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VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

RULE 74.31 – METALWORKING FLUIDS AND DIRECT-CONTACT LUBRICANTS 

(Adopted 11/12/2013) 

A. Applicability and Purpose 

 The provisions of this rule apply to any person who uses metalworking fluids or directcontact lubricants on products or parts; and to any manufacturer or supplier who supplies, 

sells, or offers for sale either metalworking fluids or direct-contact lubricants for use at 

industrial or commercial facilities. 

 

 This rule shall apply to all Reactive Organic Compound (ROC) containing fluids used for 

metalworking including, but not limited to, metal removal, metal forming, metal treating, 

or lubricating operations where the metalworking fluid or direct-contact lubricant come 

into contact with products or parts including, but not limited to, blanking, broaching, 

coining, cutting, drilling, drawing, forming, forging, grinding, heading, honing, lapping, 

marquenching, milling, piercing, quenching, roll forming, rolling, stamping, tapping, 

threading, turning, and wire drawing. 

 This rule also applies to ROC containing fluids used for metal protection, including rust 

and corrosion prevention and inhibition, but shall not apply to coatings, sealants, 

adhesives, or lubricants regulated by other District rules including, but not limited to, 

Rule 74.12, Surface Coating of Metal Parts and Products, or 74.13, Aerospace Assembly 

and Component Manufacturing Operations. 

B. Requirements 

 1. ROC Content. No person shall use or solicit the use of any metalworking fluid, 

vanishing oil, or direct-contact lubricant with a Reactive Organic Compound 

(ROC) content in excess of the following limits, as applied: 

Grams of ROC per Liter of Material (pounds per gallon) 

 Fluid Category Effective 

 January 1, 2014 

Vanishing Oil 50 (0.42) 

Metalworking Fluid: 

 Metal Forming 75 (0.63) 

Metal Removal – General 75 (0.63) 

Metal Removal – Precision Metal 130 (1.08) 

Metal Treating 75 (0.63) 

Metal Protecting – General 50 (0.42) 

Metal Protecting – Military Specified 

 Preservative 

340 (2.83) 

Direct-Contact Lubricant 50 (0.42) 
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 2. Depletion of Metalworking Fluid User Inventory: Until January 1, 2015, a 

person may use a metalworking fluid or direct-contact lubricant in excess of the 

applicable ROC content limit if the product was purchased prior to January 1, 

2014. Purchase records, sales invoices, or bill of sales may be used to verify 

eligibility for this provision. 

 3. Prohibition of Sale. No person shall manufacture, supply, offer for sale, sell or 

distribute to any person a metalworking fluid or direct-contact lubricant for use in 

the District which, at the time of sale, contains more ROC per liter of material 

than the corresponding limit in effect in Subsection B.1. The ROC content of 

metalworking fluids or direct contact lubricants that are normally diluted prior to 

use shall be calculated using the minimum recommended dilution ratio per 

product label or product data sheet. 

 This prohibition of sale shall not apply to a manufacturer or supplier of a noncomplying metalworking fluid or direct-contact lubricant provided this fluid or 

lubricant was sold to an independent distributor that was informed in writing by 

the manufacturer or supplier that this fluid or lubricant does not comply with 

District regulations. 

 This prohibition of sale shall not apply to any metalworking fluid or direct-contact 

lubricant that is collected and directed to an emission control system that complies 

with the provision of Subsection B.4. 

 4. Control Equipment

 A person may comply with the provisions of Subsection B.1 by using an emission 

control system provided that: 

 a. The control device shall reduce reactive organic compound (ROC) 

emissions from an emission collection system by at least 95 percent, by 

weight, or the output of the air pollution control device is no more than 5 

ppm ROC by volume calculated as carbon with no dilution, and 

 b. The emission collection system has been demonstrated to collect at least 

90 percent by weight of the ROC emissions generated by the sources of 

ROC emissions. 

 c. Written approval in the form of an Authority to Construct and a Permit to 

Operate for such equipment is received from the Air Pollution Control 

Officer (APCO). 

d. Any approved emission control system shall be maintained and used at all 

times in proper working condition. 
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 5. Administrative Requirements

 a. Inventory Compliance List: Any owner or operator subject to this rule 

shall develop and maintain a VOC or ROC listing of metalworking fluids 

and direct-contact lubricants purchased for use at the facility. This list 

shall contain at least the following information and shall be updated within 

seven (7) calendar days from the date of receipt of a new metalworking 

fluid or direct contact lubricant at the facility: 

 1) Name of Company, Facility Address, and APCD Permit Number, 

if applicable. 

 2) For each metalworking fluid and direct-contact lubricant: the 

manufacturer name, product name, product number or ID code, 

fluid category according to this rule, VOC or ROC content in 

grams per liter of material, and corresponding ROC limit, if 

applicable. 

 b. Monthly Purchase Records: Monthly purchase records shall be kept of 

all ROC-containing metalworking fluids and direct-contact lubricants and 

shall include product supplier, manufacturer name, product name, product 

number or ID code, and quantities purchased. Monthly purchase records 

may be used to verify the validity of the inventory compliance list. 

 c. All records shall be retained for a minimum of two years from the date of 

each entry, and shall be made available to District personnel upon request. 

