Inspection Bulletin 2017-05 FMCSA RE: FMCSA Guidance on Engine Year

With the implementation of Electronic Logging Devices (ELDs) there has been an increase in the number of driver’s and carriers utilizing pre-2000 engines in their post 2000 tractors in an attempt to avoid the ELD requirement. CVSA bulletin 2017-05-ELDs (Page 1, & Page 9-12) speaks to this issue but doesn’t not specifically answer how remanufactured engines should be treated. Detroit Diesel offers customers an option to purchase directly through their factory dealers, a REMANUFACTURED (as opposed to rebuilt which can be done at a local shop and not alter the serial number) engine. This issue speaks specifically to a Series 60 Detroit Diesel Engine, series of engines made between approximately 1987 and 2011 was various variations. According to Detroit Diesel (see attached document) these engines come with serial numbers, new build dates, and emissions labels certifying them compliant for their newly remanufactured date. Roadside, a remanufactured Detroit Diesel engine can easily be determined by looking at the engine serial number which will be in a format similar to (06RE*****, vs 06*******) where the “RE” indicates Remanufactured. Detroit Diesel indicates all previous information to determine what year block or other parts were used to remanufacture the engine are removed, scrapped, or otherwise obliterated and is not available through the dealership or the factory. For example, when an enforcement official is following guidance in 2017-05-ELDs he or she would simply open the hood of the truck, look at the new emissions label, see a date of 2017, and make the determination the driver is ELD required. The carrier and driver though, may insist the engine is pre-2000 and although it is often not the case, they may provide documentation showing a pre-2000 Detroit Diesel Serial number and build date. Often times these documents are false and never were associated with any parts of the engine, however whether false or legitimate, there is no way to positively confirm the information as the previous serial number on the block is obliterated and a new one is provided by Detroit Diesel along with a new build date. I have spoken with Detroit Diesel who provided the attached letter on the topic. I have spoken with FMCSA top enforcement officials who initially were adamant the engine should be treated by the date provided by the manufacture on the engine labels; however, they later spoke with NHTSA who said the original build date of the engine should be what is utilized. The problem with NHTSA’s take on the issue is there is no way to positively determine the original date of these engines and because they were made well past 1999, an engine with a rebuild date of 2017 could contain a majority of parts from a 1995 engine, or it could contain all parts from a 2010 engine.

For uniformity, and consistency across the country it is important we look at this issue and provide further training guidance similar to 2017-05-ELDs that instructs on how we should be enforcing the ELD mandate in these limited situations. Currently we have enforcement officials who in some states will take the driver’s word that their engine is pre-2000 without so much as opening the hood. In other states we have officials who are following the CVSA guidance of opening the hood, taking the date off the emissions control label, applying the ELD mandate, and placing driver’s out of service for no ELD and then having their inspection Data Q’d. An official stance or guidance on this matter would greatly increase consistency across the board so everyone with a stake in the issue knows what the outcome will be ahead of time.

I request we provide guidance stating specifically: “engines manufactured prior to 2000 are exempt from the ELD mandate. Engines remanufactured after the year 1999 are NOT exempt from the ELD mandate.” (See the last sentence in CVSA training bulletin 2017-05-ELDs) This language will provide for the most uniform and easily understandable guidance for an official, driver, or motor carrier. Simply look at the date on your engine, or call a local Detroit Diesel dealer or the factory, provide them with the current serial number and the build date provided will determine whether it is ELD required or not.