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Current Regulatory Agency Requirements
Dealers must ensure that all appropriate personnel are aware of current regulatory agency requirements and possible penalties.Appropriate personnel - May include, but are not limited to: Service Writers, Service Manager, Technicians, Warranty Department Personnel, TEPS Program Manager, Technical Communicator, Truck Engine Account Managers, and Truck Engine Business Manager.Due to regulatory agency requirements being continuously updated and improved, the dealer must take responsibility to understand the potential effects of any change. This Special Instruction references the United States Environmental Protection Agency (EPA) as the main regulatory agency in North America. However, compliance with all appropriate local, state and governmental regulatory agencies is required.Any unauthorized modifications to a vehicle chassis or engine that is not to the manufacturer's original specifications, risks affecting the compliance of the chassis or the engine. Modifications to emission controls may be considered tampering and are prohibited by law if the tampering "render, inoperative any device or element of design" installed on or in a motor vehicle or motor vehicle engine in compliance with EPA regulations.EPA guidance is available on the EPA website.www.epa.gov
The EPA website helps a dealer evaluate whether the activities are compliant with EPA tampering regulations. In general, EPA guidance suggests:
All persons are prohibited from making changes to the hardware or software of a vehicle or engine that would change the emission characteristics from those of the prototype for which the manufacturer obtained emission certification.
Neither the use of non-original equipment aftermarket parts, nor adjustment of parts in keeping with the manufacturer's maintenance instructions during regular maintenance will be regarded as tampering as long as the dealer has reasonable basis to know that this will not affect emission control performance.
Dealers and other personnel that perform maintenance are forbidden from actively perpetuating tampering. Thus, the dealer may not replace or repair parts that others have added or modified to render the vehicle or the engine non-conforming. The dealer may work on a vehicle or a engine suspected of having unauthorized changes without other limitation.
A dealer is not required to, but may, report tampering to the EPA. A dealer is not responsible to return an engine to the certified configuration. A dealer must abstain from repairing or replacing the part of the engine that has been tampered with unless it is returned to the certified configuration.It may be in the dealer's interest to make a record concerning work performed on engines that have been modified in a manner inconsistent with manufacturer specifications.Dealer Actions
An authorized Caterpillar dealer is required to only make repairs that keep an engine or a vehicle in emissions compliance. A dealer is responsible to ensure that any repair action taken at the dealership is within all regulatory requirements. Examples of repair actions would include, but are not limited to:
Programming engine system parameters
Aftertreatment repairs
Turbocharger repairs
Injector repairsDealer repair documentation is very important because all dealer repairs are susceptible to audits by regulatory agencies or by Caterpillar.Reasons to Suspect Modifications
During root cause failure analysis, there are many signs that may lead the technician to suspect potential engine or chassis modifications. If any of the following indicators are evident during repair, further investigation may be required to determine if the suspect modification caused the failure. Some dealer reported indicators are:
Auxiliary aftermarket device installed
Component modification visible
Unexplained or repeat failures
Black exhaust smoke or soot
Excessive heat related failures
Discoloration of the exhaust manifold or the turbocharger
Head gasket failure
ECM settings changed (Examples: FLS/FTS, Injector e-trim codes, flash file, serial number)
Driver comments
Turbocharger failure
Turbocharger wastegate supply line pinched or restricted
High boost
High exhaust temperature
High fuel rate
Performance complaints
Incorrect sensor readings or altered sensor readings
Exhaust aftertreatement removed (Examples: catalytic converter muffler, diesel particulate filter)
High horsepower
Rough idle
Block erosion
Catastrophic failures
Extra ports in piping
High fuel pressure
Open circuit sensor diagnostics
Premature engine wear
Discrepancy in miles driven related to ECM totals
Indication of improper fueling (Example: Ultralow Sulfur Diesel is required for 2007 model year engines)Note: The list above is not meant to be all inclusive. Also, not all signs will be obvious during all repairs.Visual Indicators
The technician must always watch for visual indicators of unauthorized modifications. All unauthorized modifications should be documented in the dealer history folder and considered for possible cause of any failure.Driver or Owner Interview and Notification
Do not underestimate the importance of the driver or the owner interview throughout the repair process. This Special Instruction has a section labeled ""Customer Communication Regarding Unauthorized Modifications"" that should be used during the driver or the owner interview process. Make a copy of section ""Customer Communication Regarding Unauthorized Modifications"" and distribute as appropriate.Prior to Repair
Questions should be asked to document the complaint or the reason for the visit. If the interview is not conducted properly, the technician may not be looking for the correct symptom. This can increase troubleshooting and repair time. Many times the driver or the owner will point out obvious signs that should be considered during failure analysis.During Repair
Communication with the driver or the owner should continue throughout the repair process as required. If unauthorized modifications are discovered during the repair the customer should be contacted immediately. The customer must be made aware of the findings and any customer responsibilities on decisions that must be made.After Repair
If proper communication with the customer has taken place throughout the repair, the customer will have a good understanding of any required customer responsibilities and the reason why.Failure History
A review of the Caterpillar SIMS system engine repair and failure history is a required part of any repair. Unexplained repeat failures and excessive heat or fatigue related failures must be part of any proper failure analysis for root cause.Documentation
It is suggested that the dealer should always retain proper documentation in their files on all engines repaired, to ensure that information is available for any future inquires. Future inquires may come from the customer, other repairing dealers, Caterpillar or government regulatory agencies. This documentation is very important in the case of engines or chassis that may have unauthorized modifications. The following key information should be documented.Electronic Engine Information
Electronic information from the Engine Control Module (ECM) is required on all warranty claims. This downloaded information