INFO SHEET & EPA-REGION »
BOSTON
MOBILE SOURCE ENFORCEMENT PROGRAM
TOLL-FREE HOTLINE: 1-800-821-1237
In six New England States: Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island and Vermont
Since the Mid 1980's, the U.S. Environmental Protection Agency Region I office.
located in Boston, has been actively performing mobile source enforcement
inspections and investigations.
Field work is the responsibility of EPA inspectors in the Technical
Assistance Section, a unit within the Air, Pesticides & Toxics Management
Division, and a Clean Air Counselor, provided through a contract
between EPA and the American Association of Retired Persons (AARP).
The program involves the inspection of service stations, repair
shops, automobile dealerships, and fleet operations, and even individuals for
compliance with EPA's anti-tampering prohibition and fuel regulations.
Inspections are conducted to collect evidence related to possible violations
involving removal or tampering with emission control equipment on vehicles and
possible fuels violations involving vapor pressure, alcohol and lead content of
gasoline, introduction of leaded fuel into vehicles requiring unleaded
fuel, and undersized nozzles on leaded gasoline pumps, which allows
"misfueling" of leaded gasoline intounleaded gasoline vehicles.
Violations identified through these inspections are referred to EPA's Field Office
and Support Division (FOSD) in Washington. DC for enforcement follow-up.
Region I's program compliments FOSD's existing nationwide inspection program,
allowing EPA to provide quicker response time to reported violations and overall
increased inspection coverage in the region. Region I includes the six state New
England area.
Sites for inspection are determined based on records of previous violations,
random selection, and complaints received via a widely publicized toll-free
hotline established by the Region I office. Records show that the on-going
presence of EPA inspectors in the field is acting as a deterrent against tampering
and other mobile source violations. Region I sends violations on a regular basis
.o FOSD for enforcement action.
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The hotline may be contacted regarding other automotive issues and other
mobile sources of air pollution, among others these include: automotive imports,
auto emission testing, emission control device warranties, CFC (freon) recycling and
recovery regulations for repair shops and technicians, aftermarket catalytic
converters replacement policy, and.fuels regulations.
Region I also publishes a technical bulletin concerning mobile source issues, called
'Tailpipe". It may be ordered or changes of address made by calling the Hotline toll-
free number: 1-800-821-1237 or by writing the Editor. Molly Magoon at:
U.S. Environmental Protection Agency
Technical Assistance Section (ATA)
J.F.K. Federal Building
Boston, MA 02203 •
OTHER IMPORTANT NUMBERS;
Subject:
on Spills
National Response Center (24 hrs.)
EPA Regional Lab (daytime)
Oil Spill Prevention, Control and Countermeasures
(permits for above ground storage tanks)
Hazardous Wastes (RCRA7 SUPERFUND HOTLINE)
STATE Hazardous Waste Contacts:
CT: (203)566-5712 N.H.: (603)271-2925
ME: (207)289-2651 R.L: (401)277-2797
MA: (617)292-5582 VT: (802)244-8702
Waste Oil
Stationary Air Pollution
(asbestos, incinerators, etc.)
Insecticides
Underground Storage Tanks
Underground Injection
Toxic Substances-
Emergency Planning and Community Right-to-Know
Criminal Investigations
Phone No.
1-800-424-8802
(617) 223-7265
(617) 860-4362
1-800-424-9346
(617) 573-9673
(617) 565-3258
(617) 565-3932
(617) 573-9604
(617) 565-3600
(617) 565-3744
(617) 565-3636
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EPA MOBILE SOURCE TECHNICAL BULLETIN SUMMER 1991
EPA • REGION 1 MOBILE SOURCE AIR POLLUTION HOTLINES:
Inside Massachusetts: —7 "fed094MMMi
Other N.E States: (CT,ME,NH,RI,VT) ^ 1-800-821-1237
IN THIS ISSUE:
TOUGHER EMISSIONS TESTS: Inspection and Maintenance Requirements Changing
PROTECTING THE OZONE LAYER: Federal Law Requires Certification of Both
Motor Vehicle Air Conditioner Technicians and Their CFC Recycling Equipment
TEST PIPES ILLEGAL!!!: Potential Fines Up To $2,500 For Each "Defeat Device" In
Your Facility
FYI: Auto Recall Information, GM President to Speak at Electric Car Symposium,
Gas Saving Tips
NEW CLEAN AIR ACT
The Clean Air Act has once again been
amended. The new amendments were passed
by Congress and signed into law by the Presi-
dent Bush in November of last year. The
amendments are published under the heading,
"An Act... To amend the Clean Air Act to
provide for attainment and maintenance of
health protective national ambient air quality
standards, and for other purposes." The
amendments will change and strengthen the
federal laws made to improve and protect the
quality of the air we breathe.
You can make a difference by learning
about how the new law affects you!
INSPECTION/ MAINTENANCE UPDATE
The Continuing Problem: DIRTY AIR
The Upcoming Solution: New Tests and New
Requirements
The new Clean Air Act includes provisions to
strengthen and expand existing motor vehicle
emission control system testing, inspection and
maintenance (I/M) programs. In 1992, states
must formulate "enhanced" I/M programs
where air quality is poor. Because of the sever-
ity of carbon monoxide and ozone problems in
the northeast, emission control testing and
maintenance programs will now be extended to
cover at least parts of all the New England
states.
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J/M Update front)
More Cars and More Miles Travelled
The evidence of the connection between motor
vehicles and air pollution is compelling. Motor
vehicle emissions account for more than 90% of
the carbon monoxide problem in the U.S., half
of the pollutants that produce ground level
ozone or "smog", and more than half of toxic
air pollutants. Because of this, Congress de-
cided to tighten up emission testing and main-
tenance programs nationally to reduce motor
vehicles' contribution to air pollution. While
car emission control devices perform far better
than they did when they were first introduced,
the plain fact is that there are now many more
cars on the road and those cars are traveling
more miles than in the past The number of
vehicle miles travelled has doubled in the last
two decades.
More States Will Have Programs
While there have been I/M programs for a
number of years in the southern New England
states of Connecticut, Massachusetts and
Rhode Island (state requirement), and for parts
of southern New Hampshire, tougher air
pollution reduction requirements mean that
there will be new I/M programs in Vermont
and Maine.
Residents in the area in and around Burlington,
Vermont, will have to have their cars in-
spected, tested and maintained on a regular
basis. Greater Portland, other parts of southern
Maine and some other urban areas in the Pine
State will be subject to the new requirements
for I/M. The New Hampshire program will be
expanded to cover a larger geographical area in
the southern part of that state.
Defining I/M Program Features
Based on national audits of state I/M programs
by EPA, in order to reach the ultimate goal of
achieving required air pollution reductions,
there is a strong preference for centralized
testing and maintenance programs, unless it
can be demonstrated that a decentralized
program will meet the standard of performance
of a centralized program. Today, the State of
Connecticut in the New England region oper-
ates a centralized program, i.e. vehicle owners
must use a state-managed or contractor oper-
ated central facility network for emission con-
trol equipment testing. Diagnostic information
on appropriate repairs is provided by the
inspection station, but repairs are done at
private garages.
Under the required "enhanced" program,
vehicle inspections must occur on an annual
basis unless states can show that less frequent
inspections will still result in compliance wj
tough new air quality standards. The typio.
means to enforce the inspection requirement
will be denial of vehicle registration.
New Equipment New Costs
Although centralized testing has been shown to
be more cost effective and efficient, states,
which choose states with decentralized pro-
grams will have to devote significant additional
resources to implement the new requirements.
Charging higher inspection fees is the most
likely way to cover the increased costs of the
program. While final federal guidance has not
yet been completed (see below), officials antici-
pate that a dedicated state central computer will
be needed to handle registration and inspection
data.
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I/M Update (cant.)
Facilities performing I/M tests would have to
use newly designed BAR 90 computerized
analyzers linked to a central computer in the
state. These analyzers cost $12,000 to $ 25,000.
Today many decentralized programs are
spending less than a dollar per vehicle for
program administration, and this figure would
increase to somewhere in the neighborhood of
six dollars per vehicle to comply with the
enhanced I/M program requirements. Under a
centralized program, on the other hand, costs
would be only about one or two dollars per
vehicle for program administration.
EPA I/M Guidanc
EPA's policy on what will be required for state
I/M programs is still in the development stage.
A notice will be published soon in the Federal
Register. You can provide your views to the
Agency through your state gasoline dealers'
organization or directly as an individual.
Protecting the Ozone Layer:
Upcoming Certification Program for Both
Technicians and Use of Certified Freon
Refilling and Recycling Equipment
This article discusses the problem of
releases of freon, scientifically called
chloroflurocarbons or CFCs, from motor
vehicle air conditioners during servicing and
new federal regulatory requirements that
attempt to minimize the release of this chemi-
cal. The new requirements will apply to
anyone engaged in the servicing of motor
vehicle air conditioners, also known as
"MACs".
Part of The PROBLEM: CFCs in Auto A/Cs
Freon or chloroflurocarbons (CFCs) are syn-
thetically produced chemicals that are used as
refrigerants for air conditioners, plastic foam
products, cleaning solvents and in aerosols.
Scientists have learned that the earth's protec-
tive stratospheric ozone layer is destroyed by
chemical reaction with freon, allowing more
harmful ultraviolet radiation to hit the earth's
surface. Recent NASA satellite data indicates that
stratospheric ozone depletion is occuring at twice
the rate previously believed. This translates to
200,000 additional skin cancer deaths in the next 50
years in the U.S.
Mobile Air Conditioners ("MACs")
It is estimated that MACs, account for ap-
proximately 21 % of all CFCs used in the
United States. Industry is currently develop-
ing more environmentally safe alternatives to
freon. Until alternatives are available, the
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Auto A/Cs (cont)
training and certification of technicians and the
certification of freon refilling and capture
equipment are the best methods for controlling
the escape of freon from MACs.
