Lifting the Veil on Bulk Oil

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Consumers buying oil changes will know what theyve received, and bulk motor oil shipments will require documentation in some states starting in July 2013, thanks to recent handbook amendments adopted by the National Conference on Weights and Measures.

One amendment to National Institute of Standards and Technology Handbook 130 requires retail installers to provide detailed information on customer invoices or receipts regarding oil change services. The required motor oil information includes viscosity, intended use, brand and American Petroleum Institute service category. The other amendment requires providing the same informationon invoices or similar documentation that accompanies bulk oil shipments. A house brand or private label brand is acceptable under the amendments. Both also require a visible cautionary statement whenever the motor oil doesnt meet an active API service category.

NCWM adopted the amendments at its annual meeting held July 15-19 in Portland, Maine, and they become enforceable July 1, 2013. NIST Handbook 130 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.

The American Petroleum Institute spearheaded the amendments, which were also supported by the Independent Lubricant Manufacturers Association and the Petroleum Quality Institute of America. The Automotive Oil Change Association expressed concerns to NCWMs laws and regulation committee that the amendments could be detrimental to the fast lube industry and consumers.

APIs Engine Oil Program Manager Kevin Ferrick said that while the amendment changes are important to APIs Motor Oil Matters program and consistent with the chain-of-custody standard API is readying to issue, the main point was to better inform consumers about bulk motor oil being installed in their vehicles.

We realized that the previous weights and measures rules only applied to packaged goods, Ferrick told Lube Report. So someone who was buying a quart or a gallon of motor oil had the information necessary to make an informed decision on the engine oil to be installed. Unfortunately, we realized the same was not true for bulk engine oil.

As part of its effort to sample motor oil in the marketplace, API tests products drawn from locations that install engine oil from bulk containers. In some cases, we were having a hard time identifying the proper chain of custody – in other words, identifying where the products came from, he noted. That included determining what company truly manufactured the product and whether it was really the viscosity grade it was supposed to be. Determining service category could also be a challenge.

So what we decided was at a minimum, vis grade, brand name and service category or performance level are really kind of the minimum things a consumer needs to know, he said. So thats why when you look at the amendments language that was approved, it was really focused on that – the customer receipt from the oil change identifies the vis grade, brand name and service category or performance level of the engine oil installed.

This particular change became a priority for API, Ferrick continued. Consumers had protection when they purchased packaged products, and it made no sense not to have it for bulk products, particularly when engine manufacturers and OEMs have very specific instructions on oil that can be used. We found that on bulk receipts, sometimes you would get enough information where the consumer could actually show that they got the oil recommended for their vehicle but that wasnt always the case.

According to Ferrick, API tested bulk motor oil samples from 109 locations during 2011, including from auto dealers, quick lubes and service stations. Seventy one percent of those locations identified the vis grade of the engine oil installed; however, only 44 percent provided a marketer or brand name and only 14 percent provided a performance level.

ILMA General Counsel Jeff Leiter said the association offered to review the changes, agreed with them and offered its support to API to help get the handbook amendments across the finish line this year.

The associations primary concern was with the amendments effect on the paper flow that would accompany bulk shipments, he noted. We did add bulk to our testing program last year, Leiter said. Based on the results of the testing, and anecdotal comments from members, bulk seems to have issues associated with matching up performance of the product with whats claimed. By having more detailed paperwork, that would hopefully improve the relationship between performance claims and the actual product itself.

He noted that API is balloting its Recommended Practice 1525A, which calls for chain-of-custody documentation for bulk oil shipments in support of APIs Motor Oil Matters program. With the weights and measures provision, and with the API Recommended Practice, assuming its adopted, it becomes something which ILMA then can enforce as part of its testing program under the associations code of ethics, Leiter said. Hopefully that ability will help to enhance the paper flow with bulk shipments by ILMA members.

PQIA President Thomas Glenn said in July 16 comments to the NCWM Laws and Regulations Committee that in addition to a consumers right to know the quality of the oil they purchase, they also require documentation verifying that quality to maintain warranty coverage for their cars.

Viscosity grade and API Service Classification are the most common specifications listed, but other OEM specifications may also be required, he stated. The invoice or receipt from the installer must contain this vital information to protect the customer, and where all OEM specifications are not listed, knowledge of the brand may allow the customer or car manufacturer to verify the suitability of the oil.

He noted that much like nutritional facts on food labels and octane ratings for gasoline, visibility of the metrics for engine oils increases awareness and helps consumers make informed buying decisions. Consumers shouldnt be buying blind, Glenn told Lube Report. This is a critically important product you use in your car. For most its the second largest investment in their lives.

I think it moves the ball forward quite a bit in terms of getting it done but theres still work to be done, he said of the adopted handbook changes. The next hurdle is to push to have each state adopt it as written. That still leaves us quite a distance from the endgame, which is to have a system in place where Weights and Measures is checking bulk, theyre verifying the brands that are said to be used are being used, that they meet the API service classifications, and to rigorously test and enforce the Weights and Measures requirements.

In comments to NCWMs Law and Regulations Committee July 11, the Automotive Oil Change Association said it was imperative that any installer labeling and/or receipt information requirements be matched by corresponding NCWM requirements for motor oil distributors.

Installers cannot purport to verify via any form of documentation information that distributors have not documented at delivery, AOCA asserted. For NCWM to require otherwise would be manifestly unfair to installers by subjecting them to liability for the bad actors of distributors without any paperwork trail to rely upon in their own defense.

AOCA pointed out that fast lubes follow recommendations for fluids, including motor oil, which means they carry a wide variety of packaged motor oils to accommodate very old, very new and specialty vehicles. The association sought the addition of a sentence to each amendment clarifying that no cautionary statement per SAE J183 or other negative designation such as obsolete or inactive shall be necessary where the motor oil used is in the category of motor oil originally designated for the consumers vehicle. The adopted amendments didnt include AOCAs suggested sentence.

The association also urged NCWM to eliminate the trademark requirement from the list of brand information under both amendments, saying oil companies have been notoriously difficult to work with regarding trademark usage. Listing of trade name should suffice for identification purposes. The amendments kept trademark on the list.