{"data":{"id":"sbm3c9a002813e7eb90b4c52","short_id":10,"created":"2026-05-07T19:26:11.987Z","space_id":"spc3b9aaeac473f68dfbbe14","project_id":"prj3b9a86ba78d82ca6d5958","org_id":"org20ee740c8b3c21feb3566","content":{"23zvek0s":"fil3c99fff8b8bf008c13202","f22e9n0y":"yes","zovp5q48":"Beta Analytic","would-you-like-t_08a393":"yes"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil3c99fff8b8bf008c13202":{"id":"fil3c99fff8b8bf008c13202","bucket":"files-au-climate","remote_path":"climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/Australia_NGER_Update_2026_Comment_Beta.4332f1ef.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj3b9a86ba78d82ca6d5958/submission/spc3b9aaeac473f68dfbbe14/Australia_NGER_Update_2026_Comment_Beta.4332f1ef.pdf","filename":"Australia NGER Update 2026 Comment Beta.pdf","transcribed":"Australia Department of Climate Change, Energy, the Environment and Water (DCCEEW)\nNational Greenhouse and Energy Reporting (NGER) Scheme Updates│ Stakeholder Engagement\n\nThis comment is intended to recommend the use of the Carbon-14 testing method to determine the share of biogenic carbon content of any heterogenous feedstocks, fuels and emissions under Australia’s\nNational Greenhouse and Energy Reporting (NGER) Scheme. Biogenic content measurements following methods such as ASTM D6866 Method B currently provide critical value to leading renewable fuels and emissions reporting programs around the world.\n\nIncluded here you will find:\n\nRecommendations for Australia’s National Greenhouse and Energy Reporting (NGER) 1\n\nWhat is Biogenic Testing (Carbon-14)? 10\n\nASTM D6866 Method B - The Most Reliable Method 11\n\nAbout Beta Analytic 12\n\nISO/IEC 17025:2017 laboratory 13\n\nRequired tracer-free facility for Carbon-14 13\n\nReferences 14\n\nRecommendations for Australia’s National Greenhouse and Energy Reporting (NGER)\n\nOur recommendation is that DCCEEW should implement routine biogenic content testing requirements following the ASTM D6866 Method B standard to verify the renewable (biogenic) content of any heterogeneous fuels and emissions under the NGER Scheme. Direct biogenic testing requirements are the only reliable method of incentivizing the use of biomass-derived content and guaranteeing compliance in mixed bio- and fossil streams. We specifically recommend that biogenic testing via C-14 be used to certify co-processed fuels, co-fired emissions and any fuels or emissions produced from waste.\n\nCo-Processed Renewable Fuels\nOur first recommendation is that any renewable fuels co-processed in refineries using both biogenic and fossil feedstocks should be required to submit routine biogenic testing requirements in line with those in place under leading fuel decarbonization regulations in the US, Canada and the EU. Routine direct testing is considered the best practice for regulating co-processed fuels because biogenic feedstocks do not\n\nPage 1\nbehave exactly the same as their fossil counterparts in a refinery, and resulting renewable fuels will not directly reflect the proportions of feedstocks introduced. For further information on this please subject, we encourage DCCEEW to review the ASTM D02 Committee studies on co-processing, particularly\nRR:D02-2052, which compares the results of ¹⁴C and mass balance in co-processing facilities.1\n\nCurrent requirements for routine direct testing following ASTM D6866 or international equivalents under prominent renewable fuels programs include (please see specific rules hyperlinked):\n- The US RFS currently requires routine direct testing following ASTM D6866 for fuels produced\nfrom co-processing, municipal solid waste (MSW), biogas and renewable natural gas (RNG).2\n- California’s LCFS requires routine direct testing for fuels produced from co-processing and\nrecommends for fuels produced from MSW.3\n- Oregon’s CFP requires routine direct testing following the protocols of the US RFS third-party\nengineering reviews.4\n- Washington’s CFS requires routine direct testing following the protocols of the US RFS third-party\nengineering reviews.5\n- New Mexico’s CTFP requires routine direct testing following the protocols of the US RFS\nthird-party engineering reviews.6\n- Canada’s CFR requires routine direct testing for any fuels produced from co-processing and their\nco-products.7\n- British Columbia’s LCFS requires monthly testing for any fuels produced from co-processing and\nquarterly testing for their co-products, as well as to verify biogenic feedstocks.8\n- The EU’s RED requires routine direct testing for any fuels produced from co-processing or biogas\nand renewable natural gas (RNG).9\n- ASTM D6866 is also required for prominent third-party verification programs, most notably the\nRoundtable on Sustainable Biomaterials (RSB).10 Testing requirements allow clean fuel programs\nto exclusively incentivize the renewable portion of fuels. This is especially important given the\nrecent history of attempted fraud in existing transportation fuel decarbonization programs.\n\nEmissions from Co-Firing\nSecondly, we recommend that the NGER scheme should also require routine biogenic testing requirements for any co-fired emissions, in line with the requirements for leading emissions reporting\n\n1\n2023. “RR:D02-2052.” ASTM International\n2\n2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes.” EPA\n3\n2020. “Reporting Co-Processing and Renewable Gasoline Emissions Under MRR.” California Air Resources Board\n4\n2023. “Oregon Clean Fuels Program.” Oregon Department of Environmental Quality\n5\n2022. “Chapter 173-424 WAC: Clean Fuels Program Rule.” Washington State Legislature\n6\n2026. “Clean Transportation Fuel Program Rules.” New Mexico Environment Department\n7\n2022. “Clean Fuel Regulations: Quantification Method for Co-Processing in Refineries.” Environment and Climate Change Canada\n8\n2025. “Low Carbon Fuel Regulation: Co-Processing Methodology” British Columbia Ministry of Energy and Climate Solutions\n9\n2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission\n10\n2023. “RSB Standard for Advanced Fuels.” Roundtable on Sustainable Biomaterials (RSB)\n\nPage 2\nprograms globally. Routine biogenic testing is also considered the best practice for regulating facilities co-firing biomass and fossil resources because direct flue gas measurements provide a representative sample of the renewable share of emissions. As discussed for refineries retro-fitted to accept biomass feedstocks, biogenic feedstocks will not behave the same as their fossil counterparts when introduced in coal-fired facilities and the biogenic share of emissions will not necessarily reflect their share of the feedstocks consumed.