Compliance with Requirements of Lead Regulations Regarding Unleaded Fuel, January 6, 1975


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EPA-420-R-75-001
January 1975
MSAPC ADVISORY CIRCULAR
U.S. ENYlRQNllfNTAL FMTfCTMfli MINGY
OFFICE OF AIR AND WASH NMMtSiNtlfT •
MOBUI SOURCE AIR POLLUTION CONTROL
A/C M.J2$
January 6, 1975
MSI 1 FUSES
SUBJECTi Complianca wi'th Requirement® of l>ead Regulations Regarding
A- Purpose
The purpose of this Advisory Circular is to explain the requirements
of the lead regulations (40 CFS Part 10) regarding the use of unleaded
fuel, and co emend Sections D.2.d. and E» of Advisory Circular 32A. This
Advisory Circular supersedes No. 3ZA beginning with the 1976 model year.
B. Background
1.	On January 10, 1973 EPA promulgated regulations (38 F,R. 1254)
prescribing e#rtain labeling and gasoline filler inlet requirements
applicable to aianufacturers of motor vehicles equipped with an emits ion
control device which she Administrator ha a detenaitied will be sigtiif ieantly
impaired by the use of leaded fuel. These regulations were amended on
September 21, 1973 (30 F.X. 2G449) to |>i'uvl(2ti fur Lh» approval uf ulLtiueLiv*
labels and to clarify the filler inlet restricter and 'immediate shut-off
re^ulrMttfeiiLa, The regulations were again amended on September 26, 1974
(39 F.R. 34538) to further clarify the filler ialet restriction requirements
ana to lower the fiowrate during tests for immediate shut-off. The
purpose of these requirements is to: 1) provide adequate notice to the
vehicle operator and the gas station attendant of the unleaded fuel
requirement of the vehicle, 2) co aeke accidental filling of the fuel
tank with leaded fuel almost iapossible, and 3) to make intentional
filling of the fuel tank with leaded fuel difficult.
2.	Advisory Circular No. 30 stated that manufacturers who elect
to certify non-catalysc-equlpped vehicles using unleaded fuel are required,
us a pzmdi rAexji	ieatiou, to meat the suae labeling and gasoline
filler inlet requirement*.
3.	EPA has been asked for tea interpretation of various provisions
of thane regulation*« EPA haa alae been. asked how a manufacturer may
assure himself that his vehicle conforms to the requirements of these
c emulations.
Unleaded Fuel

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4.	On November 2, 1573, EP4 published Advisory Circular Ho. 32 Co
clarity the requirements of the lead regulations (40 CM Part 80) regarding
the use of unloaded fuel. On January 10, 1954, Advisory Circular 32A revised
Section E.2. to conform with 40 CFH. 80.24(b) ae amended September 21, 1973.
That amendment set a performance standard rather than a dimejisiimai standard
for iumediate shut-off requirements.
5.	Advisory Circular No. 32B amends Section 33,2,d. to provide
more general guidelines for unleaded fuel label color requirements and
acceptance criteria. Section E. is amended to clarify the imsedlate
shut-off requirements and to eliminate the exemption of filler inlets
whose outer-most surfate or lip is too snail to allow insertion of
loaded fuel nossles. Such designs were accepted fpr the 1975 model year
but will not be permitted for 1976 and subsequent model years lor reasons
stated irt Section. E,2.
G. Applicability
the provisions of this Advisory Circular are applicable to gasoline-
fueled light duty vehicles, light duty trucks and -vehicles using gaooline-
fueled heavy duty engines which are equipped with an emission control
device which the Administrator has dRfprsnitied will be atfcnifieaatly
impaired by the use of leaded fuel, beginning with 1976 and later*model
years,
D. Labeling Requi rp-m<*nfrs
1.	40 CFa 80.24(a) requires che raauuTacturer to affix two or more
permanent, legible labels reading "Unleaded Gasoline Only" to vehicles
determined by the Administrator to be equipped with, devices which will be
significantly impaired by the use of leaded gasoline. (The label may
also read "Unleaded Fu*! Only",) One label is to be located on the
instrument panel of the vehicle and one label is to be located immediately
adjacent co each gasoline filler tank inlet* Both are to be readily
visible, in the English language in block letters, and in a-color that
contrasts with their back-ground. The regulations provide for the Administrator
to approve other label locations far the outside label which aehlpv* th®
purpose of this requirement (i.e., provide adequate norice to the gas
station attendant of the unleaded fuel requirement of th#» vehicle).
2,	For the purposes of this requirement, EPA d#£tetee certain
words used in the above paragraph as follows:
a. "Permanent" means the label cannot be removed easily.
The label need cot be wnl^ed on. It may be affixed in the bane manner
as other labels intended to be permanent which already appear on vehicles,
such as modal aaae«. A label on a filler lul«t cap, regardless whether
the cap is connected to the vehicle by chain, will not be considered a
permanent location.

