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Oil Change Stickers, Interval Recommendations, and California Law

So the other day one of our customers walked into the shop and said, “Hey, have you guys heard that you can’t recommend when to change oil or put a mileage on a windshield sticker?” Nope, we hadn’t, and I kinda doubted that it was true. So, like all information I get, I did some fact checking before accepting it. In this case it turned out that our customer who doesn’t work in the industry and got his information from a Jiffy Lube employee knew more about California automotive regulations than I did.

After checking into it, California SB-778, which as of 7/21/16 isn’t actually law yet but I’m sure it will be, prohibits any “auto repair dealer” (that’s us) or “auto maintenance provider” (that’s a new category for oil change shops) from making any oil or fluid change recommendation other than the “normal service” interval recommendation found in the owner’s manual. If the shop changes the interval recommendation, “the basis for the date or mileage recommendation shall be noted on the final invoice or on a document attached to the final invoice.” Recommendations can be verbal, on a sticker, in writing, or by changing the settings in the maintenance reminder system.

In the text of the bill the Senate laid out their reasoning for the changes in the law, and it sounds good on paper:

  1. Waste oil is one of the largest sources of hazardous waste in California and 40% of the oil is never recycled because it leaks out or burns in the engine.
  2. New grades of motor oil can last longer than older types of motor oil and 3,000 oil changes are unnecessary.
  3. Most manufacturers recommend 7500 or 10,000 mile oil changes
  4. Vehicle manufacturers specify shorter intervals when the car is driven in stop-and-go traffic, short trips, hard driving, etc.
  5. Changing oil more often than specified wastes oil and pollutes the environment
  6. The legislature doesn’t want shops that service cars to change oil more often than the specified interval or recommending that the oil be changed more often than the vehicle manufacturer does. They use the words “deceiving” and “misleading” in this statement.
  7. And finally they say they want to reduce pollution and dependence on oil.

Let’s start with one of the aspects of the law I like.

Once upon a time my wife and I bought a new car. One day and my wife was smiling when I came home.

Guess what I did today!

What?

I got the motor and transmission oils replaced so you wouldn’t have to do it!

That was nice, but we didn’t need to replace the transmission oil for another 45,000 miles.

But the guy said I had to do it now because the anti-foaming agents were depleted and it needed to be replaced right away!

As you might imagine, this is complete bullshit and I was annoyed that someone had taken advantage of my wife. I imagine that some people in the legislature also have direct or indirect experience with this, and they too were likely pissed off.  This bill may help curb quick-lube joints from recommending unneeded services. When someone with no degree, certification, or automotive knowledge starts recommending unneeded maintenance based on what they learned in the in-house sales training, I agree that it’s a problem.

However, “unneeded”, like “pornography”,  is in the eye of the beholder. What’s “needed” depends on a number of factors: risk tolerance, longevity goals, and whether the driver is checking and topping his oil. Is an oil change ever “needed”? Not really, if you’re willing to keep topping the oil and replace the engine around 60,000 miles a person could argue that the oil never needs to be changed.

How frequently the oil is changed will have a direct effect on both how long the engine lasts and the performance of the engine during its usable life. Oil changes are like exercise — if you exercise regularly you’ll likely live longer and have a better quality of life when you’re older. If you change your oil frequently, your engine will likely last longer and perform better throughout its life.

That said, there are diminishing returns as the frequency of oil changes are increased. At some point there is no advantage to changing the oil any earlier. At what interval does the cost (both environmental and monetary) exceed the value of replacing the oil? Well, it depends….

Every engine is different. There are variations in manufacturing, not as much as there used to be, but I’ve known several customers with cars that burned and polluted oil far quicker than other customers with the exact same car. Then there are variations in the engine’s “life experience”. An engine that has been oil starved, overheated, or overloaded will quickly accumulate wear beyond what’s typical for its mileage. A worn engine will burn far more oil and pump more blow-by into the crankcase to pollute the oil than a non-worn engine. So what I’m saying is that if we take two cars, exact same model and exact same mileage, one may need oil replacement more often than another, and the factory recommended interval may not be adequate for one of them.

Every driver is different.  If you read your owner’s manual or maintenance guide, you’ll see that one of the your responsibilities is to check the fluid levels and tire pressures regularly but almost nobody does. If you aren’t checking your oil, you ought to bring your car in every 3,000 miles. The oil may not be “worn out”, but a 3,000 miles oil change interval may save you from running out of oil one day. On some engines, 3,000 miles is too long; many manufacturers claim that oil loss of 1 quart per 500 miles is “normal”. By the way, 1qt/500 isn’t normal, but obviously I can’t dictate a manufacturer’s warranty policy. Our customers who own cars that will run out of oil if left for 3,000 miles either learn to check and add oil or destroy the engine and get another car. So here’s my point: if you check and top your oil regularly, you *may* be fine with the manufacturer’s normal or severe interval. You’ll need to be honest with yourself — do you actually check your motor oil level regularly?

Unless 95% percent of the readers answered, “No, I’ve only checked my oil 3 times in my life”, I suspect some of you are fibbing. We process about 30 cars a day. Every day we have several cars come in with no oil on the dipstick, so somewhere around 10% of our customers are flirting with total engine destruction, and certainly doing severe engine damage. About 1/2 of the cars I check have some oil on the dipstick, but the level is below the low mark. That leaves 40% of you that have oil in the engine when you come in. Guess who makes up the 40% that aren’t damaging their engines — the ones that change your oil unnecessarily frequently based on our now illegal recommended interval.

