Comment and Ballot Resolution API 1525A

Transcription

1 Comment and Ballot Resolution API 1525A Results and Comments June 27,

2 1525A Voting Summary (April 4, 2012) FirstName LastName CompanyName VotingCategory Vote James Linden TOTAL Lubricants USA, Inc. Abstain Matthew Ansari Chevron Global Lubricants Affirmative Barbara Dennis BP Lubricants USA Incorporated Affirmative Reginald Dias ConocoPhillips Affirmative Gail Evans Lubrizol Corporation, The Affirmative Joan Evans Infineum USA L.P. Affirmative Harji Gill Pinnacle Oil Affirmative Luc Girard Petro-Canada Affirmative David Gray Evonik - RohMax USA Inc. Affirmative Larry Kuntschik ILMA Affirmative Scott Lindholm Shell Global Solutions Affirmative Glenn Mazzamaro R.T. Vanderbilt Company, Inc. Affirmative Dan Pridemore Afton Chemical Corporation Affirmative Greg Raley Motiva Enterprises LLC Affirmative Thom Smith Ashland Consumer Markets/Cummins Filtration Affirmative Paula Vettel Amyris Inc Affirmative Rodney Walker Safety-Kleen, Lubricants Division Affirmative Mike Brown SK Lubricants Americas Inc. Negative Tom Olszewski ExxonMobil Lubricating & Specialities Company Negative

3 1525A Affirmative w/comments Comment Evans (Lubrizol): (6.5.3) While we understand the desire to not commingle additives for tracking purposes, the statement that - "Mixing different oils with different additive systems may cause adverse reactions" is unnecessarily alarmist and runs counter to the requirement for oils to pass D6922 Homogeneity and Miscibility as required for all API S categories. Proposed Resolution Remove the phrase "may cause adverse reactions" and change to "Mixing oils with different additive systems is in conflict with requirement under to provide sufficient documentation to identify product properties and quality."

4 Paragraph w/accepted Editorial Change Two or more products with different properties as identified in items a through e of shall not be commingled, even if the products are similar. Mixing different oils with different additive systems may cause adverse reactions and is in conflict with the requirement under to provide sufficient documentation to identify product properties and quality. Tanks shall be drained and flushed between different products, different grades of the same product, and different products or product groups. 4

5 1525A Affirmative w/comments Comment Girard (PetroCanada): We are not sure that addresses the issue of what is in the customer s tank vs what was on the incoming delivery truck. Paragraph indicates that products from different companies should not be commingled, even if the product is similar. It is not clear whether this is the responsibility of the Distributor/Marketer or the Installer. If this is a requirement, then the onus should be on the Installer as only they know what is in their tank. Proposed Resolution Closing sentence in should read: "The installer shall ensure that tanks are drained and flushed between different products, (...)"

6 Paragraph w/accepted Editorial Change Two or more products with different properties as identified in items a through e of shall not be commingled, even if the products are similar. Mixing different oils with different additive systems may cause adverse reactions and is in conflict with the requirement under to provide sufficient documentation to identify product properties and quality. The distributor shall ensure that Tanks shall be are drained and flushed between different products, different grades of the same product, and different products or product groups. 6

7 1525A Affirmative w/comments Comment Girard (PetroCanada): Requirements regarding invoices at the various levels (5.3.5 as one example) stipulate a need to specify licensing category on the invoice. We are confronted with invoicing-software limitations that do not always allow this due to insufficient characters in the product name field. Some passages of Section 5.1 might be interpreted as allowing this information to be supplied electronically by the marketer. Proposed Resolution If an electronic submission option is valid, the practice should be made explicitly available, ideally in sections and/or An alternate means of allowing this would be to accept traceability on the basis of product codes.

