Regulatory Decisions That Will Affect Metalworking Fluid Selection and Use John Burke Houghton international

Topics

Chlorinated Paraffins

EU Biocidal Products Regulation

Formaldehyde Releasing Biocides

Boric Acid

TSCA Reform

Phosphate Concerns

Volatile Organic Compounds (VOC) Measurement

Scope

• Metalworking Fluids

– Metal removal Coolants and cutting oils

– Metal forming Stamping and drawing

– Metal treating Heat treating, quenching

– Metal protecting Rust and corrosion protectors

• Not included are cleaners or chemical conversion coatings, acids, bases

Chlorinated Paraffins

• EPA announced intent to ban from manufacturer medium chain and long chain chlorinated paraffin. (MCCP, LCCP)

• Reasons: bio-persistence and toxic (BPT)

• Tentative target date July 2017

Chlorinated Paraffins

• Used as extreme pressure additive

• Some substitutes available

• Challenging Operations: Deep draw, stainless and steel wire drawing

Chlorinated Paraffins

• Additional challenge: Now appears to be a time constraint

– Production Part Approval Process (PPAP) + internal approvals such as compliance to local waste treatment limits

– Not enough people to make change in time

• EPA is more focused on Metalworking Fluids (MWF) because of more mobile form of CP (i.e. liquid)

Chlorinated Paraffins

Impact: • Formulators developing alternative products

• Some manufacturing companies are banning all chlorine containing products , even very long chain chlorinated paraffins (VLCCP), even though they are not targeted by EPA

• General confusion as to EPA final Action and ban date, if any

CP

Biocidal Products Regulation

• The Biocidal Products Regulation (BPR) entered into force on September 1, 2013

• The BPR regulates both active substances and biocidal products

• Some active substances will be identified as Candidates for Substitution and from Sept. 2013, will be approved for a maximum of 7 years (Ref: ECHA communication 2016 / 04)

Biocidal Products Regulation

Can MWFs be classified as a Biocidal Product or a Treated Article?

• A treated article under the BPR covers any substance, mixture or article which has been treated with, or intentionally incorporates, one or more biocidal products

• It is the properties conferred on the material that will determine whether it meets the definition of a biocidal product or a treated article

Biocidal Products Regulation

• For substances and mixtures, the question is as to whether the biocidal treatment or incorporation imparts a biocidal function to the material or not

• A biocidal function is one aimed at destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on any harmful organism

• If the treated substance or mixture does have any sort of biocidal function (e.g. metalworking fluid) then it will be a biocidal product rather than a treated article

Biocidal Products Regulation

• If the treated substance or mixture does not have any sort of biocidal function, and the treatment is purely for the protection of that substance or mixture (e.g. a metalworking fluid for only in the drum preservation) then it will be a treated article

• Hence it is important to understand both the actual function of the product and the potential implications of how it is marketed

ECHA Committee for Risk Assessment (RAC) decision December 2015:

• Three Formaldehyde Releasing Biocides (FRBs) MBO, MBM, HPT inc 1 triazine based biocide (HPT) will now be classified in line with Formaldehyde

• In addition to existing hazard classifications, these 3 will also be classified as “May cause cancer” (Carcinogen 1B; H350) and “Suspected of causing genetic defects” (Mutagen 2; H341)

Formaldehyde Releasing Biocides

• This is a precautionary measure only due to the potential for these FRBs to slowly release small quantities of formaldehyde into diluted, in-use fluids under certain conditions

• Only products containing these three FRBs at concentrations greater than 0.1% will carry the new classifications and

associated pictograms

Formaldehyde Releasing Biocides

• Re-classification has still to be implemented by either ECHA or biocide suppliers and the effective date for the new classifications for these FRBs has not been finalized

• Once implemented, this will put additional responsibilities upon suppliers and users (e.g. review safety assessments) however there is no indication as yet that the FRB will be banned or withdrawn from the market

Formaldehyde Releasing Biocides

Formaldehyde Releasing Biocides

• ECHA is currently reviewing the situation with respect to possible future restrictions on the use of FRBs

• Based on the above, it is expected that additional FRBs will be classified similarly in the future although this is not confirmed

Final Thought on Product Classifications

• When it comes to the GHS classifications of MWF products, dilution of the product at the point of use can decrease or eliminate the GHS classification

• For example, if a MWF contains 5000 PPM triazine biocide and at the point of use the product is diluted 20:1 (250 PPM) , the resulting concentration of the preservative is <0.1% (1000 PPM) and the GHS classifications of Carcinogen 1B and Mutagen 2 would not apply to the working solution

• The party diluting the product is responsible for determining the classification of the working solution and they will need to decide if the Carcinogen 1B and Mutagen 2 can be removed as well as GHS classifications for corrosion, irritation, sensitization, etc.