New dean Air Act: Part of the Solution
The new Clean Air Act establishes a deadline
of November 15,1991 as the deadline for EPA
to publish standards for the servicing of MACs.
Key deadlines in the new law are the
following:
January 1,1992 - it will be unlawful for anyone
to service MACs without properly using
federally approved and certified CFC refriger-
ant recycling and capture equipment. Techni-
cians performing such work will have to be
properly trained and officially certified.
These requirements will not apply until Janu-
ary 1,1993, at repair shop facilities that repair
and service fewer than 100 MACs air condi-
tioners in the calendar year of 1990.
Effective January 1,1993, all repair shop facili-
ties (including those that were exempted for
one year because they worked on fewer than
100 MACs in calendar year of 1990), must
submit certification of technicians and equip-
ment.
Also, effective on November 15,1992, it will be
unlawful for anyone to sell, distribute, or offer
for sale or distribution into interstate commerce
to anyone other than a certified MAC techni-
cian, any freon refrigerant substance that could
be used in an automotive air conditioner and
that is in a container of less than 20 pounds.
The purpose for this is to reduce CFC emis-
sions by discouraging "do-it-yourself' repairs
on mobile air conditioners.
Certification Requirements
EPA will establish the particulars of these
requirements in the near future. They will
probably include submittal of the name and
address of the person who is being certified and
the serial number of each piece of CFC recycling
and recovery equipment used by the facility and
used by each technician. The equipment certifi-
cation must be signed and attested by the
facility owner or another responsible officer.
Certification can be accomplished by sending
this required information to EPA on a standard-
ized form provided by the manufacturer of the
recycling and recovery equipment.
Technician Training Information Contacts
EPA will also establish technician certification
procedures, which will probably be very similar
to training already being offered privately and
in some states. EPA standards for certification
are due to be published in November 1991.
Until more guidance from EPA is received and
the final regulation is approved in November,
information can be obtained from the following
sources:
International Mobile Air Conditioning Associa-
tion, Inc. (IMACA): 2100 N. Highway 360,
Suite 1300, Grand Prairie, TX 75050;
phone (214) 988^081
Mobile Air Conditioning Society (MACS):
P.O. Box 97, East Greenville, PA 18041; phone
(215) 541-4500
National Institute of Automotive Service Excel-
lence (ASE): 13505 Dulles Technology Drive,
Herdon, VA 22071; phone (703) 742-3800
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Auto AJCs (cont.)
Recycling and Recovery Equipment
The Society of Automotive Engineers (SAE)
has published their standard for the recycle
equipment for MACs, tided "Extraction of
Recycle Equipment for Automotive A/C
Systems" (J1990). Although EPA has not
officially certified any equipment, there are
many companies that are already manufactur-
ing CFC recycling equipment.
Information on the technical standards for
manufacturers can be obtained from:
The Society of Automotive Engineers, Inc.
(SAE): 400 Commonwealth Drive, Warrendale,
PA 15096; phone: (412) 772-7100; which has
also published standards for service practices,
titled "Recommended Service Procedures for
Containment of R-12 (CFC-12y (J1989).
Thinking of Buying a New Car?
You may want consult the 1991 Gas Mileage
Guide (by law required to be displayed in
every car dealership showroom), which gives
EPA's fuel economy estimates:
The Best mileaee:
Geo Metro XFI
Honda Ci vie CRXHF
VWJetta
TheWorst mileage:
Lamborghini Diablo
Rolls Royce
BMW750IL/850I
mpg:
53 city 58Hwy.
49 dry 52Hwy.
37 city 43Hwy.
mpg:
9 city 14Hwy.
10 city 13Hwy.
12 city ISHwy.
FOR YDIJR INFORMATION:
Recent Auto Recalls
05/91: 1984 and 1985 Ford and Lincoln-Mercury
models for excessive hydrocarbon emissions.
01 /91: 1984 Ford Pick-ups with 5.0-ltr. engines for
excessive hydrocarbon and evaporative emissions.
10/29/90: 1987 Ford Thunderbirds and Mercury
Cougars with 33-ltr. engines for excessive carbon
monoxide and hydrocarbon emissions.
10/02/90: Ford LTD and LTD wagon, Thunderbird
and Mustang; Mercury Cougar, Marquis, Marquis
wagon, and Capri with 3.8-ltr. engines for excessive
carbon monoxide and hydrocarbon emissions.
09/24/90: All 1987 Chrysler passenger cars and
wagons with 25-ltr. engines due to fuel injectors causing
excessive carbon monoxide emissions.
09/04/90: 1987 Mitsubishi models with 15-ltr. engines
for excessive carbon monoxide emissions.
CEO of CM Will Speak At
Solar/ Electric Car Show and Symposium
The CEO and Chairman of GM, Robert
Stempel, will be the keynote speaker at the 3rd
Annual Solar and Electric Vehicle Symposium,
Car and Trade Show, taking place on October
26th and 27th, 1991, at the Boxborough Host
Hotel, in Boxborough, Mass. The event is spon-
sored by the U.S. Dept. of Energy. 'The sympo-
sium will bring together the people and prod-
ucts which will be instrumental in bringing
non-polluting electric vehicles to market",
according to Nancy Hazard, the spokeperson
for the Northeast Sustainable Energy Associa-
tion, the organizer of the event. For more infor-
mation contact NESEA at (413) 774-6051.
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[NOTE: This letter originated from EPA Headquarters and is reprinted for your information.]
U.S. Environmental Protection Agency
Washington D.C 20460
To whom may it concern: March 13,1991
As you know, the dean Air Act was amended on November 15,1990. Several
of the changes in the Amendments affect the automotive repair/service industry
directly. These changes include the expansion of the tampering prohibition to
include private individuals and the prohibition against the manufacture, installa-
tion, sale or offering for sale of any part or component used on any motor vehicle
or motor vehicle engine where a principal effect is to bypass, defeat, or render
inoperative any emission control device or element of design of any emission
control system.
The enclosed Fact Sheet Exhaust System Repair Guidelines has been revised to
conform to the new provisions of the dean Air Act and represents a change in our
enforcement policy with regard to exhaust repair. This change is effective imme-
diately.
Essentially, the changes in these guidelines reflect EPA's position that any pipe
used to replace the section of exhaust where the catalytic converter should be,
would be considered illegal under the revised dean Air Act Therefore, any work
in this area of the exhaust system must include proper converter replacement
Other informational materials will be revised to reflect the Clean Air Act
Amendments and will be distributed and made available when they are com-
pleted. These other materials include pamphlets on the tampering prohibition,
revised engine switching fact sheet, and possibly a revision of our enforcement
policy statement (Memorandum 1A) and /or guidance on which parts EPA
considers to be illegal
We would appreciate you informing your employees, members and/or associ-
ates about these changes. If there are questions or concerns, or if you have any
suggestions concerning these issues, please let us know. Our phone number is
(202)382-2640.
Sincerely,
Isl
Mary T. Smith
Director
Field Operations Support Division
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[Note: This letter was originated from EPA Headquarters and is reprinted for your information.]
U.S. Environmental Protection Agency
Washington, D.C. 20460
FACT SHEET: EXHAUST SYSTEM REPAIR GUIDELINES
The EPA has prepared this fact sheet to answer some of the most commonly
asked questions about the types of exhaust work a repair shop can legally per-
form. If you need any further information about the EPA's tampering policy,
please call (202) 382-2640. [In Region I, call the Hotline number listed on the
first page of this bulletin]
Question 1.
Under what conditions or circumstances can a catalytic converter be removed
from a vehicle and a converter replacement pipe be installed?
Answer 1.
Under federal law, catalytic converters may not be removed and replaced with
"converter replacement pipes" by any person. The 1990 Clean Air Act Amend-
ments even prohibit private individuals from installing "converter replacement
pipes" on their own vehicles. Anyone who installs such pipes would violate
section 203(a)(3)(A) and (B) of the Clean Air Act (Act).
In addition to federal law, forty-five out of the fifty States also have statutes or
regulations which prohibit tampering with the pollution control equipment on
motor vehicles or driving or selling such vehicles. Thus, vehicle owners who
tamper with their own vehicles may be subject to substantial penalties under
both federal and State law.
The only circumstances in which a person would be allowed to remove a con-
verter is if the vehicle is being shipped overseas to an area where unleaded
gasoline is not generally available. (Vehicles traveling to Canada or Mexico are
not eligible for this exemption.) In this instance the vehicle owner must have a
letter from the EPA specifically authorizing the converter removal from the
vehicle in question.
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Question 2.
Can I remove a converter from a vehicle that is used only for "off-road" driving?
Answer 2. No. The tampering prohibition discussed in Answer #1 applies to
this situation as well. The federal tampering prohibition pertains to "motor ve-
hicles," which are denned by section 216(2) of the Act as "any self-propelled
vehide[s] designed for transporting persons or property on a street or highway."
A light-duty vehicle manufacturer certifies as engine chassis configuration as
meeting the applicable emissions standards for the motor vehicles manufactured
in a given model year, and it is not legal for anyone to "de-certify" a motor vehicle
for "off-road" use.
Question 3.
A vehicle that has its engine replaced is brought into a muffler shop.
The owner says the new engine is pre-1975 and the vehicle no longer needs
a converter. Is it tampering to remove the converter?
Answer 3. Yes. Again, the tampering prohibition in Answer #1 applies. A motor
vehicle must be maintained in a proper certified engine-chassis configuration. In
the case of engine switching, the resulting engine-chassis configuration must be
indentical in all material respects to one mat was certified by the manufacturer for
the same model year as the chassis or newer. It is not legal for anyone to change a
vehicle into one that matches an older configuration than was certified by the
manufacturer. Thus, removing the converter would be a violation of the law.
