Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005 #547105-00031

Submission Number:
547105-00031
Commenter:
Kirk Robinson
Organization:
Washington State Department of Agriculture, Weights and Measures Program
State:
WA
Initiative Name:
Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005

May 20, 2010 Federal Trade Commission Comments on Proposed Rulemaking as related to: 16 CFR Part 306 Automotive Fuel Ratings, Certification and Posting Submitted by Kirk Robinson, Program Manager Washington State Department of Agriculture, Weights and Measures Program Dear Commission: My comments are related to the certification of octane rating for gasoline motor fuels. Washington State Department of Agriculture Weight Measures Motor Fuel Quality Program has used portable infrared octane analyzers successfully in the field to test octane levels on gasoline motor fuels for over 10 years. Portable infrared analyzers are one of several tools used by the program to determine octane level compliance of different grades of gasoline motor fuels offered for sale in Washington State. Portable infrared analyzers are used by inspectors in the field to screen gasoline motor fuel samples. If a sample is found to be out of tolerance for the octane level of the grade of gasoline motor fuel being tested, a sample of the fuel is then tested by a certified lab using ASTM D2699 and D2700 test methods to confirm the octane reading of the portable infrared analyzer. Enforcement actions are only taken when ASTM D2699 and D2700 test methods confirm the portable infrared analyzer results. We have found portable infrared analyzers to be an accurate and low cost tool in determining octane level compliance. Sincerely, Kirk Robinson, Program Manager