Fuel Freedom International
Encyclopedia
Fuel Freedom International is a multi-level marketing
company based in Altamonte Springs
, Florida
and co-owned by Wendy Lewis and Randy Ray. It sells pills trade marked as MPG-CAPS, which are claimed to improve fuel economy, reduce emissions and increase engine power. These claims are currently under civil investigation by the Office of the Attorney General of Florida (Case Number: L06-3-1090 "Unfair/deceptive business practices in the sale of product that purports to make gasoline burn with greater efficiency without independent scientific testing to substantiate claim") It is further claimed that the MPG-CAPS pills remove carbon build up from an engine and deposit a catalytic film that allows fuel to burn more completely.
The company says that the product was "originally developed by NASA for the 1970s space shuttle program", although no documentary evidence is offered to support this claim.
registered per 40 CFR 79.23 - a requirement for all gasoline additives sold in the USA. Registration involves providing a chemical description of the product and certain technical, marketing and health-effects information. The EPA did not test the claims of increased engine power and reduced emissions, and does not endorse, certify or approve the product. The company report attached to the EPA report (EPA Internal identification number 218820001) "provides technical documentation for this product as a lead replacement in gasoline for use in engines susceptible to valve seat recession".
via "independent distributors". To become a distributor there is an initial buy-in and an emphasis on the necessity of recruiting other people in order to receive commissions. This follows the structure of multi-level marketing, although there are recruiting bonuses after three retail sales a month as an incentive to grow the sales force, the majority of the cash-flow is said to be generated by commissions on sales.
However, the status of the company as a multi-level marketing enterprise is currently under civil investigation by the Office of the Attorney General of Florida (Case Number: L06-3-1090 "...product is sold/distributed by means of multi-level marketing whereby the compensation is not based primarily on volume of bona fide sales. Possible violations of Florida Unfair or Deceptive Trade Practices Act, F.S. 501.201. et. seq., production and/or soliciting on behalf of a chain letter or pyramid club (F.S. 849.091).")
(EPA) identified by test program authorities 42 USC 7525 and 49 USC 32918, and formerly known as the "511 Program".
The EPA requires a formal statement that the test laboratory "shall have no financial interests in the outcome of these tests other than the fee charged for each test performed". The Federal Test Procedure comprises a simulated city drive trace, and a simulated highway drive test. The tests are conducted in triplicate using two different vehicles. The vehicles should be from two different manufacturers and should be examples of the largest selling engine/transmission combinations on the US market. Tests are conducted in a "back-to-back" fashion. In the case of fuel additives that don't require an engine retune, then triplicate tests with and without the additive are required.
The tests on MPG-Caps do not apparently conform to this standard. Examples of such tests are:
A critical appraisal of some test results was conducted by the website www.fuelsaving.info, which notes that the MPG-Caps were originally designed to allow older engines to run on unleaded gas without valve recession and much of the fuel economy data presented is based on older vehicles. The very slight improvement in octane rating claimed might make an engine poorly tuned to the fuel it is run on perform better, especially in older vehicles without engine management computers.
Multi-level marketing
Multi-level marketing is a marketing strategy in which the sales force is compensated not only for sales they personally generate, but also for the sales of others they recruit, creating a downline of distributors and a hierarchy of multiple levels of compensation...
company based in Altamonte Springs
Altamonte Springs, Florida
Altamonte Springs is a city in Seminole county in the U.S. state of Florida, which had a population of 41,496 at the 2010 census. Located primarily in Seminole County, the city is in the northern suburbs of the Orlando–Kissimmee-Sanford Metropolitan Statistical Area, which the United States...
, Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
and co-owned by Wendy Lewis and Randy Ray. It sells pills trade marked as MPG-CAPS, which are claimed to improve fuel economy, reduce emissions and increase engine power. These claims are currently under civil investigation by the Office of the Attorney General of Florida (Case Number: L06-3-1090 "Unfair/deceptive business practices in the sale of product that purports to make gasoline burn with greater efficiency without independent scientific testing to substantiate claim") It is further claimed that the MPG-CAPS pills remove carbon build up from an engine and deposit a catalytic film that allows fuel to burn more completely.
The company says that the product was "originally developed by NASA for the 1970s space shuttle program", although no documentary evidence is offered to support this claim.
EPA registration
The product is EPAUnited States Environmental Protection Agency
The U.S. Environmental Protection Agency is an agency of the federal government of the United States charged with protecting human health and the environment, by writing and enforcing regulations based on laws passed by Congress...
registered per 40 CFR 79.23 - a requirement for all gasoline additives sold in the USA. Registration involves providing a chemical description of the product and certain technical, marketing and health-effects information. The EPA did not test the claims of increased engine power and reduced emissions, and does not endorse, certify or approve the product. The company report attached to the EPA report (EPA Internal identification number 218820001) "provides technical documentation for this product as a lead replacement in gasoline for use in engines susceptible to valve seat recession".