8 Paragraphs and w/accepted Editorial Change The marketer/blender shall clearly identify to all recipients for each engine oil to be supplied the API license status, API service category, SAE viscosity grade, and brand name. Notification may be made by paper or electronic record The marketer/blender shall verify an engine oil s license status by providing a valid copy of its Schedule A License Agreement or citing API s on-line Directory of Licensees ( Notification may be made by paper or electronic record. 8

9 1525A Affirmative w/comments Comment Raley (Motiva): (6.4.2) Some distributors may use IBCs or Intermediate Bulk Containers - these perform similar function as Totes but may not be referenced as Totes. Suggest we add "or IBC(s)" where the word "Tote(s)" is. Not sure if we need to define IBC (as Tote is not defined). Proposed Resolution Retain Samples from Totes and/or IBCs...oil by tote and/or IBC shall...

10 Paragraph w/accepted Editorial Change Retain Samples from Totes and/or IBCs A marketer/blender delivering engine oil by tote and/or intermediate bulk containers (IBC) shall retain at least 4 ounces of engine oil loaded into the tote. The samples shall be retained for a minimum of 6 months in an environment free from exposure to UV light to prevent deterioration and contamination 10

11 1525A Affirmative w/comments Comment Evans (Infineum): (7.3.1) Is there a procedure for what to do if you specify a brand and it s not available? Do you get offered a different brand? Does this order get rejected? and you have to approve an alternate? or is it sufficient to be able to 'reject' the oil upon seeing the information provided in Proposed Resolution Add comments on what to do if the specific oil ordered is not available

12 Paragraph w/accepted Editorial Change When ordering engine oil from a distributor, an installer shall request a specific brand, SAE viscosity grade, API service category, and quantity of oil per the information agreed-upon by the entities involved. As an example, the installer staff member responsible for ordering engine oil would order 2,000 gallons of Brand X SAE 5W-30 API-licensed ILSAC GF-5/API SN engine oil. If the distributor no longer carries the brand requested, the installer shall request and receive the information required under before accepting a substitute brand. The API license status of the oil shall be confirmed by the distributor. API-licensed oils are listed on-line at 12

13 1525A Comments Comment Baker (ExxonMobil): ASTM D4052 is incorrectly labeled as a viscosity test. It is actually "for density, relative density and API gravity by digital density meter" Proposed Resolution Change text for D4052 to correct ASTM wording. Add ASTM D4683 and ASTM D6616 to the normative references. Also, why are the HTHS methods not included in the normative references? ASTM D4683 and D6616 are required in parts B/Q.

14 Paragraph w/accepted Editorial Change The C of A should include results from tests as agreed between the marketer/blender and the oil recipient (see 5.2.1). Examples of tests include the following: a. Kinematic viscosity at 100 C ASTM D445 or D7279. b. temperature for viscosity grade (defined in SAE J300) ASTM D5293. c. Elemental analysis ASTM D4951, D4927, D6481 or D5762. d. Appearance (Visual). e. Specific gravity/density Density, relative density and API gravity by digital density meter (ASTM D4052). f. Pour point (ASTM D5949, D5950, D5985). 14

15 1525A Comments Comment Linden (Total): I tried to get information about our local quality system in API zones, but I have poor return and not enough detail. As a consequence I find it very difficult to say whether our affiliates are able to follow the rules of the new version of the API 1525A. Accordingly, I suggest either a neutral or an abstention vote.

16 1525A Negative Comment Olszewski (ExxonMobil): General- XOM Supports the objectives of the Program 1. What resources will API put on program? 2. How will API generate funds for program? 3. ExxonMobil believes timeline is aggressive and needs to allow sufficient time for implementation by interested companies. 4. How will multibranded distributors be managed? How will installers offering both licensed and unlicensed oils be certified?

17 1525A Negative Comment Olszewski (ExxonMobil): ( ) Concerned with requirement to retain samples kept for 6 months. (5.3) Including API Service Category and license status on C/A and Bill of Lading may require changes to software systems. (5.3.4) Retains kept for 6 months (5.3.4) Should be modified to include words "each compartment of" before "the delivery vehicle. ( and 6.2.4) A typo? Could not find in 1525A. (6.5.3) Flush oil should be specified (7.4.4) Why would the installer sample a tote and not a bulk delivery?

