Fuel Tank Regulations
What is a Legal Fuel Tank System
In the aftermarket fuel tank system industry, there is a lot of confusion over what is “legal” when adding or replacing a fuel tank. We hope the following information helps clear up some of these very important concerns. Be advised that this information is not intended to be a complete list, but rather a general overview.
In order to address the question of which federal or state regulations a fuel system must meet or exceed, it is necessary to know the particular vehicle and fuel system being used. The following information is divided into two main categories, Vehicles less than 10,000 GVW, and vehicles greater than 10,000 GVW.
- Regulations for vehicles less than 10,000 GVW
- Regulations for vehicles greater than 10,000 GVW
- ICC Fuel Tank Regulations
- Refueling Tank Regulations
- Miscellaneous Information
- Caution Information
Vehicles Less Than 10,000 GVW
TFI fuel systems meet FMVSS 301 (Federal Motor Vehicle Safety Standards), VESC-22 (Vehicle Equipment Safety Commission), NFPA 1192, ANSI 119.2, RVIA (Recreational Vehicle Industry Association) regulations, CARB (California Air Resources Board), and EPA (Environmental Protection Agency) regulations.
FMVSS 301 states that anyone who alters a vehicle must meet or exceed the structural integrity and performance of the OEM (Original Equipment Manufacturer) fuel system. A fuel system includes anything associated with fuel systems such as the fillneck, tank, gasoline lines, fuel pump, emission canister and fasteners. In other words, if an alterer adds an auxiliary system to a vehicle thereby reducing the performance of the fuel system, he or she has violated FMVSS 301 standards. An example of performance reduction could be if fuel from the original system leaked because the auxiliary system was gravity feeding into the original tank. This creates a real concern as it not only violates FMVSS 301 regulations, but is also a hazardous waste problem.
TFI’s inboard chassis frame and in-bed tank systems meet and exceed the OEM systems in the following areas:
- TFI tanks are designed using 14-gauge aluminized steel as a minimum instead of the 22 gauge terneplate or plastic that OEM typically uses. Transfer Flow’s aluminum diamond plate in-bed tanks are made from 1/8” thick aluminum.
- TFI tanks are fully baffled unlike OEM tanks which have no baffles.
- At a minimum, TFI tanks are drop tested in accordance with VESC-22. When drop tested, they are fully filled with water and cannot leak. Many of TFI’s fuel systems are also crash tested to FMVSS 301 standards.
- Tanks are 100% pressure tested. Some are tested using a sophisticated automatic Helium testing machine. This machine is capable of finding leaks with a helium concentration of less that 1.00E-7 liters/sec (leak size of 0.0000000315 in-sq or 3.15 E-8 in-sq).
- TFI tank systems meet the fastener (strap) regulations specified by ANSI, NFPA, and required by RVIA (Recreation Vehicle Industry Association).
- TFI systems meet CARB and EPA emissions regulations. We design our systems with the correct emission canister capacity necessary for gasoline applications. GM, Ford, Dodge, etc. all use different canisters with different absorption characteristics. Each TFI fuel system is designed to be compatible with that vehicle’s emissions system.
- TFI fillneck designs meet CARB fuel fill regulations. We design our fillnecks with proper alpha and beta angles and correct inclination angles for gasoline and diesel applications.
- TFI systems meet CARB and EPA requirements concerning fuel fill rates. This test verifies that our system fills at a minimum of 10 gallons per minute - a rate equal to that dispensed at most gas stations.
Vehicles Greater Than 10,000 GVW
Transfer Flow fuel systems meet VESC-22 (Vehicle Equipment Safety Commission), NFPA 1192, ANSI 119.2, RVIA (Recreation Vehicle Industry Association), CARB (California Air Resources Board) and EPA (Environmental Protection Agency) regulations.
TFI inboard mounted systems meet or exceed the following tests:
- TFI inboard frame rail mounted systems are tested following VESC-22 and RVIA regulations and standards.
- TFI tanks are drop tested as high as 44 feet, filled with water, and can’t leak.
- TFI tanks are pressurized to 5 psi with air or helium while under water.
- TFI systems meet the fastener (strap) regulations, specified by RVIA.
Plus, Transfer Flow fuel systems for vehicles greater than 10,000 GVW are designed with the following criteria in mind:
- TFI tanks are designed using, as a minimum, 14-gauge aluminized steel. Aluminum diamond plate in-bed tanks are made of 1/8” thick aluminum.
- TFI tanks are fully baffled on all four sides.
- TFI tanks are pressurized to 5 psi with air or helium while under water.
- TFI systems meet CARB and EPA emissions regulations. We design our systems with the correct emission canister capacity necessary for gasoline applications. GM, Ford. Dodge, etc. all use different absorption characteristics in their emissions canisters. Each TFI fuel system is designed to be compatible with that vehicle’s emissions system.
- TFI fillneck designs meet CARB, EPA, and DOT regulations. We design our fillnecks with proper alpha and beta angles and correct inclination angles for gasoline and diesel applications.
- TFI systems meet CARB and EPA requirements concerning fuel fill rates, which require a test that verifies our systems fill at a minimum of 10 gallons per minute for noncommercial applications.