\n\nCarbon-14 testing requirements are the best practice for reporting biogenic emissions under leading emissions reduction programs, including the following (please see specific rules hyperlinked):\n- The US GHGRP currently requires routine direct testing following ASTM D6866 quarterly for\nemissions from the combustion of biogenic feedstocks.11 California’s Cap-and-Trade (AB 32)\nrequires routine direct testing following ASTM D6866 for emissions from the combustion of\nbiogenic feedstocks.12\n- California’s Cap-and-Trade requires quarterly testing following ASTM D6866 for biogenic\nemissions from co-firing and MSW combustion.13\n- Canada’s GHGRP requires routine direct testing following ASTM D6866, “if combusted fuels or\nfuel mixtures contain a biomass fraction that is unknown or cannot be documented.”14\n- Ontario’s Emissions Performance Standards (EPS) requires quarterly testing following ASTM\nD6866 to report biogenic content in fuel combustion and petrochemical production.15\n- The EU’s ETS requires routine direct testing following the European standard EN ISO 13833 for\nemissions claiming biogenic content, as well as EN ISO 21644 for any combusted biomass\nseeking an emissions factor of 0.16\n- The UK’s ETS requires routine direct testing following EN ISO 13833, ISO 18466, or ASTM D6866\nfor stationary source emissions claiming biogenic content.17\n\nWaste Incineration and Feedstock Use\nWe also recommend implementing routine C-14 testing requirements to report the biogenic content of any fuels produced from municipal solid waste (MSW) and landfill gas, as well as any facilities directly incinerating waste or combusting landfill gas.\n\nThe same programs listed above for co-firing require direct testing for MSW incineration:\n\n11\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” National Archives Code of Federal Regulations\n12\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board\n13\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board\n14\n2020. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada\n15\n2020. “Guideline for Quantification, Reporting and Verification of Greenhouse Gas Emissions.” Ontario MECP\n16\n2018. “Commission Implementing Regulation (EU) 2018/2066.” Official Journal of the European Union\n17\n2021. “UK ETS: Monitoring and Reporting Biomass in Installations.” UK Department for Business, Energy and Industrial Strategy\n\nPage 3\n- The US GHGRP currently requires routine direct testing following ASTM D6866 quarterly for\nemissions from the combustion of biogenic feedstocks.18 California’s Cap-and-Trade (AB 32)\nrequires routine direct testing following ASTM D6866 for emissions from the combustion of\nbiogenic feedstocks.19\n- California’s Cap-and-Trade requires quarterly testing following ASTM D6866 for biogenic\nemissions from co-firing and MSW combustion.20\n- Canada’s GHGRP requires routine direct testing following ASTM D6866, “if combusted fuels or\nfuel mixtures contain a biomass fraction that is unknown or cannot be documented.”21\n- Ontario’s Emissions Performance Standards (EPS) requires quarterly testing following ASTM\nD6866 to report biogenic content in fuel combustion and petrochemical production.22\n- The EU’s ETS requires routine direct testing following the European standard EN ISO 13833 for\nemissions claiming biogenic content, as well as EN ISO 21644 for any combusted biomass\nseeking an emissions factor of 0.23\n- The UK’s ETS requires routine direct testing following EN ISO 13833, ISO 18466, or ASTM D6866\nfor stationary source emissions claiming biogenic content.24\n\nSimilarly, the same programs listed under co-processing require routine testing for MSW-derived fuels):\n- The US RFS currently requires routine direct testing following ASTM D6866 for fuels produced\nfrom co-processing, municipal solid waste (MSW), biogas and renewable natural gas (RNG).25\n- California’s LCFS requires routine direct testing for fuels produced from co-processing and\nrecommends for fuels produced from MSW.26\n- Oregon’s CFP requires routine direct testing following the protocols of the US RFS third-party\nengineering reviews.27\n- Washington’s CFS requires routine direct testing following the protocols of the US RFS third-party\nengineering reviews.28\n- New Mexico’s CTFP requires routine direct testing following the protocols of the US RFS\nthird-party engineering reviews.29\n- Canada’s CFR requires routine direct testing for any fuels produced from co-processing and their\nco-products.30\n\n18\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” National Archives Code of Federal Regulations\n19\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board\n20\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board\n21\n2020. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada\n22\n2020. “Guideline for Quantification, Reporting and Verification of Greenhouse Gas Emissions.” Ontario MECP\n23\n2018. “Commission Implementing Regulation (EU) 2018/2066.” Official Journal of the European Union\n24\n2021. “UK ETS: Monitoring and Reporting Biomass in Installations.” UK Department for Business, Energy and Industrial Strategy\n25\n2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes.” EPA\n26\n2020. “Reporting Co-Processing and Renewable Gasoline Emissions Under MRR.” California Air Resources Board\n27\n2023. “Oregon Clean Fuels Program.” Oregon Department of Environmental Quality\n28\n2022. “Chapter 173-424 WAC: Clean Fuels Program Rule.” Washington State Legislature\n29\n2026. “Clean Transportation Fuel Program Rules.” New Mexico Environment Department\n30\n2022. “Clean Fuel Regulations: Quantification Method for Co-Processing in Refineries.” Environment and Climate Change Canada\n\nPage 4\n- British Columbia’s LCFS requires monthly testing for any fuels produced from co-processing and\nquarterly testing for their co-products, as well as to verify biogenic feedstocks.31\n- The EU’s RED requires routine direct testing for any fuels produced from co-processing or biogas\nand renewable natural gas (RNG).32\n- ASTM D6866 is also required for prominent third-party verification programs, most notably the\nRoundtable on Sustainable Biomaterials (RSB).33 Testing requirements allow clean fuel programs\nto exclusively incentivize the renewable portion of fuels. This is especially important given the\nrecent history of attempted fraud in existing transportation fuel decarbonization programs.\n\nWe also recommend requiring routine testing following the ASTM D6866 Method B standard for any landfill gas combusted for flaring or energy generation, and for landfill gas captured to be upgraded to biogas/RNG fuels.