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1.1.GENERAL INFORMATION

The OSHA Metalworking Fluids Standards Advisory Committee (MWFSAC) was formed to provide OSHA advice on how to address metalworking fluids (MWFs) in the workplace. This committee had ten meetings at which it heard presentations and discussed and deliberated a wide range of issues associated with MWFs. Committee members were provided handouts from speakers as well as literature to review. The issues discussed included the scope of the fluids, machining processes and workplaces, and these topics are addressed in this first chapter. The committee reviewed the health issues, and the technological and economic feasibility of actions to mitigate health effects and these topics are found in Chapters Two through Four. Discussions of Best Practice are found in Chapters Six through Nine.

This final report is the product of the committee's deliberations. The information reviewed, concerns noted, views expressed, and decisions made are included in this report. The style used in this report reflects the voices of the individual committee members, speakers and participants. The deliberations are referenced in parentheses noting the meeting number and the page number of that meeting's minutes using the format "M #:page". In some cases the format "T #: page" is used and this refers to the page in the transcript of meeting number (#) listed. Author, date referencing is used for speaker's handouts and cited references. A list of references cited is found after Chapter Nine and before the Attachments. A list of additional references that the committee reviewed but were not cited is in Attachment #6. A list of committee members, speakers and other participants is found in Attachment #2.


1.2 COMMITTEE ORGANIZATION

1.2.1 Speakers and Presentations

Assistant Secretary of Labor for OSHA, Charles Jeffress addressed the committee multiple times to clarify what OSHA wanted from the committee. Prior to Jeffress' appointment, Acting Assistant Secretary of Labor for OSHA, Greg Watchman charged the committee with its responsibilities (M1:1). Issues such as duties, finances and ethics were addressed by Dr. Adam Finkel, OSHA Office of Health Standards, Greg Sentowski, OSHA Office of Financial Management and Robert Shapiro, Miriam Miller and Susan Sherman from the Department of Labor's Solicitor's Office (M1:1).

1.2.2 Formation of the Committee

On August 29,1996, the Occupational Safety and Health Administration (OSHA) requested nominations for membership on an advisory committee on MWFs (Federal Register, 1996). Names were submitted by a variety of stakeholders. OSHA formed a committee of five representatives of employees, five representatives of employers including two representing small business, five public members including one federal agency representative and one state agency representative. Two alternates, one representing employers and one representing employees, were chosen. The proportions of employer, employee and public membership were as stated in the OSHA statute, section 7(b) of the OSHAct. A Designated Federal Officer (DFO), representatives from the Department of Labor Solicitor's office, and OSHA staff members were assigned to assist the committee. The list of MWFSAC members and alternates and their affiliations, along with OSHA personnel is provided in Attachment #2.

1.2.3 Advisory Committee Charter (Reproduced from the Charter, a Signed Copy is found in Attachment #3)


1.2.3.1 The Committee's Official Designation
Standards Advisory Committee on Metalworking Fluids


1.2.3.2 The Committee's Objective and the Scope of Its Activities
The committee will be established under Section 7 (b) of the Occupational Safety and Health Act to recommend a standard, a guideline or other appropriate response to the dangers of occupational exposure to metalworking fluids. Such recommended action should be that which most adequately assures, to the extent feasible, the highest degree of health protection for employees based upon the best available evidence and latest scientific data. In addition, the recommended action(s) should take into consideration technical and economic feasibility as well as the impact of such recommendations on small business. In making its recommendations, the committee will review documents and information from the National Institute for Occupational Safety and Health and other pertinent data available to the committee from other sources.

The specific objectives of this committee will be to recommend an occupational safety and health standard, guideline or other appropriate response to mitigate the adverse health effects associated with occupational exposure to metalworking fluids. The following issues should be addressed in the report or recommendations of the committee: 1)definition of the scope of fluids to be covered; 2)identification of the adverse health effects associated with exposure to metalworking fluids, or specific types of fluids; 3)consideration of whether health effects associated with the various types of metalworking fluids can be generalized to all such fluids within a given category; 4)consideration of whether one or more permissible exposure limit (s) should be recommended and if so, what it/they should be; 5)determination of the significance of risk to workers exposed to metalworking fluids; 6)consideration of whether a medical surveillance program should be instituted, and if so, what components should be included; 7)consideration of whether the problem can be adequately addressed by a systems approach to fluids management (including consideration of components and degradation products) and the appropriate elements to be included if such an approach is recommended; 8)the technical and economic feasibility and small business impacts of any actions recommended by the Committee; and 9)analysis of subsidiary issues which may, in the Agency's opinion, be necessary to resolve in order to support the resolution of the above listed issues.