• Default to concentrate versus diluted fluid can be overly conservative

Final Thought on Product Classifications

Impact: • MWF , once treated, could be labeled as biocides requiring

registration as such, a lengthy and time consuming process

• Then, all MWF would have to be re-registered

• FRB potentially eliminated due to labeling concerns

• Some Manufacturing Companies banning FRB

Biocidal Products Regulation and Formaldehyde

Biocides

Boric Acid

• Now listed on Safety Data Sheets as a reproductive toxin

• Confusion regarding:

– Boron

– Borates (salts)

– Free Boric Acid

Boric Acid

Impact • Some companies are banning all “boron containing “ products

• Testing of salts is time consuming and expensive

• For automotive, Boron is a convenient and cost effective neutralization chemical and substitutes are more expensive and less effective

• Boron salts testing is ongoing

Boron

TSCA Reform

• Frank R. Lautenberg Chemical Safety for the 21st Century Act (CSA)

• First major overhaul since 1976

• CSA give new authority to EPA for testing of chemicals

• EPA to seek additional test data not previously required

TSCA Reform

Impact • New chemical review process will take longer

• Allows for additional review of chlorinated paraffins

• Individual States are pre-empted from enacting laws that are counter to EPA determination on risk assessment

• Impact not likely to be felt for several years

Potential Phosphorus Restrictions

• Phosphorus is one possible substitute for chlorinated paraffins

• Phosphorus is also used as an additive in motor oil, and many hydraulic fluids and industrial products

• Example, zinc dialkyldithiophosphate (ZDDP, ZDP)

Potential Phosphorus Restrictions

• 2014 Toxic algae resulted in no drinking water for three days in Toledo Ohio

• Toxic algae was from high levels of phosphorus

• Source farm run off, failed septic tanks, sewage treatment plants, and industrial sources

CRITAL WARNING • Midway through day 2 of Toledo's

water crisis, residents who get water

from the city of Toledo are still being

told not to drink water which comes

out of the tap.

• Healthy adults can shower and do

laundry, but water should not be

ingested or used for brushing teeth.

• Dishes can be washed using tap water,

but should be dried, then rinsed with

bottled water and dried again before

use

Potential Phosphorus Restrictions

• US EPA and Canada addressing issue by the “Great Lakes Water Quality Agreement”

• 40% reduction from 2008 baseline

• Ohio set a firm deadline by 2018

• Forty mayors in great lakes region are pushing for more prompt action

Potential Phosphorus Restrictions

Impact: • Some companies are already restricting “total P” in MWF

• Even though farm run and discharges from Publically Owned Treatment Works ( POTW) are the major contributor, industry can expect reduction of total P to discharges to POTWs

• Simply stated , it is easy to regulate point source discharges and not farmers (non-point source)

Potential Phosphorus Restrictions

Volatile Organic Compounds in Metalworking Fluids

• California south Coast Air quality Management District passed Rule 1144 – July 2010

• Set limits on VOC from:

– Metal protecting fluids

– Metal removal fluids

– Metal treating fluids

– Metal forming fluids

Volatile Organic Compounds in Metalworking Fluids

• New Test method is specific for MWF

– ASTM E1868-10 81oC for 110 minutes

– Measurement by thermo-gravimetric analysis (TGA)

• EPA Method 24 was never intended for use with MWF

• Some claimed that with no method, there are no VOC,

• Not true now

• Impact – Re-assessment of VOCs from existing manufacturing

facilities

– Permit challenges for new manufacturing facilities

– Formulators to look at low VOC products

Volatile Organic Compounds in Metalworking Fluids

Summary

• Restrictions spur innovation

• Restrictions not overly costly

• Those companies that plan ahead will benefit

• Companies may overreact by banning related substances

• Companies most hurt are those that are not here, or otherwise not informed by a trade association

• Doing nothing option is the same as “Do you feel lucky…”

Half full or

Half empty

Summary

• In light of weak or no regulation, Corporate Ethics will prevail and result in change

• Too much visibility in today’s world

• Pressure via social media

• And GHS

Summary

Summary

Thank you

John Burke, CMFS

Global Director of Engineering

Houghton International

Email jburke@houghtonintl.com

Cell: +1 216 235 1995

Green Chemistry

Valeria Szabo

Linamar Corporation

What is Green Chemistry?