Question 4.
If a vehicle is brought into a muffler shop with a missing converter and a
replacement pipe already installed, is it tampering to install a new replacement
pipe?
Answer 4. Yes. Section 203(a)(3)(B) makes it illegal for any person to sell or to
install any part where a principal effect would be to bypass, defeat, or render
inoperative any device or element of design of a vehicle's emission control system.
A principal effect of a replacement pipe is to defeat or bypass the catalytic con-
verter system as it was designed by the manufacturer. It is, therefore, a prohibited
act to install a replacement pipe in any situation. It is also prohibited act to replace
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the entire exhaust pipe without replacing the catalytic converter. In addition, a
repair facility should consult with the State to determine if the State has a similar
policy towards this type of repair work or how State laws may affect the legality
of its actions.
Question 5.
If a converter-equipped vehicle is brought to a muffler shop with the converter
already removed by the owner, is it tampering to install a section of pipe in the
space left vacant by the converter's removal?
Answers. Yes. The installation by a muffler shop of a section of pipe in the void
left where the vehicle owner removed the converter is considered by the Agency
to be part of the act of tampering. It is a violation of section 203(a)(3)(A) for a
vehicle owner to remove a converter from his own vehicle. Section 203(aX3)(A)
clearly prohibits all individuals from removing or rendering inoperative any
emission control device or element of design. If a repair facility completes, assists,
or participates in any way in this act of tampering begun by someone else, it has
also acted in violation of section 203(a)(3)(A) of the Act and by installing a defeat
device has violated section 203(a)(3)(B).
Question 6.
If a converter-equipped vehicle is brought into a muffler shop with no exhaust
system past the exhaust manifold or headers, is it tampering to install a non-
stock or dual exhaust system?
Answer 6. Yes. The answer to Question #5 applies. The repair facility would be
completing the act of tampering in this situation by manufacturing, installing and
selling an emission control defeat device
Question 7.
Is it tampering to install a dual exhaust system on a vehicle originally equipped
with a single exhaust?
Answer 7. Yes. The general rule is that a motor vehicle emission control system
(which includes the exhaust configuration) may not be changed from an EPA
certified configuration without subjecting the repair shop to liability for
violating the federal tampering prohibition. The exhaust system configuration,
including the location of the converters, and exhaust pipe diameter and length,
are items specified by the manufacturer because engines and some of the associ-
ated emissions systems are generally affected by the exhaust system backpressure;
which subsequently affects vehicle emissions. The installation of a dual exhaust
system with two converters would, therefore, be considered tampering. The
Agency will not, however, require a repair shop to restore a vehicle which has a
non-stock dual exhaust system to a single exhaust configuration. A shop may,
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therefore, replace sections of pipes on such a system, except for that portion of the
pipes where the original catalytic converter would have been located. It would not
be considered tampering to install a dual exhaust system with two converters if the
vehicle manufacturer certified an identical engine-chassis configuration for the
vehicle model year or newer that includes such an exhaust configuration.
Question 8.
Are there any general guidelines for muffler shops about the kind of exhaust
•work that can be legally performed on a previously tampered vehicle?
Answers. As the answers to the previous Questions indicate, the Agency's au-
thority to enforce against tampering violations has been greatly expanded. Indi-
viduals are now prohibited from tampering. Repair shops, therefore, must now
restore vehicles' exhaust systems to their original catalyst configuration if they
work on that part of the exhaust system. The Agency will not pursue enforcement
action against repair shops that perform repairs on one part of a vehicle's exhaust
system where tampering has occurred in another part of the system. The Agency
does require, however, that when working on a vehicle where the catalytic con-
verter has been removed, the repair shop must replace the catalytic converter if the
section of pipe where the original converter should have been, needs to be re-
placed. This would also include situations where the entire exhaust pipe is re-
placed. Repair shops must install a catalytic converter when replacing the entire
exhaust pipe.
We urge you to approach repair work cautiously and to consult with State officials
concerning applicable State law. We have enclosed a chart that briefly summarizes
the issues discussed in this fact sheet for use by any repair shop.
You should also be aware of the installation requirements applicable to aftermarket
catalytic converters which comply with our August 5,1986 interim policy. A copy
of these requirements can be obtained by calling the phone number listed at the
beginning of mis fact sheet.
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Condition of
exhaust when
vehicle entering
the shoo
p^^TT^T SYSTEM RFPAIR fiUTDELINES
Can the vehicle havf the shop in the following conditions?
Condition of the exhaust when frflFf'n? the shop
Stock exhaust
with converter
Stock exhaust,
no CAT*, test
pipe in its place
Stock exhaust,
CAT, gap in
exhaust system
(no test pipe)
No exhaust system
past manifold or
headers
Dual non-stock
exhaust with no
converters
Dual non-stock
exhaust with
converters
Stock exhaust Stock exhaust
with converter with test pipe
Yes
Yes
No
No
Dual exhaust
with converters
No
No
Yes
No
No
Yes
Yes
Yes
No
No
No
No
Yes"
Yes'
»*
Duals without
converters
No
No
No
No
No
No
** The Agency has exercised its enforcement discretion by not pursuing enforcement action against facilities for this
type of repair work, although it could be considered tampering. Please consult with State officials regarding appli-
cable State laws. Shops are encouraged to convince the vehicle owner to restore the exhaust system back to its
original configuration.
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EPA's TIPS on Saving Gas and Improving Mileage
(to be shared with family and friends!)
(Excerpted from Tips to Save Gas and Improve Mileage', published by EPA's Certification
Division at the EPA Motor Vehicle Emissions Laboratory in Ann Arbor, Michigan)
How fo Save Gas:
1. Walk, bike, take a bus, or carpool when possible.
2. Combine errands into one trip.
3. Drive your car wisely and maintain it properly.
How to Get Better Gas Mileage:
1. Go easy on the brakes and the gas pedal.
2. Avoid long idles.
3. Avoid carrying unneeded items in the trunk.
4. Avoid high speeds.
5. Use your air conditioning only when necessary.
6. Use overdrive.
7. Keep your tires properly inflated and aligned.
8. Use energy conserving oils (motor oil labeled 'EC II1).
9. Get regular engine tuneups and car maintenance checks.
UNITED STATES
ENVIRONMENTAL PROTECT:
REGION I
JOHN F .KENNEDY FEDERAL BLD
BOSTON, MASSACHUSETTS 02203
Forwarding and Address Correction Requested
Air, Pesticides and Toxics Mgmt. Div.
Technical Assistance Section CATA)
Boston, MA 02203-2211
Official Business
Penalty for Private Use
$300
First Class Mail
Postage and Fees Paid
EPA
Permit No. G-35
OIL C
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§
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
\ P«0*0
3 1991
AIR AND RADIATION
To whom may it concern:
As you know, the Clean Air Act was amended on November 15,
1990. Several of the changes in the Amendments affect the
automotive repair/service industry directly. These changes include
the expansion of the tampering prohibition to include private
individuals and the prohibition against the manufacture,
installation, sale or offering for sale of any part or component
used on any motor vehicle or motor vehicle engine where a principal
effect is to bypass, defeat, or render inoperative any emission
control device or element of design of any emission control system.
The enclosed Fact Sheet! Exhaust System Repair Guidelines
has been revised to conform to the new provisions of the Clean Air
Act and represents a change in our enforcement policy with regard
to exhaust repair. This change is effective immediately.
Essentially, the changes in these guidelines reflect EPA's
position that any pipe used to replace the section of exhaust where
the catalytic converter should be, would be considered illegal
under the revised Clean Air Act. Therefore, any work in this area
of the exhaust system must include proper converter replacement.
Other informational materials will be revised to reflect the
Clean Air Act Amendments and will be distributed and made available
when they are completed. These other materials include pamphlets
on the tampering prohibition, revised engine switching fact sheet,
and possibly a revision of our enforcement policy statement
(Memorandum 1A) and/or guidance on which parts EPA considers to be
illegal.
We would appreciate you informing your employees, members
and/or associates about these changes. If there are questions or
concerns, or if you have any suggestions concerning these issues,
please let us know. Our phone number is (202) 382-2640.
Sincerely,
oxi.
Martf T.y Smith
ijirector
Field Operations and Support Division
Enclosure
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Ti UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
S? WASHINGTON. D.C. 20460
MAR I 3 1991
OFFICE OF
AIR AND RADIATION
FACT SHEET: EXHAUST SYSTEM REPAIR GUIDELINES
The EPA has prepared this fact sheet to answer some of the
most commonly asked questions about the types of exhaust work a
repair shop can legally perform. If you need any further
information about the EPA's tampering policy, please call (202)
382-2640.
Question 1.
Under what conditions or circumstances can a catalytic
converter be removed from a vehicle and a converter replacement
pipe be installed?
Answer 1.
Under federal law, catalytic converters may not be removed
and replaced with "converter replacement pipes" by any person.
The 1990 Clean Air Act Amendments even prohibit private
individuals from installing "converter replacement pipes" on their
own vehicles. Anyone who installs such pipes would violate section
203(a)(3)(A) and (B) of the Clean Air Act (Act).
In addition to federal law, forty-five out of the fifty
States also have statutes or regulations which prohibit tampering
with the pollution control equipment on motor vehicles or driving
or selling such vehicles. Thus, vehicle owners who tamper with
their own vehicles may be subject to substantial penalties under
both federal and State law.
The only circumstances in which a person would be allowed to
remove a converter is if the vehicle is being shipped overseas to
an area where unleaded gasoline is not generally available.
(Vehicles traveling to Canada or Mexico are not eligible for this
exemption.) In this instance the vehicle owner must have a
letter from the EPA specifically authorizing the converter
removal from the vehicle in question.
