SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Final Staff Report for 

PROPOSED AMENDED RULE 1144 – METALWORKING FLUIDS AND DIRECTCONTACT LUBRICANTS 

Dated: May 2010 

Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Elaine Chang, Dr.PH 

Assistant Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

Area Sources 

Naveen Berry 

Author: Mike Morris AQ Specialist 

Reviewed by: William Wong Principal Deputy District Counsel 

 

Contributors Joan Niertit Principal AQ Chemist 

 Uyen-Uyen Vo Assistant AQ Chemist 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: DR. WILLIAM A. BURKE 

Speaker of the Assembly Appointee 

Vice Chairman: DENNIS YATES 

Mayor, Chino 

Cities of San Bernardino 

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

County of Los Angeles 

MARION ASHLEY 

Supervisor, Fifth District 

County of Riverside 

MICHAEL CACCIOTTI 

Councilmember, South Pasadena 

Cities of Los Angeles County/Eastern Region 

BILL CAMPBELL 

Supervisor, Third District 

County of Orange 

JANE W. CARNEY 

Senate Rules Appointee 

JOSIE GONZALES 

Supervisor, Fifth District 

County of San Bernardino 

RONALD O. LOVERIDGE 

Mayor, Riverside 

Cities of Riverside County 

JOSEPH LYOU, Ph.D. 

Governor’s Appointee 

JUDITH MITCHELL 

Councilmember, Rolling Hills Estates 

Cities of Los Angeles County/Western Region 

JAN PERRY 

Councilmember, Ninth District

City of Los Angeles 

MIGUEL PULIDO 

Mayor, Santa Ana 

Cities of Orange County 

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
TABLE OF CONTENTS 

Section Page 

Executive Summary 1 

Background 2 

Proposed Rule 4 

Emission Inventory 10 

Emission Reductions 12 

Cost and Cost-Effectiveness 13 

Incremental Cost-Effectiveness 14 

Comments and Responses 16 

Comparative Analysis 28 

Socioeconomic Assessment 28 

California Environmental Quality Act (CEQA) 28 

Draft Findings under the California Health and Safety Code 28 

References 29 

APPENDIX A – Laboratory VOC Content Test Method Validation Test Results 

APPENDIX B – Comments and Responses Relative to SCAQMD Method 313-L 

Determination of VOC Hydrocarbon Compounds in Lubricants 
Final Staff Report ________________________________

Proposed Amended Rule 1144 1 May 2010

EXECUTIVE SUMMARY

In March 2009, Rule 1144 – Vanishing Oils and Rust Inhibitors, was adopted establishing VOC 

content limits for vanishing oils and rust inhibitors used during metalworking and metal-forming 

operations. Vanishing oils are a small subset of metalworking fluids designed to evaporate off 

shortly after use. Rust inhibitors, more commonly referred to as metal protecting fluids, are 

inhibitors or preventatives used to prevent the corrosion of metal substrates. However, the vast 

majority of fluids used during metalworking and/or metal forming operations are lubricants and 

metalworking fluids. These fluids are used at steel tube and spring manufacturers, steel mills, 

aerospace manufacturers, automobile part manufacturers and rebuilders, as well as machine 

shops for broaching, drilling, drawing, heading, honing, forging, milling, stamping, tapping, 

threading and turning operations. 

While EPA Method 24 is the default method for determining VOC content, it is unreliable for 

semi-volatile materials typically found in lubricants and metalworking fluids. It was decided not 

to include limits for direct-contact lubricants and metalworking fluids until a more reliable 

method was validated. Recently, a thermogravimetric analysis (TGA) method was developed 

and validated by ASTM International. If approved before July 9, 2010, ASTM E 1868-10 

Standard Test Method for Loss-On-Drying by Thermogravimetry will be included to determine 

VOC content. SCAQMD Method 319-10 Determination of Volatile Organic Compounds (VOC) 

in Metalworking Fluids and Lubricants by Thermogravimetry will also be included in the rule. 

This allows limits to be set for these widely used fluids, facilitating the inclusion of directcontact lubricants and metalworking fluids into Rule 1144. 

Staff proposes the following requirements for Proposed Amended Rule 1144: 

• Revise and expand the applicability and purpose sections of the rule to include direct-contact 

lubricants and metalworking fluids. 

• Add and modify definitions for metalworking fluid, metal forming fluid, metal removal fluid, 

metal protecting fluid (rust inhibitors),metal treating fluid, military specified preservative, 

precision metal removal fluid, super compliant materials and vanishing oil to enhance the 

clarity of the rule. 

• Establish a VOC limit of 50 grams per liter of material for the use of direct-contact lubricants 

effective January 1, 2012. 

• Establish a VOC limit of 130 grams per liter of material for the use of precision metal 

removal fluids effective January 1, 2012. 

• Establish a VOC limit of 75 g/l for metal forming, metal removal and metal treating fluids 

effective January 1, 2012. 

• Establish a VOC limit of 340 g/l for military specified preservatives effective January 1, 

2011. 

• Exempt the use of dimethyl carbonate as a cooling solvent in computed numerically 

controlled (CNC) machines where permeable media are used to maintain a vacuum that holds 

the part in place during cutting provided that the equipment is enclosed and an exhaust fan 

discharges the exhaust air from the equipment outside of the building. 

• Prohibit the sale of non-compliant direct-contact lubricants and metalworking fluids, except 

those subject to CARB consumer products regulation found in Title 17 of the California 

Code of Regulations, beginning at Section 94507. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 2 May 2010

• Allow direct-contact lubricants and metalworking fluids manufactured prior to January 1, 

2012 to be sold or applied until July 1, 2012. 

• Require containers for direct-contact lubricants and metalworking fluids to display the date 

of manufacture and VOC content as supplied. 

• Establish a streamlined record keeping system for metalworking fluids and direct-contact 

lubricants subject to the rule. 

• Require annual quantity and emissions reporting from manufacturers and suppliers of 

metalworking fluids and direct-contact lubricants sold or used in the District. 

• Incorporate a TGA method, ASTM E 1868-10 Standard Test Method for Loss-On-Drying by 

Thermogravimetry and SCAQMD Method 319-10 Determination of Volatile Organic 

Compounds (VOC) in Metalworking Fluids and Lubricants by Thermogravimetry, for 

determining VOC content. 

If approved, the proposed rule amendments would fully implement control measure CTS-01 in 

the 2007 Air Quality Management Plan. 

The proposed future limits would reduce emissions by 0.86 tons per day at an estimated one-time 

cost of $2.5 million dollars to conduct laboratory testing prior to January 1, 2012. The overall 

cost-effectiveness of the proposed amendment is estimated to be $796 per ton of VOC emissions 

reduced based on discounted cash flow (DCF) analysis. Staff estimates that more than 7,000 

shops will be subject to the proposed rule. 

BACKGROUND

In March 2009, Rule 1144 was adopted establishing VOC content limits for vanishing oils and 

rust inhibitors, more commonly known as metal protecting fluids, used during metalworking 

operations. Vanishing oils and solvent cutback metal protecting fluids consist entirely or nearly 

entirely of mineral spirit type solvents. While they are a significant source of VOC emissions, 

they represent only a small fraction of the overall volume of fluids used by machine shops. The 

bulk of the volumes used are metalworking fluids and lubricants. Unlike vanishing oils and 

solvent cutback metal protecting fluids, these fluids mainly consist of semi-volatile compounds 

for which a reliable VOC content test method was not established in March 2009. However, 

recently a thermogravimetric analysis (TGA) method was developed and validation is complete. 

This allows limits to be set for these widely used fluids, facilitating the inclusion of lubricants 

and metalworking fluids into Rule 1144. 

Over 7,200 facilities, predominantly small businesses, use these types of fluids in the South 

Coast Air Basin. They are classified as fabricated metal product manufacturing [North American 

Industry Classification System (NAICS) Code 332], machinery manufacturing (NAICS 333), 

transportation equipment manufacturing (NAICS 336), and petroleum and coal products 

manufacturing (NAICS 324) sectors in the AQMD. Typical industries using lubricants and 

metalworking fluids include: 

• Aerospace 

• Machine Shop (Job Shop) 

• Steel Mills 

• Auto Rebuild 

• Screw Machine 
Final Staff Report ________________________________

Proposed Amended Rule 1144 3 May 2010

• Steel Tubes (Pipes) 

• Steel Springs 

• Maintenance 

• Captive 

Captive machine shops are machine shops located inside of another type of business (aerospace, 

automotive, etc.) that supports the business but is not the primary aspect of that business. 

Lubricants and metalworking fluids are used to reduce heat and friction to prolong the life of the 

tool, to improve product quality, and carry away debris. Metalworking fluids encompass a broad 

range of fluids including metal forming, metal protecting, metal removal and metal treatment 

fluids. Typical metalworking operations include: 

Metal Forming

• Drawing - Forming flat sheet metal into “cup-shaped” parts. If the depth of the formed 

cup is equal to or greater than the radius of the cup, the process is called deep drawing. 

• Heading – A metal forging process which involves rapidly punching a blank into a die to 

form a desired shape without adding heat. Cold heading is most frequently used to 

produce fasteners such as bolts and screws without adding heat. 

• Forging - Shaping metal by using localized compressive forces. Cold forging is done at 

room temperature or near room temperature. Hot forging is done at a high temperature, 

which makes metal easier to shape and less likely to fracture. Common forging processes 

include: roll forging, swaging, cogging, open-die forging, impression-die forging, press 

forging, automatic hot forging and upsetting. 

• Stamping – A process by which sheet metal strips are punched using a press tool which is 

loaded on a press to form the sheet into a desired shape. 

• Wire drawing - Reducing or changing the diameter of a wire or rod by pulling the wire or 

rod through a single or series of drawing die(s). 

Metal Protecting

• Rust Preventative/Inhibitor - Prevention of rust on ferrous materials 

• Corrosion Protections - Prevention of corrosion on some nonferrous materials 

Metal Removal

• Broaching – Keyway, slots or spline utilized in gear manufacturing 

• Drilling – Producing cylindrical holes 

• Honing - Manufacture of precision bores to improve the geometry, surface finish and 

dimensional control of the finished part. 

• Milling – A precisely controlled rotating cutter which rotates about the spindle axis and a 

table to which the workpiece is affixed. The cutter and workpiece move relative to each 

other, generating a toolpath along which material is removed. 

• Tapping – Creating threaded holes in parts or boring into parts and pipelines 

• Threading - Thread cutting and thread rolling applications for pipes and bolts 

• Turning - Operation that produces cylindrical parts

Metal Treatment

• Quenching – A rapid cooling of parts typically for hardening purposes 
Final Staff Report ________________________________

Proposed Amended Rule 1144 4 May 2010

The fluids used in the above operations are complex mixtures of a base material (oil), and 

emulsifiers, anti-weld agents, corrosion inhibitors, extreme pressure additives, buffers (alkaline 

reserve), biocides, as well as other additives. The base material may be naphthenic, paraffinic or 

synthetic. Some products contain extreme pressure (EP) additives containing chlorinated, 

sulfurized, or phosphorus-type extreme pressure ingredients. There are numerous formulations, 

ranging from straight oils (such as naphthenic and paraffinic petroleum oils) to water-based 

fluids, which include emulsifiable (soluble) oils and semi-synthetic/synthetic fluids. In general, 

higher oil content provides better lubricity while higher water content allows more rapid cooling. 

• Straight oil (neat oil) fluids are refined naphthenic and paraffinic petroleum or vegetable 

oils. Straight oils are not designed to be diluted with water. Light oils are naphthenic oils 

with a viscosity of 4.28 centistokes (40 SUS) or lower. 

• Emulsifiable oil (soluble oil) fluids are combinations of 30 percent to 85 percent straight 

oils and emulsifiers that may include other performance additives. Soluble oils are diluted 

with 5 to 40 parts water. 

• Semi-synthetic fluids contain a lower amount of straight oil in the concentrate (5 percent 

to 30 percent), more emulsifiers, and 30 percent to 50 percent water. The concentrate is 

further diluted with 10 to 40 parts water. 

• Synthetic fluids contain no petroleum oils and may be water soluble or water dispersible. 

The synthetic concentrate is diluted with 10 to 40 parts water. 

