It is not unusual for industry regulators and the companies they regulate to adopt adversarial positions, with each group skeptical of the others motives. It would not be surprising if that were the case with the United Kingdoms Health and Safety Executive, an agency charged with protecting workers at their job sites. The HSE has been known to hammer employers that run afoul of regulations, sometimes over the use of metalworking fluids.
But the agency also has an ongoing partnership with suppliers of metalworking fluids looking for ways to better protect workers from hazards that these fluids can pose. Carried out in conjunction with a committee of the United Kingdom Lubricants Association, this effort reveals mutual interest that the sides have in reducing sickness in the workplace and using fluids efficiently.
Representing Lube Companies
The UKLA acts as the voice of the lubricants industry in the country, providing a forum for members to share technical advice and information and a tool with which to lobby governments.
One of its most dynamic activities is the Metalworking Fluid Product Stewardship Group, which aims to encourage users of metalworking fluids to assess and improve all aspects of fluids. It covers both neat and watermix metalworking fluids and deals with the following areas:
metalworking fluids, themselves, including selection, storage, preparation and delivery to metalworking machines;
operators, who are offered training and information about worker hygiene, skin care and health surveillance;
metalworking processes. The PSG studies and advises about methods of fluid delivery, flow rates and use of enclosures and splash guards to control fluid mist and vapor;
machines. The group considers methods of contamination control and fluid monitoring, sump clean-out criteria and methods, fluid top-up criteria and methods and ways of controlling tramp oil.
The PSG consists of UKLA members involved in the manufacture or marketing of metalworking fluids or their ingredients. The group currently has 17 member companies, and all are required to pay a yearly subscription fee to finance group activities. The group holds three meetings per year, and these are attended by representatives of several outside groups that actively participate: HSE; HSEs in-house Health and Safety Laboratory; the Independent Union of the European Lubricants Industry (UEIL); and the German Lubricant Manufacturers Association (VSI).
U.K. Health and Safety Executive
The HSE is a public body created as watchdog for work-related health, safety and illness. Working in cooperation with local agencies, it focuses on sectors with facilities that pose significant hazards, such as nuclear installations, offshore gas and oil installations, oil refineries and chemical plants, along with the construction, farming, manufacturing, health care and waste management industries.
The HSE is a regulator with sharp teeth. During the 2009-2010 financial year, it imposed fines totalling 11.6 million (13.3 million) following convictions of 763 companies or individuals for breaches of U.K. health and safety laws. The largest fine ever imposed by the HSE was 2 million in 2004, on Thames Trains, following a fatal collision between two trains at Ladbroke Grove, west of London.
One major investigation in which the Metalworking Fluid Product Stewardship Group worked closely with the HSE was an outbreak of respiratory disease at Powertrain Ltd., a major manufacturer of automotive engines, gearboxes and axles in Long-bridge, Birmingham. From April 2004 to March 2006, Powertrain workers were diagnosed with 101 cases of two types of respiratory disease: extrinsic allergic alveolitis (EAA, also known as hypersensitivity pneumonitis), which causes patients to experience flu-like symptoms and coughing; and occupational asthma (OA).
HSE spearheaded a two-year investigation which ultimately concluded that parts-washing machines linked to metalworking pose a risk of respiratory disease where mist is not controlled. It called on operators to assess the mist generated by metalworking and washing machines and to control that mist. In addition, it said there are links between harmful bacteria in metalworking and wash fluids and serious respiratory disease, such as OA and EAA, and this risk needs to be assessed and controlled.
At the Same Table
Powertrain was an extreme case – one of the worst recorded outbreaks anywhere of occupational respiratory disease – but diseases like EAA and OA are typical of the problems that the HSE are trying to prevent. UKLA officials say industry also sees the value in that, which is why the association created the PSG and why members partner with HSE.
Outgoing PSG Chairman David Neadle, an independent consultant based in Walsall, West Mid-lands, U.K., describes the prime motivation for both sides at PSG meetings as communication of the issues, concerns and priorities of both parties to each other, and to spread the message about all aspects of health, safety and environmental protection to users of metalworking fluids. Industry and regulators work together to identify and understand what is acceptable practice with the technology and use of metalworking fluids and what is not. The next Chairman of the PDG will be Paul Littley, product development manager at Fuchs UK.
