Back to Final Report Metalworking Fluids Standards Advisory Committee
6.1 GENERAL INFORMATION
Chapter Three of this MWFSAC report discusses the technological feasibility of controlling MWFs. As noted in the earlier chapter, the Systems Work Group defined the role of a systems approach as managing the fluid, integrating and controlling systems that result in exposure control and enhanced MWF and machining performance (M8:3). The Systems Work Group noted the multiple purposes of MWFs, and the overlapping, and sometimes conflicting responsibilities of those employed to manage the fluid, produce useful products, operate the facility and protect the health and safety of employees (Systems, 1999). A systems approach can overcome these conflicts and provide for continuous improvement (Systems, 1999).
The discussions explained in Chapter Three are focused on ways of reducing exposure. The emphasis of this earlier chapter was divided between fluid management and exposure control technologies such as enclosure and ventilation, and the technological feasibility of these actions. Chapter Six addresses how to put together a systems management program for MWFs. Chapter Nine addresses training which must integrate into Systems Management.
The systems work group was charged with finding speakers and resources related to systems management. This work group and the committee as a whole helped provide the basic approach to systems management outlined later in this chapter.
Many individuals and groups outside of the MWFSAC have invested their time and money developing ways of managing the MWF environment. Some MWFSAC committee members have been involved in this work. A very detailed and useful product of these efforts was developed by individuals and groups representing industries that are MWF suppliers and users. This product is the ORC Management of the Metal Removal Fluid Environment. The first edition of this document was explained to the MWFSAC in late 1997. With input from the committee and others, this document was revised and a draft second edition was presented by a group of speakers at the eighth meeting in February, 1999. A CD/web version was presented to the committee at the ninth meeting in May, 1999.
Committee member, Dr. Hank Lick, provided an overview of systems management (M2:15-17). Another committee member, Frank White discussed the development of the ORC Guide (M2:16). Dr. James d'Arcy, General Motors described how to use the ORC Guide (M8:6-7). Darrell Matthias, ORC, explained how the document can be used. Dr. John Howell, committee member and Dr. Daniel Goon, Castrol, addressed issues related to product stewardship (M5;23). Dr. William Watt, Chrysler Corporation presented information on facilities and equipment. Ike Tripp, Etna, addressed fluid management principles (M8:8). Michelle Lantz, Caterpillar Corp., discussed systems management committees (M8:10). Dan Broghammer, Deere, and Greg Williams, Caterpillar, discussed fluid delivery and filtration. Tom Slavin, Navistar, addressed training and safety issues.
Howell outlined the actions an enlightened employer would take with MWFs (7:26). A systems approach would be used: workers would be trained about the fluids, the supplier would have a product stewardship program, and an ORC outreach program would exist (M7:26). Fluids would be properly selected and appropriate concentrations used, monitored and managed (M7:26). Good industrial hygiene practice would be followed, and all machines would be locally exhausted (M7:26). Exposure monitoring and medical management would be done (M7:26). Additional details of what is included in systems management is provided in Chapter Three of this document.
6.4.1 Experiences and Resources Related to Systems Management
d'Arcy and Mattheis described the organization and structure of the ORC document, CD, and the web based version using hypertext (M8:6,12; M9:5). The website has 70+ interlinked pages with a 271 page print version (M9:6). Searching is possible with the web and CD versions (M9:9). Mattheis noted the intention to have the document available free on the Internet, and at cost in CD-ROM format (M8:10; 9:6). Mattheis stated the only limitation was that information be copied in its entirety and not sold commercially (M9:6). Continuous updating will be done (M8:11).
Mattheis hoped to develop a question and answer bulletin board with an expert panel (M8:11). MWF manager certification programs are being discussed along with training seminars and other outreach efforts (M8:11). More on these issues is found in Chapter Nine.
d'Arcy stressed the importance of active management of the very complex fluid environment (M8:6). d'Arcy highlighted the quick start chapter of the ORC document which describes how to navigate the document (M8:6; M9:6). He noted other chapters on the fluids, management, health issues, facilities and equipment, employees, management programs and quality assurance (M8:6).
d'Arcy explained that the document was designed for the janitor as well as the plant engineer (M8:6). d'Arcy noted that the reading level was viewed as sixth grade level (M8:12). A question and answer format is used and self assessment checklists are available (M8:6). Tools for improvement are provided (M8:6). The document is a dynamic guideline and will be modified to include new information (M8:6).