In 2006, the AQMD and U.S. EPA Region IX co-sponsored a report by the Institute for Research 

and Technical Assistance to identify, test and demonstrate alternative low-VOC materials for 

vanishing oils and rust inhibitors. The final report, entitled Assessment, Development and 

Demonstration of Alternatives to VOC-Emitting Lubricants, Vanishing Oil and Rust Inhibitors

concludes that “alternative low-VOC materials for a variety of different types of metalworking 

operations are available and cost effective”. Thirteen facilities participated in the study that 

reviewed stamping, honing, cutting, forming and rust inhibitor applications. In each high-VOC 

application, a low-VOC alternative was demonstrated to have equivalent performance. Some of 

the participants found that their cost increased with the alternatives, but the majority realized a 

cost-savings. 

PROPOSED AMENDED RULE

Staff proposes the following requirements for PAR 1144: 

Purpose and Applicability

The purpose and applicability of the rule will be expanded to include direct-contact lubricants 

and metalworking fluids. These products represent the bulk of fluids used for metal forming, 

metal protecting, metal removal and metal treatment operations. Including these products will 

reduce VOC emissions and provide clarity with respect to applicability for the most widely used 

metalworking fluids. 

Requirements

The proposed rule will establish a VOC limit of 75 g/l of material for metal forming, metal 

removal and metal treatment fluids effective January 1, 2012. More than 90 percent of these 

types of metalworking fluids already in use today are expected meet the proposed limit. 

Annually, more than three million gallons of straight oil and emulsifiable, semi-synthetic and 

synthetic metalworking fluids are used that are super compliant (less than 50 g/l) under the 
Final Staff Report ________________________________

Proposed Amended Rule 1144 5 May 2010

applicable test methods. The remainder are light, naphthenic oils with viscosities lower than 5 

centistokes at 40°C. Light oils are used by manufacturers and distributors as a blending material 

along with much higher viscosity lubricants (greater than 38 centistokes at 40°C) to form 

medium viscosity metalworking fluids (10 centistokes or greater at 40°C). The proposed VOC 

limit will restrict this practice and require manufacturers and distributors to formulate with 

higher viscosity oils. Shops utilizing these fluids are not expected to experience any 

performance or cost impact. According to industry stakeholders, the light oils were used in the 

blend because the medium oils cost more. Changes in demand have leveled the prices and 

formulators can now eliminate the light oils without impacting costs. 

Precision metal removal fluids will be distinguished from metal removal fluids and a VOC limit 

of 130 g/l will be established effective January 1, 2012. These fluids are used in carbide 

grinding machine tools where the manufacturer of the machine tool specifies the viscosity of the 

fluid. They are also used for machining of aluminum and magnesium in single or multiple 

spindle automatic machines where the design of the machine prevents the use of water-dilutable 

metal removal fluids. According to the Independent Lubricant Manufacturers Association 

(ILMA), approximately 20,000 to 50,000 gallons per year of this material is used in the District. 

The proposed rule will also establish a VOC limit of 50 g/l of material for direct-contact 

lubricants effective January 1, 2012. Direct-contact lubricants differ from general lubricants in 

that they freely mix with metalworking fluids during the manufacturing process. Direct-contact 

lubricants have traditionally been formulated with heavier petroleum oils or emulsifiable, semisynthetic and synthetic compounds with relatively low VOC content. Establishing a rule limit is 

not expected to require formulation changes or reduce emissions. However, it will prevent 

certain types of metalworking fluids from being reclassified as direct-contact lubricants to avoid 

being subject to the proposed regulation. 

In addition to using heavier naphthenic oils, manufacturers, distributors and users of 

metalworking fluids and direct-contact lubricants have several other super compliant alternative 

technologies available. Paraffinic oils are the most similar alternative technology available for 

reformulation. Paraffinic base material costs approximately ten percent more than a naphthenic 

base material and in many cases the current practice of using naphthenic oils may strictly be 

based on cost. Both naphthenic oils and paraffinic oils are straight petroleum oils with paraffinic 

oils consisting mostly of n-alkanes while naphthenic oils are mostly cycloalkanes. Performance 

is unlikely to be impacted by the use of paraffinic oils compared to naphthenic oil as paraffinic 

oils provide better lubricity, greater oxidation resistance, more water resistance and better 

compatibility with machinery and parts. However, substantial obstacles may need to be 

overcome to completely transition away from naphthenic oils. Some fluids are specifically 

formulated for a particular operation and may contain a complex blend of additives. As some 

additives are not readily soluble in paraffinic oils, substantial reformulation may be necessary. 

The types of parts likely to be impacted by the loss of soluble additives are high value parts made 

from aluminum, stainless steel, copper, brass, and titanium. 

Another alternative available is water-dilutable metalworking fluids including emulsifiable, 

synthetic and semi-synthetic fluids. These fluids are specifically engineered for exclusive 

application as metalworking fluids. Emulsifiable and semi-synthetic fluids contain some straight 
Final Staff Report ________________________________

Proposed Amended Rule 1144 6 May 2010

oil as well, but all contain advanced additives and chemistries providing equal or superior 

performance compared to straight petroleum oils. Biocides and anti-foaming agents extend fluid 

life, reduce maintenance and machine downtime. Additionally, they are heavily diluted with 

water which improves the cooling characteristics as well. The concentrate costs are eight to ten 

times higher than straight oil costs but after dilution the overall costs are similar or lower than 

straight oils. The main drawback is that water-dilutable fluids are not always compatible with 

the machining equipment. In particular they are not viable alternatives for the single or multiple 

spindle automatic machines which use a substantial portion of the light naphthenic oils. The 

market share of super compliant direct-contact lubricants and metalworking fluids is already 

approximately 44 percent. 

Vegetable-based oils are also a potential alternative. They are significantly more expensive, 

ranging from 2.5 to 4 times the cost per gallon of naphthenic oils. Another potential limitation is 

that the vegetable-based oil waste stream must be segregated from other oil waste streams 

because of incompatibility. Despite these drawbacks, vegetable-based oils are used because of 

the superior cooling properties over naphthenic oils allowing for increased machining efficiency 

(lower labor costs). In a case study included in the referenced report by IRTA, one shop realized 

an eleven percent cost savings because of increased machining efficiency. It is estimated that ten 

percent of the impacted facilities can segregate their waste streams and overcome the high per 

gallon cost by successfully realizing increased machining efficiency. 

 

Staff will continue to monitor the progress of market penetration with paraffinic, water-dilutable 

and vegetable-based metalworking fluids through the annual quantity and emission reports 

required under the proposed rule. 

Another modification will be to distinguish military specified rust preservatives from general 

metal protecting fluids and establish a limit of 340 g/l, effective January 1, 2011. The proposed 

limit is consistent with Mil-PRF-16173E Class II for solvent cutback corrosion preventatives on 

military equipment. The higher limit will be restricted to military applications qualified under a 

military specification. Four of the six manufacturers who provide military specified rust 

preservatives offer products with VOC content below the proposed 340 g/l limit. This limit will 

forgo previously expected emission reductions of 0.06 tons per day. 

Administrative Requirements

A use and sell-through provision is already included in the rule that allows products 

manufactured before the effective date of the rule to be sold and used for up to six months after 

the effective date. With the expanded categories, manufacturers and distributors will be required 

to display the date or a date code of manufacture on the container beginning January 2012. In 

addition, the VOC content will be required to be displayed on the container. 

Manufacturers and distributors will be required to provide an annual quantity and emission 

report documenting sales volume and VOC content of metalworking fluids and direct-contact 

lubricants sold in the District. The information will provide an improved emission inventory and 

identify opportunities to further reduce VOC limits in applicable fluid categories. The emission 

inventory will be improved as VOC values are determined for the many thousands of 

metalworking and direct-contact lubricant formulations, leading to enhanced planning and 

AQMP development. Staff will work with interested stakeholders to develop reasonable content 
Final Staff Report ________________________________

Proposed Amended Rule 1144 7 May 2010

and format requirements for the annual report, protective of confidential business information (to 

the extent allowable under District Public Records Act Guidelines). Staff anticipates the 

completion of this effort no later than September 30, 2010. The other portion that staff will work 

with interested stakeholders is the product listing (i.e., product name and/or code), the 

technology used in the product (i.e., paraffin, water-based, synthetic, bio-based, etc.) and other 

such items to get a better understanding of the product offering and trend in sales over the three 

year period. Other additional information would be the category the product falls under, as 

currently included in Table A, the recommended dilution ratio (or range) if any, and an 

indication as to why a product with a higher than listed VOC limit was sold into or within the 

District (i.e., under sell through provision; specific exemption; emission control system use; or 

other). 

Recordkeeping Requirements

Many of the facilities subject to the provisions of this rule are small businesses with limited 

interaction with the District. Those small facilities with operations and equipment that do not 

use paints, coatings, solvents or adhesives and do not require permits with the District are 

unlikely to have had experience in keeping daily records. The proposed rule includes 

recordkeeping provisions. Users of fluids subject to the rule will be required to maintain a list of 

VOC containing products subject to the rule. In addition, they will be required to track usage of 

these products on a monthly basis. Alternatively, facilities may opt to maintain records per Rule 

109 - Recordkeeping for Volatile Organic Compound Emissions. Products with VOC content 

below 50 g/l will be considered “super compliant” materials and will be exempt from 

recordkeeping. This exemption only applies at facilities that do not exceed four tons of VOC 

emissions in any calendar year, determined by annual purchase records. 

Manufacturers and suppliers will be required to keep laboratory reports and/or VOC calculation 

information used to determine VOC content of products sold. These documents will be used to 

verify product VOC labeling, including claims of super compliant status. 

Test Methods and Procedures 

VOC content will be determined by thermogravimetric analysis (TGA). This method has been 

validated using ASTM E691 - 05 Standard Practice for Conducting an Interlaboratory Study to 

Determine the Precision of a Test Method. The time and temperature parameters were 

determined by comparing the test results to an evaporation study conducted by W.S. Dodge Oil 

where three naphthenic oils with viscosities of 4.28 centistokes at 40°C (40 SUS), 9.63 

centistokes at 40°C (60 SUS) and 20.50 centistokes at 40°C (100 SUS) were held at 40°C in an 

oven for six months. A provision to determine specific gravity will be included in the method. 

If approved before July 9, 2010, ASTM E 1868-10 Standard Test Method for Loss-On-Drying by 

Thermogravimetry will be included to determine VOC content. SCAQMD Method 319-10 

Determination of Volatile Organic Compounds (VOC) in Metalworking Fluids and Lubricants 

by Thermogravimetry will also be included in the rule. Water content will be determined by 

ASTM D 4017 (Standard Test Method for Water in Paints and Paint Materials by Karl Fischer 

Method). The water content measured by ASTM D 4017 will be deducted from the volatility 

measurement in the TGA test when determining VOC content. ASTM D 4017 has 

approximately a three percent margin of error which becomes critical for coatings with high 

water content where the water is excluded when determining regulatory VOC content. As the 
Final Staff Report ________________________________

Proposed Amended Rule 1144 8 May 2010

water content increases, the margin of error for the non-excluded portion of the sample increases. 

However, in this case the water content will not be excluded but instead deducted keeping the 

margin of error constant. The exempt solvent content shall be determined by SCAQMD Method 

303 (Determination of Exempt Compounds) 

The default method used for determining VOC content has been U.S. EPA Reference Method 24 

(Method 24). Method 24 was designed to determine the VOC content of coatings and inks only. 

It was not intended to be used for metalworking fluids though there is no other U.S. EPA 

approved test method other than Method 24 for metalworking fluids. Method 24 determines the 

VOC content of a product by measuring the water and the non-volatile fraction. The remainder 

is considered VOC (less exempt solvents). The non-volatile fraction is determined by placing 

the sample in a forced air over at 110°C for sixty minutes. It became apparent following the 

review of many Method 24 test results that Method 24 would not be reliable test method for 

many metalworking fluids and direct-contact lubricants which are largely comprised of semivolatile constituents. For the same samples tested, Method 24 resulted in VOC readings that 

were consistently higher than those obtained from the six-month long evaporation study 

mentioned above. The California Department of Pesticide Regulation (DPR) developed a test 

method for pesticides which primarily consist of paraffinic oils to address the semi-volatile 

nature of the oils. Their method requires the sample to be held at 115°C for 60 minutes. 

However, the sample mass loss must stabilize for an extended (11 hours) but low temperature 

(55°C) alternative is required. It is expected that there would be little difference between the 

short term and extended tests. 