\n\nFor reference, current requirements of quarterly biogenic testing following ASTM D6866 for landfill gas combustion under similar prominent programs include (please see specific rules hyperlinked):\n- The US GHGRP currently requires quarterly routine direct testing following ASTM D6866 for\nbiogenic emissions from co-firing and municipal solid waste (MSW) combustion.34\n- California’s Cap-and-Trade requires quarterly routine direct testing following ASTM D6866 for\nbiogenic emissions from co-firing and MSW combustion.35\n- Canada’s GHGRP requires quarterly routine direct testing following ASTM D6866 for biogenic\nemissions from any renewable or biogenic fuels derived from biomass including landfill gas and\nbiogas, as well as for any fuels or fuel mixtures containing an unknown biogenic component.36\n- The EU’s ETS requires quarterly routine direct testing for biogenic portions of obligated\nmaterials, fuels and emissions.37\n\nBiogenic testing requirements are also important to require for landfill gas captured for the production of biogas/RNG fuels. Current requirements of quarterly biogenic testing following ASTM D6866 for landfill upgraded to biogas/RNG fuels under similar prominent programs include (please see specific rules hyperlinked):\n- The US RFS currently requires quarterly routine direct testing following ASTM D6866 for fuels\nproduced from co-processing, municipal solid waste (MSW), biogas and renewable natural gas\n\n31\n2025. “Low Carbon Fuel Regulation: Co-Processing Methodology” British Columbia Ministry of Energy and Climate Solutions\n32\n2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission\n33\n2023. “RSB Standard for Advanced Fuels.” Roundtable on Sustainable Biomaterials (RSB)\n34\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” National Archives Code of Federal Regulations\n35\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board\n36\n2022. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada\n37\n2022. “Biomass issues in the EU ETS.” European Commission\n\nPage 5\n(RNG).38 However, the EPA’s recently published rule on the RFS for 2026-2027 will limit testing\nfrequency for the industry.39\n- The EU’s RED requires quarterly routine direct testing for any fuels produced from co-processing\nor biogas and renewable natural gas (RNG).40\n\nWe recommend reviewing Data/parameter table 2 of the UNFCCC Approved Consolidated Methodology\n(ACM) ACM0022 on “Alternative waste treatment processes” (pages 41-42) as well. This protocol requires biogenic testing following ASTM D6866 to determine the biogenic and fossil fractions of MSW for any cases where the biogenic content of waste cannot be classified or is unknown, which is critical to quantifying the sustainability of landfill gas combustion.41\n\nControlled Methane Release Study\nWe also recommend that DCCEEW consider the role of isotopic testing under the Controlled Methane\nRelease Study included in this update. Radiocarbon testing can also play a role in separating carbon sources within the system and, when combined with total carbon content, can help determine the rate of atmospheric carbon removal and establish a baseline scenario for GHG removals. Furthermore, a study by Kerfoot and all., Methane gas in landfills also gives insight into the Carbon-14 testing application to identify the source of hydrocarbons, especially in cases of carbon leakage.42 It is important to consider the risks of leakage during CO2 transportation. The study aimed to evaluate the environmental tracers at a site where soil gas source and migration evaluation is complicated by the presence of multiple methane sources and a complex geological setting. For example, this testing could be used to fingerprint and identify fugitive methane emissions found between a landfill and a refinery.\n\nThe Kerfoot study collected data in the studied areas using gas probes. Since the decomposition of organic matter produces methane and carbon dioxide, the relative concentrations and stable and radiogenic isotope composition can help track methane migration and detect changes in the gas composition and the source of methane. The study found dramatic differences in gas composition only in the transect. The study concluded that 37% of the methane measured was sourced from the landfill biogas, highlighting how dramatically the radiocarbon value of methane can vary at a single site for both concentration and the biogenic portion.43 This study highlights the need for constant monitoring, especially for projects close to oil/gas pipelines, and/or other sources of contamination, and during the\n\n38\n2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes.” EPA\n39\n2026. “Final Renewable Fuel Standards for 2026 and 2027.” EPA\n40\n2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission\n41\n2022. “Large-Scale Consolidated Methodology: Alternative Waste Treatment Version 3.0” UNFCCC\n42\n2013. Kerfoot et al, “Evaluation of the age of landfill gas methane in landfill gas-natural gas mixtures using co-occurring constituents,” Environ.\nSci Processes, 15, 1153-1161\n43\n2013. Kerfoot et al, “Evaluation of the age of landfill gas methane in landfill gas-natural gas mixtures using co-occurring constituents,” Environ.\nSci Processes\n\nPage 6\ntransportation of CO2 to detect potential leaks and to accurately determine the biogenic portion of carbon dioxide removed from the atmosphere.\n\nBiogenic Carbon Capture and Storage (BECCS) & Biomass-Based Carbon Dioxide Removal (CDR)\nWhile this consultation is not focused on renewable emissions in the context of Biogenic Carbon Capture and Storage (BECCS) or Carbon Dioxide Removal (CDR), we recommend that any future consideration of these activities under the NGER should require direct Carbon-14 testing. Direct testing using radiocarbon analysis is the only reliable way to guarantee that a given sample of CO₂ contains the biogenic content claimed. There is a long, successful track record of Carbon-14 testing requirements enabling emissions reduction programs, as well as clean fuel standards, to verify producers’ claims of biogenic content pre- and post-combustion.\n\nWhile CCUS regulations are in an early stage globally, there are already several programs requiring direct testing to verify biogenic CO₂ captured. One example is Alberta’s draft TIERS Quantification Protocol for\nCO₂ Capture and Permanent Geological Storage.44 Under the draft protocol published, direct C14 testing using the ASTM D6866 is required to report the biogenic content of CO₂ captured. Testing is required at least every 3 months if the biogenic CO2 is within a mixed stream, or every 2 years if the biogenic CO2 is not within a mixed stream.\n\nAnother key regulation to consider is the EU’s Carbon Removal and Carbon Farming Regulation (CRCF), which specifically differentiates between biogenic and fossil CO2 capture and relies on the ETS requirements and requires biomass to reflect the same sustainability criteria as the EU RED, the requirements for which are discussed above.45 The CRCF further relies on the EU ETS requirements to quantify the biogenic portion of CO2 captured, which lists C14 testing as one of the options to do so. The\nCRCF Regulation builds on the EU’s Regulation 2022/996 on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria. Article 14 of this regulation requires auditors to “verify that the estimate of emissions savings from capture and replacement of CO₂ is limited to emissions avoided through the capture of CO₂, of which the carbon originates from biomass and which is used to replace fossil-derived CO₂.”46 Direct test results are included in the required information on the origin of the CO₂ that is captured and the origin of the CO₂ that is replaced by biomass. This is a strong example to consider in this rulemaking because it provides an existing model for biogenic CO₂ capture and storage, which also relies on routine testing to verify claims.