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Question 2.
Can I remove a converter from a vehicle that is used only
for "off-road" driving?
Answer 2. No. The tampering prohibition discussed in Answer #1
applies to this situation as well. The federal tampering
prohibition pertains to "motor vehicles," which are defined by
section 216(2) of the Act as "any self-propelled vehicle[s]
designed for transporting persons or property on a street or
highway." A light-duty vehicle manufacturer certifies an engine-
chassis configuration as meeting the applicable emissions
standards for motor vehicles manufactured in a given model year,
and it is not legal for anyone to "de-certify" a motor vehicle
for "off-road" use.
Question 3.
A vehicle that has had its engine replaced is brought into a
muffler shop. The owner says the new engine is pre-1975 and the
vehicle no longer needs a converter. Is it tampering to remove
the converter?
Answer 3. Yes. Again, the tampering prohibition in Answer #1
applies. A motor vehicle must be maintained in a proper
certified engine-chassis configuration. In the case of engine
switching, the resulting engine-chassis configuration must be
identical in all material respects to one that was certified by
the manufacturer for the same model year as the chassis or pewer.
It is not legal for anyone to change a vehicle into one that
matches an older configuration than was certified by the
manufacturer. Thus, removing the converter would be a violation
of the law.
Question 4.
If a vehicle is brought into a muffler shop with a missing
converter and a replacement pipe already installed, is it
tampering to install a new replacement pipe?
Answer 4. Yes. Section 203(a)(3)(B) makes it illegal for any
person to sell or to install any part where a principal effect would
be to bypass, defeat, or render inoperative any device or element of
design of a vehicle's emission control system. A principal effect
of a replacement pipe is to defeat,or bypass the catalytic
converter system as it was designed by the manufacturer. It is,
therefore, a prohibited act to install a replacement pipe in any
situation. It is also a prohibited act to replace the entire
exhaust pipe without replacing the catalytic converter. In
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addition, a repair facility should consult with the State to
determine if the State has a similar policy towards this type of
repair work or how state laws may affect the legality of its
actions.
Question 5.
If a converter-equipped vehicle is brought to a muffler shop
with the converter already removed by the owner, is it tampering
to install a section of pipe in the space left vacant by the
converter's removal?
Answer 5. Yes. The installation by a muffler shop of a section
of pipe in the void left where the vehicle owner removed the
converter is considered by the Agency to be part of the act of
tampering. It is a violation of section 203(a)(3)(A) for a vehicle
owner to remove a converter from his own vehicle, section
203(a)(3)(A) clearly prohibits all individuals from removing or
rendering inoperative any emission control device or element of
design. If a repair facility completes, assists, or participates
j.n any way in this act of tampering begun by someone else, it has
also acted in violation of section 203(a)(3)(A) of the Act and by
installing a defeat device has violated section 203(a)(3)(B).
Question 6.
If a converter-equipped vehicle is brought into a muffler
shop with no exhaust system past the exhaust manifold or headers,
is it tampering to install a non-stock or dual exhaust system?
Answer 6. Yes. The answer to Question #5 applies. The repair
facility would be completing the act of tampering in this
situation by manufacturing, installing and selling an emission
control defeat device.
Question" 7.
Is it tampering to install a dual exhaust system on a vehicle
originally equipped with a single exhaust?
Answer 7. Yes. The general rule is that a motor vehicle
emission control system (which includes the exhaust
configuration) may not be changed from an EPA certified
configuration without subjecting the repair shop to liability for
violating the federal tampering prohibition. The exhaust system
configuration, including the location of the converters, and
exhaust pipe diameter and length, are items specified by the
manufacturer because engines and some of the associated emissions
systems are generally affected by the exhaust system
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backpressure, which subsequently affects vehicle emissions. The
installation of a dual exhaust system with two converters would,
therefore, be considered tampering. The Agency will not, however,
require a repair shop to restore a vehicle which has a non-stock
dual exhaust system to a single exhaust configuration. A shop
may, therefore, replace sections of pipes on such a system,
except for that portion of the pipes where the original catalytic
converter would have been located. It would not be considered
tampering to install a dual exhaust system with two converters if
the vehicle manufacturer certified an identical engine-chassis
configuration for the vehicle model year or newer that includes
such an exhaust configuration.
Question 8.
Are there any general guidelines for muffler shops about the
kind of exhaust work that can be legally performed on a
previously tampered vehicle?
Answer 8. As the answers to the previous questions indicate, the
Agency's authority to enforce against tampering violations has
been greatly expanded. Individuals are now prohibited from
tampering. Repair shops, therefore, must now restore vehicles'
exhaust systems to their original catalyst configuration if they
work on that part of the exhaust system. The Agency will not
pursue enforcement action against repair shops that perform
repairs on one part of a vehicle's exhaust system where tampering
has occurred in another part of the system. The Agency does
require, however, that when working on a vehicle where the
catalytic converter has been removed, the repair shop must replace
the catalytic converter if the section of pipe where the original
converter should have been, needs to be replaced. This would
also include situations where the entire exhaust pipe is
replaced. Repair shops must install a catalytic converter when
replacing the entire exhaust pipe.
We urge you to approach repair work cautiously and to
consult with State officials concerning applicable State law. We
have enclosed a chart that briefly summarizes the issues
discussed in this fact sheet for use by any repair shop.
You should also be aware of the installation requirements
applicable to aftermarket catalytic converters which comply with
our August 5, 1986 interim policy. A copy of these requirements
can be obtained by calling the phone number listed at the
beginning of this fact sheet.
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EXHAUST SYSTEM REPAIR GUIDELINES
Can the vehicle leave the shop in the following conditions?
Condition of Dual
exhaust
vehicle entering Stock exhaust Stock exhaust Dual exhaust without
shop _ with converter with test pipe with converters converters
Stock exhaust Yes No No No
with converter
Stock exhaust, no Yes No No No
converter, test
pipe in its place
Stock exhaust, no Yes No No- No
converter, gap in
exhaust system
(no test pipe)
No exhaust system Yes No No No
past manifold or
headers
Dual non-stock Yes No Yes*** No
aust with no
Dual non-stock Yes No Yes*** No
exhaust with
converters
*** The Agency has exercised its enforcement discretion by not
pursuing enforcement action against facilities for this type
of repair work, although it could be considered tampering.
Please consult with State officials regarding applicable
State laws. Shops are encouraged to convince the vehicle
owner to restore the exhaust system back to its original
configuration.
3/91
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.,— of the Clean Air Aot. Thia
Memorandum cancels end supersedes Mobile Source Enforcement
Memorandum No. 1 of December 22, 1972. '
1. Section 203(a)(3) of the Clean Air Act provides:
"The following acts and the causing thereof are
prohibited—
(3) for any person to remove or render inoperative
any device or element of design installed on or In
a motor vehicle or motor vehicle engine in compliance
with regulations under this title prior to its sale
and delivery to the ultimate purchaser, or for any
manufacturer or dealer knowingly to remove or render
inoperative any such device or element of design
after such sale and delivery to the ultimate
purchaser."
Section 205 of the Act provides for a maximum civil penalty of
$10,000 for any person who violates Section 203(a)(3),
2. This "tampering" provieion of the law has created a
great deal of uncertainty, primarily among new vehicle dealers
and automotive aftermarket parti manufacturers, regarding what
actions and/or use pf what parts are prohibited. The terms
"manufacturer" and "dealer" in 203(a)(3) refer only to motor
vehicle and engine manufacturers and new motor vehicle dealers;
however, the law impacts indirectly on aftermarket parts
manufacturers through its applicability to vehicle dealers who
are customers for their products, other provisions in the Act
establishing manufacturer warranties and authorizing compulsory
recall of properly maintained vehicles also have a potential for
anti-competitive effects in the aftermarket.
frfemtf on Rtcydtd Ptp«
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3. In general, it is clear that EPA's primary objective
in enforcing the etatutory prohibition en "tampering" must be
to assure unimpaired emission control of motor vehicles throuah-
X? th?Jr ??eful4iife* ," is EPA'B P°lic* to Attempt to achieve
this objective without imposing unnecessary restraints on
commerce in the automotive aftermarket.
4. The long range solution to minimizing possible anti-
competitive effects that could result from implementation of
these statutory provisions may lie in some type of certification
program for at least certain categories of aftermarket parts,
EPA is currently studying the technical, administrative and
legal problems which such a program presents. EPA has yet to
develop the policy, procedures, or facilities attendant to any
long range solution.
5. In the absence of a long-term solution, and in the
absence of proof that use of nonoriginal equipment parts will
adversely affect emiBoions, constraining dealers to the use of
only original equipment parts would constitute an unwarranted
burden on commerce in the automotive aftermarket. Pending
development of a long range solution, the following statement -
reflects EPA'B interim policy in the tampering area. This policy
is intended to reduce th« uncertainty which dealers now face by
providing criteria by which dealers can determine in advance
that certain of their acts do not constitute tampering.
^ ^ ^ N?w vehicle and engine manufacturers have also requested
that they be treated, in their aftermarket parts role, similarly
to other aftermarket parts manufacturers. Memorandum No. 1 was
intended to avoid unnecessary adverse impacts en all aftermarket
manufacturers; this revision, therefore, makes it clear that
EPA'e interim policy extends to vehicle and engine manufacturers.