The DPR method was tested on naphthenic oils but they did not stabilize at 115°C. The 

extended test was performed but the results differed significantly from the short term test. 

Additionally, manufactures felt that an 11 hour test would be cost-prohibitive. In response, the 

Independent Lubricant Manufacturers Association (ILMA), in cooperation with District staff, 

developed the TGA method as a more reasonable alternative with temperature and duration 

parameters that would replicate the six-month evaporation rate testing. 

An alternative method is SCAQMD Method 313-L – Determination of VOC Hydrocarbon 

Compounds in Lubricants using a gas chromatograph (GC) equipped with a flame ionization 

detector (FID). A liquid sample is injected into the GC/FID and the concentrations of the 

individual compounds that elute prior to methyl palmitate are summed. This method is currently 

undergoing validation testing and may be included at a later date. Table I below compares the 

results of three naphthenic oils tests by the different methods. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 9 May 2010

Table I – Test Method Comparison 

Method HyNap 40 (g/l) HyNap 60 g/l) HyNap 100 (g/l)

EPA Method 24 859 515 255 

SCAQMD Method 313-L 792 492 250 

DPR TGA Method (1hr @ 115°C) 849 284 86 

DPR TGA Method (11hr @ 55°C) 425 82 40 

TGA (110 min @ 81°C) 718 131 70 

Evaporation (180 days @ 40°C) 721 132 70 

The samples used in the validation testing for both the Method 313-L and TGA testing were 

formulated to test the spectrum of fluids subject to the rule and to provide guideposts to 

establishing the proposed limits. The samples consisted of a high VOC solvent cutback metal 

protecting fluid; synthetic hydraulic oil; a general purpose cutting and grinding oil; a pre-diluted 

water based semi-synthetic cutting and grinding fluid; and a lower viscosity aluminum cutting 

and grinding metalworking fluid. The general purpose cutting and grinding oil reflects the VOC 

content of a typical metalworking fluid or the fluid used in an old spindle-type machine. The 

lower viscosity oils are typically used as precision metal removal fluids. The TGA validation 

test results are included in Appendix A. 

The results from the synthetic hydraulic oil and the water based semi-synthetic cutting and 

grinding fluid, combined with DPR’s testing of paraffinic oils demonstrates that super compliant 

(<50 g/l) alternatives exist. Synthetic and semi-synthetic fluids are nearly completely nonvolatile and many are heavily (5 to 40 times) diluted with water further reducing the VOC 

content. DPR tested twenty six pesticide products which were mostly paraffinic with smaller 

amounts of naphthenic oils and other compounds. Twenty of the samples were found to have 

VOC contents below 35 g/l (5% by weight). Three others were below 70 g/l (10%) and the 

remaining three were considered test outliers. Since direct-contact lubricants and metalworking 

fluids are mainly base material with a small percent of additives, transitioning the base material 

from naphthenic oil to paraffinic oil will further reduce VOC emissions. 

Exemptions

The expansion of the rule to include direct-contact lubricants and metalworking fluids will be 

reflected in the exemptions section of the rule. Where “vanishing oils and rust inhibitors” were 

named in general terms, they have been replaced with “metalworking fluids and direct-contact 

lubricants”. Specifically all fluids subject to the rule do not have to meet the labeling and sales 

prohibition requirements if they are sold as consumer products subject to the California Air 

Resources Board consumer products regulation found in Title 17 of the California Code of 

Regulations, beginning at Section 94507. Additionally, working fluids subject to the rule are 

exempt from the sales prohibition of the rule if they are to be sold and used outside of the 

District. Finally, all fluids applied to avionics and assembled aircraft are exempted. 

An exemption has been included for fluids that have a VOC content of 50 g/l or less. These 

materials will be considered “super compliant” and be exempted from record keeping. This will 

limit unnecessary tracking of super compliant and non-VOC materials and through an anticipated 

increased demand, provide an incentive to manufacturers to provide additional super compliant 

materials to users. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 10 May 2010

An exemption has been included to allow the use of dimethyl carbonate as a cooling solvent in 

computed numerically controlled (CNC) machines where permeable media are used to maintain 

a vacuum that holds the part in place during cutting provided that the equipment is enclosed and 

an exhaust fan discharges the exhaust air from the equipment outside of the building. This type 

of use is very limited in terms of equipment and volume, and based on a risk assessment, has 

acute or chronic health impacts well below the threshold of significance. In addition any 

potential worker exposure has been minimized. 

EMISSION INVENTORY

The emission inventory for the proposed rule was done by reviewing national sales and 

comparing the number of shops nationally versus the number of shops in the South Coast Air 

Basin (Basin). Additionally, a survey of local manufacturers and distributors was conducted. 

The overall national inventory of metalworking fluids was taken from the International Lubricant 

Manufacturers Association (2003). National sales were 117.2 million gallons. EPA estimates 

10.2 percent of the fabricated metal industry are located in California in its Fabricated Metal 

Sector Notebook (1995). According to listings in the California Manufacturers Register, the 

Basin accounts for approximately 70 percent of the industry in California. This would indicate 

that 8.3 million gallons of MWF were sold in the Basin (see Table II). 

Table II – Ratio of National Sales to South Coast Air Basin Sales 

Metalworking 

Fluid 

Amount Sold 

Nationwide 

(millions of 

gallons/year) 

Amount Sold 

in California 

(millions of 

gallons/year) 

Amount Sold in 

South Coast 

(millions of 

gallons/year) 

Straight 27.3 2.8 2.0 

Soluble 49.3 5.0 3.5 

Semi-Synthetic 21.7 2.2 1.5 

Synthetic 18.9 1.9 1.3 

Total 117.2 11.9 8.3 

To supplement these estimates, in 2006, the AQMD conducted a survey of local manufacturers, 

distributors and users of metalworking fluids and direct-contact lubricants. The survey data 

indicated that those local manufacturers and distributors annually sold 4.1 million gallons of 

lubricants (including direct-contact lubricants), metalworking fluids (excluding metal protecting 

fluids), metal protecting fluids (rust inhibitors) and solvent. Presumably, the solvents are used as 

vanishing oils, metal protecting fluids, for thinning other metalworking fluids or cleaning. 

Solvents used for cleaning application subject to Rule 1124 were removed from the inventory. 

The sales weighted average VOC content was determined using TGA robustness testing, TGA 

simulation analysis, TGA validation testing results and a limited number of products testing 

using the TGA test results. Table III summarizes the AQMD survey, the sales weighted average 

(SWA) VOC content and total calculated VOC emissions from each fluid. 

Further testing by manufacturers and distributors complying with the VOC labeling requirement, 

in conjunction with annual quantity and emission reporting, will improve the emission inventory. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 11 May 2010

Table III – Surveyed Emission Inventory 

Metalworking Fluid Type 

Volume Surveyed

 (thousand 

gallons) 

Sales Weighted 

Average 

 VOC Content (g/l) 

Total VOC 

Emissions 

 (tons per day) 

Lubricants* 661.0 25 0.19 

Direct-contact Lubricants 211.1 25 0.06 

Naphthenic-based 

Metalworking Fluids** 745.5 58 0.49 

Heavy Naphthenic-based Oil 727.0 25 0.21 

Light Naphthenic-based Oil 128.4 718 1.05 

Super Compliant 

Metalworking Fluids 1,339.7 25 0.38 

Vanishing Oil 64.1 710 0.52 

Metal Protecting Fluids 140.1 660 1.06 

Military Specified 

Preservatives 15.6 660 0.12 

Solvent 167.0 790 1.21 

Total 4,119.5 N/A 5.29 

*Excludes direct-contact lubricants 

**Excludes metal protecting fluids, light and heavy naphthenic-based oils and vanishing oil 

Rule 1144, adopted in March 2009, already regulates the emissions from vanishing oils, metal 

protecting fluids and solvents in the previous rule making activity. The emission inventory, 

when adjusted for the 2.71 tons per day emission reduction from the already regulated categories, 

is summarized below in Table IV. 

Table IV – Emission Inventory (Existing Rule) 

Metalworking Fluid Type 

Volume Surveyed

 (thousand 

gallons) 

Sales Weighted 

Average 

 VOC Content (g/l) 

Total VOC 

Emissions 

 (tons per day) 

Lubricants* 661.0 25 0.19 

Direct-contact Lubricants 211.1 25 0.06 

Naphthenic-based 

Metalworking Fluids** 745.5 58 0.49 

Heavy Naphthenic-based Oil 727.0 25 0.21 

Light Naphthenic-based Oil 128.4 718 1.05 

Super Compliant 

Metalworking Fluids 1,339.7 25 0.38 

Vanishing Oil 64.1 50*** 0.02 

Metal Protecting Fluids 140.1 50*** 0.09 

Military Specified 

Preservatives 15.6 50*** 0.01 

Solvent 167.0 50*** 0.08 

Total 4,119.5 N/A 2.58 

*Excludes direct-contact lubricants 

**Excludes metal protecting fluids, light oil and vanishing oil 

*** Established VOC Limit 
Final Staff Report ________________________________

Proposed Amended Rule 1144 12 May 2010

The proposed rule amendment establishes VOC limits for direct-contact lubricants, metal 

forming, metal treatment and metal removal fluids, including a subcategory of metal removal 

fluids called precision metal removal fluids. Such limits would reduce emissions from light oils 

used in metalworking fluids and precision metal removal fluids. 

Staff notes that according to industry stakeholders, naphthenic metalworking fluid sales declined 

significantly, by approximately 40 to 50 percent, since the survey was conducted, due to 

economic recession, business closures and a general transition into lower-VOC products. Staff 

recognizes that the use cycle is dependent on external forces, but cannot conclude that the 

decline in sales will be permanent. 

EMISSION REDUCTIONS

The proposed rule will establish a VOC content limit of 50 g/l for direct-contact lubricants, 75 

g/l for metal forming, metal removal and metal treatment fluids and 130 g/l for precision metal 

removal fluids, effective January 1, 2012. The impact of these limits would be to restrict the use 

of light oils in metal removal fluid blends. This would impact about three percent of the 

metalworking fluids currently used. Industry sources estimate that 20,000 to 50,000 gallons of 

light oil are used as precision metal removal fluids while the remainder are used as blends in 

general metalworking fluids. To be conservative with respect to emission reduction, the upper 

range of the volume estimate of precision metal removal fluids (50,000 gallons) is used because 

of the higher VOC limit proposed. The distribution is noted in Table V below. 

The proposed amended rule also includes a limit for military specified preservatives used in a 

military application. The previous rule making activity provided a temporary exemption with the 

assumption that the military specified preservatives could meet the limit for general rust 

inhibitors. This limit will forgo previously expected emission reductions of 0.05 ton per day. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 13 May 2010

Table V – Emission Reductions Effective 2012 

MWF Type 

Volume 

Surveyed 

(thousand 

gallons) 

Sales 

Weighted 

Ave VOC 

Content 

(g/l) 

Proposed 

VOC 

Content 

Percent 

Reduction

Total 

VOC 

Emission 

Inventory 

(tons per 

day) 

Total 

VOC 

Emission 

Reduction 

(tons per 

day) 

Lubricants 661.0 25 50 0% 0.19 0.00 

Direct-contact 

Lubricants 211.1 25 50 0% 0.06 0.00 

Naphthenic-based 

Metalworking Fluids* 745.5 58 75 0% 0.49 0.00 

Heavy Naphthenicbased Oil 727.0 25 75 0% 0.21 0.00 

Light Naphthenicbased Oil 

(metalworking)* 78.4 718 75 89% 0.64 0.57 

Light Naphthenicbased Oil (Precision 

Metal Removal) 50.0 718 130 82% 0.41 0.34 

Super Compliant 

Metalworking Fluids* 1,339.7 25 50 0% 0.38 0.00 

Vanishing Oil 64.1 50 50** 0% 0.02 0.00 

Metal Protecting 

Fluids 140.1 50 50** 0% 0.09 0.00 

Military Specified 

Preservatives 15.6 340 340*** N/A 0.01 <0.05> 

Solvent 167.0 50 50** 0% 0.08 0.00 

Total 4,119.5 N/A N/A 2.58 0.86 

*Excludes metal protecting fluids 

**Existing limit 

***Previous limit was 50 g/l 

The adoption of the proposed VOC limits would result in 0.86 tons per day of VOC reduced. As 

summarized in the table above, emission reductions are anticipated from light-oil and precision 

metal removal fluids only, that comprise just a little more than 3.06% of the total volume of 

direct-contact lubricants and metalworking fluids surveyed, but represent 40.7% of the total 

remaining emissions from this source category. The control efficiency from these two categories 

is estimated to be 86.7%. 

