Q1.  Dan, are you aware of the law in Texas limiting the length of acronyms used to identify organizations?  To avoid stuttering and spitting, I will refer to the ILMA / MWFPSG as the ‘PSG’ (Product Stewardship Group) throughout this interview, if that’s OK with you.

DG: Sure, so long as the proper identification is made clear in the article.

Q2. What is the purpose of the PSG?

DG:  In its broadest sense and also the most simplistic definition, product stewardship means “cradle to grave” responsibility for a product including raw material selection, manufacture of the product, use and ultimate disposition of the material (recycle, reclaim, or disposal).  The PSG was created as a result of the realization that the metalworking fluid products were not being properly and safely handled.   The PSG endeavors to collect and assemble the information regarding responsible stewardship of metalworking fluid and to distribute this information through education of the user community to minimize the potential for adverse health and environmental effects.

Q3.  What does the PSG expect to accomplish next year?

DG:  The ILMA has a general policy a limited advance public relations statements regarding projects that are underway.  There are a number of reasons for this policy both internal and external.  One is to allow member companies the opportunity to benefit first from the work they have funded.  Another reason is to avoid undue expectations.

DG:  Yes, but only generally so.  We are looking generically at the changes in toxicity of MWF’s during their use.  As you know, the characteristics and composition of metalworking fluids change significantly during use due to breakdown, contamination with residue, other oils, bacterial growth, and even dissolved metals from the tools and parts being machined.  In this project, we began with a freshly charged system in a facility and have collected samples from the system at various times after charge-up.  The collected system samples were then assayed in three different animal models for respiratory toxicity to see whether there are any changes in the animal response as the in-use fluid ages.  This study is on-going.  We are also working on a data collection project from member companies who may have internal toxicology studies on their MWF’s.   The study reports were submitted voluntarily to a consultant who has been retained to review the data in detail and to write an in-depth summary of the aggregate results.  A third current focus of the MWFPSG is outreach and education.

Q5. Are these companies concerned at all about potential liability associated with the data they submit?

DG:  No.  To make it possible to collect the data, the data was supplied anonymously and sterilized of identification.  It has been evaluated and summarized by a third party consultant.  Presumably the member companies would have already fulfilled their obligation to report any significant findings to the EPA TSCA office and have also included appropriate notification in the corresponding product MSDS.

Q6.  Everyone is aware of the “MWF Management System Guidelines” jointly published by the PSG and ORC.  More recently, the ORC has published the “Guide to the Metal Removal Fluid Environment” drafted with input from other interested stakeholders including the MWFPSG, the UAW, NIOSH & OSHA staffers, and other industry groups.  What activities related to MWF is the PSG currently involved with the ORC?

DG:  We are still engaged with the ORC task force that developed the guide.  One of our biggest concerns is the use effective of the document.  We are looking at numerous options related to the additional education of the MWF community and constantly revise and polish the document.  It was intentionally written as a “living document” and released via the web rather than traditional print media in order to facilitate keeping the information current.  With regard to education, ILMA recently entered in a joint venture with the STLE, known as LubeLearn.  The purpose is to develop a web based interactive training system for health and safety issues as well as education in the area of general lubricant selection, use, and maintenance.  The MWFPSG has a particular interest in developing the health and safety pieces of this training and education project.  We believe that the rapid changes in the compositions of metalworking fluids necessitate a training system that can be regularly updated, and therefore web based.  We also believe that a strong advantage of the PSG developing this training is that we are able to discern and promote consensus best practices, and drive performance to raise the bar in terms of user expectations regarding health and safety of MWFs to a higher plane.

Q7. You are the chairman of the Oversight Committee correct?  What exactly is the function of the Oversight Committee?

DG:  The Oversight Committee is the governing body for the PSG, and  directs the activities and funds for the PSG.  It is also the first point of contact for the external groups.

Q8.  There is discussion of a function of the PSG to maintain a Product Stewardship Program (PSP) which will as one function, develop a system to “verify” or “validate” performance.  Is this a verification that will someday communicate information to end users in the form of a certification mark, like the UL mark?

DG:  I believe there may be a misunderstanding about the purpose or focus of performance validation or verification with respect to the MWFPSG and the PSP.  Successful implementation of an effective Product Stewardship Program is predicated on the principle of continuous improvement.  We recognized at the outset that it is unrealistic to expect that all companies globally can implement a gold star from Day One.  We also recognized the potential within companies for a product stewardship program to become a nothing more than a paper tiger which collects dust on the shelf after the initial push for implementation.  Certainly, if this were to occur broadly, the import and value of Product Stewardship is diminished and damaged significantly.  It is within this context that we have actively engaged in discussions regarding performance validation.