Green chemistry is the design of chemical products and processes that reduce or eliminate the use and generation of hazardous substances.

12 Principles of Green Chemistry

A framework for designing or improving materials, products, processes and systems.

They are being developed by Paul Anastas and John Warner (Oxford University, New York)*

12 Principles of Green Chemistry

*Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and

Practice, Oxford University Press: New York, 1998, p.30. By

permission of Oxford University Press.

Their application in Automotive Industry

• Focus:

– Prevent pollution of air, water sources and ground

– Prevent hazardous waste generation

– Prevent toxicity to humans

• Solution:

– Using materials that biodegrade easily in the environment

Machining Process

• Machining is the main process in Comtech Mfg. that requires

– 100 000 Liters of metalworking fluids (coolant, washer solution) per year

– 300 Operators

Problem 1: Spill

• Washer or machine leaks, or container spills that can lead to ground water contamination, or release to a natural sources or the city storm drain

Photo: Valeria Szabo

Solution 1: Synthetic Metalworking Fluids

• The solution to this problem is to use synthetic metalworking fluids

• No harm to the environment

• No harm to humans

Solution 1: Synthetic Metalworking Fluids

• Read some facts from their SDS sheets:

Solution 1: Synthetic Metalworking Fluids

• Read more facts from their SDS sheets:

Problem 2: Toxic Chemicals

• One day I noticed that an Operator sprayed his hand, I sensed an odor of alcohol and then saw that his skin turned white in discoloration. WHMIS label indicated: Methanol

METHANOL

Problem 2: Toxic Chemicals

• Investigation result: methanol was used in production for part cleaning, and in the QA Lab for contamination testing

METHANOL

Photo: Valeria Szabo

Problem 2: Toxic Chemicals

• Read some facts from SDS sheet of Methanol:

Solution 2: Alternative Chemicals

• The solution to this problem is to use environmentally friendly solvents

• Refer to customer specific Engineering Standards for such solvents

• Ford ES7T4E-6B616-AA: Recommended solvents to be used during inspection procedures are Citrikleen solution (TOX-031318), Jet90S (TOX-041616), DC-801 (TOX-145037) or equivalent

Solution 2: Alternative Chemicals

• Read some facts from their SDS sheets:

Citrikleen:

Problem 3: Rust

• Cast iron parts can get rusty easily in the humid environment, and

• Rust inhibitors are strong chemicals

Solution 3: Rust Removal using Molasses

• The solution to this problem is to use alternative rust removal ingredients

• One of our plants used molasses for rust removal of fuel rails

What is Molasses?

• Molasses is a by-product of sugar processing

• Available at your local feed store, pet food and grain store

Solution 3: Rust Removal using Molasses

• Why did they select this method? • Low Cost ($1/Liter - $10/Gal)

• Environmentally friendly

• Disposal in sanitary sewer

• No harm to people

• Does not require direct labour (no long hours sitting around and rubbing each part by several Operators)

Solution 3: Rust Removal using Molasses

• Step 1: mix mild water and molasses in 9:1 ratio

90 L lukewarm water 10 L molasses

+ MOLASSES

Solution 3: Rust Removal using Molasses

• Step 2: keep rusty parts in this mixture for 1-2 days

NOTE:

Keep the container covered

and refill with fresh mixture

after each batch due to the

awful smell caused by the

fermentation

Solution 3: Rust Removal using Molasses

• Step 3: Process parts through the washer again

Observe the result:

Conclusion

• Scientists along with Environmentalists are working hard to establish the future of our children and grandchildren – they know we need to act now!

• Green Chemistry is one area to start with!

• I invite you to join me on this journey! Review your processes for hazardous and toxic chemicals and replace them with environmentally friendly ones.