COST AND COST-EFFECTIVENESS

The transition away from light oil metalworking fluid blends to medium viscosity straight cut 

oils will have no impact on cost. According to industry stakeholders, light oils were previously 
Final Staff Report ________________________________

Proposed Amended Rule 1144 14 May 2010

used because they were lower cost than heavier oils, but changes in demand have equalized the 

price over the past few years. 

There is also no expected increase in cost from allowing the use of military specified 

preservatives. The previous rule making activity accounted for a cost increase that will no longer 

be necessary. 

Likewise, the previous rule making activity accounted for testing costs to determine VOC 

content. However, those costs were limited to vanishing oils and metal protecting fluids (rust 

inhibitors). Encompassing direct-contact lubricants and metalworking fluids will greatly expand 

the number of products that potentially need to be tested. Laboratory testing using the TGA 

method is estimated to cost $250 per sample. Manufacturers and distributors offer hundreds of 

products each. Many of those are similar with slight variations on the additives incorporated in 

the product. Manufacturers and distributors may be able to test some subset of products and be 

able to calculate the VOC content of their remaining products. Others will insist on testing every 

product to insure rule compliance. Conservatively assuming that there are 10,000 applicable 

products and every product would be laboratory tested at $250, there would be a one-time cost of 

$2.5 million. Most containers use computerized labels that can be altered by simple 

reprogramming. The cost to alter those labels is considered negligible. Likewise, the generation 

of an annual sales report by the several dozen manufacturers and suppliers of applicable fluids is 

also considered to be negligible. These costs are noted in the Socioeconomic Assessment. 

The proposed limits would reduce emissions by 0.86 tons per day (313.9 tons per year) at an 

estimated cost of $2.5 million dollars for the first year. Using a DCF methodology, the future 

cash flow is discounted over a given period of emission reductions to determine cost 

effectiveness. In this case, we evaluate the one-time cost of testing over a period of ten years. 

The overall cost-effectiveness of the proposed amendment using this methodology is estimated 

to be $796 per ton of VOC emissions reduced (see Table VI below). 

Table VI – Cost-Effectiveness 

Cost Emission Reduction over 10 year period Cost-Effectiveness 

$2.5 million 3,139 tons $796/ton 

INCREMENTAL COST-EFFECTIVENESS

Under Health and Safety Code Section 40920.6, the AQMD is required to perform an 

incremental cost analysis when adopting a Best Available Retrofit Control Technology 

(BARCT) rule or feasible measure required by the California Clean Air Act. To perform this 

analysis, the AQMD must (1) identify one or more control options achieving the emission 

reduction objectives for the proposed rule, (2) determine the cost effectiveness for each option, 

and (3) calculate the incremental cost effectiveness for each option. To determine incremental 

costs, the AQMD must “calculate the difference in the dollar costs divided by the difference in 

the emission reduction potentials between each progressively more stringent potential control 

option as compared to the next less expensive control option.” 
Final Staff Report ________________________________

Proposed Amended Rule 1144 15 May 2010

Proposed Amended Rule 1144 implements Control Measure CTS-01 from the 2007 Air Quality 

Management Plan. Because Control Measure CTS-01 is intended to meet feasible measure 

requirements under the California Clean Air Act, an incremental cost analysis is required and is 

presented in this section. 

Two alternative options were evaluated including two more stringent standards. The first 

alternative examined was to require all lubricants, metalworking fluids and rust inhibitors to 

meet a VOC content limit of 25 g/l. Similar low-VOC formulations would be utilized but 

machine operators would have to monitor the fluids to ensure that evaporation or contaminants 

did not make the fluid non-compliant. The second alternative required all fluids to meet a 50 g/l 

VOC limit effective in 2015. While industry has been cooperative in providing available 

information, they cannot provide reformulation cost data at this time. Based on the limited 

information available, the District estimates the limits effective in 2015 would result in price 

increases by up to 20%. This estimation methodology is consistent with previous cost analyses 

where reformulation cost data is not available. Using this methodology, the alternative paraffinic 

based metalworking fluid used to comply with the 50 g/l and 25 g/l is expected to have an 

average cost of $5.52 per gallon, an increase of $1.22 over the current average price of 

naphthenic metalworking fluids. The annual cost of fluid reformulation would be $1.1 million 

(see below). 

Table VII – Cost Increase per Gallon of Material 

Total Volume of Impacted 

Metalworking Fluids Increased cost per gallon Total Annual Cost 

873,900 gallons $1.22 $1.1 million 

To meet the 25 g/l limit, additional labor costs are included for fluid users to track water 

evaporation to ensure water-dilutable fluids remain below 25 g/l. 

The incremental cost analysis indicates that all of the alternatives considered have an overall 

cost-effectiveness comparable to other adopted VOC regulations. However, the incremental 

benefit gained by lowering the limits to 50 or 25 g/l is not cost-effective ($23,182 and $35,351 

per additional ton reduced respectively) because of reformulation and additional labor costs. 

Table VIII – Incremental Cost-Effectiveness 

VOC Limit (g/l) 

Emission 

Reductions 

(tons per year) 

Additional 

Annualized 

Cost (million) 

Incremental Cost 

($ per additional ton 

reduction) 

25 (all categories) 473.0 $5.4 $35,351 

50 (all categories) 361.4 $1.4 $23,182 

Current proposal 313.9 $0.3 N/A 
Final Staff Report ________________________________

Proposed Amended Rule 1144 16 May 2010

COMMENTS AND RESPONSES

This section reflects the public comments received during working group meetings, the public 

workshop held February 10, 2010, the working group meeting held January 28, 2010 and 

subsequent meetings, as well as staff responses to those comments. 

Comment 1 

How can we ensure that Method 24, the test method listed in the rule, is not used to determine 

VOC content for purposes of compliance with the 300 g/l VOC limitation for rust inhibitors 

pending finalization of a new, valid test method? 

Response 

VOC content will be determined by thermogravimetric analysis (TGA), either by ASTM Method 

E 1868-10 Standard Test Method for Loss-On-Drying by Thermogravimetry or SCAQMD 

Method 319, at 81°C for 110 minutes. U.S. EPA Method 24 will not be used for any fluid 

category VOC determination in Rule 1144. 

Comment 2 

Does the District interpret Rule 109 to apply to all such materials that may be covered by Rule 

1144, or only those that are “adhesives, coatings, solvents, and/or graphic arts materials” as 

specified in Rule 109? 

Response 

The recordkeeping requirements have been clarified in the proposed amended rule. Specifically, 

fluids subject to the rule may be tracked using procedures specified in Rule 109 or with the 

streamlined process included in PAR 1144. 

Comment 3 

Some companies report that District inspectors who have visited their facilities indicate that Rule 

1107’s “coating” requirements currently apply to rust inhibitors (metal protecting fluids), despite 

the fact that Rule 1144 addresses metal protecting fluids (rust inhibitors) more specifically. This 

raises compliance issues currently as well as after January 1, 2010. Can the District confirm that 

Rule 1107 - Coating of Metal Parts and Products does not apply to metal protecting fluids? 

Response 

There is possible overlap in requirements for some operations, particularly metal protecting 

fluids, to be covered under both Rule 1107 and Rule 1144. It is District policy for the most 

specific rule to take precedence. Therefore, Rule 1144 will be used to determine compliance of 

metal protecting fluid use. 

Comment 4 

Can the District confirm that Rule 442 - Usage of Solvents does not apply to metal protecting 

fluids? 

Response 

Rule 442 requirements are limited to operations that are not subject to a Regulation XI rule. Any 

operation subject to Rule 1144 (a Regulation XI rule) would therefore not be subject to Rule 442. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 17 May 2010

Operations specifically exempted from Rule 1144 (i.e. metal protecting fluid used on avionics or 

assembled aircraft) would be subject to Rule 442. 

Comment 5 

Can companies using rust inhibitors (metal protecting fluids) utilize the exemption from District 

permits pursuant to Rule 219(l)(6) (coating applications)? What method shall be used to 

determine emissions? 

Response 

Companies utilizing metal protecting fluids that do not exceed the provisions of Rule 219(l)(6) 

can qualify for exemption. Emissions shall be determined using ASTM Method E 1868-10 

Standard Test Method for Loss-On-Drying by Thermogravimetry. 

Comment 6 

The terminology used for describing products and processes subject to the rule should conform 

to government and industry standards. Metalworking fluids should cover a broad range of metal 

removal, forming, protecting and treating operations. “Soluble oils” should be called 

“Emulsifiable oils”. 

Response 

Staff agrees that the established Occupational Health and Safety Administration (OSHA) 

terminology will be most familiar to the affected parties. Therefore, the terminology in the rule 

will be made consistent as recommended. Metalworking fluids will be further distinguished as 

metal forming, metal protecting, metal removal and metal treatment fluids. Most fluids subject 

to the rule will have some protective properties but the metal protecting fluid category will refer 

to products that are used independently of the metal forming, removal or treating applications. 

Comment 7 

ILMA supports the inclusion of the TGA method for determining VOC content. ILMA 

recommends that the actual reference to the TGA method in the final rule be ASTM E 1868 - 10, 

Standard Test Method for Loss-On-Drying by Thermogravimetry. 

Response 

The test method referenced will be included in the final rule provided that it has been approved 

by ASTM prior to the final hearing for Rule 1144. SCAQMD Method 319-10 Determination of 

Volatile Organic Compounds (VOC) in Metalworking Fluids and Lubricants by 

Thermogravimetry will also be included to determine VOC content. SCAQMD Method 319-10 

incorporates all of the procedures and parameters reflected in the efforts of the laboratory 

subcommittee and referenced in ASTM E 1868 – 10. 

Comment 8 

AQMD should terminate further work on the development of SCAQMD Method 313-L – 

Determination of VOC Hydrocarbon Compounds in Lubricants. AQMD staff has not consulted 

with industry stakeholders and has refused to subject the test method to the same validation 

under ASTM E691 as the TGA method. AQMD has purchased and used the TGA equipment in 

its laboratory and should preserve its limited resources by terminating further efforts to develop 
Final Staff Report ________________________________

Proposed Amended Rule 1144 18 May 2010

Method 313-L. {A more detailed discussion of comments and responses regarding SCAQMD 

Method 313-L is included in Appendix B.} 

Response 

AQMD staff has provided updates and test results to industry stakeholders via the Rule 1144 

Laboratory Sub-Committee. One of the participating laboratories in the validation process is an 

ILMA-member company. As ILMA is well aware, the method is going through the identical 

ASTM E691 validation process as the TGA method although it has not yet been able to achieve 

the agreed upon validation criteria. Method 313-L has value for determining VOC content for 

high water content samples. However, until the validation criteria have been met, it will not be 

included in the rule. This commitment, and staff implementation to date, is reflected in the 

adopting Resolutions in the March 6, 2009 Public Hearing. 

Comment 9 

AQMD has overstated the emission reductions for PAR 1144. AQMD is relying on outdated 

sales data. AQMD improperly assumes that all VOCs contained in low-VOC materials are 

emitted. Many of these materials do not volatilize under normal conditions of use. ILMA has 

provided a more accurate estimate of VOC reductions based on more appropriate values for sales 

weighted average (SWA) VOC content of naphthenic oils and light oils. Naphthenic-based 

Metalworking Fluids should be just under 60 g/l after including additives. Similarly, based on 

current sales data, the SWA of “Light Oil” should be 500 g/l, rather than 718 g/l. The above 

adjustments are based upon more recent sales data as well as forecasted “no growth” in 

manufacturing in the South Coast Basin. Further ILMA believes that the expected VOC 

reductions are over estimated because they do reflect actual in-use conditions. VOC emissions 

that may exist generally condense and subsequently settle on machines, floors and building 

superstructures. 

