Verification Process for Technology Manufacturers
Testing Information
This page provides information on the process a diesel retrofit manufacturer must go through to have his product's emission performance verified by EPA.
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Program Overview for Manufacturers
- Program Overview (DOC) (14 pp, 103K, November 2003)
As retrofit manufacturers, you must complete all steps leading to verification, and you must understand the in-use emissions testing requirements for which you will be responsible. The following are some important points:
- Technology Status: You must have a commercially available product that is ready to be installed on equipment, vehicles, or engines. No products still in the research and development stage will be verified.
Fuel Additives: If a retrofit technology consists of products that require fuel additives, the additives must be registered with EPA. Registered additives must be verified by EPA's health effects analysis process. The Agency maintains current Lists of Registered Fuel Additives. These lists contain approximately 6,000 additives.
If a retrofit technology includes an additive that is not currently registered with EPA, the kit manufacturer should consult 40 CFR Part 79 and contact the following EPA representatives to assess the appropriate course of action to register the additive:
Jim Caldwell (caldwell.jim.epa.gov), telephone: 202-343-9303 or
Jose Solar (solar.jose@epa.gov), telephone: 202-343-9027. - Provide Information: Understand the retrofit technology verification process and the information you will be required to provide.
- Applications for Verification: Applications for verification are available on this Verification Process web page. The application describes the minimum information required to begin verification.
- Statement of Verification: Upon verification of your technology, you will receive a Statement of Verification. Example Verification Statement (PDF) (3 pp, 130K, October 2001)
- Verified Retrofit Technology List: Once your technology is verified, EPA will add your technology to the Verified Retrofit Technology List. The list describes the technology, the percentage of expected emission reductions, and engine family compatibility.
- In-Use Emissions Testing: Understand and comply with the information in our In-Use Emissions Testing Requirements. This in-use test element is critical to whether the technology will remain on EPA’s Verified Technology List.
EPA held a Retrofit Technology Verification Workshop in December 2007 in Washington, DC. The workshop helped technology vendors, original equipment manufacturers, fuel and fuel additive makers, diesel engine technology organizations, and other participants learn more about verifying retrofit technologies and gain an understanding of the available opportunities for verified technologies. Agenda and Presentations
Verification Process Overview
- Verification Application: To begin the verification process, manufacturers must fill out and submit the application packet to CleanDiesel@epa.gov :
- Intent to Verify Form
- Application Form Guidance (XLS) (39K, October 2006)
- Application Form (XLS) (9K, October 2006)
- Manufacturer Cover Letter (DOC) (2 pp, 20K, September 2006)
The application form outlines the minimum information required for verifying a technology. EPA requires a clear explanation of:
- How the technology works
- Intended market application and engine groups
- The basis for emission reduction claims
- Any potential unique testing needs
- Operating criteria
- Potential concerns for health or safety
Engine Groups: EPA has grouped together engine families with similar emissions performance characteristics as illustrated in the tables below. A retrofit technology manufacturer may provide test data to show that a product tested on one engine family, within a grouping, may be applied to other similar engine families.
- Highway Engine Family Groups (PDF) (2 pp, 76K, May 2006)
- Non-road Engine Family Groups (PDF) (4 pp, 184K, May 2006)
- Test Plan Preparation
A test plan is developed based on the specific technology and manufacturer's intended market. EPA provides verification protocols which are the basis for testing devices, fuels, additives and SCR systems. Under these protocols, the Federal Test Procedure (FTP) is used to measure emissions. The engine, number of tests, fuels, devices, conditioning and other details are specified.
- Testing
Prior to testing, the manufacturer provides a degreened device (25-125 hrs of operation), an aged device (1000 hrs of operation), and the test engine to the test facility. EPA prefers that the devices are aged in the field.
- Data Analysis and Interpretation
Once testing is complete, the ETV program generates a report documenting the test program and results. EPA reviews data and determines if the technology has qualified for verification and assigns the level of emissions reduction. It is important to note that this report is posted on the EPA ETV web sites and is available to the public.
- In-use Testing Requirement
Once technologies are placed on the verified technology list and 500 units are sold, the manufacturer is responsible for conducting in-use testing on field-aged devices and reporting the results to EPA. Prior to retrieving devices, EPA will work with the manufacturer to select the appropriate sources of devices and establish test sequences.
Testing Protocols
- Devices: Final Draft Testing Protocol (PDF) (48 pp, 654K, February 2002) Generic Verification Protocol for Diesel Catalysts, Particulate Filters and Engine Modifications.
- Fuels: Final Draft Testing Protocol (PDF) (67 pp, 484K, September 2003) Generic Verification Protocol for Determination of Emissions Reductions Obtained by Use of Alternative or Reformulated Liquid Fuels, Fuel Additives, Fuel Emulsions, and Lubricants for Highway and Nonroad Use Diesel Engines and Light Duty Gasoline Engines.
- SCR: Final Draft Testing Protocol (PDF) (42 pp, 212K, September 2003) Generic Verification Protocol for Determination of Emissions Reductions from Selective Catalytic Reduction Control Technologies for Highway, Nonroad, and Stationary Use Diesel Engines.