A capstone of the rule-making involved finding an acceptable test method for determining the volatile contents of metalworking fluids. Such a method never existed before, and was developed by industry stake-holders led by the Independent Lubricant Manufacturers Association, in conjunction with state officials. The test, ASTM E1868-10, is something of a mixed blessing, experts say. Yes, it averted the application of a costly alternative method, and will reduce VOC emissions in southern California. It also may enable similar VOC mandates to sprout elsewhere.

Speaking Oct. 12 at the ILMA Annual Meeting in Indian Wells, Calif., the South Coast Air Quality Management Districts Mike Morris acknowledged the major role ILMA members played in developing an acceptable test for VOCs in metalworking fluids. Morris is the districts air quality specialist responsible for developing policy recommendations for VOC-containing materials. Its his job to administer AQMDs Rule 1144, which regulates VOCs in fluids including vanishing oils, metalworking fluids and rust inhibitors.

The South Coast AQMD is the air pollution control agency for all or most of four counties: Los Angeles, Orange, Riverside and San Bernardino. The agency is under federal mandate to do whatever it takes to reduce unhealthy VOCs in the air – a monumental task for this region cradled between ocean and mountains, Morris pointed out.

A mountain range to the east blocks off the Los Angeles area from the rest of the country, and is what creates our smog problem, he explained. The bowl-shaped terrain traps pollutants so they curdle into a thick haze. After Chicago, this district has the most or perhaps second-most manufacturing facilities of any area in the country, he said. The L.A. area has 12,000 shops involved in metalworking, most of them small businesses.

In his comments to ILMA, Morris took care not to lay fault for the districts poor air quality on manufacturers. Our geography creates a big smog problem, he emphasized. If you could move the businesses out of this region to anywhere else, they could operate just as they do and thered be no problem. These businesses are as green as youll find anywhere else – but the geography here creates constraints.

These businesses are critical to our economy here and our survival. We dont want them to be hurt; we want to minimize the impact of compliance for them.

Nor did he single out metalworking fluids for blame: Metalworking oils themselves are green, he stated. Theyre recycled, reused and put back into the process. The only exception is the VOCs.

In late 2006, the AQMD undertook to survey metalworking fluid suppliers about their sales of lubricants, machining fluids, vanishing oils, rust inhibitors and solvents. The results led it to conclude that 4.2 million gallons of such fluids were sold into the South Coast jurisdiction that year, with over 300,000 gallons of these being high-VOC products. Such fluids were emitting 3.2 tons a day of VOCs, the agency estimated, roughly equivalent to a mid-size refinery.

While conceding that the survey was flawed in some aspects, Morris said it did uncover two things: First, that a high level of solvents was present in many fluids. And second, almost universally there was no information about VOCs or their content on product data sheets.

The AQMD already prohibits the sale of high-VOC vanishing oils, and VOC limits for many metalworking fluids will take effect Jan. 1, 2012. To enforce these limits, a test for VOC content was essential. We began four years ago to develop a method to measure VOCs, Morris recalled.

This is where W.S. Dodge Oil Co. in Maywood, Calif., one of the largest metalworking fluid suppliers in southern California, came in. Worried that the rulemaking could outlaw all metalworking fluids in the region, the companys Mike Pearce contacted ILMAs Safety, Health, Environmental & Regulatory Affairs Committee for help.

The SHERA group observed the agency trying to adopt for lubricants a federal test based on gas chromatography/mass spectrometry. Better suited to paints and coatings (not semi-volatile fluids like lubricants and metalworking fluids), this Environmental Protection Agency method was finicky, expensive and time-consuming.

An alternative was advanced by Bob Blithe of ILMA member company Houghton International. He suggested thermogravimetric analysis, a standard ASTM test already used for measuring the volatility of sensitive hydraulic fluids. In this test, a fluid sample is weighed, held at a predetermined temperature for a set period of time, and then weighed again to gauge the volatiles lost. Could this simple-sounding method be adapted to VOCs in metalworking fluids and rust preventives?

ILMA tapped TGA-savvy members for a task force, plus SCAQMDs laboratory, to amass the needed data and propose reasonable test parameters, including the all-critical time and temperature parameters for metalworking fluids. The method would have to produce results that corresponded with a known set of reference oils, as a baseline. After months of work, the task force showed that TGA could reliably replicate the reference oils baseline, with +/- 1 percent accuracy. More tests were done, this time with fully formulated fluids, to advance the test.