So, is maintaining oil level a valid reason for changing oil? Yeah, maybe not, but it works. Those who follow our recommendations end up with engines that work like new up to very high mileages. I have over 250K on my car. The engine is perfect and the oil level doesn’t drop at all between oil changes.  I bought the car from one of our customers when his transmission failed at 167K. I bought it because I knew he changed his oil every 3,000 miles since the car and it was worth repairing the transmission.

A while back California decided that low tire pressure is causing environmental and safety problems, so they made a law that auto repair shops must set the tire pressure on every car they work on regardless of the type of work performed, since drivers aren’t doing it themselves. Now they’re saying that mechanics are recommending oil changes too frequently. If the driving public starts changing their oil every 10,000 miles, it’s nearly certain that the engine will run out of oil between changes. Who does California think is going to check and add oil? The people they’ve determined can’t check their tire pressure on their own? Maybe they can make a law that mechanics are required to check the oil level on every car they work on. But wait, that won’t work! The oil change is the most frequent service.  If folks aren’t coming in for “unnecessary” oil changes,we won’t see them for 10,000 miles at a stretch.

Let’s take a a look at the Senate’s findings.

They say waste oil is one of the largest sources of hazardous waste in California. I assume they’re right.

They say 40% of the oil is never recycled because the oil is burned in the engine or leaked onto the ground. I’ll buy this too. However, less frequent oil changes will have no effect on this. An engine leaks and burns at the rate it leaks and burn. Longer intervals only have an effect on the percentage of the oil that’s recycled, or is potentially recyclable, not on the 40% that’s lost to leaks and burning.

They say newer types of oil can last longer. This may be true. I’m not an engineer and I’m not qualified to have an opinion on this. However, oil “can last” isn’t the same as “oil doesn’t need to changed for longer intervals.” Why? Dilution is one reason. When the air fuel mixture is burned in the combustion chamber, some of the combustion gases by-pass the piston rings and get into the crankcase, where the oil is stored. This is called blow-by. Some of the blow-by is “fire” which creates soot, which adds solids to the oil. Some of the blow-by is unburned gasoline, which thins the oil and reducing its ability to protect the moving metal parts. On some engines this can be significant. For instance, on my motorcycle engine, which spends most of its time spinning between 8,000 and 16,000 RPM, the oil level rises between changes. The engine runs at about 13:1 air/fuel ratio so there is more unburned fuel in the combustion chamber than on an engine set to run stoichiometric. (Stoichiometric means the air fuel ratio is set to 14.7:1 which in theory means all of the fuel will be used in the combustion, leaving none left over). The rich mixture, coupled with the the fact that blow-by is increased at very high RPM, makes the oil level rise as fuel is pushed into the crankcase. I change my oil every 1,000 miles on my bike. My cost (wholesale) is $11/quart (x4). If I didn’t think I needed to change the oil this often, I wouldn’t. Here’s my point, the oil may last for 10x as long, but when fuel is added, it ruins the oil. By the way, the manufacturer’s interval is every 1,000 miles.

They say most manufacturers recommend oil change intervals of 7,500 or 10,000 miles. For the cars we work on, this is true for newer models. However, all manufacturer’s have a “severe service” schedule, and the Senate does acknowledge this. The severe service interval is typically 3,750 or 5,000 miles. Almost all Bay Area driver’s will fit into the severe service criteria. Check your service manual to see what the conditions are for your car. Typically they are:

  • Stop & go driving (anyone driving on Northern California freeways is going to meet this condition)
  • Short trips (usually defined as less that 5 – 10 miles)
  • Hard acceleration (I don’t know about you, but if I see some clear freeway after being stuck in traffic, it’s pedal to the metal time)
  • Driving in extreme cold (not a problem around here)

Replacing oil according to the severe schedule has been more or less what we’ve been putting on the stickers for years. Normally we’ll use a 3,000 miles for the 3750 to allow for a little lateness and easier addition. We had been using 5,000 for cars with a 5,000 severe service interval. We’ve stopped doing this because unless we justify the recommendation in writing on the repair order, it’s not legal.

They say changing oil more often than specified wastes oil and pollutes the environment. “Wastes” like “needed” is a matter of opinion. As far as the environment goes, oil is recycled and reused, but I’m sure that the process is nowhere near 100% efficiency though, so I completely agree that oil change frequency should be limited to only what’s needed.

They say they want to reduce our dependence on oil. How could anyone disagree? There’s limited oil available. We will run out at some point and we haven’t come up with a viable replacement energy source. However, I’d argue that getting reasonable use from a car before recycling it is also important for reducing our dependence on oil. The energy that goes into building a car is not insignificant. I think that a car ought to be on the road for a minimum of 10 years. After that time it may be better for the environment to upgrade, since new models get lighter, more aerodynamic, more efficient, and pollute less. While a car is on the road it ought to be maintained so it runs efficiently and the engine doesn’t become worn during its life.

I’ll conclude with the following question: Which is better, attempting to control behavior with threats (laws and punishments) or with education (persuasive arguments for working toward the common good)?

In my experience, telling an industry “these are the rules you must not break” creates an ethos where people follow the letter of the law but not the spirit. I’d suggest that explaining issues of concern and then asking for industry input and cooperation in solving a problems will create a different mindset, one where the industry is doing their best to help solve the problems rather than simply working around any rules. Any system can be gamed. You may be thinking that if bad actors aren’t threatened with punishment they will continue to do bad acts. Here’s the thing; bad actors will just do bad acts within the new rules. Besides that, there’s not a whole lot of money for enforcement. We are a regulated industry, but enforcement is usually based on consumer complaints and egregious acts of fraud. Honestly I’d be very worried if the BAR were to actively enforce rules like this. I suspect it would result in honest shops getting violations for nothing more than recommending service based on their expertise, and shady shops gouging whenever they can, which by the way, isn’t illegal.