| Independent Shops By Kenneth Calhoun, Service Provider Technology & Maintenance Council (TMC) Board Member; Immediate Past Chairman, TMC S.16 Service Provider Study Group; and Vice President, Customer Relations, Truck Centers of Arkansas Emissions system tampering poses great risks for fl eets and service providers Best practices to avoid serious and unforeseen consequences Tampering with the emissions system of modern commercial vehicles can seriously impact equipment performance and longevity, as well as pose substantial penalties for fl eets, service providers and their employees. Is your operation at risk? Modern diesel engines are fi nely tuned to meet stringent emissions requirements. Diesel components – e.g., pistons, fuel systems, turbochargers, exhaust gas recirculation (EGR) components, aft ertreatment components, electronic system calibration, valves and actuators, etc. – are matched and intended to work together to minimize emissions while delivering excellent performance and fuel economy. Attempts to circumvent this system can have serious and unforeseen consequences. For example, if the diesel exhaust fl uid (DEF) is diluted or contaminated, a myriad of issues can occur, such as: • Foreign material can plug the tank fi lter and cause issues with the pump priming and operation. • If dirt gets past one fi lter, other issues may result downstream with fi lters designed to protect other system parts. • Liquid contamination can get past the fi lters and cause issues with the catalyst and other components. All of this can result in the incorrect amount of DEF being delivered to the catalyst to reduce the NOx, and lead to excessive emissions levels. The Law Th e U.S. EPA is tasked with setting heavy duty diesel emission standards in the United States, and the penalties associated with emissions tampering are substantial. As stated within the Clean Air Act (CAA), federal law prohibits altering or removing emissions control devices, as well as manufacturing, selling or installing defeat devices. Section § 203(a)(3)(A) of the CAA states that any manufacturer or dealer who violates this section shall be subject to a civil penalty of not more than $37,500 per violation. Any person other than a manufacturer or dealer who violates this section, or any person who violates CAA § 203(a)(3)(B), shall be subject to a civil penalty of not more than $3,750 per violation. Section 203 is entitled, Prohibited Acts - Motor Vehicle & Motor Vehicle Engines. An RP for that TMC Recommended Practice (RP) 1610, Emissions Tampering Guidelines, provides vehicle owners and service providers information regarding emissions defeat strategies/tampering devices and associated liabilities. Developed by TMC’s S.16 Service Provider Study Group, it also provides samples of tampering policies, as well as inspection protocols designed to reduce the risks associated with emissions tampering. Th is RP applies to diesel-powered commercial vehicles that must comply with 2004 model year and newer emissions regulations, including October 2002 “pull-ahead” models. RP 1610 recommends that emission systems should be maintained while in-service according to all applicable regulations and should be returned to an original, compliant condition The consequences from tampering with diesel engine emission systems could not only void the OEM warranty, but may result in civil penalties from the U.S. EPA or state and local authorities. Photo courtesy of DK Communications if found to be noncompliant. Tampering with engine or emission systems could void the OEM warranty, as well as result in civil penalties from the U.S. EPA or state and local authorities. TMC also recommends that service providers let their customers know if its service facility cannot support a non-compliant engine and emissions system without bringing it back into compliance, and that the customer would need to pay the service provider to bring it back into its original compliant condition. If the service provider works on the engine and emissions system and leaves it in a non-complaint state, the service provider can be found liable. Th is practice should be included in the service provider’s company policy on emissions tampering. Not Purposeful Usually, emissions tampering is not deliberate. Unintentional tampering or non-compliance situations most commonly occur when a technician forgets to properly reconnect wiring harness connections to the engine electronic control unit (ECU), creating a fault that normally would illuminate the malfunction indicator lamp. Specifi c limits or triggers are unique to each OEM/vocation. However, if warning lights are ignored for a period of time, the engine could de-rate or may not allow an engine to restart. Th is notifi cation is not necessarily instantaneous, though. Depending on the OEM, several hours of operation could transpire between the time the onboard diagnostics (OBD) fi rst deter- EMISSIONS TAMPERING is typically unintentional. 30 FLEET MAINTENANCE ❚ AUGUST 2016 ❚ VehicleServicePros.com
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