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Beginning June 1, 2006, 80% of the highway diesel fuel produced in the United States had to contain 15 ppm sulfur or less. To account for sulfur test method variability, the United States Environmental Protection Agency (US EPA) allowed a 2 ppm compliance margin, meaning that in an EPA enforcement action fuel measuring 17 ppm or less would still be deemed compliant since the true sulfur level could still be 15 ppm. Concern was voiced over the appropriateness of the 2 ppm compliance margin, citing recent American Society for Testing and Materials (ASTM) round-robin and crosscheck test program results that showed sulfur test lab-to-lab variability (reproducibility) on the order of 4 to 5 ppm depending on test method.

The SwRI/BMW N.A. Intake Valve Deposit Test procedure was the first performance-based test procedure adopted for fuels qualification in the United States. The initial fuel evaluations were begun in January 1988 with six 1985 BMW 318i vehicles. Since that time, the fleet has grown to include over 60 BMW cars, and more than 2000 tests have been performed. This paper gives a statistical summary of approximately 1800 tests performed over a four-year period. Performance data and possible sources of test variation are discussed. Data and analyses offered represent results of tests by all clients. However, data is presented such that no individual test or client is identified.