Quon Kwan. Safety Considerations Related to Commercial Vehicles Using Natural Gas. Natural Gas Vehicle Technology Forum San Diego, CA October 17, 2012

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1 Safety Considerations Related to Commercial Vehicles Using Natural Gas Quon Kwan Natural Gas Vehicle Technology Forum San Diego, CA October 17, 2012

2 Outline Purpose Partners Federal Motor Carrier Safety Administration s (FMCSA) Jurisdiction Vehicles Regulated Under Federal Motor Carrier Safety Regulations (FMCSRs) Consultations and Site Visits Commercial Motor Vehicle Safety Issues Identified by Stakeholders 1

3 Purpose Purpose of project is to identify safety issues related to the use of natural gas in commercial vehicles Desired outcomes: Prevent fatalities, injuries, crashes & damage USDOT Goal Improve public health and safety by reducing transportation-related fatalities and injuries Reduce pollution & other adverse environmental effects USDOT Goal Advance environmentally sustainable policies and investments that reduce carbon and other harmful emissions from transportation sources 2

4 Partners Federal Motor Carrier Safety Administration issues Federal Motor Carrier Safety Regulations (FMCSRs) National Highway Traffic Safety Administration issues Federal Motor Vehicle Safety Standards (FMVSS) Fatigue accounts for 8.15% of all fatal truck crashes Federal Transit Administration administers Clean Fuels Grant Program (urban Lack transit of safe, buses) available parking contributes to truck driver fatigue State commercial vehicle enforcement officers and inspectors Facilitating truck parking is the carrot for complying with the Hours of Service rule 3

5 FMCSA FMCSA s focus Safety of the operations and maintenance of large trucks and buses Enforcement of the Federal Motor Carrier Safety Regulations (FMCSRs) Populations Regulated under the FMCSRs Motor carriers: Commercial Drivers: Commercial Vehicles: 0.5 million* 7.0 million* 10.3 million trucks 35 thousand motorcoaches *FMCSA Strategic Plan Motor Carrier Management Information System database as of Motorcoach Census 2010 American Bus Association 4

6 Vehicles Regulated under the FMCSRs FMCSRs apply to large trucks and buses [commercial motor vehicles (CMVs)] Truck > 10,000 lbs. GVWR, GCWR, GVW, GCW, whichever is greater * Van with > 8 passengers without compensation Bus with > 15 passengers regardless of compensation *GVWR = gross vehicle weight rating GCWR = gross combination weight rating GVW = gross vehicle weight GCW = gross combination weight 5

7 Natural Gas CMVs Potentially Subject to FMCSRs *Source: 2010 Inventory from U.S. Department of Energy, Energy Information Administration, Office of Energy Consumption and Efficiency Statistics 6

8 Consultations and Site Visits California Highway Patrol Westport Innovations Peterbilt Motors Kenworth Motors Daimler Trucks North America BAF Technologies Chart Incorporated Agility Fuel Systems Ryder (DOE ARRA grantee) Port of Los Angeles Golden State Express Green Fleet Systems The Dependable Companies Total Transportation Solutions, Inc. Southern Counties Express Harbor Express Los Angeles County Metropolitan Transportation Authority Foothill Transit Truck & Engine Manufacturer s Association American Public Transit Association Clean Propulsion Committee Commercial Vehicle Safety Alliance Vehicle Committee 7

9 Commercial Motor Vehicle Safety Topics Identified by Stakeholders* 1. Fuel system safety requirements for commercial motor vehicles (CMVs) using a) Compressed natural gas (CNG) b) Liquefied natural gas (LNG) 2. Labeling requirements 3. Training requirements 4. Accident reporting requirements 5. Vehicle conversion requirements 6. Driver inspection reporting requirements * Stakeholders include the organizations listed on the previous page 8

10 1a. Safety Requirements for CMVs using CNG Identified by Stakeholders CNG fuel containers must be Manufactured in accord with FMVSS 304 Removed from service after expiration date Inspected by a qualified fuel systems inspector Every 36 months [delete every 36,000 miles for CMVs] After a fire or DOT-reportable accident Protected from damage by Road hazards, loading/unloading, direct sunlight, exhaust heat, vehicle use Equipped with a Pressure Relief Device (PRD) PRDs must be vented to vehicle exterior to avoid ignition sources, engine & passenger areas Equipped with shut-off valve with another valve to isolate entire fuel storage system from the engine 9

11 CNG Tractor Photo courtesy of Dana Lowell Photo courtesy of Ryder, Inc. 10

12 1b. Safety Requirements for CMVs using LNG Identified by Stakeholders LNG fuel containers must be Manufactured in accord with DOT Spec 4L Society of Automotive Engineers (SAE) J2343 Equipped with a Pressure Relief Device (PRV) PRVs must be vented to vehicle exterior to avoid ignition sources, engine & passenger areas Equipped with shut-off valve & with another valve to isolate entire fuel storage system from the engine LNG fuel systems must be equipped with a backflow check valve at filling connection 11

13 LNG Transit Bus Photo courtesy of So Cal Metro 12

14 Items Identified for Further Examination Whether CNG fuel systems must include a pressure relief valve downstream of first stage regulator [SAE J2406, not National Fire Protection Association (NFPA) 52] Whether CNG and LNG fuel systems must have excess flow device on fuel lines to engine (SAE J2406/J2343, not NFPA 52) Whether CNG or LNG vehicles that use unodorized gas, must be equipped with a methane detection system (NFPA 52) 13

15 2. Labeling Requirements Identified by Stakeholders Label all on-board natural gas fuel containers per FMVSS 304 for CNG and NFPA 52 or SAE J2343 for LNG Label at fuel fill location noting fuel type Service pressure, fuel container volume, installer name & contact information, fuel container (CNG) expiration date, & date next container inspection due (CNG) Label location of manual shut-off valve(s) Label location of PRD outlet(s) (if obscured ) Height noted in driver compartment for roofmounted systems Blue diamond labels on vehicle exterior Lower right rear, front, and both sides below the DOT number 14

16 Example of Need for Height Label for Roof-Mounted CNG Tanks Photo courtesy of Clean Vehicle Education Foundation 15

17 Examples of Labeling on Vehicle Exterior 16

18 3. Training Requirements Identified by Stakeholders Require all employees who inspect, maintain, service, or repair CMV natural gas fuel systems to have minimum qualifications based on Apprenticeship or certificate training program by State, Federal agency or labor union Training program by NGV fuel system or vehicle manufacturer Automotive Service Excellence (ASE) certification Training and/or experience equivalent to 1 year Motor carriers to maintain documentation of qualifications 17

19 4. Accident Reporting Requirements Identified by Stakeholders Require for all DOT-reportable accidents that motor carriers add the following information: Vehicle fuel type (e.g., diesel, gasoline, LPG, CNG, LNG, or other to be specified) If the fuel type is CNG, Date of required fuel system re-inspection by qualified inspector Attach inspection report to DOT Accident Report 18

20 5. Vehicle Conversion Requirements Identified by Stakeholders Require for all commercial vehicles converted to natural gas operation after first commercial sale: Comply with all applicable FMCSRs Include labeling to identify the company that installed the natural gas fuel system Name of company Contact information (address, phone number, ) Date of conversion 19

21 6. Driver Inspection Reporting Requirements Identified by Stakeholders Require all drivers of CMVs using natural gas to add to their mandatory pre-trip and post-trip inspections, the following checks of the condition of the natural gas fuel system: On-board vehicle fuel containers* Fuel system components* Pressure relief devices Vent outlets for all PRDs and PRVs Visible or audible leaks* *parts of the natural gas fuel system at locations inaccessible to the driver are exempt from required driver inspection 20

22 Summary The research project identified the following safety topics: 1. Fuel system safety requirements for commercial motor vehicles (CMVs) using natural gas 2. Labeling requirements 3. Training requirements 4. Accident reporting requirements 5. Vehicle conversion requirements 6. Driver inspection reporting requirements 21

23 Contact Information Quon Y. Kwan Technology Division, W68-305, MC-RRT Federal Motor Carrier Safety Administration U.S. Department of Transportation Washington, DC

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