Off-road Retrofit Safety and Exemptions

This page last reviewed January 14, 2009


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Example Installations   -   Exempt Vehicles   -   Visibility Guide and Exemptions    

ARB and the Division of Occupational Safety and Health (Cal/OSHA) have agreed on an interim retrofit visibility policy to address retrofit visibility concerns for off-road diesel vehicles. This policy will be used to address visibility concerns regarding retrofits required by the March 1, 2010, in-use off-road diesel vehicle regulation compliance date for large fleets.

For the 2010 compliance date, the exhaust retrofit will not be allowed to increase visibility masking (blocking the line of sight of the operator) in any direction. Where a retrofit would block visibility, the installer or fleet must assess another location on the vehicle. When there are no possible locations on a vehicle for a retrofit to be installed without creating visibility masking, that vehicle will not be required to be retrofit for the March 1, 2010, off-road regulation requirements (see the exemption process below). The interim policy only applies to the March 1, 2010, compliance date; a vehicle exempted from the retrofit requirements in 2010 due to visibility will not necessarily continue to receive exemptions in future years.



View the
Interim Visibility Policy
Online Here


Interim Policy FAQ

NEW! Exemptions Pending




Example Installations with No Visibility Impairment

The vehicles listed below were retrofit in a manner that meets the interim retrofit visibility policy (i.e., without blocking the line of sight of the operator in any direction). These are not the only methods in which the vehicles could be safely retrofit, they are just examples of ways to retrofit such vehicles without impairing visibility. Fleets applying for a retrofit exemption for these vehicle models should consider these locations carefully when determining whether a vehicle can be retrofit. As soon as possible, ARB will add information on the exact dimensions of the retrofits below to further assist fleets.
Vehicle Engine Description Pictures
Loader
2008 Caterpillar 938H
180 Hp 2008 Cat 6.6
8PKXL06.6PJ1
ECS Purifilter:
Underhood installation.
Groomer
2006 Prinoth BR350
Dual Cat C9s; 335 hp and 350 hp
6CPXL08.8ESK, 7CPXL08.8ESK
ECS Purifilter:
Underhood installation.


The vehicles above were retrofit with verified diesel emission control strategies (VDECS). The vehicles below have been retrofit with devices in the verification process with no visibility impairment.

Backhoe
2000 Caterpillar 416C
86 Hp 2000 Perkins CAT 3204 Underhood installation, using existing exhaust pipe.
Off-road Forklift
2005 Hyster 300
174 Hp 2005 Perkins 2182 Underhood installation, using existing exhaust pipe.
Loader
1999 Caterpillar 914G
95.8 Hp 1999 Perkins 3054 Underhood installation, using existing exhaust pipe.
Excavator
2002 Caterpillar 345BL
439 Hp 2002 Caterpillar 3176C Installation incorporated into engine cover, using existing exhaust pipe.

Although in the examples shown above, the retrofits are not visible to the operator, and the exhaust is unchanged from the unmodified vehicle, there are many cases where the VDECS is visible to the operator but does not impair visibility (i.e., not all safe retrofits must be underhood installations). Information regarding additional vehicles that have been retrofit with zero impact on visibility will posted as it becomes available.


Vehicles Exempt from 2010 Retrofit Requirements

When ARB grants a request for a retrofit exemption for a vehicle make and model based on evidence that the vehicle could not have a retrofit safely installed in any location without violating the interim retrofit visibility policy, that vehicle make and model will be posted here.

Additionally, ARB has posted information on the vehicles that are in the exemption process on the exemptions page.


Interim Retrofit Visibility Guide and Exemption

The Retrofit Visibility Guide includes information on installing retrofits without violating the Interim Visibility Policy, as well as how to request an exemption from retrofit requirements if the vehicle cannot be retrofit without creating visibility impairment. Fleet owners interested in applying for an exemption should first read the guide to determine whether their vehicles could be retrofit without violating the Interim Visibility Policy, and then (if necessary) follow the instructions on submitting an exemption request. The Occupational Safety and Health Standards Board has agreed that retrofits installed without creating visibility impairment per the guide will be in compliance with future proposed amendments to Cal/OSHA standards concerning retrofit visibility.


Application for Safety/Visibility Exemptions:
Fleets requesting an exemption from the retrofit requirements based on safety issues, violations of the Interim Visibility Policy or state, local or federal safety laws should use this form.

FAQ: Interim Visibility Policy and Credits: An explanation of how the Interim Visibility Policy and retrofit exemptions will interact with the off-road regulation requirements, and credits for fleets with existing retrofits or with retrofits on order.

Back to the homepage for the off-road diesel vehicle regulation.

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