\n\nAnother important rule to consider is the US EPA’s standards for fossil-fired power plants passed in 2024, which included landmark requirements for CCUS as the best system of emissions reduction (BSER) for\n\n44\n2024. “Draft Quantification Protocol for CO2 Capture and Permanent Geologic Sequestration.” Government of Alberta\n45\n2024. “Certification for Carbon Removals and Carbon Farming.” European Commission\n46\n2022. “Commission Implementing Regulation (EU) 2022/996 of June 14, 2022 on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria.” Official Journal of the European Union\n\nPage 7\nfossil-fired plants which plan on continuing to operate long-term.47 Under this BSER any biogenic content involved in CCUS at these plants will be required to submit quarterly biogenic testing as evidence under the EPA’s Greenhouse Gas Reporting Program (GHGRP). We recommend that California incorporate the same requirements for any biogenic CO₂ seeking recognition under a potential CCUS tax credit. The EPA has over a decade of experience with Carbon-14 testing requirements from the GHGRP and intentionally relied on this testing for a significant role in this major emissions reduction program, which would be its first attempt at regulating biogenic CO₂ for CCUS. While this program is among those targeted by the new administration’s deregulation of the EPA, CARB’s mandatory emissions reporting program is a great opportunity to take advantage of this strategy for facilities in California.\n\nThere are also several prominent third-party certification standards which have set the precedent for requiring direct Carbon-14 test results to claim the biogenic portion of captured emissions. First is\nPuro.Earth’s Geologically Stored Carbon Standard, which requires C-14 results for any biogenic CO2 claims.48 Verra’s VT0013 Standard on Differentiating Reductions and Removals in CCS Projects recently added C-14 testing for BECCS in an approach similar to Isometric’s standard, providing the option to choose direct testing or calculations.49 Isometric’s BCCS v1.3 protocol follows the same approach as Verra for co-firing, allowing operators to report using C-14 results or calculations, but any biogenic content from waste feedstocks must be reported by direct C-14 testing.50 One other major verifier to consider is\nCarbonDirect’s High Quality Criteria for Bio-CDR Removals, which was created in partnership with\nMicrosoft, currently the largest purchaser of biogenic removal credits.51 Their criteria include Carbon-14 testing as the best practice for reporting the biogenic portion of CO2 under any relevant standards.\n\nFor BECCS and biomass CDR projects, biogenic testing following ASTM D6866 should be required at least quarterly to demonstrate the renewable carbon reported. This is in line with the established requirements for emissions reporting and fuel decarbonization programs discussed above, notably including Alberta’s protocol for bioenergy CCUS.\n\nNever Rely Exclusively on Mass Balance for Quantification of Biogenic Content\nIt is critical the NGER Scheme should always rely on direct measurements for biogenic content under this program, rather than recognize any mass balance calculations for biogenic claims. Producers and industry lobbying groups continue to promote calculation-based approaches such as mass balance because they enable facilities to make claims solely based on material inputs in production. These calculations allow producers to assume that all of their biomass inputs end up in their facilities’ outputs,\n\n47\n2024. “40 CFR Part 60- New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil\nFuel-Fired Electric Generating Units” Environmental Protection Agency\n48\n2024. “Geologically Stored Carbon: Methodology for CO2 Removal.” Puro.Earth\n49\n2025. “VT0013 Differentiating Reductions and Removals in CCS Projects.” Verra\n50\n2025. “Biogenic Carbon Capture and Storage Protocol v1.3” Isometric\n51\n2025. “Biomass Carbon Removal and Storage.” CarbonDirect\n\nPage 8\ndespite it being well understood in the industry that the input of renewable feedstocks is not the same as the output because performance varies and renewable feedstocks don’t produce the same quantity of material as their fossil counterparts.52 By basing their calculations solely on production inputs rather than outputs these methods systematically over-report the renewable share of fuels.\n\nCalculation-based approaches also use a system of free allocation, meaning they do not have to guarantee that there is any renewable content in a given fuel. Producers prefer this because if 10% of their feedstocks are biogenic they can claim that 10% of their products are biogenic, even if that's not the case because biobased can go in different amounts to different products in the co-process. Even further, book and claim also allows them to claim that 10% of their products are 100% biogenic and the rest are 0%, even if all of the products should be 10% biogenic based on calculations (and would likely\nC14 test below that).53\n\nThese calculations’ reliance on free allocation creates the potential for double counting of renewable content, leaving low-carbon fuel programs susceptible to a high risk of greenwashing and fraud. For example, this threat is highlighted by the recent mass balance fraud challenges faced by the ISCC regarding fraudulent biodiesel submissions from China which “caused a dramatic fall in biodiesel prices in European markets” in July 2023.54 In response to this situation, the EU quickly updated the RED’s co-processing rules to uniformly require direct testing, including verifying the calculations of producers choosing to use calculation-based approaches.55\n\nThe importance of limiting the role of mass balance for reporting the biogenic content of fuels is articulated very well by a recent opinion of the Advocate General of the EU Court of Justice (CJEU) on the roles of mass balance and C-14 for reporting biogenic content in co-processing. The official opinion found that mass balance calculations are not intended to quantify the share of biogenic contained in a biofuel produced by co-processing.56 The opinion was reiterated in the final ruling of the case which differentiates between determining the sustainable criteria for biofuels (mass-balance) and determining the share of biogenic carbon (C14 testing).57 This judgment was issued in response to a case brought by\nBP France against the French government regarding a tax incentive requiring C-14 testing to verify claims of renewable content. BP is also notably a board member of the ISCC.58\n\n52\n2006. “Determining the modern carbon content of biobased products using radiocarbon analysis.” Bioresource Technology, 97(16), 2084-2090.\n53\n2024. “The Mass Balance Approach.” International Sustainability & Carbon Certification\n54\n2023. “ISCC Press Release July 27, 2023.” International Sustainability & Carbon Certification\n55\n2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission\n56\n2024. “Opinion of Advocate General Campos Sánches-Bordona Delivered on 11 January 2024: Case C‑624/22.” Court of Justice of the European\nUnion\n57\n2024. “Judgement of the Court (Third Chamber) of 29 July 2024.” Court of Justice of the European Union\n58\n2024. “Board Members of the ISCC Association.” International Sustainability & Carbon Certification\n\nPage 9\nRecently in the US issues with mass balance in the recycling industry have received increasing attention.