Enforcement of engine oil and transmission product labeling and receipt requirements that impact quick lubes and their distributor partners is ongoing, and requires preparation and attention to detail to avoid violations, Automotive Oil Change Association officials said during an online webinar on July 28.
Amendments to NIST Handbook 130 over the last several years, dating back to 2013, added a variety of requirements relating to customer invoices, receipts and chain of custody. In 2013, an amendment required retail installers to provide detailed information on customer invoices or receipts regarding oil change services. In 2014, an amendment backed by AOCA required that distributors of bulk engine oil provide written documentation on the quality of oil on each delivery to oil change facilities.
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The handbook contains model laws and regulations, including regulations for engine fuels and lubricants. Some states automatically adopt the latest version of the handbook, while others go through legislative or rule-making processes to adopt the latest handbook revisions.
AOCA offers its members an industry training program teaching how to ensure operators and consumers receive the exact products they order while protecting fast lubes from violating NIST’s labeling and receipt requirements. The training program is for installers, manufacturers, distributors and retail sellers. AOCA officials discussed in the webinar what’s involved in state inspections concerning product labeling and receipt requirements, and what to watch for.
Inspectors are starting to show up in stores to check labels and fluids, said AOCA Director Dave Everett, who is vice president of business development and national sales, and training director for Service Champ. “In some states it’s random, and in some it’s complaint-driven,” Everett said. “It just depends on what state you’re in. If you’re in California, they inspect everything.” He noted that the frequency of inspections can vary, explaining that a state weights and measures agency official who is at a high level within the national organization may be more inclined to do inspections more frequently.
Inspections related to labeling and receipt requirements have been going on in California for a couple of years, said AOCA Secretary Eric Frankenberger, who is president of Pleasanton, California-based Oil Changers. “I think as with most things regulatory-wise, it usually starts in California and moves to the East,” Frankenberger said. “Between California and New York I think that’s where we’re going to see a majority of some of the newer stuff coming out.”
In California, he said, multiple types of inspectors will visit a quick lube location. “When it comes to oil quality and quantity, it’s the California Department of Food and Agriculture that generally handles that for us,” Frankenberger said. “They come through and check the quality of the product.” He noted they will examine labeling on both bulk product and packaged goods at the location.
“Usually they’ll announce themselves, when they come to the store, and provide you with a business card and tell you purpose of the inspection,” he recounted. “And then they’ll start through the process of looking at whatever items they have.”
Several years ago a requirement was added that overhead dispensers of automatic transmission fluid must be labeled “automatic transmission fluid,” rather than just “ATF.” This required quick lubes to update a significant number of labels on overhead reels and bulk tanks for the fluid.
Frankenberger said that different inspectors may interpret the same regulations differently, and that the variability can create challenges. “You have to be a little bit cautious and understanding of that,” he added.
The inspections for labeling and receipt requirements help bring integrity in the process, said Justin Cialella, president and CEO of Victory Lane Quick Oil Change in Plymouth, Michigan. “I think it’s important to understand, as legitimate, good operators, we want this type of regulation,” Cialella said. “This helps us. It really creates the trust between not only us and our suppliers, but us and the customers, which is really the most important thing.”
His company has worked with the Department of Agriculture in Michigan to help develop the inspection process. This was crucial because many inspectors had never been in a quick lube before, he noted. “We were able to help them understand what the layout is, and what to look for,” Cialella said.
The inspection process is typically straightforward, he said, with the inspector taking a sample of the fluid and checking the labels. “Right now it’s in the early stages of this,” he noted.
Cialella encouraged quick lube operators to work with inspectors to correct things that do not comply with rules. “Don’t get confrontational, which can lead to all kinds of other problems,” he cautioned. “In Michigan it’s a $1,000 fine per infraction. These can add up very quickly, and you don’t want to get on the other side of it.”
He said it’s also important to make sure a quick lube’s distributor partners are also up to speed on the labeling requirements. This includes helping the distributor make sure it has the right labels, that the product is labeled correctly and that it has a proper process for flushing hoses when switching between lubricant products.
Everett emphasized the importance of getting all the labeling correct. “You need to get labeling from your manufacturer or your distributor, and you have to have them on all your bulk tanks, and on your reels or dispenser guns or the console that they’re on,” he said. “Everything has to be labeled, and you have to make sure that it’s correct.” It’s not sufficient for labeling to say, for example, 0W-20 or 15W-40 alone, he added. Product brand, specifications and other information are also required.