The HSEs representative to the Product Stewardship Group, Simon Edwards, principal inspector of health and safety for the manufacturing sector of HSEs Operational Strategy Division, explained how HSE benefits from participation in the group.
The HSE is keen to ensure that manufacturers, marketers and users of metalworking fluids understand the importance of health and safety issues, he said. The HSE takes the results of HSL research and development, combined with inputs from the PSG, and converts these into published guidance for metalworking fluid users.
Neadle added, Product Stewardship Group members seek to inform regulators of the formulation and technical pressures on fluid manufacturers to achieve specific performance properties for metalworking fluids. The UKLA aims to obtain HSE advice and agreement on the guidance on health and safety that should be provided to users of metalworking fluids. Neadle noted that this involves sharing best practice to avoid or minimise risks to fluid users health and safety and potential damage to the environment.
At the May meeting of the PSG, Gareth Evans, principal scientist at HSL, presented a summary report on the HSE Cancer Burden Project. This project was started in 2003 to update the estimate of current numbers of cancers attributable to occupational exposure to carcinogens.
Helena Scaife, HSL senior research scientist, then summarized progress with another HSE-funded research program on metalworking fluids, which started in June 2008 and is planned to continue until March 2012. This work started with a review of published research that had examined evidence for respiratory and skin disease attributable to work with used water-mix metal working fluids. Laboratory studies investigated the growth of pathogenic bacteria and fungi in different types of metalworking fluids.
More recent work considered the influence of alkaline pH in metalworking fluids on restricting the growth of bacteria. The growth of bacteria in biocide free metalworking fluids was also being studied. Industry and other experts are being consulted about current methods to quantify exposure to metalworking fluid mists, whether the use of compressed airlines to remove metalworking fluids causes an increase in respirable mists. The HSL is also investigating the potential for Legionella to survive and proliferate in water-mix metal working fluids.
The PSG is currently working towards a multi-level approach to reach users of metalworking fluids. Strategies being considered include:
Educating senior managers in companies that use metalworking fluids, stressing the importance of conducting regular risk assessments for these products;
Educating middle managers responsible for the use of metalworking fluids;
Educating machine operators who handle metalworking fluids.
The PSG believes that a mailed letter to senior managers might alert them to the general problem, but that middle managers may benefit from more help, which may require a DVD or access to web-based information. For machine operators, industry standard information multi-page labels on packages have been suggested as a way to present detailed best practice pointers and to generate curiosity and initiate upward pressure on managers to adopt best practices for using metalworking fluids.
Cooperation Yields Results
UKLA and HSE representatives believe the organizations achieve more working together than they could apart.
Working in close cooperation with regulators has been a key enabling factor in many worthwhile achievements, such as road shows for users of fluids, publications, improvements in practice and production of a DVD, Neadle said. The effectiveness of this working relationship is due in no small part to the commitment shown by representatives of the HSE and the HSL.
As an example of the cooperation between the
HSE and the UKLA Metalworking Fluid Product
Stewardship Group, in 2009 they jointly produced a DVD titled The Safe Handling and Use of Metalworking Fluids.
The DVD, copies of which have been widely available to users of metalworking fluids throughout Europe, contains presentations on all aspects of metalworking fluids:
fluid characteristics;
functions in daily use;
assessing the potential risks to health;
preventing dermatitis;
managing risks to prevent skin problems;
monitoring and control of fluid selection;
glove demonstration;
risk assessment checklist.
The DVD also contains a case study of a U.K. company, Biomet, that manufactures orthopaedic implants, such as replacement hips, knees, ankles and shoulders. The video presentation describes how the company employs best practices in its production of metal components, using many types of machining methods and metalworking fluids.
It is very important that users and manufacturers of metalworking fluids work together on an international basis to ensure the spread of best practice throughout the world with regard to health, safety and environmental responsibility in the use of metalworking fluids, said Paul Whitehead, previous chairman of the PSG and recently retired from Castrol. The DVD is another way of achieving this aim, he said.
The main result of this cooperation is that manufacturers and marketers of metalworking fluids understand and appreciate the requirements of the regulators of health and safety protection, while the regulators understand and appreciate the formulation and performance technology issues that face fluid developers and manufacturers. The people who benefit most from the cooperation are the users of metalworking fluids, who have access to the best practices associated with using fluids safely and minimising their impact on the environment.