Underwriter Laboratories - Questions and Answers

The following questions and answers relate to technical issues regarding the Underwriter Laboratories (UL) E85 fuel dispenser activities. The Webcast focused on the Underwriters Laboratories (UL) progress report related to E85 fuel pump efforts.

Q: What is the level of risk that final the UL87standard would change the test protocol and therefore cause any testing done before UL87 is completed to be invalid?

A. The research that is being performed would serve as the technical basis for the requirements proposed to the standards, and based on that technical foundation it is expected that the adopted requirements in the standards will follow the certification requirements closely. However, it is possible that the requirements that obtain consensus could be different from the certification requirements. In this case several options exist regarding standard development, but these options would not invalidate any existing certifications to the certification requirements. The most likely outcome in this scenario is that there would be a transition period until the final adopted requirements become mandatory for all certified products; existing certifications would be maintained until the effective date to allow for verifying compliance with the adopted requirements. For more information, go to: http://www.ul.com/gasandoil/development_may07.html

Q: You indicated you used an E93 sample. What is that and where did you find it and its associated equipment?

A: E93 is a shorthand term for hydrated ethanol fuel that is currently being used in Brazil (93% ethanol, 7% water).

Q: If only one E85 dispenser was submitted to UL in May 2006, will any UL listing apply to all types of E85 dispensers or will a UL listing only apply to this one type of dispenser?

A: UL is developing safety requirements that will apply to E85 dispensers in general. However, each design from each manufacturer will have to be evaluated separately.

Q: What, if any, are the implications in the E85 listing process for biodiesel dispensers? In other words, are biodiesel dispensers going through this same process yet?

A: The work being done for high percentage ethanol fuels will have some relevance with respect to other biofuels. UL plans to leverage the work we are doing for E85 to the greatest extent possible. However, each biofuel will have to be considered individually to ensure the testing protocol represents the fuel's unique characteristics.

Q: What is the process underway for certifying biodiesel dispensers? What blend levels are being tested and what blend? Are biodiesel blender pumps being tested? What is the time frame for certifying a dispenser for various blends of biodiesel?

A: UL has not received any submittals for the Listing of biodiesel dispensers, nor has UL Listed any dispensers for the use with biodiesel. UL has initiated technical review of biodiesel fuels in order to begin preparation for subsequent certifications: however, at this time our resources are focused on the E85 activities.

Q: What is timeframe for beginning the static testing?

A: UL began short-term static testing on individual components in early March and began static testing of dispensers on March 26th

Q: How likely is it that a dispenser installed or allowed to remain in service under a waiver would have to be replaced once the UL listing becomes available? What are the possible scenarios that could result in this kind of stranded capital investment at a refueling station that now dispenses E85 or installs E85 dispensers before the UL process is complete?

A: UL certifications facilitate approval of installed equipment; however, the local authorities have the final say about the installation and continued operation of any dispensers.

Q: Given that many E85 pumps have been working in the field for well over 5 years, even a few that are 10 years old, without any apparent problems, why has it been hard to find equipment of this vintage, and why is the age range equipment you have "harvested" from the field only 1 to 3.5 years old?

A: UL tested the equipment that has been made available to us. Access to this type of equipment is limited in some cases by practical issues, such as service conditions. UL is still actively attempting to harvest equipment, and has received some preliminary offers to supply UL with equipment from the field that has been in service for longer periods of time. If you know of any additional equipment that may available, please contact UL.

Q: Many of the past, current and future E85 retail locations will be created by converting existing equipment. Will there be specific UL certified protocol, methods, and/or equipment to ensure that the converted equipment for E85 will be able to achieve UL listing? Has any company presented UL with an E85 "conversion kit" for UL certification? Does the current process involving full dispensers address this? If not, what is the plan to initiate a process to do so?

A: To date, no vendor has submitted a "conversion kit" for listing. UL would consider certification for field conversion kits for specific UL Listed equipment if such products were to be submitted. In addressing this type of product, the UL certification would have to address both the conversion process and its parts, as well as the ultimate compliance of the resulting product with the applicable requirements. Please note that there may also be additional and unique requirements needed for field conversion kits to address issues such as seal response to different fuels and galvanic interaction of metallic parts.

Q: We understand from our contacts with some manufacturers that the critical problem with this situation is the lack of test protocols for E85 dispensers. Once these standards are developed, it will be easier for manufacturers to design product based on these standards. Is your (UL) process one of setting standards or testing specific products or both? Do any standards exist for corrosiveness, leakage and so forth - for fuel dispensers regardless of the fuel? Does your product testing relate to these standards or will the testing process lead to development of these standards?

A: UL functions both as a standards development organization and a certification organization. In this case, existing standards for fuel dispensers and components of fuel dispensing equipment do not specifically address material compatibility with E85 fuel. UL is currently pursuing four concurrent initiatives to serve as input to the developing of test protocols and safety requirements, including: general information outreach, initiating a research test program, conducting field observations and harvesting product. Once the research is finalized and the science established, UL expects to be prepared to accept products for evaluation and certification. UL currently expects to finalize research and publish certification requirements by the end of the fourth quarter of 2007 and, immediately thereafter, accept E85 dispensing equipment for investigation to the safety requirements and certification of compliant equipment.

Q: What is the timeline for moving forward and completing this process? Do you think you will have an E85 certified dispenser by the end of 2007, sooner, or later? Will you have equipment certified for conversions by that time, sooner or later?

A: Once the research is finalized and the science established, UL expects to be prepared to accept products for evaluation and certification. UL currently expects to finalize research and publish certification requirements by the end of the fourth quarter of 2007 and, immediately thereafter, accept E85 dispensing equipment for investigation to those newly established test protocol and safety requirements that we determine appropriate based on the completion of the research. Once a manufacturer has demonstrated compliance with the requirements, they will have the ability to use the UL Mark.