1.2.3.3 The Period of Time Necessary for the Committee to Carry Out its Purpose
Two years from the date of establishment.


1.2.3.4 The Agency or Official to Whom the Committee Reports
Assistant Secretary
Occupational Safety and Health Administration
U.S. Department of Labor


1.2.3.5 The Agency Responsible for Providing Necessary Support for the Committee
Occupational Safety and Health Administration (OSHA)


1.2.3.6 A Description of the Duties for Which the Committee is Responsible
The Committee is responsible for representing various points of view in advising the Assistant Secretary regarding the appropriate approach for the Agency to take to help mitigate the adverse health effects encountered by those exposed to metalworking fluids in the workplace. The Committee members will be expected to discuss and analyze information on the risks involved in working with these fluids, possible solutions that will decrease the health risks posed to workers exposed to these fluids during the course of their employment, the costs of various solutions under consideration, the benefits associated with suggested solutions, as well as the technological and economic feasibility and the small business impacts of any recommended solutions. The Committee's recommendations and conclusions will be detailed in a report submitted to the Agency.


1.2.3.7 Membership
The Committee will be composed of not more than 15 members who have been selected to represent the various interests involved. The makeup of the Committee shall comply with Section 7(b) of the OSHAct which requires the following: at least one member who is a designee for the Secretary of Health and Human Services; at least one designee of a State health and safety agency, and equal numbers of representatives of employers and employees. Section 7(b) of the Occupational Safety and Health Act allows the selection of additional members from professional organizations and national standards-setting groups.


1.2.3.8 Estimated Annual Operating Costs in Dollars and Staff Years for Such a Committee
Staff Salaries               2.5. FTEs
Committee Expenses and operating costs $68,000


1.2.3.9 The Estimated Number and Frequency of Committee Meetings
Meetings will be held as necessary; it is estimated that a minimum of eight meetings will be held over a span of two years.


1.2.3.10 The Committee's Termination Date
Two years from the date this charter is filed.


1.2.3.11 Filing Date
This charter is filed on the date indicated below.
Signed by Alexis M. Herman, Secretary of Labor, 8/28/97
1.2.4 Deliberations of the Committee

The committee conducted their deliberations through public meetings that consisted of invited speakers and panelists, committee discussion, and as time permitted, comments from the audience attending these meetings. In addition to the specific issues related to the duties of the committee, individual committee members were tapped to provide general information to educate the committee on basic concepts such as epidemiology. A list of speakers and panelists for each topic area is provided in the beginning of each chapter of the report. An overall alphabetized list of all committee members, OSHA staff, speakers and other participants is provided in Attachment #2. The meeting agendas are found in the Attachment #4. A court reporter provided transcripts of each meeting. Meeting minutes, referenced to the transcript, were compiled by the chairperson and the minutes for meetings one through nine are provided in Attachment #5. The minutes for the final meeting will be available through the docket office as they become available.

In preparation for discussion at meetings, documents were provided for committee members to review. These materials included government documents such as the NIOSH Criteria for a Recommended Standard:Occupational Exposure to Metalworking Fluids (1998) and reports from OSHA. The committee assessed peer reviewed articles, NIOSH Health Hazard Evaluation reports, state government reports, analyses by industry consultants, union reports, and news articles. The proceedings from two MWF Symposia, and ANSI and ASTM standards were reviewed. The committee, and particularly some specific members, provided significant input into the development of the second edition of Organization Resources Counselors' (ORC) Management of the Metal Removal Fluid Environment, 1999. Items specifically referenced in this report are found in the references section of this report which is provided after Chapter Nine. Additional references, not specifically cited but reviewed by the committee are provided in Attachment #6. The items the committee reviewed including publications and speakers' handouts along with other materials were submitted to the docket for this committee. The docket list is provided in Attachment #7.

