AUTOMOTIVE


COMPLIANCE OBLIGATIONS IN THE U.S.A. UNDER THE OSHA FORMALDEHYDE STANDARD


GENERAL BACKGROUND Aqueous metalworking fluids commonly contain biocides, some of which, including 'triazine' (full name: Hexahydro-1 ,3, 5-tris(2-Hyd roxyethyi)-S-Triazine), are made by reacting formaldehyde with various other substances, e.g. monoethanolamine in this case. Such condensation products are equilibrium systems in which small quantities of the constituent materials, in this case formaldehyde and monoethanolamine, are present in the free, i.e. unreacted form. Since formaldehyde is a suspected potential human carcinogen, many countries have now imposed limits on the maximum permissible concentrations for this substance in air, since inhalation is the most likely route of entry into the body. There is a general consensus within the lubricants industry that triazine is the most widely used formaldehyde- condensate biocide in metal-working operations.


U.S. Situation


Since no data was available for the guidance of the manufacturers of metalworking fluids for their obligation under the US Formaldehyde Standard legislation, the five major manufacturers of triazine formed a non-profit organisation, the Triazine Joint Venture. The purpose of this organisation was to conduct a comprehensive workplace exposure monitoring study (Joint Venture Study, JVS) to assess the potential of triazine-containing metalworking fluids to


release formaldehyde under normal conditions of use. Their findings (A Study of Formaldehyde Exposures from Metalworking Fluid Operations Using Hexahydro-1,3,5- tris(2-Hydroxyethyi)-S-Triazine, Dr. H.J.Cohen, May 3 1994) have been summarised by ILMA. The final conclusion is to the effect that the use of concentrated triazine, as specified in the study, would not result in detectable employee exposures, and that such exposure levels would be below the 0.1 ppm 8-hour TWA level stipulated.


U.K. Situation


In the UK, in view of the equivocal nature of the human epidemiology data and concerns for carcinogenicity raised by the animal data, it is also considered prudent to regard formaldehyde as a potential human carcinogen, For this reason a Maximum Exposure Limit (MEL) has been assigned, at 2 ppm for both the 8-hour Time Weighted Average and the 15 minute Short Term Exposure Limit. Although this limit is higher than in the US, under the COSHH regulations, employers who use triazine-containing metalworking fluids must ensure that the workplace exposure to formaldehyde is as low as is reasonably practicable and in any case below the MEL. The results of the American JVS may well be used as a reference document in such cases, since the information therein could be incorporated into the workplace assessment process.


D.J.Margaroni


Are pleased to announce their appointment by


DOW CHEMICAL COMPANY LIMITED for the UK distribution of


SYNTHETIC BASE FLUIDS FOR THE LUBRICANTS INDUSTRY


SYNALOX* TERRALOX* TERRALOX* HP


For further details, please contact: Steve Mayo,


P-Oiartech


Polartech Limited, Nash Road, Off Ashburton Road West, Trafford Park, Manchester M 17 15X Telephone 0161 876 5673 Facsimile 0161 872 8567


* TRADEMARK OF THE DOW CHEMICAL COMPANY


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