ILMA Compoundings May 2017 - 3

LETTER FROM THE CEO
BOARD OF DIRECTORS
President
Beth Ann Jones
Hangsterfer's
Laboratories, Inc.
Vice President
Dave Croghan
Maxum Petroleum
Treasurer
Barbara Kudis
Allegheny Petroleum
Products Co.

Ann Ball
CIMCOOL Industrial
Products LLC
Barbara A. Bellanti
Battenfeld Grease &
Oil Corporation of N.Y.
Michael Damiani
Radco Industries, Inc.
Lon Fanning
DuBois Chemicals

Secretary
Charles Decker
American Oil &
Supply International, LLC

Jarrett Flegel
Boss Lubricants

Immediate Past President
Frank H. Hamilton III
South Atlantic Services, Inc.

Greg Julian
Advanced Lubrication
Specialties

Catharine T. Golden
Etna Products, Inc.

Kent Morris
Pinnacle Oil, Inc.
Ronald M. Powell
Moroil Technologies
Scott A. Schwindaman
Lubrication Engineers, Inc.

STAFF
Chief Executive Officer
Holly Alfano
Associate Director
Martha F. Jolkovski
Director of
Communications
Brenda Gillinson, CAE
Member Services/
Marketing Manager
Tim Mack

Communications
Manager
Amber Lopez
Membership Coordinator
Meg Thaxton
Accounting Manager
Margaret Smith
General Counsel
Jeffrey L. Leiter

EDITORIAL, DESIGN
Contributing Editor
Brenda Gillinson, CAE

Designer
Mark St. Amand

THE YGS GROUP
Editorial Director
Annette Gray

Copy Editor
Amanda Holahan

Senior Editor
Drew Bankert

Account Director
Tina Enck

Managing Editor
Sam Hoffmeister

MEDIA SALES
VP, Media Sales
Susan Welter
Media Sales Director
Stephanie Harkins

Advertising Account
Executive
Tima Good
tima.good@theygsgroup.com

INDEPENDENT LUBRICANT
MANUFACTURERS ASSOCIATION
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Compoundings (USPS 003-447) is published monthly by the
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A Win for ILMA, A Win for
Manufacturers of Metalworking Fluids

lmost exactly two years ago in this space, I wrote about how EPA's
attempts to circumvent the ordinary process of managing chemicals
should be of concern for every ILMA member. In particular, EPA had
medium-chain and long-chain chlorinated paraffins (MCCPs and LCCPs) in the
crosshairs and developed a creative maneuver to eventually ban the chemicals while
avoiding public comment and transparency.
By threatening hefty fines against CP manufacturers and forcing them into settlement agreements because EPA disagreed with the way the products were defined via
their Chemical Abstracts Service (CAS) numbers, EPA was able to require these manufacturers to submit a pre-manufacturing notice (PMN). This legal fiction to treat MCCPs and LCCPs as "new chemicals" created the opportunity for EPA to ban MCCPs
and LCCPs without a notice-and-comment rulemaking. And that's exactly where EPA
was headed, first threatening a ban in 2016 and later pushing the threat out to 2017.
EPA was pursuing this initiative without giving any public notice whatsoever, and never
once publicly disclosing any of these dates in writing so the industry could prepare.
It was a long fight - more than two years, but it paid off. I'm happy to report some
very good news, particularly for our metalworking fluid manufacturers.
EPA finally listened to ILMA and other stakeholders, and responded to the advocacy from an industry coalition ILMA helped lead over the past two years. The result
is that EPA has reconsidered its ban of MCCPs and LCCPs as "new chemicals," and
instead is expected to approve the PMNs, subject to additional testing. Some of our
coalition partners want such testing to occur as "existing chemicals" under TSCA
Section 6, which requires an open, transparent process.
Over the last two years, ILMA consistently told EPA its use of TSCA Section 5
was not appropriate procedurally and that a ban on the manufacture of MCCPs and
LCCPs would cause significant economic disruption to our members and their customers. ILMA estimated a cost to members and their customers to reformulate their
products to be more than $70 billion.
As I write this column, details of EPA's change in direction remain to be ironed out
with the PMN submitters, who are ILMA Supplier Members. However, as ILMA
and the coalition repeatedly argued, if the prospective testing identifies unreasonable
risks that are scientifically justified, EPA then can take appropriate risk management
measures to address those risks.
Did the new regime in Washington, D.C. have anything to do with these developments? While I know that not every ILMA member is a fan of the new president,
there's no question that the change in administration made a difference. The Administration stance on regulatory rollback, along with the no-nonsense style of the new EPA
Administrator Scott Pruitt, certainly contributed to this turnabout.
It's far from radical to demand that the process at any government agency be open
and fair. The previous approach was a flagrant abuse of power, targeting our industry.
Despite the long odds, ILMA, our members and our coalition did not waiver. We
laid the groundwork over two-plus years and it paid off. Congratulations to all who
pitched in on conference calls and in meetings at EPA and on the Hill.
Your persistence paid off.

Holly Alfano
Chief Executive Officer

© 2017 Independent Lubricant Manufacturers Association.
All Rights Reserved.
ILMA is pleased to present a variety of viewpoints in Compoundings magazine. Readers should keep in mind that bylined articles
represent the views of the named author or authors and not
necessarily the opinions, viewpoints or positions of ILMA

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ILMA Compoundings May 2017

Table of Contents for the Digital Edition of ILMA Compoundings May 2017