The Debate Over Diesel Fuel Storage Regulations

But what about stored diesel fuel? Are there rules governing it?

On one hand, stored diesel fuel always has to meet D-975 requirements to still be “in-spec” and still be diesel fuel. Diesel fuel changes over time and certain essential properties of it may degrade. Then, not only will it not meet D-975 standards anymore, but there are some potentially serious operational pitfalls in play. If it’s backup fuel, the emergency generator systems it's intended to power may not function. After every major hurricane, we hear stories about backup systems not functioning when needed, because the fuel wasn’t checked. It “went bad” in storage and couldn’t successfully do the essential job for which it was intended.

For these kind of situations, diesel fuel storage regulations come to bear.  Certain essential industries, historically, have been subject to regulatory requirements concerning their stored fuel and how they take care of it.  Intuition tells us that this is probably a good idea. For example, nursing homes and other medical facilities in the state of Florida are now required to have 72-96 hours worth of viable backup fuel at the disposal for use at all times. They don’t want a repeat of the Hollywood Hills nursing home tragedy where a number of elderly residents died because the facility’s air conditioning couldn’t be powered after a hurricane.

The Debate Over NFPA 110

Unless you’re really in the know, you may not know about the discussions happening with NFPA 110, specific to the EGSA and the proposals about having stored fuel tested. Without putting you to sleep amidst dreams of four-letter acronyms, here’s the basic summary.

The NFPA is the National Fire Protection Association. It is the national trade association that writes many of the rules and standards used by local governments and businesses across the country – pretty much everyone in business and government who matters.  We said rules and standards, but really they are recommendations - the NFPA doesn't have police that raid generator users who don't listen to their suggestions. But many industries adopt their recommendations as their own de-facto policies.

One of the major industry groups that pays close attention to the NFPA is the EGSA, the Electrical Generating Systems Association. They are the world’s largest organization dedicated to on-site power generation. If you think about it, that’s a pretty large group that touches just about everyone. It is impossible to do business in the United States without interacting with a company or industry that’s part of the EGSA.  And they all look to the NFPA for guidance on all sorts of things, including what to do with their fuel.

“NFPA 110” is the NFPA’s most recent set of codes and standards, and there’s a section covering stored fuels. What the recommendations are for how to take care of it.  So far, so good, right?

Except, for something so important, NFPA 110 is surprisingly vague and general about what to do to take care of stored fuel. To paraphrase, their entire recommendations for making sure essential stored fuel is ready to go whenever you need it was “test your fuel once a year. We can’t tell you how to test it or what to look for, just figure it out.”

As you might expect, people have started to recognize that perhaps these recommendations could benefit from being beefed up a little bit.  So a group from the EGSA (remember, they’re one of the constituencies that NFPA serves or advises) got together and came up with an updated proposal to change the recommendations. Flesh them out and eliminate the vague language so people would actually understand what they should be doing.  No longer would it be “test your fuel somehow once a year”. They drew from best practice recommendations that have been proven in the industry to be advantageous to stored fuel.

“Test your fuel annually in some way” became “you should test your fuel using at least these specific tests that are important for documenting your fuel’s condition.”  The specific tests recommended were all tests proven to have usefulness in assessing the proper condition and viability of stored diesel fuel – tests like stability and microbial content.

Things Are Rarely As Simple As They First Appear

But the banner of continued ambiguity wasn’t going down without a fight. Despite months of discussions and voting to get the final proposal nailed down, despite approval and overt support from some of the nation’s largest producers and users of electrical equipment, at the 11th hour a group of engineers affiliated with the NFPA raised their hands as if to say “why do we need to change? This is too much work”.

They even mischaracterized the requirements in their frenzied attempts to keep the status quo from changing (“this proposal requires everyone to use an ASTM-certified lab” – no it doesn’t, because the ASTM doesn’t certify labs. It requires certain ASTM tests, which any good lab can do). 

And in the end, fear of change won out while users of stored fuel bear the real costs of this. At best, stored fuel users will continue to operate under blissful ignorance, not knowing what they need to do to make sure their mission-critical stored fuel is still good.  This NFPA group probably feels pretty good about derailing change at the last minute. But it’s all fun and games until the next major hurricane strikes and they’re scrambling to cover their you-know-whats and explain why they didn’t do what other people tried to tell them they should be doing.

This fight isn’t over, as the EGSA will probably move forward and create their own list of recommendations which the NFPA won’t have any say in.  The EGSA will move to the forefront of advising its members on the best practices for the industry. It’s just too bad the NFPA chose to abdicate its leadership role to someone else.