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by Dom Ruggeri

September  2001:

Back in the early eighties when I was fresh out of school and still a novice in this industry I learned a new term “Product Modification.”  To this day the there is still no clear cut definition of what determines a product modification as opposed to a new product.

One day, while working for a medium sized metalworking-formulating house, the chief chemist handed me a project.  A major customer was having a problem with a product they bought for 20 some years.  I was told to fix the problem.  The material was up to the M modification and this customer had just purchased 10 drums of the current product.  Well it would stand to reason that the current modification was causing the problem, and the solution should be easy go back to the previous modification for this customer.  Case closed.

Further investigation showed that modification M was so totally different from formulation A, that it could easily be shown that these 2 formulations were different products.  So when does a modification to an existing formulation become a different product?  The answer, according to the chief chemist was, “when the customer says so.”

By now we have formulated a masterpiece, tested the product and it passed with ease.  Now as it’s useful life goes on, the customers want better performance.  For instance:

  1. Better Tramp Oil Rejection
  2. Smaller Emulsion Particle Size
  3. Better Corrosion Protection
  4. Longer Sump Life  
  5. Better Lubricity

Needless to say, these are only 5, and the list could go on and I am sure you, the reader, can add quite a few more performance enhancing suggestions.  Certainly every one of the above requests can be met, but at what point is our product so modified that is truly a new product? I can assure you that this question has been discussed many times in many companies.  I am sure that many companies have guidelines established.  However, in other companies this question remains unanswered.

In a perfect ISO-9001 world, this topic will be covered in a procedure and everyone would understand and abide by it.  Well life isn’t perfect.  As a matter of fact, the approval process at many end users is so long and tedious that many customers will tell the coolant supplier to keep the name the same just to avoid the approval process, and the salesman is happy to comply.

Let’s look at 2 real life examples:

Customer 1 is using our masterpiece but they want a more clear emulsion so they can see the work piece.

Customer 2 is also using our masterpiece; they want no Boron in their coolant because of local regulations.

What can we do?

Customer 1: We found that simply by adjusting the ratio of surfactants we can meet this customer’s needs.  However, we have not changed any raw material, just the ratio of certain raw materials.  Therefore, the basic chemistry of this formulation is unchanged.  This is a product modification.

Customer 2: Boron is found in boric acid.  When boric acid is reacted with amines the resultant product is a great corrosion preventative.  To remove the boric acid and replace it with another organic acid is to change the basic chemistry of the fluid.  This change in chemistries makes our masterpiece a new product.  Therefore, it should be treated as such.

To sum this up in a neat bundle Dom’s rules are:

  1. If the quantity ratios of the constituent elements are changed, then the product is modified.
  2. When the basic chemistry has changed by any other means, this is a new product.


It is hard for me to believe that this is my 12th article (yes I have been boring you for a year).  I never dreamed I had so much to write about and there is still much more.  Thank you all for the kind words of encouragement I do appreciate them all.  As always should you have any questions please feel free to e-mail me at the magazine.

Good Luck