Q9.  The Fluid Testing and Advocacy Program (F-TAP) is scheduled to replace the existing testing by the PSG.  Will information useful to the end user be derived from F-TAP?

DG:  We are planning a fundamental change to the organizational infrastructure of the MWFPSG in the near future.  At the core of the re-organized group will be the Product Stewardship Program.  It is likely that adoption and implementation of the PSP will be a prerequisite for membership to the MWFPSG.  All too often when people here the term “product stewardship” they automatically think and assume testing, when in reality it is so much more (“cradle-to-grave responsibility for your products”).  The current MWFPSG structure is too rigid.  If an issue is not a concern to a majority of members, the group is unlikely to become engaged or expend funds to address the issue.  In the re-organized organizational structure, the F-TAP will allow smaller groups of MWFPSG-member companies to take-up issues of mutual concern or interest under the auspices of the MWFPSG.  These groups are intended to be fluid (rather than standing committees or task groups) as issues ebb and flow.

Q10.  Any plans for a third Metalworking Fluid Symposium? 

DG:  Not that I know of.  The first two Symposia were organized and convened by the AAMA (American Automobile Manufacturers of America) with the assistance and cooperation of many, many stakeholders – including industrial users of MWFs, manufacturers of MWFs, labor unions, academia and government agencies.  The AAMA disbanded following Daimler’s acquisition of Chrysler.  The MWFPSG and ORC are focusing current efforts on outreach and education – to “get the word out” regarding the lessons learned and information brought forth in the first two Symposia rather than convening another symposium.

Q11.  Where do people now get copies of the papers of the first and second MWF Symposiums? 

DG:  The proceedings for the first Symposium (1995) is out of print, but is available as a PDF file posted on ORC’s website (“orc-dc.com”).  Printed copies of the second Symposium proceedings (1997) are still available.  I can arrange to have copies of the second Symposium proceedings shipped to you for distribution to interested readers.

(METALWORKING FLUID MAGAZINE FOLLOWED-UP WITH A REQUEST FOR COPIES OF THE PAPERS FOR OUR SUBSCRIBERS)

Q12.  OK, now for the really tough questions.  In the Summary of deliberations of the OSHA MWF Standards Advisory Committee, a minority of members consistently rejected association of dermatitis, respiratory effects, cancer and skin cancer, generally denied technical and economic feasibility, and adamantly opposed regulatory control.  The majority supported the scientific findings of the NIOSH criteria document and other literature.  The minority members were Howell, Burch, Cox, and White (ORC), all of whom you know well.  It appears to the end user community that the ILMA members maintained a strict special interest line of opposition to any regulation of MWF’s, even in the face of substantial evidence from the scientific community.  

The reality of America is that managers MWF’s, and Managers of EH&S (environmental health and Safety) are unable to extract any funds from corporate management to modify mist collection systems, monitor employee health, and otherwise improve existing machinery and working conditions of employees in the absence of enforceable regulations.  Corporate management is duty bound, by fiduciary duty to stockholders, to maximize the value of the stock.  If there is no regulation, management sees no issue.  The presumption is that if it is dangerous, then OSHA has issued an appropriate regulatory standard.  This is the absolute reality in America today.

Thus, the position of the ILMA, and the minority representation, if accepted, would have positively ensured, with very few exceptions, the future continued exposure of over million workers to the present levels of MWF’s.  While that position ensures a short term savings in capital improvements to equipment, and expenses related to training and medical surveillance, it also ensures long term general continued harm to the health of employees, including many of the managers of MWF’s and their co-workers.  Unlike the manufacturers of ILMA, the end user knows the exposed worker, and often knows his/her children as well.  While the end user supports the economic well being of his employer industry, he increasingly recognizes himself as a member of the human community and neighborhood as well.   Clearly, the interests and actions of the ILMA and the end user/MWF managers have taken polar positions on this issue.  Please give us your comments.

