VOCs help produce ground-level ozone and smog. Section 110(a) of the Clean Air Act requires states to submit regulations that control VOC emissions.

South Coast Air Quality Management Districts Rule 1144 defines a direct-contact lubricant – such as a slideway lubricant or vanishing oil – as a fluid that comes into direct contact with the product or part during manufacturing or assembly and is used to reduce friction and to prolong the life of machine tools and machinery. A direct-contact lubricant is not a metal forming fluid and is not a metal removal fluid.

The Independent Lubricant Manufacturers Association and Maywood, Calif.-based W.S. Dodge Oil Co. Inc. assisted Ventura County in the development and writing of the countys Air Pollution Control District Rule 74.31, which was implemented in 2013. The rule establishes VOC content limits and usage for metalworking fluids and direct-contact lubricants.

W.S. Dodge Oil Technical Sales Director Mike Pearce told Lube Report that the role of ILMA and W.S. Dodge Oil was to explain the key working elements of a similar regulation already adopted by another district, the California South Coast Air Quality Management District. ILMA and Dodge advised that if Ventura adopted the pertinent part of the South Coast regulation, Rule 1144, as-is, Ventura would already be in compliance the day its rule took effect.

Rule 1144 restricts VOCs levels in metal forming, removal and treating fluids 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 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.

From our perspective, keeping those elements from 1144 – the same VOC limits, using Method E1868-10, adopting the Super Compliant carrot (if you are Super Compliant, no recordkeeping is required), product labeling for VOC, and the key exemptions – for EDM and lapping – meant the precedent was set for a uniform rule that could be adopted across the country, he said. If we ended up with different elements, it would become a regulatory quagmire for the industry.

He explained that electrical discharge machining (EDM) fluid, also called dielectric fluid, is used in sinker EDM machines, where it functions to prevent electrical current where it is not wanted and to flush away the by-products. The fluid has to be very low in viscosity to do its job. Lapping is a polishing or ultra-fine grinding process. Both the lapping and sinker EDM machines were designed for a straight oil (solvent) fluid, and cannot run with aqueous products. Therefore, with the low viscosity requirement they are essentially solvents sometimes with low viscosity additives. As such, they are always very high in VOC and cannot meet the 75 grams per liter limit.

Pearce noted the Ventura County Air Pollution Control District was extremely cooperative, and we worked well with them. They have found near 100 percent compliance on their rule.

Adopting a rule as part of the State Implementation Plan gives it the final blessing from EPA, he explained. It is required of all the air districts in California, Pearce explained. Once in the Federal Register, it is extraordinarily difficult to challenge its validity.

EPA is fully approving the submitted rules because we believe they fulfill all relevant requirements, the agency stated. We do not think anyone will object to this approval, so we are finalizing it without proposing it in advance. If the agency doesnt receive timely adverse comments, direct final approval will go into effect on May 26.

For more details, view the March 27 Federal Register item online.