Status Update: Requirements Have Not Changed (June 2008)

Recently, some Clean Cities coordinators have been hearing unsubstantiated rumors that the UL listing (approval) of E85 dispensing equipment has been delayed until at least the 4th quarter of 2008 --- reportedly due to "new or changing UL requirements that affect hoses, nozzles, and other hanging hardware." This has resulted in considerable confusion and is simply not the case. The following points should help to clarify the current status of E85 equipment testing and procedures at UL. Please read them carefully and share with your stakeholders that are interested in this matter.

• UL has not stated that dispensers, hanging hardware or any other components will not be certified until the 4th quarter of 2008 or any other time. They have consistently stated that UL Listings will be granted as soon as the equipment has been submitted to them and demonstrated to comply with the published requirements.
• In order for an E85 dispenser to be listed, all components and pieces of the dispenser must be suitable for use with E85 and compatible with each other. A listed dispenser must include or specify all of the hoses, nozzles, and other hanging hardware for configuration in the field.
• From the time the UL E85 dispenser requirements (UL Subject 87A) were published in October 2007, the requirement for specifying compatible equipment through the entire fuel path (including hanging hardware) has been present and has not changed. This is to address galvanic compatibility of the materials and to promote proper selection of all components in the fuel path. This is necessary based on the unique properties of high percentage ethanol/gasoline fuel blends. Dating back to October 2007 UL has been in communication with dispenser manufacturers on this topic. The responsibility for establishing a compatible E85 dispenser product lies fully with the dispenser manufacturers. This is not a new topic or a change in UL policy.
• UL does not mandate that manufacturers participate in this certification process, nor do they dictate when manufacturers submit their equipment for evaluation. This is done fully at the discretion of the equipment manufacturer. UL cannot begin an investigation until the manufacturer submits a product to UL and provides the necessary materials. UL has been accepting new submittals of E85 dispensing equipment ever since the publication of UL Subject 87A in October 2007, but some manufacturers have only recently submitted their systems and components for evaluation.
• Understanding the demand for E85 dispensers, UL has placed a very high priority on the requests they have received for certification of E85 equipment. UL has acted responsibly and with a sense of great urgency on those submittals received to date.
• The requirements of UL Subject 87A are different from requirements previously established for gasoline products. Since publishing UL Subject 87A in October 2007, the only changes UL has made have been to provide additional compliance flexibility options for some limited cases. Since publishing Subject 87A, UL has not established any additional restrictions in the evaluation procedures or protocol.
• Equipment may not always pass safety testing on the first try. If that is the case, then the manufacturer of the parts or equipment may need to modify their design and then resubmit to UL for re-testing. This takes time and is not a case of simply asking UL to "speed up the process." The testing agency has no control over whether the products being sent to them will pass or fail.