. In all fuels (e.g. kerosene. diesel and gasoline). ii. In additives or dyes if the marker is to be, added via this route. c) Unique, Secret and Patent Protected. i. Describe Uniqueness which will prevent marker being mis-identified in adulterated fuel in the market ii. Describe measures to ensure marker identity is kept secret iii. Describe patents etc No Effect on Product Specification i. Describe final marker concentration in adulterant (the lower the concentrate on, the safer it will be) ii. Describe tests carried out on all products iii. Describe experience in other countries i. Laundering i. Is the marker detectable after laundering attempts by such agents as acid. alkali, alcohol, cellite/clay ii. Is the marker system flexible so that the combination and concentration of the markers used can be· altered when laundering is suspected j. Detection - The need to stand up in Court with No Mistakes i. What is the marking concentration ii. What level of marker can be detected a. Gasoline b. Diesel c. Biofuel d. Gasoline with iii. Describe how the marker can be detected with no mistakes or mis-identification with another chemical iv. Describe how the test system can be protected from illegal use by adulterers. A propriety test system is critical to prevent abuse of the system v. What is the back-up lab test (this should not be the same as the field test) Evaluating the Criteria for a Successful Fuel Marking Program Criteria Marks Available Experience Existing Partnership Contracts (with reference clients 10 (20) for validation) Infrastructure Company Reputation 5 Marker Company Reputation 5 Operations Strategy 5 (40) Program Management and Audit Experience 5 Implementation and Operation) Proram Operations and SOPs for Marker Manufacture 10 Marker Blending/Security Marker Distribution Marking Auditing Sampling/Analysis Database and Reporting System 5 Staff Competence 10 Training Programs 5 Marker (40) Number of Markers Characteristics/Uniqueness' 5 Marker Anonymity 5 Marker Specificity and level of detection 5 Marking Level 5 Effect on Product Spec (including colouring) 5 Laudering Resistance (Clay, Acid, alkali etc) 5 Property Field test effectiveness (balancing ease with 5 mis-use by adulterers) Back - up Lab Test (not the same as the field test) 5 Totals 100 Petroleum Marker Technology Comparison Technology Use For Measuring Dilution For Measuring Adulteration Immunoassay Accurate test Measures very low levels of Can be done "On - adulterates site" or in the lab Only marker recognised by the test High security No mistakes Works in all fuels Covert Easy test Easy test Chemicals Needs calibration on Can be limited different fuels Problems with false positives Low level of security Direct Read Very easy, quick test Instruments 'noise' in lead to false Technologies Results may lack positive accuracy but are Should only be used in conjunction suitable for screening with a "Yes/No" marker Restricted number of markers Isotopes Very accurate lab- Not suitable as no field test available based test which is slow and expensive No field test GC X-Ray Accurate Instrument "noise" can lead to false Diffraction Needs large or positive. lab/based Should only be used in conjunction instrumentation with "Yes/No" marker To meet the requirements of any marker system there is the need to Accuracy coupled to "on -site" testing. Marker security (the marker can not be imitated) Unequivocal identification of adulterants (making mistakes is costly) In general, only a multi-layered marking system meets these requirements.