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Coming Soon to a Label Near You


If you havent done so yet, you may be overdue in putting a critical item on your industrial product labels. Since Jan. 1, California sharply limits the VOC (volatile organic compounds) allowed in metalworking fluids and rust preventives used in Los Angeles, Orange, Riverside and San Bernadino counties. And to ensure compliance, all such products must be labeled with their VOC content.

The only practical way to accomplish this, sources agree, is to label all affected products sold nationwide, not just those headed to the four-county area. Southern California is home to some 7,000 machine shops, making it an important market for any fluid supplier, but the impact of Californias Rule 1144 stretches far beyond the region and could spread to other lubricant products as well.

The labeling requirement and tighter VOC limits kicked in on Jan. 1. With rare exceptions, Rule 1144 now restricts the VOC content of metalworking fluids, direct-contact lubricants and vanishing oils to 75 grams or less of VOC per liter. Any products over these limits are banned from use and sale in the affected region (which is why the labels are needed). Violators – fluid suppliers and users alike – will face fines of $10,000 per day.

Labels must include three data points: the date or date code of manufacture; the VOC content of the metalworking fluid concentrate; and the in-use VOC level, if its a product intended for dilution.

Meeting all of Rule 1144s requirements is a very large undertaking, confirmed Shawneen Mitchell, general manager of fluid supplier Chem Arrow in Irwindale, Calif. Ive been working on this all of 2011. The most difficult part is that we use many, many raw materials and we had to gather the VOC content information on each one. We need this information when formulating our products. But many of our suppliers didnt know anything about this rule, and it was mid-December before we got the majority of the information. And then we had to calculate the VOC for all products and change our labels by January 1. It took months and months of overtime and weekends. I couldnt begin to count the hours weve spent on this.

We have a very large product line, but all our MSDS are updated now and weve put the VOC information on all our labels, she added confidently. We put it on all products, not just the ones going to Southern California, because its easier to just update everything. And if this regulation spreads around the country or to the rest of the world, were ready.

John Burke, engineer with Valley Forge, Pa.-based Houghton International, said his company also is on solid footing with Rule 1144. Our computer system allows us to track what is sold where, which products are covered, and which are banned now in Southern California. Problem is you dont know where a drum of product will end up. You might ship it to Nevada, and a distributor there sends it to another distributor, and it then goes to Southern California. Or you maybe send it to an aircraft component plant in Seattle, which then sends it down to their sister plant in Los Angeles. So you pretty much have to label everything you make: totes, drums and 5-gallon pails. In some cases, we might even add a second label, saying Not for use in Southern California.

Compliance will ramp up, believes Mike Morris, who administers Rule 1144 for the South Coast Air Quality Management District in Diamond Bar, Calif. Weve been flooded with questions on the labeling requirements since the first of the year. Its typical when a new regulation takes effect to see a lack of awareness, a lack of understanding. Were making an effort to explain and educate users and suppliers.

However, eventually we will have to go to enforcement, he added, while declining to say when. Enforcement actions could be a written notice of violation, an order to fix the problem, or fines. Readers can download AQMD Rule 1144 from reg11/r1144.pdf.

Theres also a symposium March 8 at SCAQMD in Diamond Bar, cosponsored by the Independent Lubricant Manufacturers Association. The symposium will be webcast, Morris pointed out, so that regulators elsewhere in the United States can participate via internet. We dont think many other agencies will be able to travel here in person due to budget constraints, and this will let them learn about the rule, he said.

Any state can pick up this rule and run with it now, and its gotten the attention of the auto industry, noted Burke. There are many other cities under VOC-reduction mandates where this will be looked at with strong interest. In general, regulators in California say we can expect it to take one to 10 years for other states to follow the states lead on any environmental mandates like this.

Mike Pearce, salesman at metalworking fluid maker W.S. Dodge Oil Co. in Maywood, Calif., said his company was involved with the rulemaking since it was proposed in 2009, and still spent countless hours and steps in the run-up to Jan. 1, 2012. First, you have to collect all the VOC data, and most companies dont have the required instrument to measure this, he said. You also have to collect VOC data from your suppliers, who also need to get the tests done. It took months to get this information.

Second, you have to do the calculation of VOC content for every product, Pearce continued. In order to put the VOC content on your label, you need to have documentation on file of how you generated the VOC number – by calculating it or by TGA [thermogravimetric analysis].

Finally, you have to make space for the information on your labels. Our labeling program lets us do this, but some formulators dont have software that lets them easily modify their labels, and some labels dont have space to add the information.

Dodge Oil aims to be super-compliant with the rule, meaning all its products sold in the district will have VOC below 50 g/l. As well, we decided that if were going to do the required calculations and TGA measurements for our metalworking fluids, wed start labeling all our lubricants as well – including hydraulic oils, gear oils and so on, Pearce said. The whole process has been costly, but on the plus side we have picked up some business, because word got out that you can call Dodge Oil and get answers on this.

To determine the VOC content for labels, Rule 1144 includes a new method, ASTM E1868-10, Loss-on-Drying by Thermogravimet ry. The test sounds simple enough; you put the fluid sample on a scale in a lab oven, heat it up, and measure the weight loss over time. But the test requires precision, few small companies can afford a TGA instrument, and a single sample can cost upwards of $400 to have tested at an independent laboratory.

The TGA instrument is commonplace, but not this method, observed Dennis Kelley, general manager of Herguth Laboratories, Vallejo, Calif. We saw a lot of test samples in the past year – including one order of 50 samples from a big metalworking fluid company – and weve not seen a slow-down yet. We were so busy that we bought a second TGA machine. Word is still getting out, so were seeing samples come from metalworking fluid people on the product development side, and also from end users, who want to be sure theyre complying with the rule.

Chem Arrows Shawneen Mitchell is breathing a little easier, now that the compliance goal has been met. Our next big project is to get the word out that we have AQMD-compliant products. At least were getting a head start, and if the rest of the country goes to similar regulations – and that remains to be seen – well be ahead of the curve.

And if youre behind the curve, youd better get to work because its not going to happen overnight, urged Dodge Oils Pearce. Just use common sense. California didnt write this rule because its pretty; theyll have to start enforcing it. After the first month they probably arent going to issue fines – but after six months, there will be no excuse for not complying.

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