Howell highlighted fluid topics covered in the document, such as fluid use and selecting fluid suppliers (M8:7). Howell noted descriptions and functions of the fluid and some typical compositions (M8:7). A flow chart of the manufacturing process describes potential problems with the fluids such as contamination and microbial growth (M8:7). Howell noted how fluids can get out of control and potentially cause increased occurrences of dermatitis (M8:7).
Howell explained that the second part of the chapter on fluids addresses how to choose a fluid supplier and supplier support (M8:7). He noted characteristics of a good supplier who will provide good systems product quality and technical support, and be ISO 9001 or QS 9000 certified (M8:7). The supplier must provide the appropriate fluids for the specific operations in a shop (M8:7). Compatibility between other machine related fluids and metal removal fluid is important (M8:7). Another selection criterion is the ability of the supplier to provide a fluid management program if the user needs an externally provided one (M8:7). Other supplier attributes include: a customer support program, and a product stewardship program (M8:7).
Howell noted that health, safety and environmental characteristics were the first selection criteria for a fluid, followed by compatibility and performance characteristics (M8:7). Howell noted new information available such as misting characteristics, raw materials used and the toxicity of the whole fluid as used compared to components (M8:7). Howell explained how fluid life can be extended by proper fluid selection (M8:7).
Tripp explained how the ORC document addresses management of the fluid (M8:8). He stressed looking at individual components and the entire process including effects of previous operations (M8:8). Tripp highlighted sections on managing the fluid in use, renewing or changing over systems and dealing with environmental concerns (M8:8).
Tripp outlined important management components including: a designated responsible person in charge, proper cleaning and disinfecting of machines, high water quality for water based fluids, and on-going maintenance of machines to prevent leaks and contaminants (M8:8). He stressed how proper management could lengthen tool life and this means less time changing tools resulting in less exposure during tool changes (M8:8).
Tripp stated critical fluid parameters to consider such as: concentration, stability, lubricity, foaming, microbial concentration, vulnerability to tramp oils, and extent of contamination (M8:8). He noted that the ORC guide provides checklists and other ways to assess these parameters (M8:8). He provided examples of tests such as refractive index, alkalinity, and conductivity (M8:8). Observations such as appearance and odor are important for operators to report (M8:8). He shared an example of a log to record important variables (M8:8). Tripp noted other potential contaminants such as airborne dust (M8:8). Tripp explained that the operator has to be considered to reduce any potential for dermal or respiratory effects (M8:8).
Tripp explained a system renewal or change out and stressed that every part of the system must be cleaned to avoid reintroducing contaminated coolant (M8:8). The environmental section of the ORC document addresses pretreatment and disposal of the spent fluid (M8:8). The document reviews airborne emissions of volatile organics and particulates (M8:8).
Howell discussed the health effects section of the ORC document, noting that it was not designed to take the place of the NIOSH Criteria Document and was not a summary of the medical effects literature (M8:9). The chapter includes routes of exposure for operators and others, limited information on health effects, prevention of these effects, and discusses MSDSs (M8:9).
Watt provided an overview of how the ORC document addresses facilities and equipment (M8:9). Information is provided for those building a new facility, updating an existing facility or using their current facility (M8:9). Ideal building characteristics, ventilation, and enclosure design are addressed (M8:9).
Broghammer discussed additional design considerations for fluid delivery systems and the differences between self contained vs. central fluid systems (M8:9). Williams described the importance of fluid filtration and what the document provides to address this issue (M8:9).
