Tampering with the emissions system of modern commercial vehicles can seriously impact equipment performance and longevity, as well as pose substantial penalties for fleets, service providers and their employees. Is your operation at risk?
Modern diesel engines are finely tuned to meet stringent emissions requirements. Diesel components – e.g., pistons, fuel systems, turbochargers, exhaust gas recirculation (EGR) components, aftertreatment components, electronic system calibration, valves and actuators, etc. – are matched and intended to work together to minimize emissions while delivering excellent performance and fuel economy.
Attempts to circumvent this system can have serious and unforeseen consequences. For example, if the diesel exhaust fluid (DEF) is diluted or contaminated, a myriad of issues can occur, such as:
- Foreign material can plug the tank filter and cause issues with the pump priming and operation.
- If dirt gets past one filter, other issues may result downstream with filters designed to protect other system parts.
- Liquid contamination can get past the filters and cause issues with the catalyst and other components.
All of this can result in the incorrect amount of DEF being delivered to the catalyst to reduce the NOx, and lead to excessive emissions levels.
The Law
The U.S. EPA is tasked with setting heavy duty diesel emission standards in the United States, and the penalties associated with emissions tampering are substantial. As stated within the Clean Air Act (CAA), federal law prohibits altering or removing emissions control devices, as well as manufacturing, selling or installing defeat devices.
Section § 203(a)(3)(A) of the CAA states that any manufacturer or dealer who violates this section shall be subject to a civil penalty of not more than $37,500 per violation. Any person other than a manufacturer or dealer who violates this section, or any person who violates CAA § 203(a)(3)(B), shall be subject to a civil penalty of not more than $3,750 per violation.
Section 203 is entitled, Prohibited Acts - Motor Vehicle & Motor Vehicle Engines.
An RP for that
TMC Recommended Practice (RP) 1610, Emissions Tampering Guidelines, provides vehicle owners and service providers information regarding emissions defeat strategies/tampering devices and associated liabilities. Developed by TMC’s S.16 Service Provider Study Group, it also provides samples of tampering policies, as well as inspection protocols designed to reduce the risks associated with emissions tampering.
This RP applies to diesel-powered commercial vehicles that must comply with 2004 model year and newer emissions regulations, including October 2002 “pull-ahead” models.
RP 1610 recommends that emission systems should be maintained while in-service according to all applicable regulations and should be returned to an original, compliant condition if found to be non-compliant. Tampering with engine or emission systems could void the OEM warranty, as well as result in civil penalties from the U.S. EPA or state and local authorities.
TMC also recommends that service providers let their customers know if its service facility cannot support a non-compliant engine and emission system without bringing it back into compliance, and that the customer would need to pay the service provider to bring it back into its original compliant condition. If the service provider works on the engine and emissions system and leaves it in a non-complaint state, the service provider can be found liable.
This practice should be included in the service provider’s company policy on emissions tampering.
Not Purposeful
Usually, emissions tampering is not deliberate. Unintentional tampering or non-compliance situations most commonly occur when a technician forgets to properly reconnect wiring harness connections to the engine electronic control unit (ECU), creating a fault that normally would illuminate the malfunction indicator lamp.
Specific limits or triggers are unique to each OEM/vocation. However, if warning lights are ignored for a period of time, the engine could de-rate or may not allow an engine to restart.
This notification is not necessarily instantaneous, though. Depending on the OEM, several hours of operation could transpire between the time the onboard diagnostics (OBD) first determines a fault exists and the check engine light (CEL)/malfunction indicator light (MIL) is illuminated or the engine is de-rated.
There are many components to emissions performance and monitoring systems. To keep these systems operating, periodic maintenance is required that makes them susceptible to unintentional tampering. Many of these components are also exposed, making them susceptible to damage and willful tampering.
There are several methods to detect unintentional out-of-compliance conditions. Among them:
- Performing a walk-around inspection of the vehicle.
- Checking for warning lamp illumination, selective catalyst reduction (SCR) inducement (engine de-rating) or a low volume of DEF.
- Looking for third-party DPF defeat devices and/or third-party sensors that could have been added in the exhaust control system.
- Running a diagnostic check of OEM software to review component calibrations and specific engine software.
Lower the Possibility
To help reduce the risk of unintentional tampering:
- Follow proper procedures as supplied by the OEM when making repairs.
- Ensure inspection protocols include all visible parts of the emissions system and the specific area around components serviced to ensure sensors and harnesses are in working order, and all connectors are properly seated.
- Check DEF volume, or level, to determine if levels are at the required reading.
- Run the truck to see if the warning lamp illuminates, and follow up with a test drive to look for fault codes and additional warning lamp engagement.
RP 1610 also addresses intentional tampering situations, tampering identification guidelines and policy development and communication of emissions practices in the service provider environment. It is just one of more than 400 RPs created by TMC for the purpose of improving maintenance efficiency and providing the industry with trucking solutions.
Kenneth Calhoun is vice president of customer relations for Truck Centers of Arkansas (www.truckcentersar.com), a full-service dealership headquartered in North Little Rock, Ark. He serves as a service provider director at large on TMC’s board of directors and is the immediate past chairman of TMC’s S.16 Service Provider Study Group. TMC (www.trucking.org/Technology_Council.aspx) is North America’s premier technical society for truck equipment technology and maintenance professionals.