1.2.5 Organization of the Committee and Final Report

Prior to the first meeting, the chairperson decided to include the two alternates in all discussions. The purpose of this action was two-fold: each alternate would be fully prepared to step in, if needed, to replace a committee member, and these individuals had much to give the committee in terms of expertise and experience. The comments and concerns of committee members as well as these alternates are provided in the report. Neither alternate was allowed to vote.

In 1997, the committee was organized by the chairperson into work groups to address specific issues. In 1999, a change in the work group structure was made by the chairperson with the groups asked to address certain questions developed by the committee and the chairperson.

The members of each original working group were: Government Options: Mirer, Cox and White; Systems: Lick, O'Brien, Shortell, Sheehan; Cooperation and Comparison: Burch, Howell, McGee, Day; Health: Wegman, Teitelbaum, Newman, Anderson, Frederick, Kushner. The members of the revised work groups were: Health: Wegman, Anderson, Newman, Teitelbaum, White, and Cox was half time; Cooperation and Comparison: Burch, Day, McGee, and Howell and Kushner were each half time; Systems: Lick, Shortell, and O'Brien half time; and Exposure Assessment: Mirer, Frederick, and Kushner, O'Brien, Howell and Cox each half time. The original duties of each group and questions the revised groups were asked to address are in Attachment #8. The products of these groups are found in the appropriate chapters of this report and meeting minutes. The leaders of each group are named first in the above list.

A duty of all work groups was to visit worksites that use MWFs. These visits included a large facility outside of Cincinnati, three small businesses in the Cleveland area, and a mid sized facility outside of Detroit. In order to better understand the issues related to diagnosis and medical monitoring of respiratory disease, the work groups visited a respiratory disease medical research center in Denver. These visits were discussed at meetings, so information on them is found in the minutes.

In order to provide the most useful information to both OSHA and those employees and employers who use MWFs, the final deliberations, and this report were organized into two major divisions. These divisions include: deliberations on actions OSHA should take (Chapters 1,2,3,4 and 5) and best practices for MWFs (Chapters 6,7,8 and 9). The second section of Chapter One addresses the scope of MWFs. deals with the committee's deliberations on the health issues related to MWFs. The committee's input on the technical feasibility is found in Chapter Three. The economic feasibility of actions that could be taken by OSHA is provided in Chapter Four. The committee's recommendations for OSHA actions related to MWFs are found in Chapter Five. The committee's assessment of the best practices for those working with MWFs include: Chapter Six - Systems Management, Chapter Seven - Exposure Assessment, Chapter Eight - Medical Surveillance and Chapter Nine - Training and Information Outreach.

Many of the chapters overlap in content. Sections of the Second through Fifth Chapters of this report could be incorporated in an OSHA action. Chapters Six through Nine were developed as an almost "stand alone" document. These latter chapters are designed to provide guidance to OSHA, and also to provide immediate recommendations to the entire MWF community of stakeholders.

1.2.6 What is Expected of the Committee

Watchman and Jeffress noted their desire for the committee to investigate various options (M1:1). The charter provides a list of duties for the committee. Jeffress emphasized a focus on best practice activities for protecting workers in the MWF environment. Individual committee members had their own individual perspectives on what the committee should accomplish. Overall, the committee decided to provide OSHA in this report: documentation of committee discussions, majority and minority recommendations and rationale for OSHA actions, and detailed instructions for best practice related to Systems Management, Exposure Assessment, Medical Surveillance, and Training and Information Outreach.


1.3 SCOPE OF THE MWF ISSUE

1.3.1 Speakers and Presentations

The scope of the MWF issue was primarily addressed at the first, second and fifth meetings and discussed at other meetings. Committee member, Dr. Dennis O'Brien provided an overview of the types of machining operations using MWFs (M1:1). Committee member, Dr. John Howell explained the composition and use of MWFs (M1:1). Committee member, David Burch presented information about characteristics of machining in small business (M2:3). Dr. William Lucke, Cincinnati Milicron, explained the development of MWFs. Robert Burt, OSHA Office of Regulatory Analysis, presented an industry profile of companies potentially affected by an OSHA action. Greg Piacitelli, NIOSH provided information about characteristics of companies that participated in the NIOSH Small Business Study.