Response 

The District is using survey data of sales from manufacturers and distributors between 2004 and 

2006. The survey data was used to determine emission inventory and emission reductions when 

Rule 1144 was adopted last year. Recent data provided by industry does suggest lower sales 

volume most likely associated with the recent economic downturn. However, there is no 

evidence to suggest that the downturn is permanent resulting in a “no growth” forecast. Recent 

TGA test results suggest lower sales weighted average VOC contents for metalworking fluids 

and direct-contact lubricants and those averages have been adjusted accordingly. However, there 

is no evidence suggesting that light oils used for blending includes additives or heavier oils that 

might lead to a lower sales weight average VOC content. With respect to light oils, the original 

sales weighted average VOC content will be retained. Based on comments received, the District 

has re-evaluated the inventory from the survey and is including the full volume of light oils 

reported for developing the emission inventory. 

Comment 10 

We recommend establishing a 50 g/l limit for direct-contact lubricants effective 2012 and 

eliminating the 2015 limits entirely. Emission reductions are minimal while the increased costs 

will impair the competitiveness of Southern California machine shops and aerospace facilities. 

Any decrease in competitiveness will lead to lost manufacturing jobs. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 19 May 2010

Response 

A 50 g/l limit will be established for direct-contact lubricants and the 2015 limits will be 

removed from the rule. Uncertainty in sales weighted average VOC content for some 

metalworking fluids and reformulation costs suggest that more study is necessary. To facilitate 

this, the rule will require an annual quantity and emission report to track sales and VOC 

emissions. This information, along with a technology review, will provide the foundation for 

determining if future VOC reductions from applicable categories are appropriate. 

Comment 11 

AQMD has overstated the estimated emission reductions from the 2015 limits and understated 

compliance costs. AQMD did not take into account front-loaded research and development 

costs, disposal costs, base oil price volatility, increased recordkeeping costs and customer testing, 

qualification and approval costs. ILMA conservatively estimates the annual costs to be 

$2,000,000 or higher. Using ILMA’s cost-effectiveness estimates and suggested emission 

reductions, the cost-effectiveness of PAR 1144 is $19,239 per ton of VOC reduced. At $19,329 

per ton makes poor financial sense and the proposed 2015 limits should be withdrawn. ILMA 

members indicate that the proposed 2012 limits will cause no disruptions or reformulations. 

AQMD is specifically required by statute to provide cost-effectiveness, including alternatives to 

the proposed rule and incremental cost-effectiveness which the Preliminary Draft Staff Report 

does not include. 

Response 

In presenting cost estimates in the Preliminary Draft Staff Report and in the Public Workshop 

and working group meetings, staff has requested interested stakeholders to provide cost estimates 

for research and development activities so they could be included when making a costeffectiveness determination. Some limited anecdotal evidence has been provided but it is 

insufficient to make cost-effectiveness determinations. Because of limited reformulation cost 

information and uncertainty with respect to the sales weighted average VOC content of 

metalworking fluids, the 2015 limits of the proposed rule has been withdrawn. The 2012 limits 

for metalworking fluids and direct-contact lubricants will be included and are expected to have 

little or no cost impacts as noted in the comment above. As required under Health and Safety 

Code Section 40920.6, the Draft Staff Report does include cost-effectiveness, including 

incremental cost-effectiveness for rule alternatives based on the 2012 limits only. 

Comment 12 

AQMD improperly assumes that the change from naphthenic base oils to paraffinic base oils is 

easy. A wide range of additives do not solubilize and/or respond properly in paraffinic base oils, 

especially extreme-pressure additives and emulsifiers. Also, a reliable supply of paraffinic oils 

in not locally available and must be transported by truck or rail from Texas or Louisiana. 

Response 

While it was noted that some reformulations would be straightforward without the necessity of 

reformulation, the staff report did recognize that substantial reformulation may be necessary for 

additives that did not solubilize in paraffinic oils. This is further reflected in staff’s request to

industry stakeholders to provide reformulation cost estimates. Finally, the proposed limits 

requiring reformulation were scheduled to occur in 2015 allowing sufficient time for 
Final Staff Report ________________________________

Proposed Amended Rule 1144 20 May 2010

manufacturers and distributors to incorporate new technologies. However, since the 2015 limits 

have been withdrawn, the change from naphthenic base oils to paraffinic base oils is no longer 

necessary. 

Comment 13 

The proposed recordkeeping requirements are excessive. Contrary to AQMD’s assertion, the 

proposed recordkeeping requirements are not “streamlined”. ILMA requests that the water 

disposal column on the proposed recordkeeping form be eliminated. It suggests that the records 

allow for a “mass balance” accounting of VOC emissions which would not take into account 

fluid lost on parts or other loss streams. 

Response 

The proposed recordkeeping requirements provide the necessary information to document 

compliance. They are in a more streamlined format than the Rule 109 – Recordkeeping for 

Volatile Organic Compound Emissions requirements already included in the rule. At the request 

of industry, either recordkeeping format will be acceptable. There is no requirement to track 

water disposal or waste disposal for recordkeeping purposes. The proposed rule does require 

that purchase records be maintained for verification purposes. If a facility chooses to create a 

“mass balance” of fluid use and loss, it could be done on a completely voluntary basis. 

Comment 14 

The proposed recordkeeping requirements jeopardize information historically treated as 

confidential. AQMD’s existing procedure for asserting trade secrets should work well for 

companies that use products covered by the rule. However, it does not protect manufacturers of 

the products because they are not directly involved in the preparation of the documents that will 

be submitted to the AQMD. In order to protect manufacturer’s trade secrets, manufacturers 

should have the opportunity to claim trade secret status whenever a document kept by one of its 

customers is submitted to the AQMD or to implement a coding system for data entry on the 

document that masks the identity of the manufacturer and product. 

Response 

Manufacturers and distributors are welcome to ask users of the fluids they sell to request that the 

information be kept confidential. Only information claimed to be a trade secret at the time of 

submittal to the District may be treated as a trade secret. [Masonite Corp. v. County of 

Mendocino A.Q.M.D., 49 Cal.Rptr.2d 639 (1996)]. The District will follow the Guidelines for 

Implementing the California Public Records Act (Adopted by the Governing Board May 6, 

2005). These guidelines are available for review at http://www.aqmd.gov/prr/prag.html. 

 

Comment 15 

ILMA acknowledges that other chemistries, notably vegetable-based lubricants, can provide a 

low-VOC alternative for some formulations. However, mixing vegetable lubricants with mineral 

lubricants (naphthenic or paraffinic), results in a waste solution mixture that has no recyclable 

value. It will take years to build an infrastructure to effectively handle either straight vegetable 

oil or comingled vegetable and mineral oil products. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 21 May 2010

Response 

Vegetable-based lubricants are an option for users seeking a super compliant alternative to 

naphthenic-based lubricants. Other options include water-dilutable fluids, including emulsifiable 

oils and semi-synthetic and synthetic fluids, and paraffinic-based lubricants. Users are not 

required to select any particular option and likely will choose options that maintain or exceed 

performance requirements, are cost-effective and have an infrastructure in place to handle waste 

solutions. As demand for super compliant and environmentally preferable materials grow, it is 

expected that technological barriers will be overcome allowing for greater use over a wider range 

of applications. 

Comment 16 

Case studies have been provided which demonstrate a pattern of implementation costs that can 

be expected for each and every large user of these fluids if reformulation is required for any 

reason at all. Formulation changes made to improve the process save customers money while 

reformulation to an arbitrary standard not directly related to performance or improvements have 

great cost impacts. We think it is fair to assume costs proportionately similar to these for all 

customers who need reformulating, testing and re-approvals. 

Response 

After reviewing the detailed costs, the 2015 limits that would require reformulation, testing and 

re-approvals were withdrawn. The 2012 limits proposed in the rule do not require reformulation, 

testing or re-approvals. Those limits have been found to be cost-effective and remain in the 

proposed rule. 

Comment 17 

We believe that Pale Oil 100 (100 SUS @ 100°F or 22 cSt @ 40°C) is needed for our 

formulations. Many customers buy it without additives or use it as the basestock. The limits 

proposed for 2015 would require a change to paraffinic basestock, with all of the attendant costs 

and difficulties of reformulating, testing and re-approvals. We see no sense in mandating such a 

monumental change in products for a few hundred pounds per day of emission reductions. 

Response 

The proposed limit effective in 2012 will allow the use of Pale Oil 100 type fluids to be used. As 

stated earlier, the 2015 limits have been removed from the proposal. Staff will continue to 

evaluate costs associated with reformulation, sales and emission reduction potential to determine 

if further VOC limit reductions are feasible. 

Comment 18 

We recommend a tightly proscribed “Precision Metal Removal Fluid” category limited to 

specific applications of aluminum machining and carbide grinding. Slightly lighter viscosity oil 

mitigates contamination with aluminum oxide and excess loss on chips resulting in poor cuts and 

reduced tool life. For many years a common practice has been to use solvent previously used for 

cleaning as a diluent for aluminum cutting oil. By allowing the use of slightly lighter viscosity 

oil, the District will realize extra, unanticipated VOC reductions by the elimination of this 

practice. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 22 May 2010

Response 

A “Precision Metal Removal Fluid” category has been included in the proposed rule. The VOC 

limit proposed will allow 60 SUS @ 100°F type oils to be used in fluids used for carbide 

grinding machine tools where the manufacturer of the machine tool specifies the viscosity of the 

fluid or for machining of aluminum in automatic lathes where the design of the machine prevents 

the use of water-dilutable metal removal fluids. The proposed limit will curtail the use of solvent 

used as diluents in these applications. 

Comment 19 

I find it difficult to comprehend how my use of a non-volatile fluid in our 3 man shop will affect 

the air quality. I suggest you create a size threshold of some sort to exempt a shop of our size 

from whatever recordkeeping scheme is imposed. 

Response 

The recordkeeping provisions of the rule have been streamlined because of the nature of the 

machine shops using the fluids. Most are small businesses using fluids that have little or no 

VOC. Thus a provision in the rule specifically exempts small shops (emitting less than 4 tons of 

VOC per year) from keeping records of non-volatile fluids (those with VOC contents less than 

50 g/l). 

Comment 20 

We are a two person prototype machine shop. We are asking that the rule have minimal 

financial impact on our company. Please apply any fees based on annual usage rather than per 

business. We use 5 gallons per month of water soluble coolant and should not pay the same fees 

as someone who uses or emits much more. Many machine shops have closed and further 

financial burdens should not be imposed. 

Response 

There are no direct fees associated with the proposed rule. Facilities emitting over four tons per 

year of VOC emissions would be subject to annual emission reporting and fees. However, shops 

using super compliant water soluble coolant would have to use many thousands of gallons per 

year to reach this threshold. Additionally, water soluble coolants typically have VOC contents 

below 50 g/l and the rule exempts super compliant fluids from recordkeeping requirements. In 

the two person shop scenario described, the only likely change for the machine shop would be 

that the water soluble coolant container would include VOC content information and a date code. 

No process changes, no recordkeeping and no fees are expected to impact this shop. 

Comment 21 

We provide alternative and fully compliant non-petroleum technology to the local manufacturing 

community. We are pleased to say we can deliver compliant products to the market; products 

that are both functionally effective and in most cases cost neutral. 

Response 

We encourage you to provide specific case studies and cost information regarding your successes 

in transitioning shops to super compliant non-petroleum alternatives. The District will continue 

to evaluate the opportunity to further reduce emissions from these processes and information 
Final Staff Report ________________________________

Proposed Amended Rule 1144 23 May 2010

regarding successful conversions will be highly beneficial. As noted in the staff report, several 

alternative technologies show great promise and it is anticipated that their market share will grow 

as users seek super compliant and environmentally preferable alternatives to petroleum products. 

This is particularly true as reformulation costs decrease, machines are specifically designed to 

use alternatives and infrastructure is developed to better utilize the alternative fluids. 

Comment 22 

 We do realize that a new survey needs to be done on the emissions inventory and we don’t have 

any data to give, so we can’t contradict any existing data. But, we do agree that we should 

probably, until 2011 or mid 2011 where the first part of the rule of 1144 comes in to place, let’s 

do a formal survey. ILMA, our trade association, will participate with AQMD as much as we 

can and give as much data we have collected. What we are asking, and it looks like we have 

some general concurrence from AQMD, is to have a symposium here at this headquarters. We 

want to bring individuals from the United States, if not around the world, to discuss this new 

technology. We will have challenges. We don’t think any of the challenges are insurmountable. 

But the only way to hear them out is to bring the experts in here. And our trade association has 

access to these individuals and has the advertising on the road to help get those people to come 

here. And again we have some concurrence that that’s a good idea and we support that fully. 

