Blenders Face Regulatory Challenges

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MIAMI BEACH, Fla. – Californias move toward adoption of a test for volatile organic compounds in metalworking fluid mist, and the impact of OSHAs proposed new chemical hazard communication rules top the list of issues challenging independent lubricant manufacturers.

At the Independent Lubricant Manufacturers Associations annual meeting here this week, the trade groups Safety, Health, Environmental and Regulatory Affairs Committee highlighted the industrys top issues.

Committee chairman John Burke of Houghton International said the industry should be concerned about Californias South Coast Air Quality Management Districts Rule 1144 regulating volatile organic compounds in vanishing oils – defined to include metalworking fluids – and rust inhibitors.

This is a major rule affecting importers of products into the [Los Angeles basin] as well as end users in the [Los Angeles basin], Burke said. But the implications of this rule go far beyond Los Angeles and will spread beyond air quality regulation. The test methods being adopted in Southern California could be used to measure VOCs in all metalworking fluids in the workplace, he warned.

ILMA has been working actively with the Air Quality Management District staff to assure that the test methods the government agency will use are sound and reliable. ILMA has recommended validated thermogravmetric analysis and is undertaking round-robin testing to demonstrate its suitability, as an alternative to a flawed test originally proposed by the District.

The Occupational Health and Safety Administrations proposed new hazard communication rule (see last weeks Lube Report: http://www.imakenews.com/lng/e_article001561088.cfm?x=b11,0,w) is the lubricant industrys next highest priority, the committee heard. Richard Kraska of Kraska Consultants pointed out that virtually every U.S. lube manufacturer will be required to review and change its safety data sheets and labels to comply when the new Globally Harmonized System for hazard communication becomes effective.

Major issues for blenders, said Kraska, include sufficient time to comply; the proposed effective date is three years from publication of the final rule with no extension for formulators or small businesses. Hazard criteria are changed, and the current mixture rule will change and become more complex. The proposal continues to include trade secret protections and product liability protection, both important to U.S. manufacturers.

There are some positives for lubricant manufacturers in the proposal, Kraska noted, including the elimination of references to ACGIH and NTP ARC lists, and some of the changes to hazard definitions.

Label rules will be significantly revised, said Kraska, basically following ANSI standards. Mandatory hazard symbols and pictograms are required.

OSHA is taking comments on the proposed new rule through year-end, and the association plans to comment on its effects on the lubricant industry.

Other key industry issues included likely reforms to the Toxic Substances Control Act; Californias Green Chemistry proposals; likely restrictions on chlorinated paraffins; ASTMs development of a metalworking fluid health and safety standard; and NTP testing of metalworking fluids.

The ILMA committee provides a forum for lubricant manufacturers and suppliers to exchange information and recommend and execute industry actions on key safety, health and environmental issues. At the conclusion of the ILMA meeting, Deborah Purnell-Otely of Dow Chemical took over as committee chair.

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