Slavin discussed the ORC document and training (M8:9). More information on this is given in Chapter Nine of this MWFSAC report on training. Slavin also addressed other issues such as machine safety and personal protective equipment (M8:9,10).
d'Arcy spoke on how the document deals with exposure assessment which includes both a qualitative and quantitative assessment (M8:10). Baseline and periodic sampling and a planned exposure reduction program should be implemented (M8:10). More information on exposure assessment is provided in Chapter 7 of this MWFSAC report.
d'Arcy explained that an exposure limit alone would not ensure elimination of health effects, especially if HP is considered (M8:10). The ORC document recommends everyone be below 2 mg/m3 with 1 mg/m3 as a target (M8:10).
Mattheis discussed medical surveillance and monitoring, noting that the document may include what was developed by MWFSAC (M8:10). More information on medical surveillance is in Chapter Eight in this MWFSAC report.
Lantz explained that the first approach in actual managing was to put together a committee representing different groups in the work place (M8:10). She recommended including: maintenance, operators, safety, chemical management, operations and manufacturing, machine tool designers and waste treatment (M8:10).
Goon spoke about ILMA Product Stewardship and how it integrates into the other issues that have been discussed (M8:11). Other information he and Howell provided can be found in Chapters Three and Nine of this MWFSAC report. Howell outlined ILMA's Product Stewardship activity (M7:32). There was an implementation task force consisting of three companies which conducted a pilot of a draft program (M7:32). Results of this program are expected in late 1999. ILMA has 100 member companies that produce MWFs which is about 75% of the US production of MWFs (M4:4).
6.4.2 Additional Resources
The systems group recommended resources in addition to the ORC document (M8:5). These resources include: the ANSI B-11 Mist Control document, NIOSH Criteria Document, and the ACGIH Ventilation Manual (M8:5). Howell cited the National Center for Manufacturing Sciences Metalworking Fluids Optimization Guide (M8:7). Literature about microorganisms and MWFs can be obtained from Biosan, Warren, MI. Handouts of Lick, Gauthier and Burke also provide supplementary information (Lick, 1997; Gauthier, 1997; Gauthier, 1999; Burke, 1998). Additional references are found in Attachment #6.
6.5.1 Size of Business
Burch thought the ORC document for systems management was valuable for small business and was encouraged by the use of CD-ROMs and websites (M8:12). He thought the hypertext web version would be useful in obtaining information quickly, especially in crisis situations (M8:12). He noted that small business does not always access information like this, or like the OSHA consultation program, as much as it should due to lack of knowledge or lack of time (M8:12). Burch explained that the document begins to present a system that any size business could integrate into their operations (M8:12).
Sheehan asked if the ORC document would prevent the poor decisions evident in a small business site visited by the group (M8:12). She was concerned about the impact of the document in preventing situations in which suppliers were victimizing small business (M8:12). Cox thought the document was a fine teaching tool and may prevent the poor decisions seen in the plant visited in Cleveland (M8:12). Howell thought it would not solve all problems, but that combining the document, the web version, education, outreach and stewardship could go a long way to changing behavior (M8:12).
Burch noted that other issues were at work besides what is addressed in the document, such as some workers not wanting to report problems because of fear of job transfer and reduced pay (M8:12). Burch explained that in a small business because of lower pay, there is less incentive to stay in a job with, e.g., irritation, if you know there is another job in a cleaner shop for as much or better pay (M8:12). Burch noted that in small business, workers complain to the president, not a medical department (M8:12). The president has an incentive to improve the situation so as not to lose the worker to a competitor (M8:12).
Cox noted that no matter what action the MWFSAC takes, the ORC document is a great document and he would push for its availability to his membership (M8:12). Cox agreed with Kushner that health and safety go hand in hand with product quality and profit (M8:12). The smart businessman knows that you can replace a machine easier than skilled labor (M8:12). Cox thought it should be read by the owner and foreman in a small shop (M8:12). Cox noted that these facilities do not have anything available now (M8:12).
6.5.2 Assessment and Accountability
Committee members were concerned about how the quality of a systems management program can be determined. More information on these concerns are in Chapters Three and Seven of this MWFSAC report. Members were also concerned about accountability of suppliers and users.
