Risk Analysis in Customs Control: Conformity Assessment of Denatured Alcohols using Measurement Uncertainty Evaluation

Ilya Kuselman, Independent Consultant on Metrology, 4 Yarehim St., Modiin, Israel
Boris Ginzburg, Department of Customs & Vat, Israel Tax Authority, 5 Bank of Israel St., Jerusalem, Israel
Orna Dreazen, Nextar Chempharma Solutions Ltd, 13B Einstein St., Weizmann Science Park, Ness Ziona, Israel

The guidelines of World Customs Organization and European Commission define risk as the potential for non-compliance with customs laws. Risk analysis in customs control is the systematic use of available information to determine how often defined risks may occur and the magnitude of their likely consequences. When substances and/or materials are under customs control, one of such risks is caused by measurement uncertainty of chemical analytical (test) results. The reason is the influence of measurement uncertainty on conformity assessment of any substance or material at comparison of the test results with the respective specification limits.

As an example of substances under customs control, denatured alcohols are discussed. Alcohol (ethanol for human consumption) is subject to excise duties, while denatured alcohols (for industrial use) are not, and the task of the control is to distinguish between them. There are some opportunities for fraud (denatured alcohol can be cleaned up afterwards) and illicit alcohol should be identified with minimal risk in the control.

Analytical methods for testing denatured alcohols include gas chromatography with flame ionization detection and high performance liquid chromatography with ultraviolet detection. These methods were recently validated with evaluation of measurement uncertainties by European Joint Research Center and customs laboratories.

The risk analysis in conformity assessment of completely denatured alcohols caused by the measurement uncertainties is the subject of the present lecture. This analysis is applied to the specification limits of denaturants permitted for use in Israel.