B. Interim Policy
1. Unless and until otherwise stated, the Environmental
Protection Agency will not regard the following acts, when
203?aH3? of Jvd8aler' to con*titute violations of Section
.(a) Use of a nonoriginal equipment aftermarket
part (including a rebuilt part) as a replace-
ment part solely for purposes of maintenance
according to the vehicle or engine manufac-
turer's instructions, cr for repair or
replacement of a defective or worn cut part,
if the dealer has a reasonable basis for
Knowing that eueh use will not adversely
affect emissions performance; and
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(b) Use of a nonoriginal equipment aftemarkat
part or system as an add-on, auxiliary,
augmenting, or secondary part or system,
if the dealer has a reasonable basis for
knowing that such use will not adversely
affect emissions performance; and
(c) Adjustments or alterations of a particular
part or system parameter, if done for purposes
of maintenance or repair according to the
vehicle or engine manufacturer'B instructions,
or if the dealer has a reasonable basis for
knowing that such adjustment or alteration
will not adversely affect emissions
performance.
2. For purposes of clause (la), a reasonable basis for
knowing that a given act will not adversely affect emissions
performance exists ifi
(a) the dealer reasonably believes that the
replacement part or rebuilt part is designed
to perform the same function with respect
to emission control as the replaced part,
or
(b) the replacement part or rebuilt part is
represented in writing by the part manufacturer
to perform the same function with respect to
emission control as the replaced part.
3. For purposes of clauses (Ib) and (Ic), a reasonable
basis for knowing that a given act will not adversely affect
emissions performance exists if:
(a) the dealer knows of emissions tests which
have been performed according to testing
procedures prescribed in 40 C7R section 83
shoving that the act does not cause similar
vehicles or engines to fail to meet applicable
emisoion standards for their useful lives
(5 years or 50,000 ailes in the case of
light-duty vehicles); or
the part or system manufacturer represents
in writing that tests as described in (a)
have been performed with similar results;
or
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(a) a Federal, 6tat* or local environmental
control agency expressly represents that
a reasonable basis exists. (This provision
ia limited to the geographic arta over
which the State or local agency has
jurisdiction).
4. For purposes of clauses (la), (ib), and (Ic):
(a) except when necessarily done in conjunction
with acts under l(b) or l(e) which EPA dots
not consider to constitute violations of
Section 203(a)(3), the permanent removal or
disconnecting or blocking of any part of the
original eystem installed primarily for the
purpose of controlling •missions will be
presumed to adversely affect emission
performance; and
(b) the proscription end appropriate publication
by EPA of an act as prohibited will be deemed
conclusive that such act will adversely affect
•missions performance.
C. pieeussien
1. Clause (la) vill apply to new or rebuilt replacement
parts. protecting the dealer when he uses such a part to conduct
necessary maintenance if a person familiar with the design and
function of motor vehicles and engines would reasonably believe
that such a part is designed to perform the same function as the
replaced part, cr if there is written representation by the parts
manufacturer that the part is so designed. Other reasonable
bases {e.g., emissions test showing no adverse effect) may exist/
but these other bases will probably not ooour often in the
replacement part context. If EPA gains information that certain
replacement parts do adversely affect emissions, a listing of
such parts will be published.
2. Clause (Ib) will protect the dealer who installs add-en
parts if he knows, or if it has been represented in writing to
him by the- part manufacturert that emissions tests have been
performed according to Federal procedures which show that such a
part will not cause similar vehicles to fail to meet applicable
emission standards over the useful life of the vehicle. The
dealer is protected from prosecution even if the test results
have not been reported to EPA. However, the aftermarkat parts
manufacturer who represents that euch tests have been conducted
should have available the data from the tests, including where,
when, how and by whom the tests were conducted should EPA request
it. Such add-on parts might be auxiliary fuel tanks, which would
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require evaporative emission control on light-duty vehicle* to
the prescribed standard, or superchargers, which would require
emission testing shoving conforaance to standards ov*r tht useful
lift of th» vthicle or engine. Clause (Ib) will alto protect the
dealer who installs retrofit devices to reduce emissions at the
request of a State or local environmental control agency.
3. Clause (Ic) applies to dealers•performing necessary
adjustments or alterations, according to th« vehicle or engine
manufacturer's instructions, of parts already on the vehicle or
engine, e.g., adjuctamnt efi the eas*feuj?*t»* e? ignitien timing.
It also covers adjustments or alterations, as in the case of
altitude "fixes11, if a "reasonable basis" exists as described
above,
4. This interim policy provides general guidance to dealers
as to these acts which do not constitute tampering and those acts
which may constitute tampering. It also allows aftermarXst parts
manufacturers an opportunity to protect their markets by provi-
ding dealers with assurance that their parts do not cause
emissions standards to be exceeded. Vehicle and engine manu-
facturers also often function as aftermarJcet parts manufacturers.
For example, many vehicle and engine manufacturers provide
aftermarket parts for the in-use vehicle and engines of other
manufacturers aa well as for their own in-usa vehicle and
engines. In their after-market parts role, vehicle and engine
manufacturers may take the same steps (set forth in this
memorandum) as parts manufacturers who are not also vehicle or
engine manufacturers to provide dealers with assurances that they
are not in violation section 203(a}(3), However, in their role
as vehicle or engine manufacturers, procedures exist whereby they
may obtain approval for any emission related change in a vehicle
or engine from its certified configuration or parameters (See
MSAFC Advisory Circulars No. 2-B "Field Fixes Related to Emission
Control-Related Components" and No, lfi-2 "Approval of Emission
Control Modifications for High Altitude on New Light Duty Motor
Vehicles", March 5, 1974). This Memorandum does not relieve
vehicle or engine manufacturers from complying with the
procedures set forth in the advisory circulars except in their
specific function as afteraarfcet parts manufacturers.
5. Any questions regarding this interim policy should be
addressed to the Mobile Source Enforcement Division (EG-240),
Office of Enforcement and General Counsel.
Norman D. Shulter, Director
Mobile Source Enforcement Division
Office of Enforcement and General Counsel
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OCT 22 '91 13=10 EFR FOSD P'2
'
s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
V XSHNGTON, D.C. 20460
«**
21961
OPFKSOF
Alt AND IADIATWM
ENGINE SWITCHING TACT SHEET
Pursuant to frequent requests for information received by
the U.S. Environmental Protection Agency (EPA) regarding th«
legality and effects of engine switching, this J^™* »"*
sunmarite federal law and policy pertaining to this natter, and
will discuss other related issues.
A. federal Law
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and delivery, «nd the c.u.ing thereof. The »»xl»»
e 1W for a violation of this .eotion by • manufacturer
or dealer is $85,000) for any other p.r.on, JS.500.
section J01(a)(3)(B) of the Act prohibit! any .«"?"
nanufacturing or .elling. or offering to jell,
installed for such usi, The naxinua civil penalty for
violation of this section is $2,500.
EPA received many questions regarding the W^Atioj[ of
this law to a situation where one «^inV *• f600™* "^
vehicle and another engine is installed in its Plje«.
regarding -engine switching" is «jv.r.d und er thj
necessary to aaXe this determination.
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OCT 22 '91 13:11 EPfi FOSD P.3
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A "certified configuration11 is an engine of engine-chassis
design vhich has been "certified" (approved) by EPA prior to the
production of vehicles with that design! Generally, tht manufac-
turer submits an application for certification of the designs of
each engine or vehicle it proposes to manufacture prior to
production! The application includes design requirements for til
emission related parts, engine calibrations, and other design
parameters for each different type of engine (in heavy-duty
vehicles), or engine-chassis combination (in light-duty
vehicles). EPA then "certifies11 each acceptable design for use
in vehicles of the upcoming model year.
For-light-duty vehicles, installation of a light-duty angina
into a different light-duty vehicle by any person would be
considered tampering unless the resulting vehicle is identical
(with regard to all emission related parts/ engine design
parameters, and engine calibrations) to a certified configuration
of the same or never model year as the vehicle chassis, or if
there is a reasonable basis for knowing that emissions are not
adversely affected as described in Memo 1A. The appropriate
source for technical information regarding the certified
configuration of a vehicle of a particular model year is the
vehicle manufacturer.
For heavy-duty vehicles, the resulting vehicle must contain
a heavy-duty engine vhich is identical to a certified configura-
tion of a heavy-duty engine of the same model year or never ae
the year of the installed engine. Under no circumstances,
however, may a heavy-duty engine ever be installed in a light-
duty vehicle.
The most conmon engine replacement involves replacing a
gasoline engine in a light-duty vehicle vith another gasoline
engine. Another type of engine switching vhich commonly pccurs,
hovever, involve* die
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OCT 22 '91 13:12 EPfi FOSD
-3-
Another situation recently brought to EPA'B'attention
involves the offering for e&le of used foreign-built engines.
These engines are often not covered by a certified configuration
for any vehicle sold in this country. In such a case, there is
no way to install such an engine legally.
EPA has recently brought enforcement actions against certain
parties who have violated the tampering prohibition by performing
illegal engine switches.
It should be noted that while CPA's policy allows engine
switches as long ae the resulting vehicle matches exactly to any
certified configuration of the came or newer model year as the
chassis, there are soae substantial practical limitations to
performing such a replacement. Vehicle chassis and engine
designs of one vehicle manufacturer are very distinct from those
of another, such that it is generally not possible to put an
engine into a chassis of a different manufacturer and have it
match up to a certified configuration. Therefore, practical
considerations will generally limit engine switches to
installation of another engine which was certified to be used in
that same make and model (or a "twin" of that make and model,
e.g., Pontiac Grand Am and Oldsmobile Calais). Zn addition,
converting a vehicle into a different certified configuration is
likely to be very difficult, and the cost may prove prohibitive.
B. State Laws
Many states also have statutes or regulations prohibiting
tampering in general. Most of these laws specifically prohibit
tampering by individuals. A few specifically prohibit engine
switching, using provisions similar to those stated in EPA's
policy. To determine the state law in any given state, the
state's Attorney General's office should be contacted.