 

 6. Storage and Disposal of ROC-Containing Materials: All ROC-containing 

materials shall be stored in closed vapor-tight, non-leaking, nonabsorbent 

containers, except while adding or removing them from containers. 

 7. Container VOC Labeling Requirement. No person shall sell or distribute any 

container whose contents include any metalworking fluid or direct-contact 

lubricant subject to this rule without displaying the VOC content on the container. 

 

C. Exemptions 

 1. The Sales Prohibition in Subsection B.3 and the Administrative Requirements in 

Subsection B.5 shall not apply to metalworking fluids and direct-contact 

lubricants subject to the consumer products regulations of the Air Resources 

Board (ARB) pursuant to Title 17. California Code of Regulations, beginning at 

Section 94507. 

 2. The ROC content limits of Subsection B.1 shall not apply to: 
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a. The use of any metalworking fluid or direct-contact lubricant subject to 

ARB Consumer Product Regulations and applied via a hand-held prepressurized non-refillable aerosol product, provided 100 cans or less per 

calendar year are used based on purchase and/or usage records. 

 b. The use of any metalworking fluid or direct contact lubricant for the 

purpose of maintaining or repairing operator-owned machine tools. 

 c. Research Operations. 

 3. The Sales Prohibition in Subsection B.2 shall not apply to metalworking fluids 

and direct-contact lubricants sold in this District for shipment and use outside of 

this district or for shipment to other manufacturers for repackaging. 

 4. The ROC content limits of Subsection B.1 and the Sales Prohibition in Subsection 

B.2 shall not apply to metalworking fluids or direct-contact lubricants designed by 

the manufacturer to be used solely for the following operations: 

 a. Lapping; 

 b. Sinker EDM 

 c. Avionics, assembled aircraft or any assembled aircraft component 

 d. Space vehicle components 

 e. Fluids utilizing the control equipment option in Subsection B.4 

5. The Administrative Requirements in Subsection B.5 shall not apply to 

metalworking fluids that are “Super Compliant,” (ROC content is 50 grams per 

liter of material or less). If a shop uses both super compliant and non-super 

compliant materials, the administrative requirements in Subsection B.5 still apply 

to the non-super compliant materials. Any person claiming this exemption shall 

provide documentation or other evidence to substantiate this claim, upon request 

of APCD personnel. This exemption does not apply to metalworking fluids used 

at metal forging operations. 

D. Test Methods and Procedures 

 The following test methods and procedures shall be used to determine compliance. 

 1. Determination of ROC Content: ASTM E 1868-10, Standard Test Method for 

Loss-On-Drying by Thermogravimetry. Quality assurance and quality control 

procedures shall be conducted using SCAQMD Additional Requirements to 

ASTM Standard Test Method E 1868-10 Loss on Drying by Thermogravimetry 

for Rule 1144 Metalworking Fluids and Direct-Contact Lubricants, December 

2010. Water content shall be determined by ASTM D 4017-02(2008)e1 (Standard 

Test Method for Water in Paints and Paint Materials by Karl Fischer Method) if 

applicable to the specific sample. The exempt solvent content shall be determined 
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by SCAQMD Method 303-91, Revised August 1996 (Determination of Exempt 

Compounds). 

Exempt Perfluorocarbon Compounds 

The following classes of compounds: cyclic, branched, or linear, completely 

fluorinated alkanes; cyclic, branched, or linear, completely fluorinated ethers with 

no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary 

amines with no unsaturations; and sulfur-containing perfluorocarbons with no 

unsaturations and with sulfur bonds only to carbon and fluorine, will be analyzed 

as exempt compounds for compliance, only when manufacturers specify which 

individual compounds are used in the coating formulation. In addition, the 

manufacturers must identify the USEPA, CARB, or the SCAQMD approved test 

methods used to quantify the amount of each of these exempt compounds. 

 2. Determination of Flash Point: ASTM D93-07, Standard Test Methods for Flash 

Point by Pensky-Martens Closed Cup Tester. 

 3. The capture efficiency shall be determined according to EPA's technical 

document, "Guidelines for Determining Capture Efficiency," January 9, 1995, and 

Methods in 40 CFR 51 Appendix M, Methods 204-204F, as applicable: 

Methods 204, Criteria for and Verification of a Permanent or Temporary Total Enclosure 

 Method 204A, VOC Content in Liquid Input Stream 

 Method 204B, VOC Emissions in Captured Stream 

 Method 204C, VOC Emissions in Captured Stream (Dilution Technique) 

 Method 204D, VOC Emissions in Un-captured Stream from Temporary Total Enclosure 

 Method 204E, VOC Emissions in Un-captured Stream from Building Enclosure, and 

 Method 204F, VOC Content in Liquid Input Streams (Distillation Approach) 

Control system efficiency shall be determined by 40 CFR 60, Appendix A, 

Method 18, “Measurement of Gaseous Organic Compound Emissions by Gas 

Chromatography,” Method 25, “Determination of Total Gaseous Non-methane 

Organic Emissions as Carbon” or Method 25A, “Determination of Total Gaseous 

Organic Concentration Using a Flame Ionization Analyzer.” Alternatively, South 

Coast AQMD Method 25.1, “Determination of Total Gaseous Non-methane 

Organic Emissions as Carbon,” or SCAQMD Method 25.3(March 2000), 

“Determination of Low Concentration Non-methane Non-ethane Organic 

Compound Emissions from Clean Fueled Combustion Sources,” may be 

substituted as applicable. 