1.3.2 Review of Available Information


1.3.2.1 Experiences and Resources Related to the Scope of the Machining Processes
Committee member, Dr. Dennis O'Brien provided an overview of machining processes at the first meeting and provided handouts. Machining processes include: turning, milling, grinding, drilling, sawing, and threading. Turning uses a single point tool that is fed into a rotating workpiece. Turning operations include cylindrical turning, boring, facing and taper turning. Milling uses a rotating multipoint tool and the workpiece is fed into the cutter. Milling operations include slab milling, face milling, end milling, broaching and hobbing. Broaching is milling with a linear tool. Hobbing is a specialized milling operation with a complex rotation of the workpiece. Grinding is done with an abrasive wheel and the workpiece may rotate or move in a plane. Grinding operations include cylindrical grinding, centerless grinding and surface grinding. Drilling short holes can be done using a radial drill and the tool rotates in the operation. Drilling deep holes may require a gun drill and the workpiece may rotate in this operation. Sawing is similar to using a narrow broach or grinder. Threading can be done by turning, tapping, grinding or rolling. (O'Brien, 1997). Diagrams of these processes and general machining characteristics can be found in handouts of O'Brien (1997) and Burke (1998).

Burch described machining and the use of MWFs in small businesses such as those represented by his organization, Precision Machined Products Association (PMPA) (M2:3). Burch explained that machine tools in his organization's companies include: single-spindle automatic screw machines (ASMs), multiple spindle ASMs, Computer Numerically Controlled (CNC) turning machines and rotary transfer machines (Burch, 1997). Internal machining operations include: drilling, reaming, cross drilling, cross reaming, broaching, counterboring, polygon boring, recessing, tapping, boring, chamfering and bank-end drilling (Burch, 1997). External machining operations include: turning, forming, roller shaving, skiving, broaching, thread rolling, die head threading, single point threading, milling, deburring, slotting, sawing, cutoff, polygon turning, knurling and roll marking (Burch, 1997).

O'Brien explained that MWFs can be applied to the tool/workpiece interface through the tool, as an air carried mist, or by flooding. He noted that MWF mist can be generated by nozzle atomization, centrifugal atomization, evaporation/condensation, splash and the cola effect. The cola effect is due to air entrapped in the fluid and the effect is similar to a carbonated beverage (O'Brien, 1997; T1:85).

Lick explained that traditional machining should be the scope (M2:23). If other materials are machined in these environments, these other materials may be covered in the context of that machining plant (M2:24). Lick noted that defining the operations may be more important than defining the fluid (M2:23). Grinders are used in other environments (M2:23). Including stamping would lead to including forge plants and the fluid components start to differ from MWFs, according to Lick (M2:23).


1.3.2.2 Experiences and Resources Related to the Scope of MWFs
Committee member, Dr. John Howell provided an overview of the MWFs along with handouts (M1:2). Howell explained that metal removal fluids are a subset of metalworking fluids (M1:2). Howell described the term metal removal fluids as those used for cutting, machining, grinding and honing (M2:23). For the purpose of this report, MWFs were used instead of metal removal fluids, the term Howell used. A diagram used by Howell is provided in Attachment 9.

The primary functions of MWFs are to cool and lubricate the machine tool/workpiece interface. In addition, MWFs provide corrosion protection, removal of chips and swarf, and lubricate the machine tool. Components are added to enhance these effects as well as address issues such as rancidity control and foaming. Howell explained, and Lick later stressed, how important chip removal is for transfer line operations and for the integrity of the machined part (M2:15). Waste management is another issue (Howell, 1997a).

The four categories of MWFs are: straight or neat oils, soluble oils, semisynthetics and synthetics, according to Howell. Howell provided typical components and characteristics of each of these categories and these can be found in his handout (Howell, 1997a). Typical components of MWF categories were provided by the Independent Lubricant Manufacturer's Association (ILMA) (ILMA, 1998). Howell addressed the issues of changes in refining affecting the petroleum oils used in straight and soluble oils and semisynthetics. He explained that soluble oils are diluted 5-20 times with water, while semisynthetics are diluted 2.5 to 10 times with water, and synthetics 1 to 10 times with water (Howell, 1997a).

Specific components such as alkanolamines and biocides were explained by Howell. More on alkanolamines is provided in Lucke's presentation provided later in this chapter. Triazine and formaldehyde issues have been associated with biocide use although Howell noted that the background level of formaldehyde was the problem in some studies. (Howell, 1997a).

