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 
 
Confidentiality Notice:  This communication is confidential and may contain privileged information.  If you have 
received it in error, please notify the sender by reply e-mail and immediately delete it and any attachments without 
copying or further transmitting the same. 
 
 
All attachments are MS Office XP and are MIME encoded.  If you have any software compatibility issues, please 
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

