Dodge Oil

HOW TO COPE WITH AQMD RULE 1144 This letter is designed to help you understand and cope with Rule 1144 just enacted by the South Coast Air Quality Management district (AQMD). BACKGROUND AQMD came to us last year and told us they were intending to regulate solvents and other volatile organic compounds (VOC) used in metalworking fluids. Together with our industry trade association, we have been in constant study, negotiating, and even rule writing with AQMD. AQMD also developed a new test method for VOC that was to be used in this Rule. The bad news is that the new method shows all oils, not just solvents, as VOC. The good news is that the test method cannot be verified as reliable and repeatable by any standard method or organization. Therefore, we are now in a period of testing, writing, and validating a whole new test method. Meanwhile, for the current version of Rule 1144 we are using an old standby method for determining VOC, EPA Method 24. It too does not work well with oils, but is acceptable for solvents. In recognition of our current limitations, AQMD for now is only regulating vanishing films (VF) and rust protectants (RP). After our current validation work is completed there will be a major amendment to Rule 1144, although it is our goal to keep all oils excluded from further regulation. Under Rule 1144, vanishing films must be less than 50 grams/liter (about 4%) VOC. RP has a VOC limit of 300 grams per liter. A key part of Rule 1144 as it stands for now is the exclusion of all VF (not RP) with a flash point greater than 200°F. This was done deliberately so that our investigation and testing of alternate VOC test methods could go on without severely disrupting industry. KEY DATES • January 1, 2010 o VF and RP exceeding the new limits cannot be manufactured  VF and RP manufactured or purchased prior to 1/1/2010 can be sold and used for 6 months • July 1, 2010 o No further sale or use of VF and RP not meeting the new limits • January 1, 2012 (proposed) o Amended regulations on RP and VF take effect o New regulations on all metal working fluids take effect  THESE REGULATIONS HAVE NOT BEEN WRITTEN YET; THEY WILL DEPEND ON THE NEW TEST METHOD NOW IN DEVELOPMENT. VANISHING FILMS Classic VF is usually 90% or more solvent. It may contain some low viscosity lubricity and EP additives, but as a whole the VF is designed to evaporate and leave a clean part ready for pain ting, plating, or further assembly operations. VF is used in metal forming operations such as drawing, stamping, blank and piercing, and extrusion of aluminum. We have a number of suggested alternatives. They include: • Synthetic water based stamping fluids • MQL (minimum quantity lubricant) • Very thin oils All of these will involve changes to your operations, although we hope they will be minimal. Our sales engineers will help you custom design the solution that meets your particular needs. A side benefit may be that if you use water extended fluids you might end up saving a considerable amount of money RUST PROTECTANTS RP has always varied greatly in design. There are straight oil, water based, and solvent cutback classes of products. The one currently affected is solvent cutback. Solvent is used in this class of RP because it helps spread the RP, displaces water, and after it evaporates it leaves behind a waxy or greasy film to help with protection. Possible alternate products: • RP with lower solvent content (under 30% or so) • Oil type • Water extended One special area of concern with RP is that AQMD considers them a “coating”. As such, the equipment used to apply them (dip tank, spray assembly, flood applicator, wipers, etc.) may require an AQMD permit. This permit is extremely expensive. However, under AQMD Rule 219 this equipment is exempt if you use less than 3 pounds of VOC (only the actual VOC portion of the RP, not the entire volume) or 66 pounds per month of VOC per application station. Once again, our sales engineers will assist you in a custom solution that meets or exceeds your needs. CUTTING AND GRINDING OILS AQMD will regulate all metalworking fluids as VF, even if you are cutting or grinding. It is imperative that you not use solvent, kerosene, deodorized kerosene, solvent 140, odorless mineral spirits, or any other fluid with a flash point under 200°F. Even adding used solvent to your sumps can put you in violation; it only takes about 2% solvent to lower the flash point below the limit. We have reformulated products with suitable flash points for your use. They will not change in cost, and will perform as well or better than your current oil. CONCLUSION Although we cannot imagine a worse time for implementing a new rule, Dodge Oil has been fighting on a daily basis to minimize any negative impact on your manufacturing processes. We have proven solutions on hand, and we will help guide you every step of the way towards full compliance. Please call us with any questions or comments. We are here to serve you.