\nA ProPublica investigation published in June 2024 that products advertised as 30% recycled through mass balance often contained less than 1% recycled content.59 Similar concerns were shown by the US\nEPA as early as 2023, which described the mass-balance methodology as deceptive and advised against promoting it. In August 2024, the US Environmental Protection Agency (EPA) launched a federal action against the mass-balance methodology used in the recycling sector.\n\nIn September 2024, California Attorney General Rob Bonta filed a lawsuit against ExxonMobil claiming that the oil major “deceptively” promoted chemical recycling as a solution to the plastic crisis, citing their use of mass balance calculations such as ISCC Plus.60 That lawsuit directly challenges the standard’s use of ISCC’s free allocation method as a system designed to enable greenwashing.61 The New York Times also recently published a relevant article on the challenges that mass balance presents to the recycling industry, which aligns with the challenges experienced in the renewable products industry.62 Recently, the ACC dropped a separate lawsuit against the state of Colorado for limiting the use of mass balance in recycling reporting as well.63\n\nRelying on mass balance rather than direct testing would also be prohibitive to small businesses seeking to take advantage of opportunities in the renewable fuel and emissions markets. In terms of costs, ISCC certification requires thousands of dollars in membership fees, annual fees, and members must then hire their own independent auditors to check their facilities.64 ASTM D6866 testing costs a one-time charge between $300 and $500, depending on your choice of laboratory, which has helped to make it an efficient tool for quarterly reporting under these established programs.\n\nIt is in the best interest of Australia’s decarbonization goals not to allow any producers to report their biogenic content using mass balance calculations. However, if mass balance is used at all in this methodology, it is critical that these calculations be routinely verified by direct testing. The advantage of the updated RED protocol is that producers can choose to use calculations internally, while the program still ensures the information reported is accurate through direct Carbon-14 analysis. This is the only way to mitigate the risk to the program introduced by these calculations.\n\nWhat is Biogenic Testing (Carbon-14)?\nCarbon-14 analysis is a reliable method used to distinguish the percentage of biobased carbon content in a given material. The radioactive isotope carbon-14 is present in all living organisms and recently expired\n\n59\n2024. “Biden EPA Rejects Plastics Industry’s Fuzzy Math That Misleads Customers About Recycled Content.” ProPublica\n60\n2024. “The People of the State of California v. Exxon Mobil Corporation.” Superior Court of the State of California\n61\n2024. “ExxonMobil Accused of “Deceptively” Promoting Chemical Recycling as a Solution for the Plastics Crisis.” ProPublica\n62\n2024. “Is Your Water Bottle Really Made From Recycled Plastic?” The New York Times\n63\n2026. “Colorado Mass Balance Debate Underscores Industry Faultlines.” Waste Dive\n64\n2024. “The Mass Balance Approach.” International Sustainability & Carbon Certification\n\nPage 10\nmaterial, whereas any fossil-based material that is more than 50,000 years old does not contain any carbon-14 content. Since Carbon-14 is radioactive, the amount of carbon-14 present in a given sample begins to gradually decay after the death of an organism until there is no carbon-14 left. Therefore, a radiocarbon dating laboratory can use carbon-14 analysis to quantify the carbon-14 content present in a sample, determining whether the sample is biomass-based, fossil fuel-derived, or a combination.\n\nThe analysis is based on standards such as ASTM D6866 and its international equivalents developed for specific end uses, such as ISO 13833. ASTM D6866 is an international standard developed for measuring the biobased carbon content of solid, liquid, and gaseous samples using radiocarbon dating.65 There are also many international standards based on the specific use of direct Carbon-14 testing, such as ISO\n13833, which is an international standard developed for measuring the biogenic carbon content of stationary sources emissions.66\n\nCarbon-14 analysis yields a result reported as % biobased carbon content. If the result is 100% biobased carbon, this indicates that the sample tested is completely sourced from biomass material such as plant or animal byproducts. A result of 0% biobased carbon means a sample is only fossil fuel-derived. A sample that is a mix of both biomass sources and fossil fuel sources will yield a result that ranges between 0% and 100% biobased carbon content. Carbon-14 testing has been incorporated into several regulations as the recommended or required method to quantify the biobased content of a given material.\n\nASTM D6866 Method B - The Most Reliable Method\nCarbon-14 is a very well-established method which has been in use by many industries (including the fossil fuel industry) and academic researchers for several decades.\n\nCarbon-14 measurements done by commercial third party testing is robust, consistent, and with quantifiable accuracy/precision of the carbon-14 amount under ASTM D6866 method B. The EN 16785 is the only standard that allows a variant of the Mass Balance (MB) method of ‘carbon counting’ under EN\n16785-2. The EN 16785-1 requires that the biocarbon fraction be determined by the carbon-14 method.\nHowever, when incorporating this EN 16785 method, certification schemes like the “Single European\nBio-based Content Certification” only allow the use of EN 16785-1 due to its reliability and the value of a third-party certification. http://www.biobasedcontent.eu/en/about-us/\n\nIn ASTM D6866 method B, the carbon-14 result is provided as a single numerical result of\n\n65\n2021. “Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis.”\nASTM International (D6866-21)\n66\n2013. “ISO 13833:2013 Stationary source emissions: Determination of the ratio of biomass (biogenic) and fossil-derived carbon dioxide.”\nInternational Organization for Standardization\n\nPage 11\ncarbon-14 activity, with graphical representation that is easily understood by regulators, policy makers, corporate officers, and more importantly, the public. The overwhelming advantage of carbon-14 is that it is an independent and standardized laboratory measurement of any carbon containing substance that produces highly accurate and precise values. In that regard, it can stand alone as a quantitative indicator of the presence of biobased vs. petroleum feedstocks. When carbon-14 test results are challenged, samples can be rapidly remeasured to verify the original reported values (unlike mass balance).