Californias South Coast Air Quality Management District plans to regulate the volatile organic compound content of metalworking fluids, restricting VOC to 25 grams per liter and requiring every metalworking fluid andrust inhibitor used or sold in the district to be labeled with VOC content and date of manufacture.
Everyone, anywhere, selling to Los Angeles must comply by July 1, 2009, the AQMDs Michael Morris told the Metal Removal Fluid Symposium in Dearborn, Mich., earlier this month. Sale is prohibited for noncompliance.
AQMDs proposed Rule 1144, which is intended to reduce VOC emissions from metalworking fluids and rust inhibitors, applies to all industrial users of these products in Californias Orange County and in the urban portions of Los Angeles, Riverside and San Bernardino Counties, and to the fluid manufacturers and marketers who supply them. The rule will reduce VOC emissions in the district by more than three tons per day, AQMD has claimed.
The Independent Lubricant Manufacturers Association, based in Alexandria, Va., has objected to a number of provisions in the new regulation, including the test method the district plans to use to determine compliance with Rule 1144.
Convinced that standard industry test methods such as U.S. EPA Reference Method 24 are not effective with relatively low-VOC substances like most metalworking fluids, AQMD plans to use its own SCAQMD Method 313 Determination of VOC by Gas Chromatograph/Flame Ionization Detector.
AQMDs Morris argued that Method 313 was repeatable and effective for low-VOC and high water-content materials, as well as being relatively affordable; private labs charge $200 to $500 per sample, he noted.
ILMA is concerned that its members will incur substantial costs testing their many metalworking fluid formulations for compliance with the 25 gram per liter limit using the AQMDs test method, and that July 1 is too soon to expect full compliance.
ILMA challenged the test method on the grounds that it uses a high temperature (200 degrees C), while metalworking fluids are generally used at room temperature. In addition, ILMA objected that Method 313 has not been validated through a rigorous consensus-based process. And finally, the trade association objected to Method 313 specifying methyl palmitate as the delineation between VOC and non-VOC substances, without scientific justification. Using methyl palmitate, for example, a 9.6 cSt hydrotreated naphthenic oil came out as a VOC.
Morris has invited industry to provide input on alternate end points for identifying a substance as a VOC.
But time is running out. AQMD has scheduled a public consultation meeting for next Wednesday, Oct. 29, to receive information and comments from the public, and the proposed rule is up for adoption by the AQMD governing board on Dec. 5.
For more information about proposed Rule 1144, visit www.aqmd.gov and enter Rule 1144 in the search box.