Howell explained the effect of use on MWFs, noting that water soluble fluids are very dynamic. MWFs are vulnerable to contaminants such as tramp oil from e.g. leaking hydraulic oil from the machine, as well as particulates, dissolved metals and abrasives. Concentrations can shift and with water soluble fluids, microorganisms and their byproducts can cause problems. All of these interactions can result in the production of a fluid that is very different from what it was originally, according to Howell. Managing the fluid is the key to success (Howell, 1997a; T1:153).

Burch described the use of MWFs in small businesses such as those represented by his organization, PMPA (M2:3). In companies represented by PMPA, 26.9% use straight oils only; 1.9% use water-soluble MWFs only; 0.6 % use semi-synthetics only; and, 0.6% use synthetics only (Burch, 1997; M2:3). Looked at a different way, 95.5% of the companies use some straight oils in their operations; 58.3% use some water solubles; 12.8% use some semi-synthetics; and, 16.0% use some synthetics. (M2:3). Once a company finds a fluid that fits its needs, the business usually will not change fluids (M2:3). O'Brien, Burch and Howell explained that screw machines will continue to use straight oils, and that CNC machines and grinders were more apt to use or change to non-straight oil MWFs (M2:3).

Burke cited a Cincinnati Milicron study (Burke, 1998). This study estimated that 100,000 small businesses use MWFs, 20,000 medium size companies use MWFs and 150 large businesses use MWFs (Burke, 1998).

In Lucke' s presentation about the history of MWFs, he explained the changes in MWFs chemistry over time (M5:16). He noted that the earliest use of MWFs occurred in the 1830's and the fluids were water, soap solutions, and animal and fish oils (M5:16). Around 1850, with the production of crude oil, straight oils were used (M5:16). The first synthetic, a saturated solution of sodium carbonate and water, was used in 1883 (M5:16). Soluble oils came into use around 1915, and in 1947, semi-synthetics were developed (M5:16). Soon after, modern synthetics with sodium nitrite, a rust inhibitor were used (M5:16). One change made in the 1950's by the oil industry was more severe refining with reductions of the PNA content (M5:16). Kerosene was used in straight oils as a viscosity improver but removed in response to customer demands (M5:16). PCB's were used in straight oils and soluble oils as extreme pressure lubricants, but in 1970 they were taken off the market (M5:16). Since whales became a protected species, it became illegal to use sperm oil (M5:16). Chloroform and carbon tetrachloride were used as tapping fluids but are no longer used (M5:16). In 1976, nitrosamines in metalworking fluids were found at the parts per hundred level and by 1984-1985, most nitrites had disappeared from the market (M5:16). There are still products being sold in the US that have up to 16 percent nitrite but these suppliers are not members of the ILMA, according to Lucke (M5:17). Most formulators replaced the nitrites and also labeled those fluids that contained the nitrites according to Lucke (M5:16). Lucke stated that some products with diethanolamines (DEA) are being reformulated without DEA, and others formulated with lower amounts but with warnings on the material safety data sheets (M5:16). Use of phenolic biocides was reduced around 1970 due to a waste disposal issue, and PTBBA was also removed due to concern about skin absorption in the presence of dimethylsulfoxide (M5:16). He noted that PTBBA and some of its replacements have been associated with the "cola" type of aerosol generation in which the additive acts to entrain air into the fluid and there is fizzing in the sump (M5:16) Lucke explained that dichromates were used as corrosion inhibitors but have been replaced (M5:17). Lucke explained that some of these additives can be found in the mist at 10 to 100 times greater levels that they are in the bulk fluid (M5:17). Additional information on fluid components and the history of fluid formulation can be found in articles by Howell, Lucke, his presentation handout, and an article by Kelly (Howell, 1997b; Lucke, 1993, 1996, 1998; Kelly, 1996).


1.3.2.3 Experiences and Resources Related to the Scope of the Workplaces
OSHA economic feasibility determinations, according to Burt, indicate that 1.1 to 2 million employees use MWFs (M7:24). These workers are in 169 third digit SIC groups but if a 2 digit level is used, there are 6 principal SIC code groups, 33 though 38 (M7:24). According to Burt, using the NIOSH NOES data, there are 15 occupations primarily exposed to MWFs (M7:23). Another 10 to 15 occupations occasionally use MWFs (M7:23).