White noted that assessing a fluid management program would be similar to assessing a health and safety program (M7:23). He challenged the group to come up with criteria that determine effectiveness (M7:23). Criteria were incorporated into a qualitative assessment tool that is part of Chapter Seven of this report.
Mirer gave an example of a NIOSH HHE that demonstrated that a poor systems management program did not protect workers (M8:5). He was concerned that this poor program would meet any OSHA or ISO proposed program (M8:5). Mirer was concerned that the ORC document does not help with the assessment of which products are going to be good or not good from a health standpoint (M8:13).
Wegman was concerned that the checklists presented in the ORC document are a beginning, but are not enough to determine the adequacy of a fluid management program (M8:8). He noted the linkage of systems management to the medical surveillance program which has the fluid management program as a trigger (M8:8). He noted that as stated, this is an audit, but not an audit that determines if the program has reached or exceeded the threshold of a good management program (M8:8).
Howell explained that the supplier is accountable for providing education and outreach to customers (M8:12). Howell noted that no one is going to check the supplier except themselves (M8:12). Goon explained that the ILMA product stewardship group was working on the issue of accountability (M8:12).
Sheehan questioned who is responsible in the team format recommended for systems management (M8:12). Lantz noted that people should be responsible for their own well-being to report problems and find someone to help (M8:12). Lantz viewed that the employer is responsible to provide a work environment and team to solve the problem (M8:12). Lantz thought that the team peer pressure was useful for behavioral change (M8:12). Cox explained that the ultimate responsibility was the owner's (M8:12).
6.5.3 Is the ORC Document Enough for Systems Management?
Cox commented that the ORC document was a stand alone document to assist different size businesses in the management of MWFs (M8:7). White noted that the document is stand alone (M8:7).
O'Brien complimented ORC on the quality of the document (M8:7). He disagreed with the document being stand alone because the Disease section is written to be inoffensive instead of complete (M8:7). White admitted the limitations in the document in areas such as medical surveillance and exposure levels, noting that these issues would evolve (M8:7). Howell explained that ORC did not want to duplicate the NIOSH Criteria Document (M8:7).
6.5.4 Health Issues Related to Systems Management
The relationship between systems management and health effects is outlined in Chapters Two and Three of this MWFSAC report. Information discussing what additional health information, other than what is outlined in the ORC document, is needed in a systems management program is provided here.
Newman noted that one of the goals of managing the fluid is to control the health effects and recommended more emphasis on relating any systems management program and health (M8:8,11). He noted simple medical terms like "cough" should be used in training workers and clarifying effects (M8:11). Sheehan and Lantz agreed on a focus on symptoms so workers report health problems (M8:12).
Newman advised against listing other factors that could cause health effects because they understate the health effects a systems management program is trying to prevent (M8:8). Lantz agreed that the operator's health and safety as well as teamwork need more emphasis in the ORC document (M8:8).
O'Brien viewed that the 2 mg/m3 time weighted average stated in the ORC document as an acceptable limit, had no basis (M8:11). He noted that it was inconsistent with ILMA's own recommendation of this value for a peak (M8:11). O'Brien explained that 2 mg/m3 as a peak value is roughly equivalent to 0.5 mg/m3 as a time weighted average (M8:11).
Anderson recommended including MSDS's under technical support provided by suppliers (M8:7). Information provided by suppliers about the toxicity of individual components and aerosol generating potential of the fluids would be useful (M8:7). Mirer appreciated the fluid suppliers removing problem ingredients, but was concerned with what was remaining (M8:13).
Teitelbaum questioned the use of terms in the ORC document, recommending that physicians peer review it (M9:6). Teitelbaum recommended avoidance of the term "healthy fluid" which he thought implied a healthy environment (M8:8). Teitelbaum noted that the "integrity of the fluid" would be a better term (M8:8). Lick indicated the extensive peer review the document received from all who were involved in its production (M9:6). Teitelbaum recommended review by the American Thoracic Society or the American College of Occupational Medicine (M9:8).
