The U.S. Occupational Safety and Health Administrations Metalworking Fluids: Safety and Health Best Practices Manual was issued in 2001, based on 1998 and 1999 recommendations and publications from the agencys MWF Standards Advisory Committee, the National Institute of Occupational Safety and Health, and Organization Resources Counselors. Its time for a 10-year report card, said Howell. How well have we done at complying?

Fluid Selection, Exposure Limits
Fluid managers have grasped the basics. They know a fluid is no longer safe when its rancid or employees have skin or respiratory irritation, said Howell. They know that an abnormal appearance, contamination by tramp oil, rust or corrosion, tool failure, growth of fungi, and suspended dirt and grit are all red flags. Fluid suppliers are good at providing guidance, including up-to-date material safety data sheets. But fluid users should also be looking at toxicity characteristics.

Were doing reasonably well at fluid selection, Howell said. Most users and suppliers know that product selection is the key to minimizing many problems. But it doesnt eliminate all problems. For example, review of component toxicity probably doesnt always occur, especially at smaller users.

Exposure limits include both required and recommended limits to fluid mists, and good fluid management includes monitoring employees exposure to aerosols. Exposure monitoring is still not being done unless an employee complains, said Howell. Every shop should know the level to which employees are exposed, and its easy to obtain qualitative exposure readings.

Management Programs, Controls
Every metal removal fluid user should have a fluid management program, designating responsibilities, spelling out the data collection and tracking systems, with action plans and response plans if the data show problems. The programs must have employee participation and include training; they must spell out how to keep the fluid system performing well; and they should use OSHAs self-assessment check list. Preventing or minimizing adverse health effects from chemical components, fluid alkalinity and hypotonicity, and microbial contamination are key goals of the programs.

How do we score? Pretty good at establishing management programs, Howell continued, But, how effective is the program? How are we measuring the results? And where is the continual improvement program?

Turning to engineering controls and work practices, Howell noted that these are a large part of the OSHA Manual, with its detailed list of tips and focus on lowering worker exposures. And if engineering controls dont suffice, employers must modify work practices. Most fluid managers are probably doing quite well at implementing proper controls, Howell said, but how do you know how well youre doing if you dont measure exposure?

Medical Management, Training
Medical monitoring is a proactive process of periodic medical screening aimed at early diagnosis and treatment of disease in employees exposed to a potentially hazardous substance. OSHA has recommended what to include in the monitoring process, whom to include, how frequently to test, what symptoms and conditions to look for. Industry here scores pretty poorly, Howell contended. No one is doing medical monitoring until a problem arises. Medical monitoring is particularly important in situations where exposures are routinely higher than the recommended exposure limits, he noted.

Hazard communication programs are just the minimum for worker training, Howell said. An adequate training program should include much more, including the employers fluid management program, the nature of possible health effects and actions employees can take, safe work practices to limit exposures, and emergency procedures.

The lessons weve learned in the past decade, said Howell, include:

• every facility that uses metal removal fluids must have a fluid management program;
• continuous improvement must be a key part of every program;
• microbiological control is a critical topic. Much more needs to be done, particularly in the area of endotoxin;
• exposure monitoring is essential, not just for large but also for mid- and small-size facilities, so they can judge the effectiveness of their fluid management program and their engineering controls;
• medical monitoring should be done on a proactive basis; and
• fluid users can be better trained.

“There are a lot of Ds and Fs in exposure and medical monitoring, Howell concluded. And he cautioned that, in a new administration in Washington, a new director of OSHA could look hard at this issue.

OSHAs best practices manual for metalworking fluids is available on the OSHA web site.

The Metal Removal Fluids 2008 Symposium was held Oct. 5 to 8, sponsored by the Independent Lubricant Manufacturers Association, the Automotive Industry Action Group, the American Industrial Hygiene Association, and UEIL, the European Union of Independent Lubricant Manufacturers.