Response 

We concur that a survey and report are necessary and therefore PAR 1144 includes paragraph 

(f)(3) that includes an annual quantity and emissions report requirement by manufacturers and 

suppliers that sell metalworking and direct-contact lubricants into or within the District. This 

reporting requirement will be for annual sales and VOC content and we will work with interested 

stakeholders on the format of the survey. The additional survey items can include information 

the parties agree gives the District a better understanding of product trends in the District as 

documented in the Board resolution. Staff also concurs that a symposium to be held at the 

District will be beneficial to further get a better understanding of low-VOC technology under 

development or already commercialized. 

Comment 23 

We use a Datron CNC machine to fabricate metal parts which uses denatured ethyl alcohol as a 

machine coolant. For more than twelve months, we have tried a variety of substitute coolants. 

We have found just one solvent, dimethyl carbonate, that meets our requirements. We hereby 

request the SCAQMD to classify dimethyl carbonate as an exempt compound. As an alternative, 

we ask that an exemption be made in Rule 1144 for cooling solvents used in CNC machines 

where permeable media are used to maintain a vacuum that holds the part in place during cutting. 

Response 

An exemption has been included in PAR 1144 to allow the use of dimethyl carbonate as a 

cooling solvent in computed numerically controlled (CNC) machines where permeable media are 

used to maintain a vacuum that holds the part in place during cutting. The exemption further 

requires that the equipment be enclosed and emissions be vented and discharged outside of the 

building. This type of use is very limited in terms of equipment and volume, and based on a risk 

assessment, has acute or chronic health impacts well below the threshold of significance. In 

addition any potential worker exposure has been minimized. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 24 May 2010

Comment 24 

To this date we can only speculate with little accuracy the true VOC of a “neat” oil. Is there an 

estimate on how much money and time has been invested in determining a VOC test method? 

How can a rule be in place when it cannot be tested? What is the real value in testing a low VOC 

oil? 

Response 

Through the efforts of the laboratory subcommittee formed to address the question of VOC 

content of metalworking fluids and lubricants, a public/private partnership has been successful in 

developing a repeatable and reproducible method to determine the VOC content of these fluids. 

The subcommittee met on more than half a dozen occasions and both District and private 

laboratories conducted several rounds of testing. While this has been a considerable investment, 

it has lead to significant and cost effective emission reductions. 

Comment 25 

Little study has been performed on oils taken from working situations. Is the AQMD and 

industry confident that they can test these “real world” oils? 

Response 

The test method developed is robust enough to test products taken directly from field use. The 

method can test the wide range of fluids used for metalworking and lubricant applications 

including those with specialized additives. 

Comment 26 

Whether a customer is military or commercial, specifications for a rust preventative or sealant 

will not typically change. If a change is required by the regulation, the business will go to 

someone else. If a customer cannot send in a request for quote with a high VOC rust 

preventative without violating the solicitation provision in the rule, we will lose business. 

Response 

Low-VOC metal protecting fluids have been developed that meet or exceed the performance 

requirements included in military and commercial specifications. Businesses will continue to be 

able to satisfy their customer’s needs for adequate corrosion protection. Only the direct 

requirement to use a high-VOC product constitutes a violation of the solicitation provision. 

Comment 27 

What is the real cost and true value of the proposed regulation? The loss of high performance 

oils is a cost and lost revenue for the end user and the District. 

Response 

The cost and cost-effectiveness of the rule is included in the staff report. Furthermore, a 

socioeconomic analysis has been conducted to evaluate the impact of the proposed rule on the 

local economy. The proposed rule is cost effective and overall there would be few job impacts 

of the proposed amendments on the local economy. For those fluids impacted by proposed VOC 

limits, adequately performing low-VOC alternatives have been identified. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 25 May 2010

Comment 28 

“Turning” comprises at least half of all metal removal applications and should be included in the 

definition of metal removal. 

Response 

“Turning” has been included as an example in the metal removal definition. 

Comment 29 

It continues to be our understanding that the proposed limits are not necessarily achievable for 

oils if the refiner uses a lighter oil to blend to achieve appropriate viscosity. Enforcement should 

be addressed at the oil manufacturer, as labeled, not the shop level. 

Response 

Usually only small amounts of light oil are used for base stock adjustments and should not 

significantly change the VOC content of the oils. Manufacturers and suppliers of blended fluids 

are required to label the container with accurate VOC content, including base stock adjustments. 

It is easily calculable to determine the VOC content of a base stock oil with a known amount of 

light oil added for viscosity adjustment. 

Comment 30 

The phrase “used in an emission control system” is vague and non-definitive. Please consider 

replacing that statement with “under the control of an emission control system”. 

Response 

The phrase “used in an emission control system” has been changed to “collected and directed to 

an emission control system” to clarify the intent. 

Comment 31 

The recordkeeping requirements are excessive and redundant. A listing of materials and 

quantities should be sufficient. 

Response 

The proposed recordkeeping requirements provide the necessary information to document 

compliance. They are in a more streamlined format than the Rule 109 – Recordkeeping for 

Volatile Organic Compound Emissions requirements already included in the rule. Including a 

means to verify the listing and quantities reported is critical to determine compliance. 

Comment 32 

The exemption for avionics and assembled aircraft should be change to the manufacture of parts 

for avionics and aircraft. 

Response 

Expansion of the exemption to all aircraft manufacturing is unnecessary. The aerospace industry 

has been using low-VOC lubricants, metal working fluids and rust inhibitors on the vast majority 

of their metal working applications. Many tens or even hundreds of thousands of gallons of 
Final Staff Report ________________________________

Proposed Amended Rule 1144 26 May 2010

metal working fluids used on aerospace products are ultra-low VOC technologies that the staff 

report identifies as low-VOC alternatives to high-VOC products. 

Comment 33 

The approval of the VOC test method developed by a public/private partnership between the 

District and metalworking suppliers has been delayed by ASTM International. We propose that 

the District delay hearing the rule until ASTM International has approved the method so that it 

can be incorporated into the rule. 

Response 

The District has agreed to delay the hearing until June 4July 9, 2010. If ASTM International has 

not approved the method by that time, staff will recommend that the Board adopt SCAQMD 

Method 319-10 Determination of Volatile Organic Compounds (VOC) in Metalworking Fluids 

and Lubricants by Thermogravimetry. Method 319-10 reflects the efforts made by the laboratory 

subcommittee to develop a reliable and repeatable method for determining VOC compounds of 

metalworking fluids and lubricants. 

Comment 34 

The Annual Quantity and Emission Inventory Report should be as narrow as possible. ILMA 

understands that AQMD staff is drafting a Governing Board resolution that will direct staff to 

work with interested stakeholders in developing reasonable content and format requirements for 

the annual report that are protective of confidential business information. However, ILMA 

requests that the Governing Board’s resolution make it explicit to the staff that content 

requirements of the reporting form should not be used as a “back door” way for AQMD staff to 

develop regulatory and enforcement information. 

Response 

The report was included in the regulation because ILMA and industry agreed that more 

information was necessary to develop an accurate inventory of emissions, particularly sales 

weighted average VOC content, and to analyze trends of low-VOC products. Staff also concurs 

that a symposium to be held at the District will be beneficial to further get a better understanding 

of low-VOC technology under development or already commercialized. All of this information, 

along with case studies, technology assessments, stakeholder discussion and other research will 

be used to determine if future regulatory action is warranted. 

Comment 35 

The applicability section uses such words and phrases as “coining”, “blanking”, 

“marquenching”, “piercing” and “roll forming” in specifying operations subject to the rule. 

None of these words or phrases was defined in the rule. CARB believes that without defining 

these words and phrases, some parts of the rule will be difficult to enforce. To improve clarity 

and enforceability of the rule, we suggest that those words and phrases be defined. 

Response 

Coining, blanking, marquenching, piercing and roll forming are included in the rule as examples 

of metal forming, metal removal or metal treating operations. These operations themselves are 

defined in the rule and that should be sufficient to provide clarity and enforceability. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 27 May 2010

Comment 36 

The proposed rule introduces a new test method for determining VOC content. EPA is currently 

reviewing the TGA method. 

Response 

We look forward to your comments on the test method. EPA is currently reviewing the TGA 

method. The parameters have been revised to more accurately test naphthenic oils used in the 

metalworking industry compared to paraffinic oils used in pesticides. 

Comment 37 

Rule 1144 references SCAQMD Rule 109 for recordkeeping requirements. Because the revised 

Rule 1144 is adding a test method, we recommend a corresponding section with the new test 

method be added to Rule 109. 

Response 

We plan to include the new TGA test method in Rule 109 the next time Rule 109 is opened for 

amendments. 

Comment 38 

Rule 1144 as it stands produces great, if economically impossible, hardship on our 

manufacturing process. Currently there is only one source of vanishing oil that complies with 

the current rule that took effect in 2010, and no viable solutions for the existing limits that will 

take effect in 2012. Unless the government can offer a viable solution, we face either 

noncompliance with the rule or the probability of relocation or closure in 2012. We have been 

burdened with extensive testing of products from many vendors and have provided the results. 

Of the 28 products tested, only one of the products proved satisfactory and that product will be 

non-compliant in 2012. The lack of governmental support for this new rule has caused severe 

frustration and unnecessary complications in the downward economy. We cannot fathom why 

the government chooses to be the limiting factor that will ultimately force what no other 

competitor or economic woe has been able to accomplish; the closure or huge expenditure of an 

industrial relocation to a more economically sustainable governance. 

Response 

As noted in the comment, a viable vanishing oil replacement is available to the company to 

comply with existing limits until 2012. In the interim, staff will continue to work closely with 

the facility to identify a compliant product. Alternatives to high solvent content vanishing oils 

include water-dilutable metal working fluids and straight oils. Water-dilutable metalworking 

fluids used in vanishing oil applications have sufficient rust preventative compounds to protect 

parts when the water evaporates. They provide sufficient lubricity but, like traditional vanishing 

oils, provide little tooling protection. Because they are so dilute, they evaporate leaving a dry, 

light protective film that is not tacky or gummy. Parts machined in this manner were found to 

have similar or superior corrosion protection to parts machined with conventional solvent-based 

vanishing oil, and did not require subsequent cleaning according to an AQMD co-sponsored 

report, “Assessment, Development and Demonstration of Alternatives to VOC-Emitting 

Lubricants, Vanishing Oils and Rust Inhibitors.” The high water content of the water-dilutable 

metal working fluids used in these applications makes them less expensive than vanishing oils. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 28 May 2010

COMPARATIVE ANALYSIS

Health and Safety Code Section 40727.2 requires a written analysis comparing the proposed rule 

with existing federal and AQMD regulations. Federal regulations do not regulate VOC 

emissions from lubricant and rust inhibitor operations. Solid film lubricants, dry lubricative 

materials and barrier coatings are subject to Rule 1124 - Aerospace Assembly and Component 

Manufacturing Operations and are not subject to this proposed rule. Similarly, paint and coating 

intended to completely cure and leave a solid, permanent film to beautify and protect metal 

surfaces are subject to other coating rules in Regulation XI and are not subject to this rule. 

Examples include aerospace, architectural, auto body, and metal paints and coatings with 

applicable VOC limits in Rules 1113 – Architectural Coatings, Rule 1124, Rule 1151 - Motor 

Vehicle and Mobile Equipment Non-Assembly Line Coating Operations, and Rule 1107 – 

Coating of Metal Parts and Products respectively. 

SOCIOECONOMIC ASSESSMENT

A socioeconomic analysis of Proposed Amended Rule 1144 is included in Attachment G. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, 

appropriate documentation will be prepared to analyze any potential adverse environmental 

impacts associated with the Proposed Amended Rule 1144. Comments received at the public 

workshop and CEQA scoping meeting will be considered when preparing the CEQA document. 

DRAFT FINDINGS UNDER THE CALIFORNIA HEALTH AND SAFETY CODE

Health and Safety Code Section 40727 requires that prior to adopting, amending or repealing a 

rule or regulation, the AQMD Governing Board shall make findings of necessity, authority, 

clarity, consistency, non-duplication, and reference based on relevant information presented at 

the hearing. The draft findings are as follows: 

Necessity – State and federal health-based ambient air quality standards for ozone are regularly 

and significantly exceeded in the AQMD. The reduction of VOC from Proposed Amended Rule 

1144 is part of a comprehensive strategy to meet federal and State air quality standards. 

