The manufacturing industry is changing, and so are the regulations surrounding it. In the United States alone, four newer regulations are changing the way cutting fluids are formulated: Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for hazard communication, Frank R. Lautenberg Chemical Safety for the 21st Century Act, California’s Proposition 65, and South Coast Air Quality Management District Rule 1144. As more companies go global, they must also pay attention to EU standards like European REACH Substances of Very High Concern (SVHC) or the Restriction of Hazardous Substances (RoHS) directive. GI Joe said, “Knowing is half the battle,” so here’s what companies need to know about re-evaluating their cutting fluids in a rapidly changing regulatory environment.
The current and changing regulatory environment
To break it down further, the U.S. adopted Revision 3 of GHS, a system of visual cues designed to protect people from potential dangers associated with hazardous chemicals. The Occupational Health and Safety Administration (OSHA) enforces these standards, which require all chemicals — individual substances as well as mixtures like cutting fluids — to be classified and clearly labeled with visuals that can be understood by employees at a glance.
The Frank R. Lautenberg Chemical Safety for the 21st Century Act was signed into Federal law in 2016. It intends to modernize the 40-year-old Toxic Substances Control Act (TSCA) by characterizing existing chemicals in the TSCA inventory as “active” or “inactive.” Only chemicals classified as “active” can be used in U.S. commerce, and metalworking fluid manufacturers are now required to ensure they only use active ingredients in their formulations.
While California’s Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, isn’t anything new, it is dynamic and will likely continue to evolve. In 2017, an amendment for Clear and Reasonable Warnings added a labeling requirement to chemicals to warn consumers of potential hazards. While this regulation applies more to consumer-grade products, it is still one to watch, as consumers can come into contact with industrial-grade products via distribution channels.
Additionally, South Coast AQMD Rule 1144 applies directly to metalworking fluids and direct-contact lubricants. It was adopted in California in 2009, and while it only affects half of California, including most of Los Angeles, Orange County, Riverside, and San Bernardino, it still requires metalworking fluid manufacturers to comply with the regulation to ensure their regional customers are not adversely affected.
Finally, two EU regulations are becoming more of a concern as companies expand globally. The European SVHC and RoHS lists have designated chemicals that are restricted for use and can affect end user acceptance. While these are of primary concern in the EU, it is likely that some of these chemicals will be restricted in the U.S. in the future.
To ensure compliance with all applicable regulations, companies need to consistently pay attention to the Safety Data Sheet (SDS) and labels for their chemicals, including metalworking cutting fluids. Classifications of chemicals, transportation requirements, Federal reporting requirements like SARA 313 and Clean Air Act reporting, and state-mandated requirements like Proposition 65 and AQMD, should all be clearly stated on the SDS and label.
Best practices for re-evaluating cutting fluids
The SDS that comes with the chemicals will be the most valuable tool for re-evaluating cutting fluids and ensuring compliance with applicable regulations. While keeping track of current and emerging regulations will be necessary, the SDS will have critical information for any additional safe handling practices for your cutting fluids. With GHS, it becomes even more important to become familiar with new SDS format(s) and classifications, even if the same product has been in use for years.
Because machining operations typically result in operators having contact with the metalworking fluids, it’s also extremely important to choose formulations that will not have reactions with skin, eyes, and lungs. This is something that will have to be determined based on the cutting fluid manufacturer, so companies will need to inquire about and evaluate their chemicals carefully. The SDS will also provide information on any exposure limits that individual components in the cutting fluid mixture might have.
The regulatory environment changes quickly. Understanding the regulations that have been passed and comparing them to the existing SDS can be the difference between a hefty fine or smooth operations.
For help evaluating your cutting fluids for compliance, contact Master Fluid Solutions at [email protected] or call +1 800-537-3365.