In addition, many states have state or local antitaapering
inspection programs which require a periodic inspection of
vthicles in that area, to determine the integrity of emission
control systems. Many programs have established policies for
vehicles which have been engine switched* While EPA does not
require these programs to fail engine switched vehicles which are
not in compliance with federal policy, the Agency does strongly
recommend that those programs set their requirements so as to be
consistent with the federal law. State or local programs which
pass illegally engine switched vehicles may mislead federally
regulated parties into believing that engine switching is allowed'
by federal law.
Attachment
4/91
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Engine Bvitebina end Conveniomt
Any repair facility that performs engine
conversions should sake s'ure it has -ftA- facts
as possible, here are some of the facts:
1. The repair facility nust be avare of its.r*s€:pC?ronid^«iS i«
switching engines or converting engines (such es from fiiesel to
gasoline).
2. An engine being installed in a vehicle ^^t provide at least
the same amount of emission control as the certified configuration
for that model year. In most cases, on 1980 and older^vehicles,
this means the engine must be the same model y*ar " "T" "?. ~T
chassis of the vehicle into vhich the engine is. b*in!7*n^{4*e°:
(For example, a 1976 engine could *>ejinfta}1«a.*n * «76 vehicle i
however, a 1974 engine could not be installed in a 1976 vehicle.)
On 1981 and newer light duty vehicles, the «ni«i°P *?*n"r"n215!
been the same so theoretically these engines could be^interchanged,
however, all components, including computers, must be B^PPe° ^
the engine. Therefore, most shops von't do an engine swap unless
they can find an exact replacement engine.
3. When an engine is installed, all emissions .^P*6"* <*a* **
part of that engine's original design (how it originally ^came iron
the manufacturer) must be installed and operating with the » nevly-
installed engine or the repair facility could be cited for
tampering.
A. The original exhaust system configuration (as designed by the
r-anufacturer) for the newly-installed engine jnust be P"sent on the
vehicle. This means that a single exhaust engine Bay riot be
reconfigured to dual exhaust — unless the manufacturer happens to
have a %al exhaust configuration designed for that particular
engine and year (be «ure it is for that engine and year) .
5. Changing the original exhaust system configuration,
off any emissions control equipment, or reconfiguring the e.
emissions control system vill usually adversely affect the .engine *
performance and the emission control system's •J."^ *?
effectively control harmful emissions. The tailpipe test alone
cannot be used to determine whether or rot the vehicle's emission
control system is functioning properly. (See the next section,
"The Federal Test Procedure (FTP) and the Tailpipe Test.")
6. Diesel conversions to gasoline engines Bust include ^ all
emission controls on the engine as veil as any catalytic
converter (s) , evaporative controls, and a fuel inlet restrictor.
7 Everv vehicle sold in the U.S. has an engine or engine-chassis
2esiarvMch has to be "certified" (approved) by EPA prior to the
production of vehicles with that design "A Policy states ^ that
*nv TT,ndification to a "certified configuration" (such as not
iJXtaTling i Vo»« "or all of the emission controls that are part of
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an engine design) vould be considered tampering unless there is &
reasonable basis for Knowing that the emissions are not adversely
'affected. In aost cases, an FTP vould be necessary to aake this
determination. In other cases, a judgement can be made based on
ZFA's Tampering Enforcenent Policy which states:
"...
.the permanent removal or disconnecting or blocking of
any part of the original system installed primarily for the
purpose of controlling emissions vill be presumed to affect
adversely emission performance..."
If an 7TP is necessary to make a determination, the facility who
performed the engine work is responsible for having the vehicle
tested according to the FTP.
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Working together to
keep you informed
American Automobile
Association
Automotive Service
Association
Autobody Association
of Connecticut
National Automobile
Dealers Association
New England Interstate
Water Pollution Control
Commission
Professional Insurance
Agents of New England
Safety-Kleen
Corporation
U.S. Environmental
Protection Agency
Vermont Automobile
Dealers Association
Spring 1992
Preventing Pollution
in the
AUTO REPAIR BUSINESS
Do you spend more time with government paperwork than with
auto repair?
Are you disturbed about the skyrocketing costs of managing
hazardous materials?
Do you feel threatened by high liability costs associated with
waste handling?
Don't know whom to call for information?
JSIDE
Do-it-Yourself Self-Inspection Checklist
Determine areas in your shop where you can prevent pollution
.Guide to Reducing Wastes
How to minimize most commonly produced automotive repair wastes
Whom to contact for Help and Information on Regulations
State-by-state list of regulatory and assistance programs
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BENEFITS
It's likely that you, as a repair shop owner, spend many hours filling out forms and keeping records to
meet government reporting requirements for wastes - because it Is so Important to make sure these
materials are disposed of properly and kept out of the environment. This booklet was produced to
help you not only comply with government regulations to prevent groundwater pollution, but also
reduce your waste management costs.
Why The Paperwork?
Almost half the people in the United States get
their drinking water from wells or springs that are
supplied by groundwater. Rainwater filters through the
ground and collects underground in layers of porous
materials known as aquifers. Wells and springs draw
water from these pristine underground aquifers.
Pollution in groundwater can overwhelm the natu-
ral ability of some types of soils to filter the water, and
flushing or cleaning the water may be financially
impractical or physically impossible. When groundwa-
ter is polluted, it can become undrinkable for years.
decades, or even centuries. As a result, hundreds of
public wells and thousands of private wells have been
closed in the United States because they are polluted
and cannot be restored practically.
Light industries such as auto repair shops.
drycleaners, phctofinishers. and furniture strippers use
icmicals and produce wastes and wastewater which
can enter and contaminate groundwater aquifers if not
handled carefullv.
How Might Auto Repair Shops Affect Groundwater?
Auto repair shops, including radiator repair shops,
paint and body (collision repair) shops, service stations.
and auto dealerships, produce many types of wastes
which may pollute groundwater. including:
» Waste oil. lubricants, and transmission fluids
* Spent solvents
+ Spent caustic parts washing solution
+ Parts cleaning tank sludge
* Oily waste sump sludge
* Used antifreeze
+ Used lead acid batteries
* Absorbents used to clean up spills
+ Floor wash waters containing detergents, fuel.
oils, solvents, and paint
These wastes can move through leaks, spills and
floor drains into the ground and pollute an aquifer
which may supply drinking water.
How You Can Benefit from the Suggestions in this Booklet
The techniques listed in this booklet are aimed
to save you money, time, and headaches. Refer to them if
you want to:
Reduce costs by using fewer raw materials
Reduce transportation and disposal costs
Increase income from sale or reuse of
waste
Reduce costs for wastewater treatment
Improve worker safety - lower risk of spills.
accidents, emergencies
Lower long-term liability and insurance-
costs
Improve ability to meet new federal regula-
tions and reduce paperwork required
Improve your image in the community by
working to prevent chemical releases to the
environment
An insert to this booklet which includes a Self-Audit
Checklist and a Guide to Minimizing Automotive Wastes is
provided for your convenience.
Recordkeeping and documenta-
tion are essential to good business.
-------
CASESIUDIES
One Auto Repair Shop's Experience In Using Suggested
Pollution Prevention Techniques
Many auto repair shops have benefited from
practicing pollution prevention. Brown's Garage (not
the real name) In southern New Hampshire Is an
example. Brown's is a general automotive repair garage
with six employees. No body work Is done and there
are no gas pumps.
The garage generates 1500-2000 gallons of waste
oil per year and ships its waste oil using a licensed
waste oil hauler to be rerefined as lubricating oil. Even
though the costs can be. in some cases, more than
other methods of used oil recycling, Brown's has
chosen this method to send a positive message to its
customers and improve its ability to meet federal and
state regulations. In addition, Brown's offers rerefined
oils to its customers.
Brown's currently contracts with an outside
company to recycle its antifreeze, but is now seriously
considering buying its own antifreeze recycling machine
as the recycling company's charges have become
prohibitive. (These machines are required in some
states.) The garage manager is also looking into recy-
" "ng oil filters and plastic oil containers.
Though this booklet concentrates on groundwater
protection, it is interesting to note that Brown's has
also taken steps to prevent air pollution. Brown's
recently purchased a freon recycling machine at a cost
of less than $3.000. The machine has enabled Brown's
to cut its freon use by about 25%. in addition to
benefitting the environment by reduced freon disposal.
Since the cost of freon rose from $30 to $175 per
cylinder in just a few years, the cost savings have been
significant.
What Can Happen if a Shop Isn't Careful
On the other hand, some shops have learned too
late the costs of not using safe handling practices for
wastes. In southern Maine, for example. Sandy's
Variety Store and Gas Station (not the real name) and
Sandy's petroleum distributor have found themselves
liable under Maine law for more than $300.000 in
damages for pollution of a public water supply well.
In Fall 1990. leaks were detected in the gasoline
pumps at Sandy's store, which allowed gasoline to
enter the groundwater flowing towards the public well.
The contaminated well was shut down, leaving the
ected town to purchase water from a neighboring
nmunily at a cost of about $10.000 extra per month.
—ndy's and its petroleum distributor are responsible
for this extra cost, as well as for the cleanup of the well.
which is underway: the total liability as of August 1991
Recycling solvents saves money
and reduces wastes.
was $300.000. with at least $35.000 estimated addi-
tional cleanup costs to come.
How to Minimize the Hazardous Waste You Produce
Management's attitude is the most important factor
in minimizing waste to prevent groundwater pollution
and reduce costs. Shop owners and managers must
make a commitment to reducing hazardous waste,
communicate that commitment to the staff, and take
an active role In their shop's waste reduction program.
Like your gas and electric bills, waste management
is another cost of doing business, which can be mini-
mised by proper planning. The insert has a checklist of
things you can do to manage the wastes you produce
while helping to reduce operating costs. Keep this
checklist on file for your use and review it periodically.