Authority - The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules 

and regulations from Health and Safety Code Sections 39002, 40000, 40001, 40440, 40441, 

40702 and 41508. 

Clarity - The AQMD Governing Board has determined that Proposed Amended Rule 1144 – 

Metalworking Fluids and Direct-Contact Lubricants, is written and displayed so that the meaning 

can be easily understood by persons directly affected by them. 

Consistency - The AQMD Governing Board has determined that Proposed Amended Rule 1144 

– Metalworking Fluids and Direct-Contact Lubricants, is in harmony with, and not in conflict 

with or contradictory to, existing statutes, court decisions, federal or state regulations. 
Final Staff Report ________________________________

Proposed Amended Rule 1144 29 May 2010

Non-Duplication - The AQMD Governing Board has determined that Proposed Amended Rule 

1144 – Metalworking Fluids and Direct-Contact Lubricants, does not impose the same 

requirement as any existing state or federal regulation, and the proposed amendments are 

necessary and proper to execute the powers and duties granted to, and imposed upon, the 

AQMD. 

Reference - In adopting this regulation, the AQMD Governing Board references the following 

statutes which the AQMD hereby implements, interprets or makes specific: California Health 

and Safety Code sections 40001, 40440, and 40702. 

REFERENCES

California Department of Pesticide Regulation (February 2005), Estimation of Volatile Emission 

Potential of Pesticides by Thermogravimetry.

California Manufacturers Register. Twinsburg: Harris Infosource, 2006. 

Green, C. (2009, August 26). U.S. Base Oil Price Report. Lube Report, Volume 9, Issue 34 

Green, C. (2010, January 13). U.S. Base Oil Price Report. Lube Report, Volume 10, Issue 2 

“Comments of the Independent Lubricant Manufacturers Association (ILMA) on ‘Metalworking 

Fluids: Summary of Nomination for Review: NTP 12th Report on Carcinogens, September 2003 

Submitted by Report on Carcinogens Group, NIEHS’”, [Online] Available at 

www.ilma.org/about/ntp_comments.pdf (Accessed July 29, 2008). 

“Assessment, Development and Demonstration of Alternatives to VOC-Emitting Lubricants, 

Vanishing Oils and Rust Inhibitors”, August 2006. Prepared by the Institute for Research and 

Technical Assistance for South Coast Air Quality Management District Under Contract No. 

05058 and the United States Environmental Protection Agency Region IX. 

Qualified Products Database, Governing Spec: MIL-PRF-16173E (retrieved January 19, 2010) 

from http://qpd.daps.dla.mil/qpd/quick_search/default.aspx?qpl=QPL-16173

Segawa, R. (September 2008). Analysis of Anomalously High Emission Potential Values for 

Certain Spray Oil Products, Memorandum, California Department of Pesticide Regulation 

SCAQMD, (May 1999). Final Socioeconomic Impact Assessment. Proposed Amendments to 

Rule 1113. 

U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, 

Office of Compliance (September 1995). Sector Notebook Project: Profile of the Fabricated 

Metal Products Industry [Online] Available at 

http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/fabmetsn.pd

f (Accessed July 29, 2008). 
Final Staff Report ________________________________

Proposed Amended Rule 1144 30 May 2010

Method 24 – Determination of Volatile Matter Content, Water Content, Density, Volume Solids, 

and Weight Solids of Surface Coatings. U.S. Environmental Protection Agency, February 2000. 
Final Staff Report - Appendix A

Proposed Amended Rule 1144 1 May 2010

Laboratory VOC Content Test Method Validation Test Results 

Lab

Solvent 

Cutback Rust 

Preventative 

Synthetic 

Hydraulic 

Oil 

General 

Purpose 

Cutting and 

Grinding Oil 

Pre-diluted waterbased semisynthetic cutting 

fluid* 

Aluminum 

Cutting 

Fluid 

A 621 60 982 85 

B 625 45 90 

C 636 2 50 974 72 

D 642 50 979 92 

E 637 80 145 

F 633 56 981 95 

G 646 66 981 104 

H 608 5 65 929 89 

*Before water removed 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 1 May 2010

Comments and Responses Relative to SCAQMD Method 313-L Determination of VOC 

Hydrocarbon Compounds in Lubricants 

The following paragraphs provide staff responses to ILMA’s specific comments relative to 

SCAQMD Laboratory Method 313-L included in their February 17, 2010 letter to the District. 

Comment 

The use of Gas Chromatography (GC) for the determination of the VOC content of oil- based 

lubricants and rust preventatives by SCAQMD Method 313-L has proven to be difficult in 

practice, and with regards to rapidly obtaining results that show inter-and intra-lab 

reproducibility. 

Response 

Method 313-L is going through the ASTM E691 validation process although it has not yet been 

able to achieve the agreed upon validation criteria. Method 313-L has value for determining 

VOC content for high water content samples. However, until the validation criteria have been 

met, it will not be included in the rule. 

Comment 

Running the method as written requires a minimum of 10 hours of instrument time for just one 

sample. Each additional sample adds at least 90 minutes of additional analysis time. This does 

not account for the lab hours required to prepare the seven standards, sample duplicates, blanks, 

and matrix spikes. 

Response: 

The estimate of "10 hours of instrument time" is overestimated. The reality is that Method 313-L 

currently takes less time per sample than TGA: 105 minutes versus 140 minutes (including 

between-sample GC cleanup and TGA cool-down). Although Method 313-L requires more 

quality control, the ability to run GC autosamplers overnight more than compensates for the 

additional injections. 

ILMA Reply 

Method 313-L requires the analysis of seven external standards, a blank, a matrix spike standard, 

and matrix spike standard duplicate at a minimum for each batch of metalworking fluids 

analyzed. Additionally, the column must be “baked out” in-between sample runs to minimize 

sample carry-over. As each run is approximately 45 minutes, and assuming one sample is 

analyzed in duplicate, this works out to 13 runs x 45 minutes = 9.75 hours. Good analytical 

practice demands that all standards are run for every batch of samples tested. The assumption 

that all labs have autosampler capability is dubious. The “10 hour” number could also be an 

under-estimate of the method set-up time, as the 10- hour estimate assumes the preparation goes 

as planned. TGA analysis does not require the extensive preparation steps/standards that 

GC/FID analysis requires. 

AQMD Response 

Method 313-L does not mention running “seven standards” with every batch; therefore 

subsequent comments and calculations based on this assumption significantly overstate required 

time. Instead of requiring “13 runs”, the method only requires one calibration check, one blank, 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 2 May 2010

a matrix spike and duplicate per batch, or 5 runs. After these instrument checks, ten samples are 

analyzed. Because the instrument checks are divided among many samples, the analysis time 

reduces to approximately 105 minutes per sample. TGA, on the other hand, requires well over 

two hours for each sample; and because an autosampler cannot be used for TGA analysis, this 

impacts staff time directly. 

Comment 

Following the method as written, final calculations require at least 10 mathematical steps to 

arrive at an answer. Calculations require the generation of a statistics package and the use of 

linear regression. Results may be affected by how the analyst chooses to perform the regression 

(dropping the y-intercept or forcing the equation through zero). 

Response 

These kinds of calculations should be within the capacity of GC laboratories experienced with 

ASTM simulated distillation and similar methods. The calculation of linear regressions, for 

example, is a routine part of GC analysis and can be accomplished either using standard 

chromatography software or functions built into modern spreadsheets. In any case, if the 

participating laboratory does not want to develop its own spreadsheets, the AQMD will supply 

them. 

ILMA Reply 

Relative to the TGA method (ASTM E1868-10), the calculations required to arrive at an answer 

for Method 313-L are clearly more complex and subject to more opportunities for error. The fact 

that AQMD staff has to help individual labs to perform calculations by creating spreadsheets is 

self-evidence of the highly complex nature of the method. AQMD lab staff has revised the VOC 

calculations several times because of inconsistent instrument response. AQMD lab staff also has 

attempted to apply correction factors to data generated by outside labs in order to obtain the 

results they desired to see. These calculations involve operator judgment, which is always a 

problem for standardized methods. 

AQMD Response 

Calculating a calibration curve and checking to see if the curve and instrument is stable from 

batch to batch is a routine part of gas chromatography. One of the reasons for providing a 

spreadsheet was to simplify review by creating a standard format.

Comment 

The method calls for ramped flow rates, which require electronic flow control (EFC). Many 

older or entry level GC’s in use today do not have this capability, and thus, some labs will be 

forced to alter the method to suit available hardware. This has been shown to lead to large 

discrepancies in the retention times of the marker compound (methyl palmitate). During the 

initial Method 313-L robustness testing, retention times for methyl palmitate among the 

participating labs ranged from 25 –42 minutes, which is an enormous spread in GC terms. 

Response 

Most GC methods (including this one) assume uneven instrument capabilities. This is why most 

GC methods (including ASTM GC methods) either “recommend” or list “typical” instrument 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 3 May 2010

parameters rather than “require” them; and focus instead on performance check standards to 

validate final results. Retention time markers are a common form of quality control which 

specifically allow for variations in flow, temperature, column performance etc. (deliberate or 

otherwise) without disturbing the final result. Whether the observed retention time spread is "too 

large" to generate a reproducible result is one purpose of the interlaboratory study, and should 

not be assumed in advance. So far, results do not support concerns about the range of methyl 

palmitate retention times. However, staff is also continuing to evaluate other Method 313-L 

endpoints to address other issues. 

ILMA Reply 

There is a large difference between “uneven instrument capabilities” resulting in fluctuations of 

retention times by 1 – 5% among labs, and the results observed for the inter-lab study, in which 

retention times were found to differ by as much as 30 – 40%. The method, as written, assumes 

advanced GC capabilities that all labs do not have, and the results of the initial inter-lab study 

clearly reflect this. The variations considered acceptable by the AQMD lab staff may be okay 

for analysis of organic compounds of a similar chemical nature (hydrocarbons, carboxylic acids, 

carboxylic esters, amines, and fatty alcohols), but they become unacceptable when analyzing a 

complex mixture of organic compounds. 

AQMD Response 

One point in ILMA’s initial comment needs clarification: Method 313-L does not require 

“ramped flow” or “advanced capabilities”. Different laboratories did indeed choose to utilize 

somewhat different elution conditions. But since they all used the same column, the various 

compounds all eluted in the same order, even if they didn’t elute at the same time from lab to lab. 

In other words, compounds which eluted after the retention time marker always eluted after the 

retention time marker, whether that marker eluted at 25 minutes or 40 minutes. Therefore, the 

same compounds were classified as VOC (or non-VOC) no matter where the actual endpoint 

occurs, and the results were insensitive to actual marker compound elution time. 

Comment 

Under Method 313-L parameters, the signal: noise (S/N) ratio for 60 and 100 second oils is 

relatively low. Additionally, natural oils do not elute as sharp, clean peaks, but as broad 

unresolved “humps”. In practice, this means that such oils are difficult to clearly distinguish from 

the electrical noise generated by the instrument (a.k.a. column “bleed”). This results in ambiguity 

as to how to properly place the baseline for oil-based samples, and thus how to correctly 

integrate the chromatogram. Baseline placement has a profound effect on the final calculated 

results for oil based samples, as evidenced by data generated during the robustness testing: 

Table 1 –Perceived Effect of Baseline Placement on Robustness Testing Results 

Lab Baseline Type Result (g/l) Comments 

1 Flat 240-251 Includes column bleed, leads to high results 

2 Flat 277 Includes column bleed, leads to high results 

3 Angled 67-73 Low results due to failure to included all 

hydrocarbon peak area 

4 Curved (S-shaped) 133-185 Manually fitted; best compromise between flat 

and angled baseline 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 4 May 2010

Response 

There are several issues folded into one comment. 

Signal/ noise: AQMD has noted that some laboratories appear to have higher baseline signals 

and less sample response. The current Method 313-L method has been modified to increase the 

sample amount. Part of this problem may have resulted from suboptimal injection port liners, 

which have been more exactly specified (see below) 

Column bleed: Inter-sample solvent injection has eliminated carryover; some laboratories appear 

to have a baseline rise of unknown origin, which the AQMD is working to understand and 

eliminate. In any case, the current version of Method 313-L does not include the area of baseline 

rise. 