18 Resolutions of Negatives and Comments April 4 resolutions considered editorial and incorporated into revised version 1525A At May 10 Lubricants Group meeting, ExxonMobil changed negative to affirmative after API issuance of attached timeline and confirmation of editorial change to length of retain requirement for distributors On May 18, SK offered to change negative to affirmative after removal of reference to Part Q and editorial change to and

19 Retain Sample Requirement (multiple citations) Retain Samples The marketer/blender shall retain at least 8 ounces of product from each blend, and these retain samples shall be traceable to the batch. The marketer/blender shall retain samples for a minimum of 3 months (up to 6 months is recommended) in an environment free from exposure to UV light to prevent deterioration and contamination. 19

20 Milestones Approve 1525A 04/01/12 04/15/12 Pilot 04/15/12 08/31/12 Design 03/26/12 04/30/12 Select participants 04/15/12 04/30/12 Run pilot 05/01/12 08/31/12 Evaluate results 09/01/12 9/31/2012 April May June July August Sept Oct Nov Dec Database Adjust database based on pilot results 05/01/12 09/30/12 Modify licensing guidelines based on pilot results 05/01/12 09/30/12 Modify 1525A as Appropriate 05/01/12 10/31/12 Editorial changes 05/01/12 10/31/12 Ballot substantive changes 09/15/12 10/31/12 Licensing Accept license applications 11/01/12 First licensing date 12/01/12 Promotion Modify website 04/01/12 05/31/12 Design MOM promotion 04/01/12 06/30/12 Launch Promotion 07/01/12 Evaluate & Tweak MOM Promotion 08/01/12 12/31/12 20

21 1525A Negative Comment Brown (SK): ( ) Part Q does not require reporting of ASTM color and pour point. Therefore these test requirements have no baseline for tracking. ( ) Part Q does not require reporting of density and pour point. Chain of custody from Blender to Distributor has no baseline data under Part Q to verify these properties. (6.2.3) Density checking by the Receiving location has no significance to the quality and chain of custody for bulk oil. (6.2.5 and 6.4.2) Retain samples are difficult to keep at Installers. Proposed Resolution Delete Color and pour point requirements. Delete density and pour point requirements from If product density is to be used throughout the chain of custody (Blender and Distributor), this property must be reported on Part Q with a reference temperature. Density without a temperature is meaningless. Delete Installer requirement to keep retain samples. If all deleted, SKL vote is changed to affirmative.

22 Paragraph w/proposed Change Batch/Quality Certification Testing The marketer/blender shall run appropriate tests on each batch to certify the oil has been blended to meet identifiable properties on Part Q. Tests should include the following (appropriate ASTM procedures, when available, are recommended): 22

23 Paragraphs and Retain Samples The distributor shall draw a minimum of 4 ounces of engine oil from each delivery vehicle compartment from which delivery is accepted. The sample shall be traceable to the specific production batch and shall be retained for a minimum of 6 months in an appropriate environment free from exposure to UV light to prevent deterioration and contamination Retain Samples from Totes A marketer/blender delivering engine oil by tote shall retain at least 4 ounces of engine oil loaded into the tote. The samples shall be retained for a minimum of 6 months in an environment free from exposure to UV light to prevent deterioration and contamination. 23

24 Paragraph w/proposed Change Batch/Quality Certification Testing The marketer/blender shall run appropriate tests on each batch to certify the oil has been blended to meet identifiable properties on Part Q. Tests should include the following (appropriate ASTM procedures, when available, are recommended): 24

25 Paragraph w/proposed Change (6.2.3 also requires change) The C of A should include results from tests as agreed between the marketer/blender and the oil recipient (see 5.2.1). Examples of tests include the following: a. Kinematic viscosity at 100 C ASTM D445 or D7279. b. temperature for viscosity grade (defined in SAE J300) ASTM D5293. c. Elemental analysis ASTM D4951, D4927, D6481 or D5762. d. Appearance (Visual). e. Density and relative density and API gravity by digital density meter specific gravity/density (ASTM D4052) or API gravity by D1250. f. Pour point (ASTM D5949, D5950, D5985). 25

26 SK Proposed Resolution Does Lubricants Group accept SK proposed resolution? 26