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MSAPC  ADVISORY  CIRCULAR
  U.S. ENVIRONMENTAL PROTECTION AGENCY

  OFFICE  OF AIR AND WASTE MANAfiBKNT  	MOBILE SOURCE AIR POLLUTION CONTROL
     A/C  NO.JL2LS-1               November 17, 1976               PAGE T QF-L. PASES
       SUBJECT:  Compliance With Raquixamen.es of Lead RegulaHrms Regarding
                Unleaded Fuel
      A.  Purpose

           The purpose of  this Advisory Circular is to rtsvibe Advisory Circular
      32B co permit a wider range of acceptable locations for the filler inlet
      unleaded gasoline label.  This Advisory Circular amplifies  and does not
      supersede Advisory Circular 32B.
           1.  On January 6, 1975 Advisory  Circular 32B was published to clarify
      the requirements  of the lead regulations  (40 CFR Part 80)  regarding the use
      of unleaded fual.

           2.  Advisory Circular 32B included a. discussion of  th* unleaded gasoline
      labeling requirements, and specifically described acceptable locations for
      ooth the instrument panel label and the gasoline conk filler inlet label.
      These specific  locations for unleaded gasoline labels were based on EPA's
      judgnent of the minimum requirements  LUL providing adequate notice to che
      vehicle operator and the gas station,  attendant of the unleaded fuel require-
      ments of the vehicle.

           3.  Since  the issuance of Advisory Circular 323,  several manufacturers
      have informed EPA of their interest in other locations for the gasoline tank
      filler inlet label.  EPA has been shown samples of labels  placed in such
      alternate locations and has determined that these alternate locations are
      acceptable.   Therefore, Advisory Circular 32B is being revised to permit use
      of altarnat* locations for thts gasoline tank filler inlet  label, provided
      those locations satisfy the applicable visibility requirements of Advisory
      Circular 32B,

           4,   Manufacturer's attention ie also dlrectpH t-n  paragraph F of Advisory
      Circular 32B, for the procedures by which manufacturers can assure themselves
      that  their plans for complying with the label requirements of &0 CFR 80- 24 (a)
      will  not subsequently be challenged by SPA..   Unless such plans are set forth
      as discussed  in paragraph F of Advisory Circular 32B,  the  issuance of a Certi-

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                 MOTKTION AGENCY* DAWN/USAFC
 ficate  of  Conformity 
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