The rest of the story
Dr. Robert M. Gresham, Contributing Editor | TLT Lubrication Fundamentals December 2015
How SCAQMD successfully implemented Rule 1144.
Southern California has a large, dense and growing human, industrial and vehicular population coupled with a unique geography that exacerbates the propensity for air pollution.
SOME OF YOU MAY AT LEAST REMEMBER THAT A RADIO was once our major source of news and entertainment, long since supplanted by television and now the Internet, iPhones, etc. Nevertheless, there was a very popular commentator, Paul Harvey, who—as part of his newscasts beginning during World War II and ending in 1990—included a section at the end called The Rest of the Story. These were presented as short stories with little-known or forgotten facts on a wide variety of subjects with some key element of the story left out until the very end. Then the key element was dramatically revealed, and the show would conclude with Harvey saying, “And now you know (dramatic pause) the REST of the story!”
With this as a preamble, in the May 2012 TLT I wrote an article titled MWFs & VOC: Today & Tomorrow. The article summarized a joint symposium on Rule 1144 specifications and VOC regulations in MWFs, which the South Coast Air Quality Management District and ILMA hosted and STLE also co-sponsored (SCAQMD covers the broad area of Orange, Los Angeles, Riverside and San Bernardino Counties).
Southern California is an exceptional region in that it has a large, dense and growing human, industrial and vehicular population coupled with a unique geography that exacerbates the propensity for air pollution. The region is about 10,000-plus square miles with 16.5 million people and 10 million vehicles, and the air is trapped between prevailing easterly ocean breezes from the west and a high mountain range to the east. The region also is the largest manufacturing site in the U.S.
With these challenges SCAQMD has been the vanguard agency in helping the EPA promulgate regulations regarding emissions from a wide variety of sources such as vehicles, paints and coatings and now the metalworking industry. Historically much of our air regulation has begun in Southern California and moved not only to the rest of the country but also to other parts of the world. SCAQMD’s story, long term, has been one of incredible success. Despite the region’s incredible growth since 1950, the peak ozone levels have dropped from 0.68 ppm in 1950 to present day levels of 0.18 ppm.
Rule 1144, enacted in 2010 and modified Jan. 1, 2012, regulates specific emissions in the metalworking community. This community is large with 12,000 commercial machine shops as well as in-house machining for many large manufacturing companies. There were 4.2 million gallons of MWFs sold into the region in 2007. Due to a lack of adequate test methods, it was not possible to even know for certain the levels of VOCs in these fluids beyond general knowledge of their formulations. Thus, SCAQMD, under the leadership of Mike Morris, set out to establish a test method for measuring VOCs, reduce emissions in the MWF industry while minimizing impact on small machine shops (i.e., keep them competitive) and prohibiting the sale of non-compliant fluids in the region. To do this, SCAQMD assembled 200-plus stakeholders and created a committee to develop a test method in order to develop a smart rule that will reach the common goal of managing specific emissions in the MWF industry. ILMA was the key trade association partnering in this effort.
STLE Fellow John Burke, CMFS and Ku Award winner of Houghton International, Inc., and STLE-member Mike Pearce, CMFS and CMFS Committee member of W.S. Dodge Oil Co., were key members of ILMA’s team working with SCQAMD lab people and doubtless many, many others to develop the test method ASTM E-1868-10 for measuring VOCs in MWFs. With a test method in hand, it was possible to develop needed VOC information on existing products and set reasonable regulatory limits and reporting and labeling requirements. Then the implementation process began.
Now for the rest of the story. At the 5th International Conference on Metal Removal Fluids, Sept. 27-30, 2015, hosted by ILMA and its presenting partners PMPA, STLE and UEIL, Pearce gave a fine presentation on the outcome of the Rule 1144 implementation by SCAQMD. For reference, the VOC limits are >75g/l VOC banned, 50-75g/l requiring a VOC label and reporting and <50g/l are considered “super compliant” and require no labeling. Compliance was 90% by 2013 and approaching 98% in 2015. This is a virtually unheard of success for a rule implementation. Further, because of the cooperation between industry and SCAQMD, the stated goal of VOC reduction in tons of VOC from the area was actually substantially
exceeded!
Further, all five local compounder/blenders in the Los Angeles area have achieved 100% "super-compliant” product lines (excluding exempt products) with no significant increase in total raw material costs, although some lost some revenue. Often when new regulations come down, industry frets that the new rule will cause business closings or layoffs. Thus far, the implementation has resulted in
zero business closings or layoffs as a result of the rule! Major Kudos go to Mike Morris, Mike Pearce, John Burke and all the others who worked to make this happen.
And now you know (dramatic pause) the REST of the story!
Bob Gresham is STLE’s director of professional development. You can reach him at rgresham@stle.org.