Contact Information

My contact information:

E-mail: valeria.szabo@linamar.com

Phone: +519-821-7576 Ext: 14409

The New Car Smell

Wayne Reeder & Mark Polster

The New Car Smell

• New Mandatory Regulations That Can Impact the New Car Smell.

• Fragrances and Effects on Interiors

• Formaldehyde and Acetaldehyde • Results From Vehicle Testing to ISO 12219-1

Fogging, Odor and VOC Testing

FOGGING

ODOR

VOC

Sampling Methods

VEHICLE

COMPONENT MATERIAL

Analytics

GC-MS

HPLC

Real Time Measurements

FID FTIR

SFIT-MS

E-NOSE

AND MANY MORE…

The New Car Smell – Interiors

New Mandatory Regulations That

Can Impact the New Car Smell

The New Car Smell – Interiors

• New regulations are forcing suppliers to reduce volatiles in final products.

• Due to globalization, regulations in a few countries are driving conformance across the world.

• China and Korea are preparing to enforce new VIAQ emissions regulations. • These new regulations probably won’t eliminate the “New Car Smell”

altogether, but qualifying to these new regulations probably will make the “New Car Smell” not as profound

China Regulatory Update - Limits and Timing

No. Items GB/T 27630-2011 Limit (µg/m3)

GB 27630-XXXX Limit(µg/m3)

1 Benzene / 苯 110 60 2 Toluene / 甲苯 1100 1000 3 Xylene / 二甲苯 1500 1000 4 Ethylbenzene / 乙苯 1500 1000

5 Styrene / 苯乙烯 260 260 6 Formaldehyde / 甲醛 100 100

7 Acetaldehyde / 乙醛 50 200

8 Acrolein / 丙烯醛 50 50

Implementation timing is currently proposed in the draft

• January 1st of 2017, new vehicle models applying for type-approval

• July 1st of 2018, in-production vehicle models

The New Car Smell – Air Fresheners

Air Fresheners and Effects on Interiors

The New Car Smell – Air Fresheners

• For those who really like “The New Car Smell”, it can be enhanced by;

The New Car Smell - Air Fresheners

• But if you would rather have it smell like something else, there are a variety of air fresheners and styles to choose from.

• Beware of air fresheners contacting interior plastics or painted plastic surfaces.

The New Car Smell – Air Fresheners

• Damages may result.

• Interior paints have been reformulated to be more resistant to chemical exposure but long term exposure potentially still may cause damage.

The New Car Smell - Aldehydes

Formaldehyde and Acetaldehyde

The New Car Smell - Aldehydes

• Tests were conducted to determine behavior of formaldehyde and acetaldehyde during cycles of ISO 12219-1

• ISO 12219-1 testing conducted on day 9 and day 24 after vehicle came off production line.

The New Car Smell - Aldehydes

• Three Testing portions to ISO 12219-1

• Ambient Mode - 25°C & 50% RH

• Parking Mode – “Lights on” yielding ~ 400 W/m²

• Driving Mode – “Lights off” and vehicle A/C on w/motor running.

• Air sampling conducted at end of ambient mode and parking modes and at beginning of driving mode.

The New Car Smell - Aldehydes

0

20

40

60

80

100

120

Ambient Mode Park Mode Drive Mode

Formaldehyde

Day 9 Day 24

µg/M³

25

103

33

26

8

24 day old vehicle shows higher formaldehyde levels at cooler conditions and/or when A/C is on.

24 day old vehicle has lower formaldehyde levels during peak temperature. (Parking Mode)

20

The New Car Smell - Aldehydes

0

20

40

60

80

100

120

140

160

180

200

Ambient Mode Park Mode Drive Mode

Acetaldehyde

Day 9 Day 24

µg/M³

42

190

77 68

24 day old vehicle shows lower acetaldehyde levels during peak temperature. (Parking Mode)

55

12

The New Car Smell - Aldehydes

• M. Polster of Ford, has shown that both acetaldehyde and formaldehyde concentrations increase sometime after 30 days and continues on after 60 days.

• Point at which concentration build-up peaks and start to dissipate remains to be determined.

The New Car Smell

QUESTIONS? Wayne Reeder

(248) 431-9687

wayne.e.reeder@gm.com

Mark Polster

(313) 206-2831

mpolster@ford.com