Contact the state Technical Assistance Programs listed
in this booklet under CONTACTS for more detailed In-
formation on how to reduce the wastes your shop pro-
duces. The trade associations listed under CONTACTS
are another source of Information. Finally. EPA has two
recent publications which give more detailed Informa-
tion on these techniques. Refer to the last section of
this booklet for Information on how to obtain the
guides.
-------
CONTACTS
i to Contact for Information on Regulations
wrcncur1*611011 C°ntro1 tmc|
t|inr(iiiciu or Environmental Protection
llurc-iu of Water Management
122 Wellington Street
ll.inford. CT06106
1203) 5GG-25S8
MAINE
Department of Em-lronmcntal Protection
Hureau ofWalcr Quallly Control
Division or Environmental Evaluation
and Lake Studies
St.itc I louse Station 17
Aii(justa. ME 04333
(207) 239-3901
Ground Water Discharge Permit!
CONNECTICUT
Department or Environmental Protection
liureau or Water Management
Ground Water Section
122 Washington Street
ll.infonl. CTOGIOG
(203) 5G6 7295
MAIM:
Department or Environmental IVolcctlon
Bureau or W.itcr Quality Control
Division on.lccn&mj;. Enforcement A.
1'iclil Services
State I louse Station 17
AutfUMa. Mi: 04333
(207) 239-7603
MASSACHUSETTS
Department ofEnvironmcnl.il Protection
Division or Water Supply
1 Winter Street. 9th Floor
Boston. MA 02103
(617)232-5770
NEW HAMPSHIRE
Department ofEnvtronmcnl.il Services"
Ground Water Protection Ourcnu
P.O. Dox 95. 6 llazcn Dnve
Concord. NT 103301
(G03I271-3G44
MASSACI IUSETTS
Department orEm1ronmcnt.il Protection
Division of Water Pollution Control
I Winter Street. 6 & 7ih Floor
Hoston. MA02108
(G17) 292 5673
NEW HAMPSHIRE
Department of Cnv1ronnicnl.il Sen ices
Cround Water Protection Bureau
PO I)ox95. 61 la/.cn Dm c
Concord. Nil 03301
(G03)27l-3fi44
WIODE ISLAND
Department of Eimrrmmail.il Management
Division or Ground W.itcr
291 Promenade Street
Providence. HI 02JJ08-57G7
(401)277-2234
VERMONT
Department or Em-1ronmcnl.il Conservation
Water Supply Division
Ground Water Supply Section
103 South Main Street
WcM Office Huildintf
Wntcrbury. VT05G71-0403
(302I244-I5G2
HHOOE ISLAND
Department or Enrironmrnl.il M.in.i
Division of Ground W.itcr
231 lYomrn.idc Sircct
IVovfdcnrc. Kl 02108-5767
1401)277.2234
VERMONT
Diparlmciit orEmirnnnirnl.il Conservation
Prrnulj, Compliance A IVolei linn DUIMOM
103 South M.nn Slrcet/Aiiiiu lluililin,;
W.ilcrlniij-. VT05G71-0405
(S02I 244-SG74
3 Permlti [Dliehargci to Surfkce Water)
CCTICUT
•iicnt of Emironmcnlal Protection
i or\V.iter Manajjcmcnt
Industrial Section
122 Washington Slrect
Ilirtfiird CTOG10G
(2011 5GG-5003
I}i.;i.irlm(.nt orrmironmcnlal IVolccllon
lli.re.iu of Water Quality Control
Division of l.in.nsir.({ Enrorccmcnt &
I"*. Id St-rvices
Stale House Slallon 17
AU{,iiii.i. ME 04333
(207) 2S'J 7G93
MASSACI IUSETTS
DLpartmcnl or Emironmcnlal Protection
Division or Water Pollution Control
1 Winter Sircct. 6 & 7ih Floor
IlosIon.MA02103
(fi 17)292-5073
NI:WI(AMPSIII[U:
Dt.partmcnl orEmiranmcnt.il Scnicc.i
Wjicr Quality & Permit' Compliance llureau
Division of Water Supply A Pollution Control
PO lioxS-j. SllaanDmc
Concord. Nil 03301
(003)271-2457
RIIODi:iS!.\ND
Dcpannimt cirEmironmmlil M.in.i|ji:meiii
DIMMOII orw.ittr Kc.sniirrcs
2!) I Promen.idc Street
Pnnlclenic Kl 02'.)OH-57fi7
(1011 277 (JS19
VERMONT
Dip.irtmcm or Einnrofiiiiuil.il ConsL-rv.iiinn
Ptrmits Compll.inre A IVolei lion DUIMOM
103 Souih Main Slrccl/Annux Ihiililiiw
W.i.irini(.nt uf Emironmcnlal Protection
Hurc.ui ofll.izardou!. M.ilcrlals It Solid
W.ISIL Control
Division prLicensing A Enforrcnicnt
hi.He llou-ie Slallon 17
Anuisi i ME 04333
I: [J 2051
MASSACI lusirrrs
D<.partmcnl or Environmental Protcttion
Division of It.-uurdou:. Wastes
1 Winter Street. 5lh Floor
Boston. MA 02108
((117)202-5857
NEW HAMPSHIRE
Department of Emnronmcnt.il Services
WaMc Management Division
II.iA-irdous W.islc Conipli.inec Sctllon
G I la/en Dnvc
Coneonl. Nil 03301
(b03)27l-2942
RHODE ISLAND
Dcp.irlnii.nl of i:ii\iroimn.nl.il Management
DIVI.SIOII of Air & I Inxirdous M.ilenals
291 Promcn.-idc Street
Providence. Kl 02008-57G7
1101)277-275)7
VERMONT
Department of Environmental Conserv.ilIon
Il.i/.irdous M.itenals Division
103 South MJIII Street/West OITirc llniltlinii
W.iicrbtiry. VT05fi7l 0104
(H02) 2 1-1 H702
-------
CONTACTS
iderground Storage Tank (State) Program (D8T|
>me states may also have local UST programs, Jor
_ imple. in some Massachusetts and Connecticut
communities. Check with your local fire department
for any additional requirements/
CONNECTICUT
Department of Environmental Protection
Bureau of Waste Management
Oil & Chemical Spills Response Division
122 Washington Street
Hartford. CT 06106
(203) 566-4530
MASSACHUSETTS
Department of Public Safety
UST Program
P.O Box 490
Tcwksbury. MA 01876-0490
(508)851-9813
MAINE
Department of Environmental Protection
Bureau of Hazardous Materials & Solid
Waste Control
Division of Licensing & Enforcement
Slate House Station 17
Augusta. ME 04333
1207)289-2651
Hazardous Waste Tanks
Department of Environmental Protection
Division of Hazardous Waste
1 Winter Street
Boston. MA 02108
(617)292-5898
NEW HAMPSHIRE
Department of Environmental Services
Division of Water Supply & Pollution Control
Ground Water Protection Bureau
P O Box 95. 6 Hazen Dnvc
Concord. NH 03301
(6031271-3644
Whom to Contact for Additional Information
State Technical Aiilitance Programi
CONNECTICUT
ConnTAP
Technical Assistance Program
900 Asvlum Avenue. Suite 360
Hartford. CT 06105-1904
'33)241-0777
JNC (no Technical Assistance Program)
Jepartmcm of Environmental Protection
Office of Pollution Prevention
Commissioner's Office
Slate Mouse Station 17
Augusta. ME 04333
(207)289 4152
MASSACHUSETTS
Executive Office of Environmental Affairs
Office of Technical Assistance
100 Cambridge Street
Boston. MA 02202
(617) 727-3250
NEW HAMPSHIRE
Department of Environmental Services
Technical Assistance Program
Waste Management Planning Bureau
6 Hazen Drive
Concord. NH 03301
(6031 271-29IS
RHODE ISLAND
Department of Environmental Management
UST & Oil Pollution Control Section
291 Promenade Street
Providence. Rl 02908-5767
(401) 277-2234
VERMONT
Department of Environmental Conservation
Hazardous Materials Division
103 South Main Street/West Office Building
Waterbury. VT 05671-0404
(802) 244-8702
RHODE ISLAND
Department of Environmental Management
Technical Assistance Program
Office of Environmental Coordination
291 Promenade Street
Providence. RI 02908-5767
(401) 277-3434
VERMONT
Department of Environmental Conservation
Pollution Prevention Program
103 South Main Street
Waterbury. VT 05671-0404
(802) 244-8702
Organization* Which Provided Information
for thU Booklet
American Automobile Association
Public Affairs
1050 Hlngham Street
Rock land. MA 02370-1090
1-800-222-8252
Automotive Service Association
P.O. Box 929
Bedford. TX 76095-0929
(817)283-6205
Auto Body Association of Connecticut
P.O Dox 529
Dranford. CT 06405
(203) 488-7626
U. S Environmental Protection Agency
Croundwater Management Section
JFK Federal Building (WCP-445)
Boston. MA 02203
" 7) 565-3600
»'ional Automobile Dealers Association
Kcgulatory Affairs
8400 Wcatparli Drive
McLean VA22102
(7031821-7040
New England Interstate Water
Pollution Control Commission
85 Men-imac Street
Boston. MA 02114
(617)367-8522
Professional Insurance Agents of
Ncu England
1 Ash Street
Hoplanton. MA 01748
1-800-742-6363
Safety-Ween Corporation
392 East Merrow Road
TollandCT 06084
(203)871-0027
Vermont Automobile Dealers Association
73 Main Street. P O. Box 561
Mompeber VT0560I
(802) 223-6635
Additional copies of this booklet are available
from these organizations.
The booklet sponsors have
provided pollution prevention tips
and techniques. In addition.
information was obtained from
state publications prepared by
California. Oregon. New York, and
Pennsylvania. This booklet was
prepared by Barry Lawson
Associates. Inc.. under contract
with the New England Interstate
Water Pollution Control
Commission.
