Underwriters Laboratories E85 Fuel Dispenser Listing
Triggered by the need to establish comprehensive safety requirements for an entire E85 dispenser system, Underwriters Laboratory (UL) in October 2006 suspended their official listings (certification) for individual parts that compose an E85 fuel dispenser. In October 2007, UL published listing procedures for evaluating and certifying E85 equipment. This technology bulletin offers an overview, including background, timeline, and contact information.
Recent Updates
- Background
- Current Underwriter Laboratories Actions and Timeline
- Fire Codes for Fuel Dispensers
- Interim Steps to Continue Deployment and Use of E85 Fuel Dispensers
- Examples of State Letters Granting Variances/Waivers
- Contact Information and Related Links
- Frequently Asked Questions
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Background
In May 2006, an E85 dispenser manufacturer approached UL with the first request to certify an E85 dispenser. At that time, no safety standards or testing protocols for E85 dispensing systems were in place in North America.
Though some individual components (like hoses and fittings) had previously been tested, a complete system (i.e., a complete assembled E85 dispenser) had never been tested by UL or any other nationally recognized standards development organization (SDO). This led to considerable confusion about what had been tested and listed by UL and what had not.
UL recently identified the need to establish safety requirements for E85 dispensers prior to certification, so material compatibility issues could be addressed. The decision to suspend authorization for individual components soon followed, so the new requirements could be applied consistently across all related products.
Normally individual manufacturers, industry groups, or insurance underwriters approach a SDO or testing agency well in advance of new product introductions and work together (via a consensus committee) to develop rigorous safety standards and testing procedures that will be used to evaluate their products. The group of manufacturers and industry partners interested in introducing these products to the market place usually bear the cost of this standards development and subsequent testing work. For more information on how the certification process usually works, go to the "Product Certification: Options Prior to Formal Adoption of a Standard" page on the UL Web site.
Since becoming aware of this issue, DOE has partnered with UL to help accelerate the process and assist in evaluating the safety performance of this equipment in the shortest time possible. The time it takes to complete the testing and issue subsequent certification (listings) depends on the how well the equipment performs. In October 2007, UL issued certification requirements and started accepting certification investigation requests for E85 fuel dispensing equipment.
At present, UL received dispensers for testing but has not listed dispensing related equipment for use with E85 fuel blends. Current dispensing equipment listings are limited to conventional fuels and ethanol blends up to 10%.
Current Underwriter Laboratories Actions and Timeline
The status of Underwriter Laboratory (UL) testing and progress towards certification is constantly changing. For the latest update, go to the UL Web page on Information Related to the Development of Safety Requirements for E85 Dispensers and Components.
Press Release: Underwriters Laboratories now accepting certification investigation requests for E85 fuel dispensing equipment (PDF 36 KB)
Press Release: Underwriters Laboratories now accepting certification investigation requests for gaskets and seals for use with E85 motor vehicle fuels (PDF 146 KB)
Fire Codes for Fuel Dispensers
Each authority sets the codes and standards for their jurisdiction. These codes may be set and enforced on a state, regional or local level. Two recognized organizations, the National Fire Protection Association (NFPA) and the International Code Council (ICC), provide standard codes that are adopted as-is or modified to meet local requirements.
- The NFPA 30A Code for motor Fuel Dispensing Facilities and Repair Garages as shown below is the basic requirement for listing E85 dispensers.
- 6.3.2 Dispensing devices for Class I liquids shall be listed.
- 6.3.2.1 Existing listed or labeled dispensing devices shall be permitted to be modified provided that the modifications made are "Listed by Report" by an approved testing laboratory or as otherwise approved by the authority having jurisdiction. Modification proposals shall contain a description of the component parts used in the modification and the recommended methods of installation on specific dispensing devices. Modification proposals shall be made available to the authority having jurisdiction upon request. For the complete code, go to http://www.nfpa.org.
- ICC 2006 International Fuel Gas Code - This loose leaf version of the code book (available at cost) has information on Code for Motor Fuel Dispensing Facilities and Repair Garages in the Installation Section (section number 305).
- New Safety Video for First Responders — This video, "Responding to Ethanol Incidents" (Media Player version, Quick Time version), was produced by the Renewable Fuel Association (RFA) and is targeted at first responders and ethanol plant operators. It details the proper materials needed to combat ethanol related spills and fires. In addition, the film explores the production and distribution of ethanol-blended fuels.
Interim Steps to Continue Deployment and Use of E85 Fuel Dispensers
Most jurisdictions allow alternate equivalent dispenser designs to be submitted for approval. Each jurisdiction has its own process and discretion in granting variances or waivers to approve designs not UL certified. For example NFPA 30A has Section 1.5, listed below, which addresses the process for approving equivalent equipment:
- 1.5 Equivalency. Nothing in this code is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this code. Technical documentation shall be submitted to the authority having jurisdiction to demonstrate equivalency. The system, method, or device shall be approved for the intended purpose by the authority having jurisdiction.
Examples of State Letters Granting Variances/Waivers
To date, numerous states and organizations have chosen to grant variances/waivers or have produced a written stance on the E85 Underwriter Laboratories Certification requirements. These letters from state officials are provided as reference:
- Colorado (PDF 67 KB)
- Illinois (PDF 134 KB)
- Iowa (PDF 31 KB)
- Michigan (PDF 18 KB)
- Minnesota (PDF 48 KB)
- New York (PDF 620 KB)
- Ohio (PDF 33 KB)
- Oregon (PDF 551 KB)
- West Virginia (PDF 38 KB)
- Wisconsin (PDF 23 KB)
For questions contact either your local state energy office or Clean Cities Coordinator:
Contact information is also available for states that indicated a position on continued use or installation of E85 dispensers (PDF 39 KB).
In addition, dispenser manufacturers who warrantee their products for use with E85 may provide information useful in the variance process. This is a summary of components and systems used by CLEANFUEL USA dispensers compatible with E85/E100 (PDF 718 KB). CLEANFUEL USA also has documentation on Underwriters Laboratories Safety Requirements Update by CLEANFUEL USA (PDF 392 KB).
Contact Information and Related Links
- U.S. Department of Energy's Clean Cities Technical Response Service (800) 254-6735
- Underwriter Laboratories E85 authority jurisdiction information
- Underwriter Laboratories Safety Standards
- National Fire Protection Association
- International Code Council
- Petroleum Equipment Institute's ethanol compatible equipment online guide
- UL Webcast - Presented for Clean Cities Coordinators by DOE
- March 2007 UL News - Underwriters Laboratories moves closer to completing E85 fuel dispenser.
- Ethanol Flexible Fuel Vehicle Conversion Kits
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