\n\nThe quantification of the biobased content of a given product can be as low as 0.1% to 0.5% (1 relative standard deviation – RSD) based on Instrumental error for Method B (AMS). This error is exclusive of indeterminate sources of error in the origin of the biobased content, and manufacturing processes. As such a total error of +/-3% (absolute) has been assigned to the reported Biobased\nContent to account for determinate and indeterminate factors.67\n\nIt is also important that the program should always require ASTM D6866 Method B, rather than allow\nMethod C for any use. Where ASTM D6866 Method B uses the AMS Instrument to measure 14C, Method\nC uses Liquid Scintillation Counting (LSC). In Method B, the AMS Instrument directly measures the 14C isotopes. However, in Method C, scintillation molecules indirectly absorb the beta molecules that release with the decay of 14C and convert the energy into photons which are measured proportionally to the amount of 14C in the sample. Since Method B directly measures the 14C isotopes and Method C measures them indirectly, Method B is significantly more precise and should be prioritized in regulations.68 LSC measurements, like those used in Method C, are commonly used as an internal testing tool when samples are limited and accuracy does not need to be extremely high.\n\nAbout Beta Analytic\n\nBeta Analytic was among the originators of the use of Accelerator Mass Spectrometry (AMS) for the\nASTM D6866 biobased / biogenic testing standard using Carbon-14 to distinguish renewable carbon sources from petroleum sources. Beta began testing renewable content in 2003 at the request of United\nStates Department of Agriculture (USDA) representatives who were interested in Beta’s Carbon-14 capabilities for their BioPreferredⓇ Program (www.biopreferred.gov). At their request, Beta joined ASTM under subcommittee D20.96. Beta’s previous president, Darden Hood, was positioned as a technical contact for the USDA and within 3 months completed the ASTM D6866-04 standard. The Carbon-14 technique is now standardized in a host of international standards including ASTM D6866, CEN 16137,\nEN 16640, ISO 16620, ISO 19984, BS EN ISO 21644:2021, ISO 13833 and EN 16785. Carbon-14 analysis\n\n67\n2021. Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis. ASTM\nInternational (D6866-21). pp 1-19. doi: 10.1520/D6866-21.\n68\n2022. “Testing the methods for determination of radiocarbon content in liquid fuels in the Gliwice Radiocarbon and Mass Spectrometry\nLaboratory.” Radiocarbon\n\nPage 12\ncan be used on various types of samples (gas, liquids and solids). Beta Analytic continues to be a technical contact for ASTM D6866 with current president Ron Hatfield and is involved with all their latest\nASTM D6866 versions.\n\nThe Carbon-14 standardized method is also incorporated in a variety of regulatory programs including the California AB32 program, US EPA GHG Protocol, US EPA Renewable Fuels Standard, United Nations\nCarbon Development Mechanism, Western Climate Initiative, Climate Registry’s Greenhouse Gas\nReporting Protocol and EU Emissions Trading Scheme.\n\nWe are currently technical experts on Carbon-14 in the following committees:\n\nASTM D6866 (D20.96) Plastics and Biobased Products (Technical Advisor)\nASTM (D02.04) Petroleum Products, Liquid Fuels and Lubricants (Technical Advisor)\nASTM (061) US TAG to ISO/TC 61 Plastics (Technical Expert)\nUSDA BioPreferred Program TAC (Technical Advisor)\nISO/TC 61/SC14/WG1 Terminology, classifications, and general guidance (Technical Expert)\nCEN/TC 411 Biobased Products\nCEN/TC 411/WG 3 Biobased content\nCEN/TC 61/SC 14/WG 1 Terminology, classifications, and general guidance (Technical Expert)\n\nISO/IEC 17025:2017 Accredited Laboratory\nTo ensure the highest level of quality, laboratories performing ASTM D6866 testing should be ISO/IEC\n17025:2017 accredited or higher. This accreditation is unbiased, third party awarded and supervised. It is unique to laboratories that not only have a quality management program conformant to the ISO\n9001:2008 standard, but more importantly, have demonstrated to an outside third-party laboratory accreditation body that Beta Analytic has the technical competency necessary to consistently deliver technically valid test results. The ISO 17025 accreditation is specifically for natural level radiocarbon activity measurements including biobased analysis of consumer products and fuels, and for radiocarbon dating.\n\nRequired tracer-free facility for Carbon-14\nFor carbon-14 measurement to work, be accurate, and repeatable, the facility needs to be a tracer-free facility, which means artificial/labeled carbon-14 is not and has never been handled in that lab. Facilities that handle artificial carbon-14 use enormous levels relative to natural levels and it becomes ubiquitous in the facility and cross contamination within the facility, equipment and chemistry lines is unavoidable.\nResults from a facility that handles artificial carbon-14 would show elevated renewable contents (higher pMC, % Biobased / Biogenic values), making those results invalid. Because of this, Federal contracts and agency programs (such as the USDA BioPreferred Program) require that AMS laboratories must be 14C tracer-free facilities in order to be considered for participation in solicitations.\n\nPage 13\nAreas where cross-contamination might occur include but are not limited to; biomedical or nuclear reactors, isotope enrichment / depletion columns, water, soil, plant, or air samples collected near or at biomedical / nuclear reactor sites, medical, industrial, or hazardous waste sites, samples specifically manipulated to study the uptake / fractionation of stable isotopes due to biological or metabolic processes. To learn more about the risks associated with testing natural levels Carbon-14 samples in a facility handling artificially enhanced isotopes please see the additional information provided after this comment.\n\nReferences\n2006. “Determining the modern carbon content of biobased products using radiocarbon analysis.” Bioresource\nTechnology, 97(16), 2084-2090.