Refueling Tank Regulations
Transfer Flow refueling tanks meet and exceed D.O.T. standards for Intermediate Bulk Containers. Our refueling tanks must adhere to the following guidelines:
- The Department of Transportation has issued Transfer Flow Special Permit E SP-1911 to manufacture and sell refueling tanks that can store gasoline, diesel, gasohol, methanol, ethanol, jet fuel and kerosene.
- Transfer Flow refueling tanks are designed to be mounted near the head gate in a pickup box, flat bed or utility box. No other location on the pickup or truck is recommended.
- Transfer Flow refueling tanks meet or exceed the testing and certification requirements specified in 49 CFR 178.803.
- All refueling tanks, including Transfer Flow¹s, must be retested every 2.5 years in accordance with 49 CFR 180.352.
- D.O.T. requires that Transfer Flow refueling tanks must be attended at all times during loading and unloading by a qualified person. Attended and qualified shall have the meanings described respectively in 49 CFR 177.834 (i), (3), and (4).
- A copy of Transfer Flow¹s DOT Special Permit E SP-11911 must be carried aboard each motor vehicle used to transport a refueling tank.
The following are notes concerning questions we are frequently asked:
- The 1990 Clean Air Act states that an individual owner of a vehicle may modify his fuel system only if it complies with all federal regulations. If he does not, he will risk state and federal penalties.
- When an auxiliary system is added to a gasoline powered vehicle, the fuel must be drawn through a pipe at the top of the tank. Balance lines or tanks in series so that one tank supplies another is not permitted. Gravity feeding from one tank to another using a balance line is illegal for all systems except ICC diesel systems.
- Replacement systems are acceptable as long as they meet the previously discussed regulations.
- Should non compliance with FMVSS or the 1990 Clean Air Act be discovered, the owner would be liable for civil penalties up to $2,500 for each violation. Also, the Federal Clean Air Act requires manufacturers to exercise more care in their product applications to avoid violations of the law. Violations can carry penalties up to $200,000. For example, adding a fuel system that does not meet provisions for proper emissions control could be in violation of the Federal Clean Air Act.
- Fuel line routing should allow for a minimum of 3 inches of clearance from the exhaust system or else a metal heat shield must be provided.
- Fuel lines should never be routed on the outside of the vehicle body.
- Transfer Flow fuel tanks are not to be used in conjunction with fuel tanks manufactured by other aftermarket fuel tank manufacturers.
- Transfer Flow fuel tanks are not to be used in any manner not intended, or in connection with aircraft.
Important Note: FMVSS 301 requires that anyone who alters the fuel system of a vehicle may do so only for the final owner of that vehicle. Any fuel system alterations need to be completed after dealers have transacted the sale or lease. As a result of crash testing, several of TFI’s auxiliary and replacement tanks meet FMVSS 301 standards. Transfer Flow is now able to offer some of our fuel systems to ship-through programs and to dealerships. Contact Transfer Flow for a list of our fuel systems that are available to install prior to the first sale or lease of the vehicle.
Careful attention must be paid to our instruction sheets in order for our Transfer Flow systems to operate as intended. Each fuel system is accompanied by a complete set of instructions. These instructions must be followed with no exceptions. The systems must be used as intended. Always follow State and Federal guidelines for installation of fuel systems. Always follow existing recommendations from the manufacturer concerning system installations.
Note: Failure to adhere to the following Transfer Flow guidelines and instructions will invalidate all Transfer Flow, Inc. warranties and responsibilities:
- Do not weld or torch any fuel tank or fuel system component.
- All fuel system components, including the emission canister for gas applications, must be installed on vehicles to maintain CARB and EPA standards.
- Always check fuel lines for restrictions or kinks. A restriction or kink can result in either fuel returning to the wrong tank or loss of power when pulling heavy loads.
- Always use proper venting procedures (gas cap and/or rollover emissions valves) to prevent over pressurization of the tank.
- Never connect a hot wire with 12 volts directly to the sending unit. This will burn up the sending unit resistor.
- Never apply more than 3 psi to any Transfer Flow fuel tank.
Always test the sending unit prior to installation using the following procedure:
- Using an ohm meter, measure the resistance of the sender at empty and full before installing it in the tank.
- Install the sending unit in the tank. Be sure the float arm is positioned so that it will not hit a baffle or stick behind the draw tube. Again, measure the sender at empty and full. The resistance readings should be very close to the ohmages read when the sender was outside of the tank.
- Do not purchase an in-bed auxiliary fuel tank system for a pickup with a camper shell if you plan to sleep in the bed.
- Do not install fillnecks within 3 feet of any heat source or open flame.
- Do not install fuel lines within 3 inches of an exhaust system.
- Reminder: There is no warranty on any part that is installed in a tank not manufactured by Transfer Flow, Inc. Transfer Flow, Inc. cannot guarantee these parts because we have no way of knowing the condition and legality of the fuel tank in which the parts are to be installed.
- Installers must follow local, state and federal OSHA rules for safe work practices.
- Transfer Flow fuel tanks are not to be used in conjunction with a fuel tank manufactured by another aftermarket fuel tank manufacturer. Our auxiliary tanks will only operate with OEM and Transfer Flow fuel tanks.
- We advise replacement of the stock fuel filter at 2,000 to 3,000 miles after installation of our fuel system.