The next step was to validate the test as a standard ASTM method. Metalworking fluid expert John Howell of Primagy Consultants agreed to shepherd the method through ASTMs notoriously slow consensus process. In ASTM, the method would have to prove it was robust – repeatable and reproducible by other laboratories with a high degree of accuracy.

John Burke of Houghton recalled this as an intense time, with over 100 companies involved in the rigorous ASTM consensus process. The work went remarkably smoothly, however, with frequent meetings and strong participation over about 12 months, he said. Now in place, the method is available from ASTM for laboratories everywhere to use.

This summer, seeing the TGA test was ready, AQMD leaped on it. The agency voted to accept ASTM E1868-10 as the only one for measuring VOCs in metalworking fluids.

This means that for rust protection products, from now on VOCs will be determined by the ASTM method, Pearce of W.S. Dodge Oil explained to ILMAs Metalworking Fluids Committee in October. There were casualties, he added. Under this test, some very light oils cannot meet the southern California VOC limits. Theyre gone, he said. In most metal removal, forming and drawing fluids, a straight-cut, naphthenic 100-Second base oil is pretty much the only naphthenic we can use now. Paraffinics, vegetable base oils and various synthetics will have to fill the void left by the removal of all 40-Second pale oils, which cannot pass the test; use of 60-Second naphthenic will be greatly limited, too.

Morris, in his presentation to ILMA, reiterated that his agencys basic idea is to remove solvents from these products, and also some light oils. We didnt want to go after the backbone of naphthenic base oils, although we might have to in the future if alternatives are available someday.

He also outlined other Rule 1144 requirements:

On or before Jan. 1, 2012, the VOC content and manufacturing date must be displayed on all containers of metalworking fluids, rust preventives and contact oils such as slideway lubes. Several leading fluid suppliers already have said theyll apply such labels to all products shipped nationwide.

Suppliers must report their annual sales into the district, beginning with 2011 volumes reported in 2012, and continuing in 2013 and 2014. Every manufacturer of metalworking fluids in the United States who sells into California may be asked to fill in the survey.

Fluid suppliers will have to keep records for five years on how they determined the VOC content of their products.

He concluded by surmising, We wouldnt be surprised if this type of regulation spread throughout the United States in a decade or so.

Also, a seminar on best technologies for ultra-low or VOC-free metalworking fluids is in the planning stages for early 2012, AQMD planning and rules manager Naveen Berry told LubesnGreases. This will be a cooperative effort with ILMA to build on their current relationship. The goal is to solicit papers on product improvements and the benefits of transitioning to lower-VOC oils, such as biobased fluids.

Regarding the coming annual surveys of product volumes, Berry explained, We want manufacturers to tell us what the products are, how much comes in to the district, and their VOC content.

The survey will go to all those nationwide that supply fluids into the district, he added. We expect to get a pretty good handle as to how much fluid is sent here, and their VOC emissions. Over time, AQMD hopes to see total reported VOCs decline while fluid volumes stay stable – a signal that fluids are complying with Rule 1144.

Ironically, more products and producers outside California are likely to be affected than inside the state. There will be VOC labels on drums and product containers and safety data sheets, but where are these products going? John Burke mused recently. Its not just to California. Other customers will see them and find they have a VOC number on the drum they werent expecting. We need to be prepared to respond to that.

For one thing, he added, the end users environmental compliance manager will be startled to find that additional VOCs are being reported, and will have to add these to their facilitys annual air emissions inventory. Metalworking fluid suppliers need to begin addressing such issues immediately with their customers, Burke advised.

They also should prepare to see other jurisdictions follow southern Californias example, especially wherever air quality issues are at stake. The ASTM test to measure VOCs in metalworking fluids is a ready-made tool for regulators, which theyll surely use, he added.

AQMDs Morris and Berry agreed that the development of ASTM E1868-10 and its acceptance by their agency is a big step forward. We hope to see emissions benefits, Morris said, while Berry added, From AQMDs perspective, ILMA was extremely helpful and cooperative.

Dodge Oils Pearce also is grateful for a positive outcome. Everybody won, he told LubesnGreases. Business gets to continue in southern California, and theres no draconian regulation on us. People will get used to the tests and reporting, and it all can be done at an acceptable cost. And the district won – they did get rid of solvents, which was their goal. We can honestly say this was a win-win, even if its not perfect.

By the middle of next year, I predict that 90 percent of the metalworking fluids sold here will be super-compliant. And TGA shows tremendous promise. It may become the de facto test for regulators in the rest of the country, as they move in this direction.

AQMD Rule 1144 can be read online at http://www. aqmd.gov/rules/reg/reg11/r1144.pdf