\n\n2010. “40 CFR Part 80 Subpart M– Renewable Fuel Standard.” National Archives Code of Federal Regulations https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-80/subpart-M\n\n2013. Kerfoot et al, “Evaluation of the age of landfill gas methane in landfill gas-natural gas mixtures using co-occurring constituents,” Environ. Sci Processes, 15, 1153-1161\n\n2013. “ISO 13833:2013 Stationary source emissions: Determination of the ratio of biomass (biogenic) and fossil-derived carbon dioxide.” International Organization for Standardization\n\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” National Archives Code of Federal\nRegulations https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-C\n\n2016. “Standard Practice for Collection of Integrated Samples for the Speciation of Biomass (Biogenic) and\nFossil-Derived Carbon Dioxide Emitted from Stationary Emissions Sources.” ASTM International (D7459-08). doi:\n10.1520/D7459-08R16\n\n2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” California Air Resources Board https://ww2.arb.ca.gov/sites/default/files/classic/cc/reporting/ghg-rep/regulation/subpart_c_rule_part98.pdf\n\n2020. “Reporting Co-Processing and Renewable Gasoline Emissions Under MRR.” California Air Resources Board https://ww2.arb.ca.gov/sites/default/files/2020-09/MRR_coprocessing-slides_Sept_2020.pdf\n\n2020. “Guideline for Quantification, Reporting and Verification of Greenhouse Gas Emissions.” Ontario Ministry of the Environment, Conservation and Parks https://www.ontariocanada.com/registry/showAttachment.do?postingId=30247&attachmentId=42676\n\n2021. “UK ETS: Monitoring and Reporting Biomass in Installations.” UK Department for Business, Energy and\nIndustrial Strategy https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1033859/uk-e ts-monitoring-reporting-biomass-installations.pdf\n\nPage 14\n2021. “Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using\nRadiocarbon Analysis.” ASTM International (D6866-21). pp 1-19. doi: 10.1520/D6866-21.\n\n2022. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada https://publications.gc.ca/collections/collection_2023/eccc/En81-28-2022-eng.pdf\n\n2022. “Clean Fuel Regulations: Quantification Method for Co-Processing in Refineries.” Environment and Climate\nChange Canada https://www.canada.ca/en/environment-climate-change/services/managing-pollution/energy-production/fuel-reg ulations/clean-fuel-regulations/compliance/quantification-methodco-processing-refineries.html\n\n2022. “Chapter 173-424 WAC: Clean Fuels Program Rule.” Washington State Legislature https://app.leg.wa.gov/WAC/default.aspx?cite=173-424&full=true\n\n2022. “Biomass issues in the EU ETS.” European Commission https://climate.ec.europa.eu/system/files/2022-10/gd3_biomass_issues_en.pdf\n\n2022. “Commission Implementing Regulation (EU) 2022/996 of June 14, 2022 on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria.” Official Journal of the\nEuropean Union https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0996\n\n2022. “Large-Scale Consolidated Methodology: Alternative Waste Treatment Version 3.0” United Nations\nFramework Convention on Climate Change.\nhttps://cdm.unfccc.int/UserManagement/FileStorage/61X9DPNL7G4Y5JMB3CKFHUSREO2QVI\n\n2022. “Testing the methods for determination of radiocarbon content in liquid fuels in the Gliwice Radiocarbon and\nMass Spectrometry Laboratory.” Radiocarbon, 64(6), pp.1-10. DOI:10.1017/RDC.2022.35\n\n2023. “RR:D02-2052.” ASTM International https://www.astm.org/rr-d02-2052.html\n\n2023. “Oregon Clean Fuels Program.” Oregon Department of Environmental Quality https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=1560\n\n2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European\nCommission https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12711-Renewable-energy-m ethod-for-calculating-the-share-of-renewables-in-the-case-of-co-processing_en\n\n2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other\nChanges.” Environmental Protection Agency https://www.govinfo.gov/content/pkg/FR-2023-07-12/pdf/2023-13462.pdf\n\n2023. “ISCC Press Release July 27, 2023.” International Sustainability & Carbon Certification https://www.iscc-system.org/news/press-release-27-july-2023/\n\n2024. “40 CFR Part 60- New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and\nReconstructed Fossil Fuel-Fired Electric Generating Units” Environmental Protection Agency\n\nPage 15\nhttps://www.federalregister.gov/documents/2024/05/09/2024-09233/new-source-performance-standards-for-gre enhouse-gas-emissions-from-new-modified-and-reconstructed\n\n2024. “Draft Quantification Protocol for CO2 Capture and Permanent Geologic Sequestration.” Government of\nAlberta https://www.alberta.ca/system/files/epa-draft-quantification-protocol-co2-capture-and-permanent-geologic-seque stration-v2.pdf\n\n2024. “Certification for Carbon Removals and Carbon Farming.” European Commission https://eur-lex.europa.eu/EN/legal-content/summary/establishing-a-union-certification-framework-for-permanent- carbon-removals-carbon-farming-and-carbon-storage-in-products.html\n\n2024. “Geologically Stored Carbon: Methodology for CO2 Removal.” Puro.Earth https://7518557.fs1.hubspotusercontent-na1.net/hubfs/7518557/Supplier%20Documents/Puro_Geologically_Stor ed_Carbon_Methodology.pdf\n\n2024. “Biden EPA Rejects Plastics Industry’s Fuzzy Math That Misleads Customers About Recycled Content.”\nProPublica https://www.propublica.org/article/epa-rejects-mass-balance-plastics-recycling-safer-choice\n\n2024. “ExxonMobil Accused of “Deceptively” Promoting Chemical Recycling as a Solution for the Plastics Crisis.”\nProPublica https://www.propublica.org/article/exxonmobil-plastics-recycling-pyrolysis-lawsuit-california\n\n2024. “The People of the State of California v. Exxon Mobil Corporation.” Superior Court of the State of California https://oag.ca.gov/system/files/attachments/press-docs/Complaint_People%20v.%20Exxon%20Mobil%20et%20al.\npdf\n\n2024. “Is Your Water Bottle Really Made From Recycled Plastic?” The New York Times https://www.nytimes.com/2024/08/26/business/energy-environment/tritan-renew-plastic-bottles-recycled.html?u nlocked_article_code=1.F04.bY6M.-T_BnLuNxj6i&smid=url-share\n\n2024. “The Mass Balance Approach.” International Sustainability & Carbon Certification https://www.iscc-system.org/news/mass-balance-explained/#:~:text=Mass%20balance%20provides%20manufactu rers%20with,production%20process%20through%20certified%20bookkeeping.\n\n2024. “Opinion of Advocate General Campos Sánches-Bordona Delivered on 11 January 2024: Case C‑624/22.”\nCourt of Justice of the European Union https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:62022CC0624#Footnote1\n\n2024. “Judgement of the Court (Third Chamber) of 29 July 2024.” Court of Justice of the European Union https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62022CJ0624&qid=1736867604637\n\n2024. “Board Members of the ISCC Association.” International Sustainability & Carbon Certification https://www.iscc-system.org/governance/iscc-association/board/\n\n2025. “Criteria for High-Quality Carbon Dioxide Removal.” Carbon Direct https://www.carbon-direct.com/criteria/2025-edition/biomass-carbon-removal-and-storage\n\nPage 16\n2025. “VT0013 Differentiating Reductions and Removals in CCS Projects.” Verra https://verra.org/wp-content/uploads/2025/04/VT0013-Differentiating-Reductions-and-Removals-in-CCS-Projects- final-publication.pdf\n\n2025. “Biogenic Carbon Capture and Storage Protocol v1.3” Isometric https://registry.isometric.com/protocol/biogenic-capture-and-storage/1.3\n\n2025. “Commission concludes examination of potential Chinese biofuel imports fraud.” European Commission https://energy.ec.europa.eu/news/commission-concludes-examination-potential-chinese-biofuel-imports-fraud-20\n25-07-18_en\n\n2025. “German biofuels regulator links two companies to certification fraud.” S&P Global https://www.spglobal.com/energy/en/news-research/latest-news/crude-oil/050725-german-biofuels-regulator-link s-two-companies-to-certification-fraud\n\n2026. “Final Renewable Fuel Standards for 2026 and 2027.” EPA https://www.epa.gov/renewable-fuel-standard/final-renewable-fuel-standards-2026-and-2027\n\n2026. “Colorado Mass Balance Debate Underscores Industry Faultlines.” Waste Dive https://www.wastedive.com/news/colorado-mass-balance-lawsuit-epr-plans\n\nPage 17\nDemand a Tracer-Free Laboratory\nfor Radiocarbon Dating\nAs part of its commitment to provide high-quality results to its clients, ISO/IEC\n17025-accredited Beta Analytic does not accept pharmaceutical samples with\n“tracer Carbon-14” or any other material containing artificial Carbon-14 (14C) to\neliminate the risk of cross-contamination. Moreover, the lab does not engage in\n“satellite dating” – the practice of preparing individual sample graphite in a remote\nchemistry lab and then subcontracting an AMS facility for the result.