White agreed with Frederick and Newman that the section of the ORC document defining causes of skin irritation was not adequate (M8:9). White noted the difficult balance between providing adequate health information and making the information useful to the reader (M9:7).
6.5.5 Other Issues Needed in a Systems Management Program Document
Burch recommended more clarity about which advice in a systems management program applies to which type of fluid (M8:8). This would reduce confusion in shops (M8:8).
Mirer recommended making ORC's checklists more performance or objective oriented (M8:11). Terms need to be clearly defined in a program, according to Frederick (M8:9). White noted that the ORC document needed to do a better job of defining terms such as "high mist level" (M8:9).
Newman agreed that the ORC document was a strong one and a powerful teaching tool for some groups in industry but did not think it was written at a level for workers (M8:11). Newman and Sheehan thought the level was as a trainer's manual (M8:11).
White hoped OSHA would embrace the ORC document and noted that industry would rather have a voluntary compliance program than regulation (8:7). He explained that with the ORC document industry has shown that it is willing to do something (M9:34). If the voluntary approach would not work, some combination may be appropriate (8:7). d'Arcy viewed the ORC consensus document approach as more valuable than a rigid regulation which could not incorporate new information (8:6).
Teitelbaum explained his concern was an evidence question and if one believes voluntary approaches will work, it needs to be proven (M8:11). He cited OSHA court cases that have required statistical evidence (M8:11).
Lantz noted that the ORC document can help protect the greatest number of people from threats to their health and safety from working with MWFs or in the MWF environment (M8:10). Lantz emphasized that OSHA should provide information found in the ORC document to get information out to the shop floor (M8:10). It is essential to teach people to be proactive so they can recognize a fluid problem and know who can help them solve it, according to Lantz (M8:10).
Howell noted that the ORC document contains elements of recommended practice that mirrors what OSHA would recommend if it promulgated a standard or guideline (M9:8). He explained that the ORC document would get us further down the road than anything OSHA will do (M9:8).
O'Brien noted that the production of the document was due to the threat of regulation (8:7). Mattheis agreed that without potential regulatory action by OSHA, the ORC document would not exist (M8:10). Mattheis explained the limits of OSHA in protecting worker health citing the focus on inspections of large workplaces (M8:10). Mattheis was concerned about how to reach smaller workplaces who have very little systems management (M8:10). Mattheis noted that the impact of OSHA can be much greater than just inspections (M8:10). Mattheis agreed that the document is not stand alone but needs the help and input of industry, government and labor (M8:10). Mattheis urged the development of alliances to help distribute the information needed to improve these workplaces (M8:10).
White emphasized the importance of partnership and suggested that MWFSAC go beyond the charter to take advantage of useful products such as the ORC document (M8:11). He noted that if action can be taken without a standard, or in preparation for a standard, or as part of a standard, it should be considered (M8:11). White explained it could take until 2005 for any standard to be implemented (M9:5). The ORC guide provides an opportunity for the health and safety community to act to reduce risk now (M9:6).
Mirer explained that the combination of the ORC document, other industry consensus documents, and the NIOSH Criteria Document provide a significant package for compliance assistance.
Shortell cautioned against viewing the ORC Document as a committee document (M9:8). It would take too much time to change the May,1999 version of the ORC document to make it acceptable to the whole committee (M9:8).
Mirer recommended a short form summary of what was presented in the ORC document (M8:11). He suggested including fluid management, enclosure and ventilation issues (M8:11). He recommended developing 10 to 12 key recommendations for MWF management into a document that could be included in a guideline or standard (M8:11).
No formal vote was taken to accept or reject the ORC Guide to Controlling the Metal Removal Fluid Environment. The general consensus was that for most topics, other than health issues or defining an exposure limit, the document was a very useful contribution to systems management of the MWF environment. Chapters Two and Five of this committee report provide the committee's assessment of the health issues and exposure limit. Concerns still remained on how to assess a systems management program's quality.
The committee decided to cite the ORC Document as a definitive resource for systems management. The committee summarized the following pages as the basis for OSHA to include in either a guideline or standard. The best practice for systems management of MWFs includes: