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OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

12) IV-F-10 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 12 of 30 
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«*-? 

Statement Before the U.S. 

Environmental Protection Agency 

Hearing on On-Board Refueling Vapor 

Recovery Systems. 

\ 

Adrian Lund 

September 26,1991 

F 

TITUITE 

AFIETY 

loos N GLEBE ROAD. ARLINGTON, VA 22201 (703) 247 1500 
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I am Adrian Lund, Assistant Vice President for Research for the Insurance Institute for 

Highway Safety, a nonprofit research and communications organization that identifies and 

develops ways to reduce motor vehicle crash losses. We are supported by the nation's 

property and casualty insurers. Thank you for the opportunity to present the Institute's views 

on the safety of on-board refueling vapor recovery systems. 

The Institute has long been involved in reducing the risks to the public posed by vehicle fires. 

For example, Institute research and crash testing in the early 1970s led to the strengthening 

of the federal motor vehicle safety standard on fuel system integrity. It was because of our 

concern about any action that can increase the risk of fire that the Institute entered the debate 

on controlling refueling emissions in 1986, when the Environmental Protection Agency (EPA) 

was considering two alternative approaches to trapping those emissions. The first approach 

involves capturing the vapors with recovery systems installed on board each motor vehicle. 

The other would trap vapors at the gasoline pump. The Institute was the first organization to 

oppose the on-board approach because it would increase the risk of fire in motor vehicle 

crashes. 

Since 1986, the National Highway Traffic Safety Administration (NHTSA), the National 

Transportation Safety Board, and others have confirmed the Institute's concerns about safety 

and also opposed the use of an on-board system because of its potential to increase the 

number of vehicle crash fires. On-the-road testing of vehicles with prototype on-board 

systems have raised additional safety concerns about fuel expulsion and fuel spitback that 

may occur with some on-board designs. Vapor lock problems with some on-board designs 

also can cause hesitation and sudden stalling, which increases the risk of a vehicle being 

involved in a crash. In addition to crash-related fire hazards, NHTSA has also identified the 

potential for increased numbers of safety-related defects because of the increased complexity 

of fuel systems designed to capture refueling vapors. The Institute agrees with NHTSA's 

assessment in this regard. 

Insurance Institute for Highway Safety 

1005 N. Glebe Road, Arlington, VA 22201 

September 1991 
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NHTSA Safety Assessment 

NHTSA's July 1991 report, "An Assessment of the Safety of On-board Refueling Vapor 

Recovery Systems," reiterates the safety problems associated with those systems. The 

primary reasons that on-board systems pose an increased risk of fire are the large size of the 

system components and the complexity of the design needed to meet the stringent vapor 

recovery requirements of the 1990 Clean Air Act Amendments. Because the charcoal 

canisters in which the vapors are captured must be much larger than current evaporative 

emissions systems and must function at high operating temperatures, they would contain 

much more vapor than current systems. As NHTSA points out, they will increase the 

likelihood of fires if a release of captured vapor should occur in the presence of an ignition 

source. And the laboratory testing done by NHTSA shows that three common ignition sources 

~ a spark, a hot surface, or a flame ~ that are present during normal vehicle operations or 

during a crash can easily ignite those vapors. 

The types of designs needed to comply with the emission requirements also make the 

systems vulnerable to failure in the wide range of crash configurations and severities that 

vehicles experience in real-world crashes. As NHTSA notes, These systems, with 

complicated mechanical nozzle seals and vapor control valves near the top of the fuel filler 

pipe, have performed very poorly in the limited collision testing that has been conducted." 

Quantifying the Increased Risk of Crash Fires 

NHTSA has noted the difficulties in quantifying the increased risk of crash fires with on board 

refueling vapor recovery systems. The major problem is the absence of reliable data. 

Although the police usually note fire events on crash reports, even crashes involving firerelated deaths are rarely investigated fully enough to determine the location of the fuel system 

failure. In many cases, the crash reports will not even indicate which vehicle in a multiple 

vehicle crash was the source of the fire, let alone the location of the fuel leak. And, if fuel 

spillage did not result in a fire, it is unlikely that the fact of the spillage would be noted. The 

unfortunate fact is that no crash data base contains the detailed information necessary to 

reach firm predictions about the incidence of crash fires. 

Insurance Institute for Highway Safety 

1005 N. Glebe Road, Arlington, VA 22201 

September 1991 
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Nevertheless, the risk of crash fires is real and cannot be ignored. Despite the scarcity of 

data, NHTSA has reported an indicative analysis of fire-related events associated with the 

introduction of the on-board evaporative vapor recovery system in 1971 model year cars. 

NHTSA estimated that the introduction of this smaller, less complicated system increased the 

incidence of crash fires in police-reported crashes by an average of 27 percent. The 

statistical accuracy of this estimate is limited by the data, but traditional statistical procedures 

suggest that the actual increase was at least 6 percent and may have been as great as 53 

percent. 

This increased risk cannot be ignored. So many serious motor vehicle crashes occur every 

year that even small increases in risk can translate into substantial numbers of additional 

crash fires. More than 19 million total crashes occur each year, and more than 2 million of 

these are severe enough for at least one vehicle to be towed from the scene. As NHTSA 

points out in its July 1991 assessment of on-board systems, some 28,800 passenger car and 

light truck fires occur annually in motor vehicle crashes. During 1978-1988, there were an 

average of 1,365 fatal injuries and nearly 12,000 nonfatal ones in these crashes. Although we 

cannot quantify how many more people would be injured in crash fires if all vehicles were 

equipped with on-board refueling vapor recovery systems, it is clear that use of those systems 

will needlessly expose motorists to possible injuries and death. 

Additional Risks: Safety-Related Defects 

The complexity of the design of on-board systems poses other risks that need to be 

considered. As NHTSA reports, since 1970 there have been 71 safety recalls, involving 

nearly 2 million vehicles, for defects in current evaporative emission systems. This recall 

situation would worsen with on-board refueling vapor recovery systems because of the 

increased number and complexity of the components used in their designs. Because most 

defects are related to mistakes in the manufacturing process, the complexity of the designs 

will make it easier for an error in one component to lead to an increased fire risk. Again, 

although it is impossible to quantify how many manufacturing mistakes would occur, it is clear 

that they will occur and expose the public to an increased risk of vehicle fire. 

Insurance Institute for Highway Safety 

1005 N. Glebe Road, Arlington, VA 22201 

September 1991 
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Conclusion 

NHTSA's most recent data analyses and testing again confirm that on-board refueling vapor 

recovery systems pose an increased and unreasonable risk of fire in motor vehicle crashes. 

There is no reason to impose additional hazards on motorists when a safe alternative exists. 

According to NHTSA, Stage II fuel vapor recovery devices on gasoline pumps have actually 

lowered the risk of fires at the pump. In addition, NHTSA reports that a study by the 

California Air Resources Board indicate that Stage II systems are more effective in controlling 

refueling vapors than on-board systems. EPA can achieve the goal of the Clean Air Act 

Amendments of 1990 of reducing refueling emissions without risking additional motor vehicle 

deaths and injuries by using Stage II systems on gasoline pumps. Given the unreasonable 

risk of death and injury posed by on-board system, there is no other rational choice. 

Insurance Institute for Highway Safety 

1005 N. Glebe Road, Arlington, VA 22201 

September 1991