 4. Alternative Test Methods: The use of other test methods may be used in place of 

test methods specified in this rule if they are determined to be equivalent or better 

and approved, in writing, by the Air Pollution Control Officer. 
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E. Violations 

 Failure to comply with any provision of this rule shall constitute a violation of this rule. 

F. Definitions 

 1. “Direct-Contact Lubricant”: Any fluid that comes into direct contact with the 

product or part during manufacturing or assembly and is used to reduce friction 

and to prolong the life of machine tools or machinery. Fluids defined as MetalForming Fluids (Subsection F.5) or Metal Removal fluids (Subsection F.8) are not 

subject to the ROC content limit for direct contact lubricants. 

 

 2. “Exempt Organic Compounds”: As defined in Rule 2 of these Rules. 

 3. "Grams of ROC per Liter of Material"(VOC Actual): The weight of ROC per 

volume of material and calculated by the following equation: 

 Grams of ROC per Liter Ws - Ww - Wes

 of Material = _____________ 

 Vm

 Where: Ws = Weight of volatile compounds (grams) 

 Ww = Weight of water (grams) 

 Wes = Weight of exempt organic compounds (grams) 

 Vm = Volume of material (liters) 

 4. “Lapping”: A manufacturing method that employs particles of an abrasive 

material, suspended in a liquid carrier, between rotating plates. 

 5. “Metal Forming Fluid”: Any fluid used at the tool and workpiece interface to 

facilitate the flow of metal over the tool and to extend the life of the tool. 

Common metal forming operations include, but are not limited to, blanking, 

coining, drawing, forming, forging, heading, piercing, roll forming, stamping, and 

wire drawing. 

 6. “Metal Protecting Fluid”: Any fluid that inhibits or prevents the corrosion of 

metal surfaces, and applied independently of any other metalworking, lubricating, 

or cleaning application. 

 7. “Metal Protecting – Military Specified Preservative: Any metal protecting 

preservative that was formulated by the manufacturer to comply with Mil Spec 

MIL PRF 16173E Class II Corrosion Inhibitor, and is designed to protect ferrous 

and non-ferrous parts for indoor or covered storage and during shipping. 
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 8. “Metal Removal Fluid”: Any fluid used at the workpiece interface to facilitate the 

removal of metal from the part, cool the part and tool, extend the life of the tool, 

and to flush away chips and debris. Common metal removal operations, include, 

but are not limited to, broaching, cutting, drilling, grinding, honing, lapping, 

milling, tapping, threading, and turning. 

 9. “Metal Treating Fluid”: Any fluid used to remove heat from metal parts, affect 

their hardness, and/or change the grain structure of the metal. Common metal 

treating operations, include, but are not limited to, marquenching and quenching. 

 10. “Metalworking Fluid”: Any fluid that facilitates operations involving the 

working, protecting, or modifying of metals, including metal forming, treating and 

removal, and may consist of straight oils, emulsifiable oils, synthetic, or semisynthetic fluids. 

 11. “Precision Metal Removal Fluid”: Any fluid used for: 

 a. Carbide grinding machine tools where the machine tool manufacturer 

specifies the viscosity of the fluid, or 

 b. Machining of aluminum or magnesium in single or multiple spindle 

automatic machines. 

 12. “Reactive Organic Compound (ROC)”: As defined in Rule 2 of these rules. The 

term "volatile organic compound" (VOC) is equivalent to ROC. 

 13. “Research Operation”: Any prototype operation whose product is not designed to 

be sold and whose sole purpose is to develop something new or test an update of 

an existing version. 

 14. “Sinker Electrical Discharge Machining (EDM)”: A method of removing material 

by a series of rapid recurring electric arcing discharges between an electrode and 

the workpiece, in the presence of an energetic electric field and in an insulating 

oil. EDM using a water-based dielectric fluid such as Wire EDM are not included 

in this definition. 

 15. “Space Vehicle”: A vehicle designed to travel beyond the earth’s atmosphere. 

 16. “Solicit”: Solicit is to require for use or to specify by written or oral contract. 

 17. “Vanishing Oil”: Any direct-contact lubricant or metalworking fluid containing 

petroleum distillates having a flash point less than 200o

F (93oC) and is designed to 

evaporate from the workpiece after first providing necessary lubrication.