There is great need for toxicology, epidemiology and other studies of the complex mixtures that metalworking fluids are, White explained. But the prohibitive costs of research put it beyond the reach of most individual companies. By forming a consortium, fluid manufacturers could identify research needs, select and fund projects, and share the results with consortium partners. The bottom line is that the cost is shared to keep metal removal fluids on the cutting edge.

Global regulations are business realities, and we have to live with them, White told the conference. The chemical industry is the second most-regulated, behind pharmaceuticals. For example, there are over 700 unique CAS numbers for metal removal fluid constituents alone.

Compliance is expensive, White continued. Costs include employee salaries; filing fees, permits and licenses; safety training and equipment; engineering controls such as ventilation and machinery enclosures; facility maintenance, upgrades and inspections; and the costs of modifying products. Research and development is very important, said White. Were making products with constituents that are added or removed because of regulations.

Developing nations will continue to exercise more regulatory oversight of chemical products. They often adapt U.S. or EU policies initially, said White, but national chemical inventory lists will become more comprehensive and requirements for chemical imports more rigorous.

In the United States, the National Institutefor Occupational Safety and Health has recommended an exposure limit for metalworking fluids of 0.5 mg/m³. However, there is no U.S. regulatory occupational exposure limit for the fluids because of the complexity of formulations and the vast numbers of products in the marketplace, White said. (There continues to be a permissible exposure limit of 5 mg/m³ for mineral oil mists, under U.S. Occupational Safety and Health Administration rules.)

U.S. challenges for fluid formulators include the current revision of the Toxic Substances Control Act. Critics of the act claim it is outmoded, not tough enough, exerting less control than REACH. Industry advocates, White said, argue that it should not emulate REACH.

Another challenge is advances in chemical analytical methods that enable lower limits of quantification. Human responses to extremely low exposures are uncertain – not just parts per million but now parts per billion or even parts per trillion – and toxicology lags behind analytical capabilities, White said.

The public is increasingly aware of chemical exposures, with information, which may be inaccurate or anti-industry, easily available on the internet. And both regulatory and market forces pressure all manufacturers for greener products.

Regulations are not made in a vacuum, said White. We can and do and must actively provide industry expertise to the regulatory process. We know our products best. The industry must include partners in developing nations; it must identify and work with allied trade associations on issues of common concern; and it must assure that end-users are partners as well as customers.

Creation of a global metal removal fluid research consortium, said White, would offer a major opportunity to fluid manufacturers. Such research could lead to improved occupational health and safety and to better environmental outcomes.

According to OSHA, White said, 10 percent of EU workers today are employed by U.S.-owned companies and 10 percent of U.S. workers are employed by EU companies. Trade and employment are globalized, and global worker protections are sure to follow. We must be prepared to meet this challenge, White concluded.