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Labour is another important aspect of the U.S. business environment. The Biden administration is addressing issues that have been a concern for organised labour for some time. A number of programmes from the Occupational Safety and Health Administration (OSHA) are expected to change employer responsibilities, creating some uncertainty for industry. For example, President Biden issued an executive order in July directing the Federal Trade Commission to ban noncompete agreements, with the intent of promoting competition for labour. Many ILMA members use these and similar restrictions in their employment contracts, so ILMA is keeping a close eye on how this initiative plays out.


OSHA is also attempting to better align its Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), as the U.S. is several versions behind the United Nations’ Purple Book (a guidance document on the Globally Harmonised System of Classification and Labelling of Chemicals). OSHA has stated that many of the changes it is proposing to the HCS will not create a regulatory burden and will produce better harmonisation with Canadian and European trading partners. While the intent is honorable, ILMA sees significant compliance costs for our members. Further, the changes will require


everyone – in both the U.S. and the EU – to ensure they are in compliance with the final rule. ILMA is aware that the ECHA is in the final process of designating mid-chain chlorinated paraffins as a substance of very high concern and that the United Kingdom is proposing to add them to the list of persistent organic pollutants through the Stockholm convention. While experts doubt the U.S. Environmental Protection Agency will follow suit, the Biden administration seems to favour a more European-style approach to chemicals management in terms of assessing the risk of new and existing chemicals, and changes to Toxic Substances Control Act (TSCA) implementation may be on the horizon.


Other more temporary challenges remain for 2021 that will probably carry into 2022. Supply chain disruptions, raw materials scarcities and the truck driver shortage in the U.S. continue to confound sourcing and delivery for lube makers.


Uncertainty is the rule of the day in the United States as the lubricants industry uneasily awaits the chance to settle into a “new normal.”


LINK www.ilma.org


Certificate of Lubricant Competence 2022


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Beginning February 2022: a complete basic lubricant training programme devised and developed by leading industry experts.


Modules include: 1. Exploration & Refining 2. Base Oil Types and Characteristics 3. Basic Tribology 4. Lubricant Additives 5. Industrial Lubricants 6. Automotive Lubricants 7. Greases 8. Metalworking Fluids 9. Health, Safety & Environment 10. Certification Session


Registered Lubricant Professional


ATTEND 9 MODULES AND THE FINAL CERTIFICATION SESSION IS FREE For more details visit www.ukla.org.uk/training


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