\n\nHigh Risk of Cross-Contamination Avoid the Risks\nPharmaceutical companies evaluate drug metabolism Find out from the lab that you are planning to use that by using a radiolabeled version of the drug under they have never in the past and will never in the investigation. AMS biomedical laboratories use 14C future: as a tracer because it can easily substitute 12C atoms\n- accept, handle, graphitize or AMS count samples in the drug molecule, and it is relatively safe to\ncontaining Tracer or Labeled (Hot) 14C.\nhandle. Tracer 14C is a well-known transmittable contaminant to radiocarbon samples, both within the\n- share any laboratory space, equipment, or\nAMS equipment and within the chemistry lab.\npersonnel with anyone preparing (pretreating,\ncombusting, acidifying, or graphitizing) samples that\nSince the artificial 14C used in these studies is\ncontain Tracer or Labeled (Hot) 14C.\nphenomenally high (enormous) relative to natural levels, once used in an AMS laboratory it becomes\n- use AMS Counting Systems (including any and all ubiquitous. Cross-contamination within the AMS and\nbeam-line components) for the measurement of the chemistry lines cannot be avoided. Although the\nsamples that contain Tracer or Labeled (Hot) 14C.\nlevels of contamination are acceptable in a biomedical\nAMS facility, it is not acceptable in a radiocarbon dating facility.\nTracer-Free Lab Required\nBiomedical AMS facilities routinely measure tracer-level, labeled (Hot) 14C samples that are Recently, federal contracts are beginning to specify hundreds to tens of thousands of times above the that AMS laboratories must be 14C tracer-free natural 14C levels found in archaeological, geological, facilities in order to be considered for participation in and hydrological samples. Because the 14C content solicitations.\nfrom the biomedical samples is so high, even sharing personnel will pose a contamination risk; “Persons A solicitation for the National Oceanic and from hot labs should not enter the natural labs and Atmospheric Administration (NOAA) has indicated vice versa” (Zermeño et al. 2004, pg. 294). These two that “the AMS Facility utilized by the Contractor for operations should be absolutely separate. Sharing the analysis of the micro-samples specified must be a personnel, machines, or chemistry lines run the risk of 14C tracer-level-free facility.” (Solicitation Number: contaminating natural level 14C archaeological, WE-133F-14-RQ-0827 - Agency: Department of geological, and hydrological samples. Commerce)\n\nAs a natural level radiocarbon laboratory, we highly\nrecommend that researchers require the AMS lab\nprocessing their samples to be Tracer-free.\nNo Exposure to Artificial Carbon-14 Useful Reference\nAccording to ASTM International, the ASTM D6866 1. Memory effects in an AMS system: Catastrophe standard is applicable to laboratories working without and Recovery. J. S. Vogel, J.R. Southon, D.E.\nexposure to artificial carbon-14 routinely used in biomed- Nelson. Radiocarbon, Vol 32, No. 1, 1990, p. 81-83 ical studies. Artificial carbon-14 can exist within the doi:10.2458/azu_js_rc.32.1252 (Open Access) laboratory at levels 1,000 times or more than 100 % biobased materials and 100,000 times more than 1% “... we certainly do not advocate processing both biobased materials. Once in the laboratory, artificial 14C labeled and natural samples in the same chemical can become undetectably ubiquitous on materials and laboratory.” “The long term consequences are other surfaces but which may randomly contaminate an likely to be disastrous.” unknown sample producing inaccurately high biobased 2. Recovery from tracer contamination in AMS results. Despite vigorous attempts to clean up contami- sample preparation. A. J. T. Jull, D. J. Donahue, L.\nnating artificial 14C from a laboratory, isolation has\nJ. Toolin. Radiocarbon, Vol. 32, No.1, 1990, p.\nproven to be the only successful method of avoidance.\n84-85 doi:10.2458/azu_js_rc.32.1253 (Open\nCompletely separate chemical laboratories and extreme\nAccess) measures for detection validation are required from laboratories exposed to artificial 14C. Accepted require- “... tracer 14C should not be allowed in a ments are: radiocarbon laboratory.” “Despite vigorous recent\nefforts to clean up the room, the “blanks” we\n(1) disclosure to clients that the laboratory working with measured had 14C contents equivalent to modern their products and materials also works with artificial 14C or even post ‐bomb levels.”\n(2) chemical laboratories in separate buildings for the handling of artificial 14C and biobased samples 3. Prevention and removal of elevated radiocarbon\n(3) separate personnel who do not enter the buildings of contamination in the LLNL/CAMS natural the other radiocarbon sample preparation laboratory.\n(4) no sharing of common areas such as lunch rooms and Zermeño, et. al. Nuclear Instruments and Methods offices in Physics Research Section B: Beam Interactions\n(5) no sharing of supplies or chemicals between the two with Materials and Atoms\n(6) quasi-simultaneous quality assurance measurements Vol. 223-224, 2004, p. 293-297 within the detector validating the absence of contamina- doi: 10.1016/j.nimb.2004.04.058 tion within the detector itself.\n“The presence of elevated 14C contamination in a\nlaboratory preparing samples for natural\nASTM D6866-22 – Standard Test Methods for Determin-\nradiocarbon analysis is detrimental to the ing the Biobased Content of Solid, Liquid, and Gaseous\nlaboratory workspace as well as the research\nSamples Using Radiocarbon Analysis.\nbeing conducted.”\n\n4. High level 14C contamination and recovery at\nXIʼAN AMS center. Zhou, et. al. Radiocarbon, Vol\n54, No. 2, 2012, p. 187-193\ndoi:10.2458/azu_js_rc.54.16045\n\n“Samples that contain high concentrations of\nradiocarbon (“hot” samples) are a catastrophe for\nlow background AMS laboratories.” “In our case\nthe ion source system was seriously contaminated,\nas were the preparation lines.”\n\nwww.radiocarbon.com","size":3198466,"redacted":[],"meta":{"name":"Australia_NGER_Update_2026_Comment_Beta.4332f1ef.pdf","mime_type":"application/pdf","transcribe_error":null,"transcribe_status":null,"transcribe_queued_at":null,"transcribe_started_at":null},"config":{}}}}}