EPA-HQ-OAR-2008-0708-DRAFT-0308[1]

From: Suchecki, Joe [JSuchecki@ngelaw.com]

Sent: Monday, December 14, 2009 2:12 PM

To: Tanya Parise

Subject: RE: oil analysis program

Tanya,

Here is the EMA response to your question regarding an oil analysis program. Our 

assumption is that you are interested in compression ignition/diesel engines at this 

time since the stationary diesel engine regulation needs to come out soon. The 

following response is relevant to compression ignition engines. Spark-ignited, 

gaseous fueled engines have different characteristics and we will work on getting you 

a specific answer for them shortly.

Joe

The following applies to compression ignition engines

 As EMA has mentioned in previous comments, the maintenance and oil 

change intervals for a specific engine depend on the characteristics, size, and 

operating cycle of the engine and there is no standard acceptable, maintenance 

schedules that fit all engine or operating conditions. For all but the largest stationary 

diesel engines, the best and most cost-efficient practice is to follow the recommended 

oil change interval recommended by the engine manufacturer. 

 For some large compression ignition engines, it may be cost effective to run an oil 

analysis program. Such programs can be used to adjust the recommended oil change 

interval as needed to minimize costs and ensure that the oil continues to meet any 

required specifications. For larger engines, say above 500 hp, or where the cost 

incurred by implementing an oil-analysis program can be balanced against savings 

from potentially longer oil change intervals. As an example, for a 100 hp diesel 

engine, the cost of collecting and analyzing the in-use oil is most likely greater than 

any savings that might result from a slightly longer oil change interval.

 

 Given the above, however, EMA does not believe that EPA should mandate an oil 

analysis program for any size engines. Rather, in terms of required maintenance, 

EMA believes that EPA should allow owners and operators the option to perform oil 

analysis as a way to demonstrate the feasibility of adjusting or extending the 

manufacturer's recommended maintenance interval if they would like to do so.

Joe Suchecki 

Director, Public Affairs 

Engine Manufacturers Association 

Two North LaSalle Street, Suite 1700

Chicago, IL 60602

Tel: 312-827-8734 

Fax: 312-827-8737 

jsuchecki@emamail.org 

www.enginemanufacturers.org 

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EPA-HQ-OAR-2008-0708-DRAFT-0308[1]

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contact EMA at (312) 827-8700 immediately. 

From: Tanya Parise [mailto:parise.tanya@ecrweb.com] 

Sent: Tuesday, December 08, 2009 1:27 PM 

To: Suchecki, Joe 

Subject: oil analysis program

Joe,

Melanie wanted me to ask you one additional thing. I know EMA has previously helped out with the 

issue regarding maintenance practices and I understand that it’s EMA’s position that there aren’t any 

maintenance practices that would be suitable to all engine types. However, we’d really appreciate 

your thoughts on a potential oil analysis program. I know Waukesha specifically recommends that oil 

changes be through such a program if feasible. What is EMA’s position regarding maintenance based 

on an oil analysis program? Is this something EMA would be in favor of? 

Tanya

Tanya Parise

EC/R Incorporated

501 Eastowne Drive, Suite 250

Chapel Hill, NC 27514

(919) 484-0417

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