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b.	"Immediately adjacent to" means on the door to the filler
inlet compartment or within six inches of the door to the filler inlet
compartment or, In the absence of a door, of the filler inlet cap,
provided that it may be at a greater distance if a greater distance ie
necessary to meet the "readily visible" requirements of Section D.2.c.
below.
c.	"Readily viaiMV means * location which is uuLimlered
from view (e.g., not on che underside of the bumper). The letters on
dashboard labels durC ho no smaller than 1/8" high. Tliti letters on
outside vehicle labels must be no smaller than 1/4" high.
d„ "Color that contrasts with their background" m&ms a
hue, chroaa, and/ox degree of reflectance easily distinguishable front the
background. Examples could be color combinations at least one primary
color away or black and white. Adequacy ot contrast will be judged on
an individual basis by EPA.
3. An example of an alternate label location to the outside label
requirement specified in the regulations which EPA would consider acceptable
is a label on a second door inside the filler inlet compartment which
would require a separate action from opening the outside compartment
door in order to reach the filler inlet.
E, Fillar Inlet Restriction and Immediate Shuc-Off Requirement
1.	40 CFR 80.24(h) requires the manufacturer to equip vehicles
with a gasoline tank filler inlet having a restriction which prevents
the insertion of a leaded fuel noaclc and allows the insertion of an
unleaded fuel nozzle. The regulations prescribe a test procedure for
de term-in-frig eoraplianca with chat requirement. The test procedure defines
"injmediate shut-off" to mean, no more than 700 c,c. of fuel pass into the
fuel tank when insertion and filling are attempted with a leaded fuel
nozzle whose terminal end and vacuum port are inserted within the filler
ialoc. During the test, che nozzle may be positioned in any orientation
or depth except those which would cause fuel spillage other than splash
tack. Futsl spillage is fuel which does not pass through che plane of the
fuel filler ir.let during an attempted fill. Fuel splash hack is fuel
which is splashed or reflected back from the filler inlet after it has
passed through the plane of the filler inlet. Positions which cause such
fuel spillage will not be used in test evaluation since they would net
normally be encountered in actual use.
2.	Further investigation haa convinced EPA that eonfigurations in
which the I.D. of the cam surface or outermost lip of the filler inlet
is small enough to prevent insertion of the leaded fuel noesle will not
meet the intent of the regulations, i.e., to limit the accidental or
intentional introduction 
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PROTECTION AGINCX • HiB/MllW
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inco che fuel tanks v&en. tilling is attempted vith a leaded fuel nozzle,
toy design or configuration which a manufacturer feels is not applicable
for evaluation under the fcisfc procedure specified in 40 CfR Fart 80 will
be evaluated by EPA on an individual hasls» at the request of the manufac-
turer* to determine if that design or configuration meets the 700 c.c.
maxictua fill requirement.
F. Procedure for Seteminiflg Assuranri* of Acceptable Labals and Filler
Inlet Kestrictors, and- Performance of Immediate Shut^Off" Sequireaeat~
1.	A manufacturer of light duty vehicles or light duty trucks
may, if b® wishes to assure hiccclf that his vehicles or truuks-cuuiurai
to the requirements of 40 CFR 80.24, describe his unleaded fuel label,
filler inlet rccKiccian, and the means to sAULsCy the iaaedlarc shut-
off requirement in his Part 2 application, a subsequent amendment to
the Pert t, ar in c. letter to {.he Director, Certification and Surveillance
Division, U.S. Environmental Protection Agency* 2565 Plymouth Road,
Ann Arbor, Michigan 48105. EPA will notify the ssnutacturer in writing
whether his vehicles or trucks conform with those regulations. In
making that determination, efa osy require actual labels and/or eoler
pictures of label locations, EPA may also require demonstration of the
filler inlet restriction and demonstration of the imediate shut-off on
a non-certification vehicle or on a vehicle simulation.
2.	A heavy duty vehicle manufacturer may, if be wishes to assure
hlraseif that his vehicles conform to the retirements of 40 CFR 80.24,
describe his unleaded fusl label, filler -trtlet restriction, and the
means to satisfy the immediate shut-off requirement in a letter to the
Director, Certification snd Surveillance Division, EPA, 2565 Plymouth Head,
Ann Arbor, Michigan 48105, EPA will notify the manufacturer in writing
whether his vehicles censors with those regulations. In making that
determination, IFA nay require actual labels and/or color pictures of
label locations. IfA say else require demonstvatiuu u£ the filler inlet
restriction and demonstration. of the immediate shut-off on a vehicle or
on a vehicle simiuJUtlou.
3.	Though certification test vehicles need not conform to the
requirements of 40 CFR 80,24» manufacturers are strongly urged to have a
clear indication near the filler Inlet compartment that the vehicle, if
applicable, requires unleaded fuel.
Eric 0. Stork
Deputy* Assistant AdminIserator
for Mobile Source Air Pollution Control
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