Distribution
The company retails MPG-CAPS directly or through multi-level marketingMulti-level marketing
Multi-level marketing is a marketing strategy in which the sales force is compensated not only for sales they personally generate, but also for the sales of others they recruit, creating a downline of distributors and a hierarchy of multiple levels of compensation...
via "independent distributors". To become a distributor there is an initial buy-in and an emphasis on the necessity of recruiting other people in order to receive commissions. This follows the structure of multi-level marketing, although there are recruiting bonuses after three retail sales a month as an incentive to grow the sales force, the majority of the cash-flow is said to be generated by commissions on sales.
However, the status of the company as a multi-level marketing enterprise is currently under civil investigation by the Office of the Attorney General of Florida (Case Number: L06-3-1090 "...product is sold/distributed by means of multi-level marketing whereby the compensation is not based primarily on volume of bona fide sales. Possible violations of Florida Unfair or Deceptive Trade Practices Act, F.S. 501.201. et. seq., production and/or soliciting on behalf of a chain letter or pyramid club (F.S. 849.091).")
Independent testing
An example of a recognised independent testing program to "evaluate aftermarket retrofit devices which claim to improve automotive fuel economy and/or reduce exhaust emissions" is that run by the US Environmental Protection AgencyUnited States Environmental Protection Agency
The U.S. Environmental Protection Agency is an agency of the federal government of the United States charged with protecting human health and the environment, by writing and enforcing regulations based on laws passed by Congress...
(EPA) identified by test program authorities 42 USC 7525 and 49 USC 32918, and formerly known as the "511 Program".
The EPA requires a formal statement that the test laboratory "shall have no financial interests in the outcome of these tests other than the fee charged for each test performed". The Federal Test Procedure comprises a simulated city drive trace, and a simulated highway drive test. The tests are conducted in triplicate using two different vehicles. The vehicles should be from two different manufacturers and should be examples of the largest selling engine/transmission combinations on the US market. Tests are conducted in a "back-to-back" fashion. In the case of fuel additives that don't require an engine retune, then triplicate tests with and without the additive are required.
The tests on MPG-Caps do not apparently conform to this standard. Examples of such tests are:
- A study conducted by ABC NewsABC NewsABC News is the news gathering and broadcasting division of American broadcast television network ABC, a subsidiary of The Walt Disney Company...
affiliate WPVIWPVI-TVWPVI-TV, channel 6, is an owned-and-operated television station of the Walt Disney Company-owned American Broadcasting Company, located in Philadelphia, Pennsylvania, USA. WPVI has its studios located on the border between Philadelphia and Bala Cynwyd, and its transmitter is located in the...
found no improvement at lower speeds and only a 4% improvement at highway speeds. However, it was later found that in the test, the reporter only drove around 50 miles – and the product is only expected to work after a few tanks of fuel. More comprehensive testing by ABCAmerican Broadcasting CompanyThe American Broadcasting Company is an American commercial broadcasting television network. Created in 1943 from the former NBC Blue radio network, ABC is owned by The Walt Disney Company and is part of Disney-ABC Television Group. Its first broadcast on television was in 1948...
affiliate TMJ4WTMJ-TVWTMJ-TV, digital channel 28 ; branded as "Today's TMJ4", is the NBC-affiliated television station located in Milwaukee, Wisconsin, and the flagship station of the Journal Broadcast Group. Its signal covers most of southeastern Wisconsin and parts of northeastern Illinois, including Racine, Kenosha,...
found an increase in mileage from 22 miles per gallonGallonThe gallon is a measure of volume. Historically it has had many different definitions, but there are three definitions in current use: the imperial gallon which is used in the United Kingdom and semi-officially within Canada, the United States liquid gallon and the lesser used United States dry...
on the highway, and 18 miles on city streets; to 30 for highway and 25 city. These tests did not use the double blind technique and the results may be therefore due to a placebo effectPlacebo effectPlacebo effect may refer to:* Placebo effect, the tendency of any medication or treatment, even an inert or ineffective one, to exhibit results simply because the recipient believes that it will work...
.
- Tests by a former distributor in the program used "70 tablets to test 7 vehicles in Missouri and California (three gas vehicles and four diesel trucks) according to the FFI instructions. All the test showed an initial improvement but then showed no improvement over a longer period of time and most of them showed less mpg than the vehicles were getting before any usage".
A critical appraisal of some test results was conducted by the website www.fuelsaving.info, which notes that the MPG-Caps were originally designed to allow older engines to run on unleaded gas without valve recession and much of the fuel economy data presented is based on older vehicles. The very slight improvement in octane rating claimed might make an engine poorly tuned to the fuel it is run on perform better, especially in older vehicles without engine management computers.