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Crunch Time for Europe

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Collaboration is the prime idea behind the Technical Committee of Petroleum Additive Manufacturers in Europe, formed in 1974. Known simply as ATC, the groups prime objective is to provide a forum for its member companies to meet and discuss technical and/or regulatory developments concerning the application of petroleum additives.

However, the Additives Technical Committee has other important objectives in terms of maintaining a constructive dialogue with other industry and regulatory stake-holders, within Europe and globally. It applies increasing resources to technical work with these groups. Further objectives are to contribute to fluid supply solutions and cost-effective compliance with regulations. Again, these are achieved by a continuing collaboration with the petroleum and automotive industries.

The U.S. counterpart to ATC is the American Chemistry Councils Petroleum Additives Panel. It has similar activities to those handled by ATC in Europe; both have a Code of Practice for engine sequence tests, for example. ATC has a close liaison with the ACC Petroleum Additive Panel, and there is a joint working group composed of members from both, covering Product Safety Compliance. This is a very important effort by major chemical additives producers to achieve some uniformity between the U.S. and European markets.

LubesnGreases recently met with Richard Biggin, chairman of ATCs Representational Steering Group, to discuss current ATC activities.

Biggin, who retired officially last year from Lubrizol UK, emphasized that much of the improvement required in the performance of fuels and lubricants today is driven by environmental demands. These include lower emissions, better fuel consumption and a reduction in the amount of waste oil generated.

Getting a Grip on REACH

Also, he added, in common with other groups in Europes chemical industry, ATC is spending considerable time on the proposed legislation known as REACH (Registration, Evaluation and Authorisation of CHemicals). Currently a proposed regulation, REACH is intended to replace all current European Union legislation on chemicals. When approved – most likely next year – it will become a mandated law in member states.

Biggin explained that ATC fully supported the aims and objectives of REACH, in that it is in everyones interest to control the use of chemicals and their effect on the environment. In its current form, however, the REACH proposal looks costly and burdensome. Whats more, it is very complicated, taking up more than 1,200 pages in its draft form, in October 2003. The devil is in the detail, Biggin argues, with considerable support from the chemical industry and now it seems with considerable sympathy within the European Communitys political world, too.

There are many points to be resolved, but the overwhelming problem with REACH from ATCs perspective is the proposed requirement to disclose full chemical details of lubricant and fuel additives. The current proposal requires that formulation details and results of environmental testing be registered with the Chemical Information Centre in Finland. This information will then be formally in the public domain and available to all.

This would mean that additive manufacturers will know precise details of their competitors products, as indeed will their customers. Enormous sums of money are invested by individual additive companies in developing their products, Biggin pointed out, and they have no enthusiasm for giving away the fruits of their research and development budgets.

Taken to the extreme, the chemical industry argues, REACH could possibly mean the end of new technological chemical advances in Europe. Major additive players would concentrate their efforts in markets outside of Europe where product confidentiality can be maintained. The situation is similar for all branches of the chemical industry but it has a potentially greater impact for those segments relying on formulation technology for complex chemical mixtures.

This problem of confidential business information is the target of much of the lobbying taking place with those involved with the REACH legislation. Biggin believes, The current proposal is one that will stifle innovation within the European chemical industry. Certainly the ramifications for Europe are so serious that it seems a rethink is under way, and a practical solution will be found, he suggests. It seems that the politicians are beginning to understand the implications of REACH and its potential damage to European industry, linked as it is to the prospect of major unemployment.

ATC in its lobbying has suggested the registration of products using generic names of components or indeed providing precise formulations to the central body – provided that these details were then kept confidential. It says that either of these options would enable REACH to maintain its welcomed objectives without infringing commercial confidentiality or competitiveness.

The final legislation document will probably go before the European Council of Ministers during 2006, so much urgent work is being done behind the scenes by ATC to achieve what it considers a sensible conclusion.

Engine Test Watchdog

Another important aspect of ATCs work is the development and maintenance of fit-for-purpose engine tests in Europe. As part of the European Lubricant Quality Management System, ATC maintains and follows a Code of Practice for the registration and running of performance tests used in the ACEA Engine Oil Sequences. These in turn define the quality of engine oils in Europe. This Code of Practice was voluntarily developed by members of ATCs Quality Management Working Group, and is intended to encourage both the consistent and precise operation of engine testing and the consistent reporting of results during the performance evaluation of automotive lubricant formulations. It is also intended to generate a body of reference data and knowledge concerning the precision and consistency of operation of test methods embraced by the Code. The Code of Practice is voluntary and not restricted to members of ATC.

ATCs Code of Practice is based upon the ISO 9000 international quality system, and all participating test laboratories should comply or be in the process of complying with this system. Only test laboratory facilities which have been accredited to the international standard EN 45001 or ISO 17025 for the relevant procedures are used.

All reference tests, and candidate lubricant engine tests conducted under the Code which are intended to support candidate lubricant performance claims, must be registered with the European Registration Centre before testing begins. At the completion of the registered test run, a Test Validity Statement together with a summary of results must be declared both to the registration center and to the test sponsor. Also, a specified formulation/test coding sequence must be used to facilitate tracking of test programs. This Code of Practice, together with the other elements of the European Lubricant Quality Management System, ensures the quality of performance testing of European engine oils.

Fueling the Industry

As well as monitoring the running of engine sequence tests, ATC, as a founding member of the new CEC (Conseil Europeen de Coordination) works closely with ATIEL (Association Technique de lIndustrie Europeenne des Lubrifiants) and ACEA (Association des Constructeurs Europeens dAutomobile) to jointly develop the European engine oil specifications known as ACEA Sequences. The successful working relationship between these three industry groups has been demonstrated in the smooth introduction of the latest set of sequences, published last November.

ATC also has made contributions in the fuel additive sector. Over 10 years ago ATC published a paper demonstrating the environmental benefits of petroleum additives. This was ATC Document 52, Fuel Additives and the Environment, based on the work of a special task force which was established to bring together existing information on the effects and impacts of fuel additives. A cradle-to-grave analysis showed that low-environmental-risk chemical additives were giving a positive environmental benefit in reducing emissions and satisfying the increased demands of environmentally friendly vehicles. This was then used as the basis of informing interested parties about fuel additive technology. Document 52 has been widely presented and used extensively within Europe and is available to visitors to the ATC website (www.atc-europe.org).

Since the preparation of Document 52 and its update, major changes have taken place in both the fuels available and the vehicles that consume the fuels. In a paper presented at the Additives 2005 conference in Dublin in April, ATC showed how fuel additive technology has developed to address todays requirements. Key examples are the additive needs of ultra-low-sulfur fuels; the industry demand for gasoline and diesel performance additives; the introduction of fuel-borne catalysts as an enabling technology for diesel particulate filters; and renewed interest in the role of alternative fuels.

Mention was also made of the changing legislative environment and how future reductions in vehicle emissions, proposed changes in fuel specifications, and possible changes in chemical registration requirements all will result in challenges for the future.

As with lubricants, liaison is maintained with the European Community on future fuel quality, and tests are developed in conjunction with CEC.

There is no doubt at all that most challenges for the additives industry in the foreseeable future will be linked directly or indirectly to legislation, Richard Biggin reiterated. He concluded that it could be argued that the most important part of ATCs activity is to ensure that our legislators really understand our industry and the impact on it of all future legislation.

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