DG:  I believe that all of the members of the OSHA MWF Standards Advisory Committee recognized that action to protect the workers is needed.  Also, rather than risk getting mired into a protracted emotional and potentially divisive debate about health effects, the Standards Advisory Committee made the wise decision to simply poll the Committee members about whether they agreed or disagreed with the conclusions of the NIOSH Criteria Document.  By mutual agreement, the Standards Advisory Committee intentionally did not fully discuss or debate the issue of health effects. The ultimate debate was not about whether action is needed, but rather what type of action is the best solution.  The distinction is found in the minority report, in which the minority members preferred a non-regulatory approach.  They preferred this approach in part, because of the length of time it takes to get a regulation issued by OSHA.  For instance, if not for the position and prodding of the minority opinion-holders, it is unlikely that the Standards Advisory Committee would have recommended that OSHA begin work immediately to develop and promulgate best practice guidelines for proper management of the metal removal fluid environment.  Also, it was the minority opinion-holder who urged OSHA to work with industry and consider applying resources toward education and outreach.  There was also a disagreement as to the appropriate PEL for metalworking fluid.  While everyone agreed that 5 mg/m3 is too much, the minority members feel that 0.5 mg/m3 is economically and technically not feasible, and the hazards of exposures that concentrations that small have not been scientifically established.  It is also a very difficult problem due to the many chemical variations of metalworking fluids out there, which is further exacerbated by the infinite ways a fluid can change while in-use.  If you put the same fluid into two identical machining operations sitting side-by-side, within a very short time the two systems will have diverged and be different in terms of both chemical composition and microbiological make-up.  This makes the exposure issue very complex.  In fact, several OSHA employees have acknowledged that the agency has never had to deal with an issue as complex as MWF exposure.

Q13.  Yes, it is complex, but a lower permissible exposure limit simplifies all of that somewhat, since whatever it is, a lower exposure is better, albeit more expensive.  The bottom line is that no regulation will mean virtually no change in worker exposure.  What’s confusing to the end user is; why is ILMA fighting this?  Isn’t the cost more significant to the end user than to the ILMA members?

DG:  The simple fix is not always the best or most appropriate solution.  Arguably an appropriate PEL can be an easy effective solution when you are dealing with a single chemical substance or even a well-characterized mixture.  We have neither in the case of MWFs.  In addition, the fundamental assumption in the argument you have posed is that the controlling and monitoring MWF exposure is an appropriate surrogate that proffers effective protection.  In other words, the airborne MWF is a vehicle for “bad actor(s)” of concern.  This is fine if the air concentration profiles of everything that is present in an in-use fluid system are all linear and parallel to the airborne MWF concentration.  There is simply not enough evidence to determine the accuracy of this assumption.  For example, setting a PEL of 0.5 mg/m3 for total particulate offers no protection against the microbial contaminants that may be present in a machine sump.  Airborne bacterial or fungal components simply cannot be accurately measured (or extrapolated from) a total particulate level based upon mass per unit volume of air.  Also, volatile materials or constituents with high vapor pressures cannot be measured or effectively controlled by a PEL based upon total particulate.  As a scientist and as a health and safety professional, I personally believe a PEL of 0.5 mg/m3 total particulate is the wrong solution based upon what we know to-date.  In essence, given the acknowledged complexity of the issue we are asking that OSHA “think outside the box”.  Again, I do not personally believe that a traditional OSHA 6(B) rulemaking is the best or most expedient answer.

Q14. Many industrial groups have adopted classification schemes in order to assist industrial consumers in the identification of products, their features and  application.  For example, the International Association of Drilling Contractors adopted the IADC code for universally identifying drill bits for drilling for oil and gas.  The system gave drilling contractors a means of directly comparing the products from various manufacturers, as well as selecting the proper drill bit for the formation and conditions encountered.  Similarly, the IADC developed a system of grading the dull condition of used drill bits.  These systems are now embraced by the entire industry, not as perfect, but as essential in the daily operation of the industry.

Today, in the MWF industry, the closest thing the industrial user has to such a scheme is the MSDS and application charts provided by a few of the manufacturers.  I can think of nothing that is needed more in this industry than universal classification system for MWF’s, and I can think of no one more qualified to accept this challenge than the PSG.  Everyday, the end user faces the smoke and mirrors of product names, many humorous, and confounding product numbers that are wholly irrelevant to the selection process.  Most of these product names and numbers are generated in marketing departments, and not by the engineers or formulators.  The end user now believes the manufacturers don’t want them to know anymore, just trust the salesman.  What is the prospect of the PSG taking on this tough, but essential task?

DG:  That’s very interesting, and actually I have never heard that suggestion before.  I think it would be very difficult to do this with metalworking fluids.  Also, I don’t think this would be something that the PSG would properly undertake since we are focused primarily on health, safety and environmental issues.

Q15.  You said “cradle to grave” which includes proper selection and application.  Wouldn’t that include this issue?