According to Burt, 185,000 workplaces have metalworking machines that might use MWFs and 140,000 of these are in the 6 SIC codes (M7:24). According to Piacitelli, SIC codes 34 through 37 are estimated to represent 98% of the machining in the US (M4:1). About 88% of the 185,000 workplaces and 75% of the 140,000 workplaces are establishments with less than 500 employees (M7:24).

Burt explained that there are about 3.1 million machines in the 6 SIC code groups with about 1.3 million used by the smallest businesses with 1-19 employees (M7:24). SIC code 35 contains 43% of all the machines (M7:24).

According to Burch, forty is the average number of employees of companies that are members of PMPA (M2:3). Ninety percent of these companies are family owned (M2:3). Family members are commonly employees of these companies (M2:3). Operations can change minute to minute, depending on customer demands, according to Burch (M2:3).

Shortell disagreed with Burch's assessment of the changing nature of the work in small businesses (M2:3). Shortell noted that many small businesses, also known as job shops, have a regular product they turn out and also do smaller volume jobs that may change frequently (M2:3). Shortell explained that the jobs may change, but usually the tool does not (M2:3).

O'Brien noted the number of industry types that could have MWF exposures (M2:23). He listed: pneumatic tool use, steel rolling mills, coal strip mills, printing shops, railroads, quenching oils, drawing compounds and plastic molding (M2:23).


1.3.2.4 The Scope of the Stakeholders
The companies that use MWFs consist of small, medium and large facilities. Some of these facilities belong to trade groups. In addition to the users of the fluids, there are other stakeholders for this issue. Fluid components are provided by a variety of chemical companies and these components are blended into formulations by fluid manufacturers. Machine tool manufacturers produce the tools and are involved in the enclosure of tools. Users, consultants and some fluid manufacturers conduct fluid management. Users and consultants determine ventilation, mist control and other engineering approaches. Industrial hygienists provide exposure assessment and evaluate exposure control strategies. Trade groups, union and company industrial hygiene and safety representatives, and fluid manufacturers provide training and training materials. Medical care professionals including nurses, primary and advanced care physicians, may work for employers or contractors of the employer, or work in private patient care. Employees, employers, fluid component suppliers, fluid formulators, machine tool manufacturers, industrial hygiene and safety professionals, and medical care professionals are all stakeholders in this issue. The committee has sought the input of these groups to address and make recommendations for protecting the users of MWFs.


1.3.2.5 The NIOSH Criteria Document
NIOSH defines the MWF aerosol as "the mist and all contaminants in the mist generated during grinding and machining operations involving products from metal and metal substitutes" (NIOSH, 1998). Characteristics of the mist are a function of MWF type, contaminants, additives, how the fluid is applied, and tool and process factors such as tool speed and type (NIOSH, 1998 citing, ANSI 1997). Ventilation, air cleaning and splash guarding will affect the mist (NIOSH, 1998 citing, ANSI 1997). NIOSH defines the metalworking environment as "any environment in which workers are exposed to the following: metals, metal alloys being machined, chemical residues from preceding operations, MWF additives, MWF contamination from housekeeping and cleaning processes, biological contaminants (bacterial toxins and metabolic products), or physical contaminants (e.g. chips and fines) from MWFs (NIOSH, 1998). NIOSH uses the same four categories of fluids as noted in Howell's presentation (NIOSH, 1998; Howell, 1997). Additional information about fluid characteristics can be found in Tables 2-1 through 2-5 of the NIOSH Criteria Document (NIOSH, 1998). Tables 3-1 and 3-2 of the NIOSH Criteria Document provide information from 1983 on MWF using industries and workers potentially exposed to MWFs (NIOSH, 1998).

1.3.2.6 Additional Resources

More information on MWFs and processes associated with them can be found in Metalworking Fluids (Byers, 1994), Metalworking Fluids: Composition and Use by Howell, Lucke and Steigerwald, and Cutting and Grinding Fluids: Selection and Application (Silliman, 1992). Extended abstracts in the Proceedings from the two MWF Symposia (AAMA, 1996, 1998) can provide additional information.
1.4 CONCERNS AND LIMITATIONS

1.4.1 Size of Business

According to Burt's data, 75-88% of the workplaces using MWFs are small business (M7:24). Butch explained that anecdotal information from his member companies about OSHA citations and databases, indicate that the companies he represents do not have excess exposure (M2:3). With close to 96% of the companies in Burch's study using some straight oils, some consideration of this issue may be needed (Burch,1997).