-------
"•aoortunllles for Training and Education in
"on Prevention
This booklet focuses on groundwater protection
issues. Companion publications by EPA for the
automotive repair and maintenance Industry
encompassing air. land, and water pollution
concerns are forthcoming.
EPA has published pollution prevention waste
minimization guidance manuals for the automo-
tive repair and automotive reflnlshing Industries.
which give details on the tips and techniques
listed. Ask for
Guides to Pollution Prevention: The Automo-
tive Repair Industry (EPA/625/7-91/013)
Guides to Pollution Prevention: The Automo-
tive ReQnishing Industry (EPA/625/7-91/016)
The guides are available from: EPA OJJiceof Re-
search and Development. Publications. (513) 569-
7562 or from the RCRA/Superfund Hotline (1-800-
424-9346)
In addition. EPA's Office of Pollution Prevention
publishes an annual guide of approximately 40
pages. Pollution Prevention Training Opportunities.
Iblng training courses, workshops, and
lars being offered in each state, along with
contact names and addresses. The resource
guide also lists such available materials as fact
sheets. Instruction manuals, and videos, as well
as additional resources to obtain pollution
prevention Information, including updated lists of
State and Federal contacts. Free copies of the
guide can be obtained from:
Abby Swaine. Manager
Pollution Prevention Program
U.S. EPA - Region I
J.F.K. Federal Building (WGP)
Boston. MA 02203
(617) 565-4523
NEIWPCC
S
/n
(m)
Printed on 100% recycled
paper using soy-based Inks
VERMONT AUTOMOBILE DEALERS
^ASSOCIATION. ING.
-------
NEW ENGLAND STATE AIR PROGRAM CONTACTS
Connecticut Department of Environmental Protection
Bureau of Air Management
165 Capitol Avenue
Hartford, CT 06106
(203) 566-4030
Maine Department of Environmental Protection
Bureau of Air Quality Control
State House Station 17
Augusta, ME 04333
(207) 289-2437
Massachusetts Department of Environmental Protection
Division of Air Quality Control
One Winter Street, 7th Floor
Boston, MA 02108
(617) 292-5630
New Hampshire Department of Environmental Services
Air Resources Division
64 North Main Street, Caller Box 2033
Concord, NH 03302-2033
(603) 271-1370
Rhode Island Department of Environmental Management
Division of Air and Hazardous Materials
291 Promenade Street
Providence, RI 02908-5767
(401) 277-2808
Vermont Department of Environmental Conservation
Air Pollution Control Division
Bldg 3 South, 103 South Main Street
Waterbury, VT 05676
(802) 244-8731
-------
Moto
-------
c/EPA
United States
Environmental Protection
Agency
Office of Air and
Radiation (6202J)
July 1992
RECYCLING REFRIGERANT FROlSjL
MOTOR VEHICLE AIR CONDITIONERS
A new regulation, recently signed by
the Administrator of the United
States Environmental Protection
Agency (EPA), requires that motor •
vehicle air conditioning refrigerant be
recycled. This fact sheet will help
you become familiar with this new
law and address some of your
concerns.
Our Threatened Ozone Layer
The stratospheric ozone layer shields
the earth from harmful ultraviolet
(UV) radiation. Scientists worldwide
believe that synthetic chemicals such
as chlorofluorocarbons (CFCs, also
known by the trade name Freon) are
jdly destroying this layer of gas 10
•0 miles above the earth's surface.
w^one loss of 3.5% globally has
already been recorded and is greatest
over Antarctica, where a seasonal
ozone "bole" occurs. Recent data
strongly suggests that substantial
losses may also develop over the
North Pole, exposing parts of the
U.S. to increasing levels of UV
radiation.
Ozone loss in the atmosphere is
likely to lead to an increase in skin
cancer and cataracts and could
weaken the human immune system.
Agriculture, as well as plant and
animal life, may also be dramatically
affected.
Impact of Motor Vehicle Air
Conditioners
One of the single largest uses of
CFCs in the U.S. is as a refrigerant
in automobile air conditioners. CFC-
J2 in motor vehicles accounts for
' er 20% of all CFC use in this
untry.
Commonly released into the air when
car or truck air conditioners are
serviced, CFCs rise to the
stratosphere where they can remain
active for up to 120 years. Solar rays
break these molecules apart,
releasing chlorine. A single chlorine
atom can destroy over several
thousand ozone molecules.
Worldwide Action to Protect the
Ozone Layer
The United States joined 75 other
countries in a global effort to protect
the ozone layer as a Part)1 to the
international treaty known as the
Montreal Protocol. In 1990, these
countries agreed to phase out
production of ozone-depleting
substances, including CFC-12, by the
year 2000. The 1990 Clean Air Act
Amendments (the Act) incorporated
this production phaseout date and
also addressed the use and emission
of these chemicals. President Bush
later pledged to halt almost all U.S.
production of CFCs by the end of
1995.
Section 609 of the Act gives the
EPA the authority to establish
requirements to prevent the release
of refrigerants during the servicing of
motor vehicle air conditioners.
Recycling of CFCs can occur at
minimal cost and without damaging
motor vehicle A/C systems. The
following sections describe the
requirements of the law and its
potential impact on the service
industry.
Clean Air Act Requirements
Approved Equipment
Technicians repairing or servicing
motor vehicle air conditioners must
use either refrigerant recover/recycle
or recover-only equipment approved
by EPA. Recover/recycle equipment
both recovers the refrigerant from
the motor vehicle and processes it
through an oil separator, a filter, and
a dryer. Approved recover/recycle
machines meet the technical
specifications of SAE Standard J-
1990 and must have the capacity to
purify used refrigerant to SAE
Standard J-1991 for safe and direct
return to the air conditioner
following repairs.
Recover-only equipment removes the
refrigerant from the A/C unit as
specified by SAE Standard J-2209
and transfers it into a holding tank.
Technicians are then required by law
to either recycle the used refrigerant
on sue or send it to an off-site
reclamation facility to be restored to
ARI Standard 700-88 before it can
be used to recharge A/C equipment.
A list of both types of approved
equipment is available from EPA at
the address on the back of this fact
sheet. Most certified equipment will
be labeled as "design-certified to
SAE standards."
Technician Training and Certification
Technicians who repair or service
motor vehicle air conditioners must
be trained and certified by an EPA-
approved organization. Training
programs must cover use of recycling
equipment in compliance with SAE
Standard J-1989, the regulatory
requirements, the importance of
refrigerant containment, and the
effects of ozone depletion. To be
certified, technicians must pass a test
demonstrating their knowledge in
these areas. A list of approved
testing programs-e available from
EPA at the address on the back of
this fact sheet.
-------
Small Business Extension
The Act allows small businesses,
defined as those that performed
under 100 service jobs involving
refrigerant in 1990, until January 1,
1993 to purchase equipment. To
qualify for this extension, shops must
send a signed statement that in 1990
they serviced fewer than 100 air
conditioners to EPA at the address
on the bottom of this fact sheet.
The Agency will accept these
statements up until the effective date
of the regulations.
Small Container Restriction
The sale of containers of CFG
under 20 pounds to anyone other
than certified technicians is
prohibited after November 15, 1991
This provision is intended to
discourage "do-it-yourselfers" who
recharge their own air conditioners.
Such individuals often release
refrigerant because they typically do
not have access to recycling
equipment. The Agency encourages
"do-it-yourselfers" to bring their cars
to certified technicians who can
properly fix air conditioners using
approved equipment. This avoids
damage to A7C equipment by
improper charging and helps protect
the environment.
Recordkeeping Requirements
Service shops must certify to EPA
that they own approved equipment.
If refrigerant is recovered and sent to
a reclamation facility, the name and
address of that facility must be
retained.
Impacts on A/C Service
Because of the planned CFC
phaseout and the tax on CFCs, shops
that service air conditioners can
expect the price of CFC-12 to
increase and its availability to
decrease. Refrigerant recycling could
reduce the need for new CFC-12 and
thus help keep costs down.
Refrigerant recycling is an important
step towards the goal of eliminating
CFC use. It means that car owners
can have their air conditioners fixed
until alternatives to CFC-12 are
Important Dates
January 1, 1992
July 14,1992
August 13,1992
November 15,1992
January 1,1993
Motor vehicle A/C service
establishments must have approved
equipment. Certified technicians
must Use the equipment.
EPA final regulations published.
Effective date of EPA regulations.
Small container sales restriction
goes into effect.
Small service establishments must
have approved equipment and
certified technicians. All shops
must certify their equipment to
EPA.
developed. Several substitute
refrigerants are being tested for use
in motor vehicle air conditioners, and
research is being done to see if cars
can be retrofitted for these
alternatives. Possible replacements
include HFC-134a (which will be
used in some cars starting in model
year 1992) and ternary blends of
HCFCs. These substitutes cost more
than CFC-12, making recycling more
economical. Blends that include any
CFCs or HCFCs are already subject
to EPA's recovery and recycling
requirements. By November 15,
1995, all substitute refrigerants will
also have to be recycled.
Support for Recycling
The current CFC recycling program
has come about through the success
of joint EPA-industry voluntary
programs and support from a variety
of organizations. Many groups
endorse refrigerant recycling in
motor vehicle air conditioners and
have participated in EPA's
Stratospheric Ozone Protection
Advisory Committee, Subcommittee
for Servicing of Motor Vehicle Air
Conditioning.
By complying with the new
regulations, you will help preserve
the ozone layer for future
generations.
For further information, please
contact:
MVACs Recycling Program Manager
Stratospheric Ozone Protection
Branch (6202J)
U.S. Environmental Protection
Agency
401 M Street, SW
Washington, DC 20460
•or-
The Stratospheric Ozone
Information Hotline:
1-600-296-1996
(10am-4pm EST, Monday-Friday,
except federal holidays).
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