ILMA Compoundings May 2018 - 24

The regulation was designed to provide new guidance on
how transmission fluids must be identified and labeled in
the market. Under the changes, oil marketers can rely on
the additive company to provide credible evidence that their
additive can be used in these applications. Previously, it was
up to the oil marketer to provide documentation.

ADVANCED PREPARATION
To comply with the new regulations, Omni Specialty Packaging, based in Shreveport, Louisiana, changed its labels and
ensured it had the correct references for the performance
claims. Lena Abramov, the company's vice president of
technology, said Omni obtained the technical information
for labels from its suppliers, and it was the suppliers that
conducted the testing to support the claims.
"We started to make some adjustments to the labels to
make it more accurate two years ago," she said. "A lot of
work was done up front, and we verified all of the claims."
In addition to verifying claims from a technical standpoint, the labels have to be designed to ensure all of the
information is on the labels and then edited for accuracy.
The only corrections the company made on its ATF labels
were related to the proper size and spelling of trademarks.
"The biggest challenge is to make changes to the labels,
because this is a high-volume product. You have to make
sure all claims on all size labels are correct, and you have
to make sure the label is recognizable. That takes a lot of
work," Abramov said, adding that Omni Specialty Packaging
was in compliance before the Jan. 1 date. "We didn't have
any issues with ATF labels."

COMPLIANCE BEST PRACTICES
Leiter suggested that ILMA members maintain records that
document the testing the additive company has done or the
representations the additive supplier has made concerning
its products' suitability of use in a particular application.
"You might want to say 'This is suitable for use in these
kind of applications' without saying 'I meet the specification,'" he said.
Ferrick said marketers have to be able to identify at least
one of the standards that the product meets. "If it is a
Dexron VI transmission fluid, they have to make [sure] their
packaging identifies it as Dexron VI. If it is more than that,
they have to identify at least the one, and if there is a list of,
say, transmissions that fluid is suitable for use in, they're supposed to make that information available," he said, adding
that companies can make the information available online.
Johnson said she has gotten several questions about
whether a product data sheet or sell sheet can be used as a
tank label for bulk product. "We asked about that in our

MAY 2018

| COMPOUNDINGS | ILMA.ORG

outreach to the states. So far, no weights and measures
department has rejected the idea," she said.
Handbook 130 is available to download on the NIST website, and ILMA members can easily access the Handbook
on the ILMA website under the "Issues" tab. Marketers can
reference the regulations to ensure they're in compliance.
"The truth is, they're pretty cut and dry," Ferrick said.
The changes fall under two sections: "Uniform Regulation
for the Method of Sale Commodities" and "Uniform Engine
Fuels and Automotive Lubricants Regulation." They specify
labeling requirements for packages and containers as well as
for transmission fluid sold in bulk.
Johnson said the biggest challenge associated with the new
regulations is likely a pre-existing one: avoiding distributor
cross-contamination of bulk products during the distribution process.
Overall, Johnson anticipates that more consistency in
labeling rules nationwide will benefit ILMA's members.
"Consider the waste of money and increased risk of human
and production error associated with having to use five
different kinds of labels and receipt documents for the same
product," she said. Continued on page 27

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ILMA Compoundings May 2018

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