Cox was concerned about the data sources OSHA uses (M7:24). According to Cox, the Department of Commerce data only tracks companies down to a certain size which Cox thought was ten (M7:24).

Throughout discussions, Burch was concerned about the potential conflict between any proposed OSHA action and the Americans with Disabilities Act (ADA) (2:21). These conflicts would be difficult for a small business to resolve, according to Burch (2:21). More on this issue is addressed in Chapter Five.

1.4.2 Variability of Environments and Fluids

Members emphasized that there is not any standard machine or standard fluid. McGee noted that there is not any standard employer of management approach to MWFs (M3:11). McGee explained that there are differences between the three American auto makers and even differences that can be found at plants of the same company at the same site (M3:11).

O'Brien was concerned that we need to address the degree of contamination of the fluids (M2:23). Members and presenters reinforced the concept of how the fluids change with use. Members noted the importance of viewing not just the fluids, but the metalworking environment.

Issues cited repeatedly were product stewardship to properly develop fluids and a user's program to properly select fluids. More on these issues can be found in Chapters Three, Six and Nine. One aspect of product stewardship is removal of a potential problem product from the market or alteration of the formulation of the product. Lucke noted customer concerns about successful products being altered (M5:16).

1.5 LINKAGE OF DISCUSSIONS TO OSHA ACTION

Mirer explained the rationale for the UAW MWF petition (M2:23; 9:25). He noted that the term machining fluids did not include grinding and the term cutting fluids does not include grinding and some machining (M2:23). As a result the petition focused on what is used in engine, transmission and parts plants (M2:23).

Lick recommended limiting the scope, noting that sticking to the original petition would be difficult enough (M2:24). OSHA should limit the scope to what is do-able, according to Lick (M2;23). He explained that the ANSI document addressed traditional machining (M2:23).

O'Brien liked the term, material removal fluids (M2:23). He explained that the Byers text uses the term MWF (M2:24). O'Brien cited the NIOSH Criteria Document as referring to machine shop type operations, including machining and grinding (M9:24-25; NIOSH, 1998).

Howell noted that most of the health and other literature was devoted to metal removal fluids (M2:23;9:24). Howell explained that the work done by ASTM and the NIOSH Small Business Study addressed metal removal fluids (M2:23).

Mirer noted that the term metal removal fluids was a relatively new term (M9:25). Mirer wanted the metal contaminants included (M2:24).

Wegman noted that we need to limit the scope to move forward (M2:23). Wegman urged those workplaces beyond the scope of metal removal fluids to not be complacent since some of the same problems may occur (M9:25). The same solutions may work in these environments (M9:25). He recommended that we note in our final report that although these other areas were not included, it does not mean there is a lack of potential problems in these environments (M2:23). Lick agreed that there could be problems in these other areas (M2:24).

Shortell and Burch thought OSHA should define the scope (M2:24). Mirer thought OSHA should write the language and the committee should determine what we think it means (M2:24).

Teitelbaum saw the benefit of both a fluid and an environment approach but noted that the committee was named MWF, not MWF environment committee (M2:24).Teitelbaum recommended that OSHA clearly define terms in whatever action is taken (M9:25).

Discussion provided a scope as wide as including almost any machining process using fluids, to just including those processes in which metal is removed. According to Burch, the committee has to make sure it does the right thing and not the wrong thing to solve MWF issues (M2:3).


1.6 COMMITTEE DECISIONS AND RATIONALE

The committee did not vote on the scope of the fluids but a general consensus developed. The committee recommends that the scope of any OSHA action includes that subset of metalworking fluids that are also known as metal removal fluids. These fluids are those used in traditional operations on metal including cutting, machining, grinding and honing. The fluids and the environment they are in have to be considered together due to the changing nature of the fluids as they are used in their environment.

The rationale for this approach includes: the need to clearly differentiate the types of fluids involved, and the knowledge base available for health effects, exposure levels, exposure assessment methods and/or control. The exclusion of any related fluid, process or environment does not imply the lack of a potential problem in these related fluids, processes or environments.