ILMA Compoundings June 2019 - 31

might need to source multiple components for producing that additive.
Finally, regulation is viewed as
an ongoing risk in the industry. As
products become or seem at risk of
being regulated out, firms need viable
replacements with similar qualities
and capabilities to avoid disruption
to their operations.

Takeaway for
the Industry
Ike Tripp is chairman and CEO of
Etna Products Inc. He said that some
changes to the industry could put
companies and even products we rely
on at risk. He gives the example of
hypodermic needles. "The reality is,

hypodermic needles are needed for the
administration of life-saving drugs or
chemotherapy or just common medicine, vaccines and the like. You can't
produce a hypodermic needle within
chlorinated paraffins."
In terms of individual companies,
Tripp said some might need to change
their entire business model. For
example, a company might move from
making lubricants to making additives
for 3D printers as that technology supplants more and more of the demand
for the drawing and cutting of metal
products. Tripp said he has also read
that as electronic vehicles take more of
the market from combustion engine
vehicles, there will be less and less

need for products such as motor oil and
transmission fluid. "Those are bigvolume items for many of the lubricant
manufacturing companies," he said.
"What are they going to do?"
Globally, MWFs represent a
multibillion-dollar industry and a
significant and growing component
of the larger industrial lubricants
industry. Whether as a user or provider of MWFs, it's important
for businesses to stay up to date on
the changing technological, business
and regulatory environment that has
the potential to significantly disrupt
the industry.
Grensing-Pophal is a Wisconsin-based
freelance writer.

Regulatory Impacts: SNURs and CPs
The issue of government regulation is discussed
briefly in the main article, but the potential regulation
by the U.S. Environmental Protection Agency (EPA)
around chlorinated paraffins (CPs) deserves special
attention. The EPA regularly creates significant new
use rules (SNURs), which "can be used to require notice
to EPA before chemical substances and mixtures are
used in new ways that might create concerns."
Jeffrey Leiter is an attorney with Bassman, Mitchell, Alfano & Leiter Chtd., in Washington, D.C., who
represents ILMA. He explained that "EPA's proposed
2018 SNUR would allow medium- and long-chain
CPs to be used in metalworking and other listed
applications for five years. At the end of this period,
users would have to submit a notice to EPA. The
agency would then decide whether to continue to
allow the use of the substances."
Leiter added that inaction on the part of the EPA at
the end of this period could essentially act as a ban.
He said that these chemicals are used as
extreme-pressure additives to prevent metalto-metal contact in gears and metalworking
applications during times of high load, shock load,
high temperature, and startup and shutdown. The
intent is to prevent damage to the metal part being

produced as well as to the tools used to produce
it. Leiter said CPs are critical in a number of applications, including the production of bullets for the
military and in creating fasteners for the aerospace
industry. And Chemical Watch has reported that "the
Aerospace Industries Association (AIA) said that the
substances serve critical roles in applications such
as aircraft and jet engine fasteners and in lubricant
mixtures, and that the rules would impose uncertainty as to their continued availability."
Leiter said that acceptable extreme-pressure substitutes for these materials have not yet been found.
"If there were a way to create a substitute for CPs
in a number of critical applications, our members
would have done it already," he said.
It's important to note that while being subject
to an SNUR is not technically the same thing as
having a ban on a substance, it creates a great deal
of uncertainty. Manufacturers would have difficulty
relying on a key part of their production process
if they knew it could effectively be prohibited in
a couple of years. The time it takes to develop
or source an alternative puts a lot of pressure on
companies to quickly determine their path forward
with respect to CPs.

ILMA Compoundings June 2019

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