Proposed Regulations for Portable Fuel Containers

1. Proposed Regulations for Portable Fuel Containers Refueling Spillage Control Project January 26, 1999 California Environmental Protection Agency Air Resources Board

2. Proposed Regulations for Portable Fuel Containers Workshop • Performance Standards - Section 2472 • Exemptions - Section 2473 • Innovative Products - Section 2474 • Administrative Requirements - Section 2475 • Variances - Section 2476 • Test Methods - Section 2477 • Severability - Section 2478 • Next Steps

3. 2472. Performance Standards for Portable Fuel Containers • Automatic shut-off • Automatic closure • No secondary vent • Minimum fuel flow rate(s) • Maximum permeation rate • Warranty • Removed displaced vapor collection standard

4. Automatic Shut-Off • Stops the fuel flow when the target fuel tank reaches a sufficient level • Eliminates refueling spillage • Ideal for hand held equipment with small volume fuel tanks • Actually makes refueling all equipment easier • Currently available spouts & spout/container combinations simple to use, require no special training or skills

5. Automatic Closure • Container remains closed when not in use and automatically closes after the refueling event • Together with no secondary vent specification this eliminates Transport losses, Storage losses, and substantially mitigates breathing losses • Impossible to store containers with open spouts • Spouts won’t need to be removed for container storage • For average consumers: no more gasoline odor in your vehicle during transport

6. No Secondary Vent • Only one opening for both filling and pouring • Imperative for proper automatic shut-off operation. • Makes the fuel container relatively tamper proof • With the decrease in overall flow rates compared to conventional containers, eliminates the temptation to open the vent to increase fuel flow rates • Manual venting of container done through spout

7. Minimum Fuel Flow Rate • Nominal capacities  2.5 gallons not less than 1 gallon per minute • Nominal capacities  2.5 gallon not less than 2 gallons per minute • Must maintain a minimum fuel flow rate to satisfy the end user • Removes the temptation to tamper with the container • Considering adding third specification for hand held equipment

8. Draft Fuel Flow Rate Data • Gravimetric test with all containers half filled, approximately 1000 grams of fuel dispensed per test • 1.25 gallon Vemco - 0.54 gal/min • 1.25 gallon Safe-Spout - 1.5 gal/min • 2.5 gallon Vemco - 1.9 gal/min • 2.5 gallon SmartFill - 1.1 gal/min • Average 1.25 gallon conventional - 1.6 gal/min • Average 2.5 gallon conventional - 2.6 gal/min

9. Maximum Permeation Rate • Does not exceed 0.2 grams for any 24-hour period as determined by (TM XX) • Testing not complete, development of test method dependent upon initial testing • Draft standard based on anticipated permeation rate of 1.5 grams/gallon/day and a barrier effectiveness of 90% • 1.5 grams/gal/day X 10% = 0.15

10. Maximum Permeation Rate • Permeation appears to be a function of temperature and wetted surface area • Increased container wall thickness only provides a transient solution - eventually permeation will occur at steady state rates • Since spill-proof containers will undoubtedly have thicker walls than conventional containers, ASTM F 852 test for Permeability will not accurately define true permeation rates • Permeation test must include sufficient time for preconditioning to saturate the HDPE with fuel to reach steady state permeation • Testing will include a barrier feasibility study - fluorination & sulfonation

11. Warranty • Warranted for a period of one year against defects in materials and workmanship • Due to the anticipated increase in the per unit cost of a spill-proof container as compared to a conventional container, this warranty deemed necessary to protect the consumers investment and to instill confidence at the point of sale

12. 2472. Performance Standards for Portable Fuel Containers • Target implementation date - 1/1/2001 • Section 2472 provides a 1 year sell-through • Eligibility in the sell-through requires containers to clearly display date of manufacture or representative date

13. 2473. Exemptions • Products manufactured in California for shipment, sale, and use outside of California • Type I and Type II safety cans • Containers with nominal capacities  1 quart • Considering ‘rapid refueling’ devices used in organized racing/competition events under the auspices of a recognized sanctioned body

14. 2474. Innovative Products • Creates a process for products using new designs, delivery systems, or other factors to meet the regulatory requirements • Intended to encourage research and creative development of spill-proof systems • Our goal is to ensure that the proposed regulation does not discourage further research and development of portable refueling containers

15. 2475. Administrative Requirements • Labeling requirement - “California Spill-Proof Container” • Provides identification for consumers at point of sale and identifies products during sell-through period • Considering adding flow-rate labeling requirement

16. 2476. Variances • Provides relief to any person who cannot comply with the proposed regulation due to extraordinary reasons beyond the person’s resonable control • ARB is currently seeking input from manufacturers and other interested parties to define small volume manufacturers • Possibly example: extraordinary economic hardship

17. 2477. Test Methods • ASTM F15.10 subcommittee is currently working on Provisional Standard Specification for Self-Closing Spouts • Where possible we will incorporate by reference ASTM Standards • Test method development for flow rate testing is currently being considered • Test method development for permeation will move forward once baseline and barrier feasibility tests are complete

18. 2478. Severability • Each part of this article is deemed severable, and in the event that any part of this article is held to be invalid, the remainder of this article continues in full force and effect

19. Next Steps • Consensus needed on flow rate issues • Complete permeation testing and barrier feasibility tests • Identify acceptable test method for the determination of permeation rates

20. More Information • www.arb.ca.gov/msprog/spillcon/spillcon.htm • Workshop presentation will be posted on the web site • Check the web site for a list of FAQ’s • Dean Bloudoff (916) 263-2070 • dbloudof@arb.ca.gov