Regulatory pressures continue to push metalworking fluid formulators to find alternative chemistries, even in the absence of hard data to back up restrictions, Metalworking Fluid Hot Topics panelists said at last weeks STLE annual meeting.
The first to speak, Eugene M. White of Cimcool, Cincinnati, Ohio, summed up the impact of the federal Occupational Safety and Health Administrations (OSHA) Hazard Communication (HazCom) 2012 standards. White said that OSHAs spin on the Global Harmonization System of Classification and Labeling of Chemicals (GHS) effectively extends workers right to know to a right to understand the hazards they face in the workplace.
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It covers 40 million workers in 5 million U.S. workplaces, and OSHA expects the standards to prevent 500 workplace injuries and 43 fatalities per year. HazCom 2012 is written in user friendly language, as opposed to regulatory language, said White.
He then reviewed the new labeling requirements in HazCom 2012 and compliance dates. Labels will be required to include four elements: a pictogram, signal words, a hazards statement and a precautionary statement. The latest information on HazCom 2012 is available on the OSHA web site athttp://www.osha.gov.
John Howell of GHS Resources, Bonita Springs, Fla., reviewed changes in terminology to align the HazCom rule with language used in the GHS. The two major changes, he said, will be: hazard determination becomes hazard classification, and material safety data sheet becomes safety data sheet.
OSHA indicated that compliance with HazCom 2012 will require the conversion of 1.5 million safety data sheets, 560,000 of which relate to the specialty lubrication industry, Howell said. OSHA estimated the conversion will cost $22.5 million.
Chlorinated paraffins have been the target of regulation for some time, and Neil Canter of Chemical Solutions, Willow Grove, Pa., summed up recent regulatory activity in the United States and Canada.
The U.S. EPA intends to initiate action to ban or restrict short-chain chlorinated paraffins. And the agency has expressed concern that medium- and long-chain chlorinated paraffins do not appear on theToxic Substances Control Act(TSCA) inventory, Canter said. The agency has issued a directive that companies need to file premanufacture notices (PMNs) for these substances.
Meanwhile, he said that Canada has placed short-chain chlorinated paraffins on the list of prohibited substances. Long-chain chlorinated paraffins with chain lengths greater than C20 will not undergo any further action from Environment Canada and can be used without restriction in Canada. Environment Canada has placed chlorinated paraffins with chain lengths between C10 and C20 on Schedule 1 which means that a risk management plan will now be developed with the chlorinated paraffin industry. This move does not restrict the use of medium-chain chlorinated paraffins in Canada. The challenge for the chlorinated paraffin industry will be to show that medium-chain chlorinated paraffins are and can be used in an environmentally responsible manner.
The rule restricts VOCs from metal forming, removal, and treating to 75 grams/liter; VOCs from metal protecting fluids are restricted to 50 g/l. In addition, the product label must display the VOC content (as determined by ASTM E 1868-10) and either the date of manufacture or a code indicating the date of manufacture. Water-dilutable products must list the VOCs of the concentrate as well as the minimal dilution required to make the product compliant. After July 1, 2012, any product that does not display this information cannot be sold in the CSCAQMD and must be disposed.
In addition to the Hot Topics panel, other STLE sessions covered the effects of current regulations on metalworking formulations and the actions suppliers are taking to comply.