 

Baseline placement: The appropriate placement of the baseline is unambiguous- It is the blank 

baseline at the beginning of the run. In this regard, both the baseline difficulties and the baseline 

placement in Method 313-L are similar to ASTM simulated distillation methods and other GC 

methods of natural products. These difficulties have been successfully negotiated by many 

laboratories performing similar methods. 

ILMA Reply 

Signal/ noise: This does not address the fundamental issue that natural oils are extremely difficult 

to handle quantitatively and reproducibly by GC/FID. Specifying injection liner type is good 

practice, though the type of liner chosen will have little to no effect on overall difficult to handle

peak shape generated by natural oils. 

Column bleed: Inter-sample solvent injection may reduce carry-over, but its elimination cannot 

be guaranteed. The baseline will rise some finite amount with increasing oven temperature, no 

matter what is injected. For samples of low signal/noise ratio, accidental inclusion of this 

column bleed or electrical noise by inexperienced outside laboratories is a real concern that 

should not be overlooked by AQMD lab staff. Such practice would lead to artificially high 

calculated VOC values. 

Baseline placement: Upon close inspection of the solvent blank baseline, an S-shaped curve may 

be observed. Placement of the baseline at the lower or higher end of the curve will affect the 

final results for samples of low signal/ noise ratio. There is no provision to account for this in the

method as written, and thus is considered ambiguous. The attempt at baseline manipulation does 

not consider sample influence on the FID detector response. The FID is a flame, anything which 

disrupts the flame impacts the signal response. 

AQMD Response 

Signal/ noise: “Difficult” peaks shapes are an expected feature of natural oil analysis such as 

lubricants, diesels, bitumens, food oils, residues, crude oils and similar products. This problem 

has been encountered and resolved in chromatography methods promulgated by ASTM and other 

entities: 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 5 May 2010

ASTM D6074 - 08 Standard Guide for Characterizing Hydrocarbon Lubricant Base Oils 

references, 

ASTM D2887 - 08 Standard Test Method for Boiling Range Distribution of Petroleum Fractions 

by Gas Chromatography 

ASTM D3524 - 04 Standard Test Method for Diesel Fuel Diluent in Used Diesel Engine Oils by 

Gas Chromatography 

EPA 8270D Semivolatile Organic Compounds by Gas Chromatography/ Mass Spectrometry. 

For example, when analyzed by ASTM D 5307 Simulated Distillation Analysis, heavy bitumen 

produces the following trace (reproduced from the Shimadzu application website) 

Simulated Distillation Analysis of Heavy Canadian Crude Oil by ASTM D 5307 

(This sample has been spiked with C14 through C17, seen on the left, as retention-time markers.) 

Because of the commonality of the problem, detection and integration of merged peaks is 

supported by all chromatography manufacturers. 

Column bleed: ILMA has concerns about being able to distinguish baseline rise from sample 

VOC. There are several solutions to this issue. The first is to eliminate baseline rise as much as 

possible. Just as TGA will not work properly if it has dirty supply gases, an un-calibrated 

balance or thermometer, or dirty sample pans, a GC will not work well if it isn’t properly 

maintained. In GCs, baselines can rise for a number of reasons including dirty supply gases, 

leaks, column bleed and sample carryover. These problems are eliminated using proper 

chromatography practices. A second part of the answer is to transfer sufficient sample onto the 

column such that the sample signal is high enough to be distinguishable from baseline rise. 

Method 313-L has been modified to increase the prepared sample concentration. The last part of 

the solution is to perform a blank injection for each batch, as required by Method 313-L. This 

step allows the baseline to be evaluated for suitability. 

Baseline placement: There are several possible methods for drawing baselines, and these vary 

between instruments. If the baseline is flat, a straight line is sufficient. But in the case of nonlinear baselines, chromatography software includes a baseline subtraction option. (A few vendors 

require a SIMDIS package for this feature). However, since the temperature range of the current 

Method 313-L analysis is limited, baseline subtraction should not be necessary. 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 6 May 2010

Comment 

Column (DB-624) is classified as mid-polar, and is thus not suitable for performing a simulated 

distillation, in which compounds are separated strictly by boiling point. The use of a column 

such as DB-624 introduces a secondary retention mechanism into the chromatography (dipoledipole interactions). The analysis of MWF’s, which contain polar compounds, will result in a 

separation that is influenced by both chemical structure (dipole moment) and boiling point. 

Response 

The column was not intended to perform simulated distillation. The specified column helps 

resolve exempt compounds from VOC compounds, allowing more accurate analysis. In addition, 

there is no reason to assume that a “boiling point” column is more reflective of real-life 

evaporation. In fact, since real-life evaporation involves chemical structure (dipole-dipole 

interactions), an argument could be made that DB-624 is more reflective of real-life conditions. 

(ASTM D7398, Standard Test Method for FAME Boiling Point Range by GC). From further 

work with the method, we have found that this column can, in fact, reproduce both Method 24 

and TGA evaporative methods reasonably well. 

ILMA Reply 

The method as written clearly does not reproduce the approved TGA method (which has been 

demonstrated to reflect long term evaporation in an oven), as evidenced by the artificially high 

VOC values obtained for semi-volatile oils. The statement “The column was not intended to 

perform simulated distillation” indicates an improper understanding of GC instrumentation. The 

column is actually being used to replicate and perform simulated distillation, with chemical 

adsorption/desorption interactions also being involved. The use of a marker compound to 

differentiate a VOC from a non-VOC compound, with the stipulation that ALL compounds that 

elute prior to the marker compound are VOC in nature, replicates distillation. The 

adsorption/desorption characteristics of the column stationary phase are not the same as the 

dipole-dipole interactions of air atmosphere chemical volatilization. 

AQMD Response 

The original Method 313-L did not reproduce the currently-approved TGA method because it 

was written to reproduce the national standard, EPA Method 24. The revised Method 313-L, 

however, does compare well with the approved TGA in samples tested so far. 

Comment 

Methyl palmitate is a poor choice of marker compound, for the secondary interaction reasons 

given above, and its choice has never been clearly explained. In essence, methyl palmitate (being 

a polarizable compound) is retained for a longer time period (due to secondary column 

interactions) than a hydrocarbon of comparable molecular weight (C19H40). The end result is an 

artificially large “retention window” in which VOC is calculated, that is not representative of a 

true boiling point separation. 

Response 

Again, since the column was not chosen for boiling point determination, neither was the 

endpoint. The endpoint was determined as the closest approximation of EPA Method 24 results. 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 7 May 2010

Staff is currently evaluating alternative endpoints to assess if greater conformity with VOC 

results, as determined by evaporation rate studies and TGA, is achievable. 

ILMA Reply 

The behavior of methyl palmitate under the conditions of EPA 24 and on a semi-polar GC 

column of arbitrary temperature conditions has a tenuous correlation, if any. It is clear from the 

initial inter-lab studies that using methyl palmitate as the key retention time marker results in 

calculated VOC values for semi-volatile oils that are significantly higher than results obtained by 

the Dodge evaporation study or by the approved TGA method. Investigation of alternative 

marker compounds would certainly improve the method, though would likely require months of 

additional research and data generation. 

AQMD Response 

The originally written Method 313-L does not reproduce the evaporation study or the TGA study 

because it was designed to reproduce the national standard, EPA Method 24. While Method 313-

L and Method 24 match each other, neither method matches the evaporation study or the TGA 

method. The advantage of Method 313-L, however, is that it is possible to review the data to 

determine if a new endpoint will reproduce evaporation study and TGA results. This has already 

been done; when AQMD data is reprocessed using a new marker compound, the results compare 

well with evaporation study and TGA results. 

Comment 

Detector response factors for non-hydrocarbons are mentioned, but never clearly addressed. 

Given the vast amount of volatile/semi-volatile raw materials that could conceivably be present 

in a given MWF, the chance for erroneous results appears to be high. These errors could be 

compounding with more complex fluids. 

Response 

The errors, if there are any, will be biased low, in favor of metalworking fluids, since the 

presence of heteroatoms (oxygen, nitrogen, sulfur, and chlorine) reduces sample response. 

However, in typical metalworking fluid compounds, these heteroatoms are expected to have only 

a small negative effect. ("Modern Practice of Gas Chromatography" Robert Lee Grob, Eugene F. 

Barry p.303, “Effect of Molecular Structure Upon the Response of the Flame Ionization 

Detector”, M Kallai, J. Balla, Chromatographia 2002). 

ILMA Reply 

The unpredictable GC response of the thousands of possible compounds that might be present in 

a given metalworking fluid adds yet another layer of uncertainty to the method, and introduces 

additional sources of error to Method 313-L. As many labs would be performing the analysis on 

fluids of unknown composition, there is no practical way to account for such error during routine 

testing. FID detector response is a very real problem, not all compounds produce linear FID 

response. ILMA is concerned with the generalized opinions expressed in the AQMD response, 

and the assumptions being made. 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 8 May 2010

AQMD Response 

FID (detectors) are widely known for their linearity over several orders of magnitude, and 

laboratory results indicate that participating laboratory detectors were linear from approximately 

200 ppmv to at least 10,000 ppmv. Since sample responses never exceeded 5000 ppmv it is 

unlikely that FID linear range would be exceeded. 

FIDs are also widely known for their predictable response, earning them a reputation as “carbon 

counters”. This is due to the fact that all carbon atoms eventually form the same detected specie 

in a FID flame, no matter what the source molecule. Nonetheless, carbon response can be 

influenced by adjacent non-carbon atoms. Besides their base oils (for which FIDs are ideally 

suited) lubricants also include additives which may contain oxygen, chlorine, sulfur, nitrogen, 

calcium, zinc, phosphorous or other non-carbon atoms. Correction factors for various noncarbon atoms are widely available; they have allowed AQMD staff to estimate a negative bias of 

10% or less for chlorinated paraffins containing 55 percent by weight chlorine. 

Comment 

Split injection technique does not address the possibility of split discrimination in the injector. 

Discrimination is a phenomenon that can occur for wide boiling point mixtures in which the 

entire vaporized sample is not swept onto the column homogenously. 

Response 

AQMD has noted that some laboratories appear to have had injection irreproducibility and some 

discrimination. To obviate any potential problems, the method has been modified to specify a 

double-tapered, glass-wool filled, passivated injection port liner. This is very much like 

specifying the type of pan required for TGA analysis. However, embedded quality control in 

Method 313-L will indicate whether injection port discrimination is taking place. Therefore, the 

GC method is both self-reporting and self-correcting. 

ILMA Reply 

Split discrimination is a function of the injection technique itself, not the type of liner used. 

Discrimination (by definition) is an indeterminate source of error that could also be a function of 

injection technique. Normalizing liner type is good practice, but cannot eliminate split 

discrimination, particularly for wide boiling point mixtures. The notion that the GC method is 

self-reporting and self-correcting is debatable, at best. In order to properly determine VOC 

content by GC analysis, a split injection should not be utilized. ALL the volatile compounds 

should pass through the column for detection/analysis. A split injection technique could 

discriminate and “lose” some highly volatile compounds, thus skewing the results. 

AQMD Response 

Split injection is a technique which transfers only a portion of injected sample onto the GC 

column, and vents the remainder. This is to prevent column overloading. Sample discrimination 

can occur when disproportionate amounts of high (or low) molecular compounds are vented, 

enriching one group of compounds relative to another. If no discrimination is taking place, equal 

amounts (by weight) of C6 to C15 standards should produce equal-sized peaks. This can be 

easily checked using the C6 through C15 calibration slopes. Sample discrimination can be 

detected easily. 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 9 May 2010

Comment 

Thick fill columns (1.00 μm) are prone to bleed more than the more common 0.25μm columns. 

This effect increases over time as the column ages and the temperature is repeatedly cycled. This 

will exacerbate baseline placement issues discussed above. 

Response 

The column in the AQMD laboratory has been in use for two years, analyzing lubricants and 

paints and coatings, and has not deteriorated in performance or developed column bleed. 

Analysis blanks further address the issue of baseline drift and is therefore added to Method 313-

L protocol. 

ILMA Reply 

The degradation of GC columns over time with repeated use and temperature cycling is an 

accepted fact. Injection of real-world samples that may contain more aggressive compounds 

(inorganic acids/bases) than have been studied in the AQMD labs will exacerbate degradation, 

and may lead to baseline and/or column problems that staff has thus far not anticipated. Column 

degradation is a very real concern, especially when the cost per column is rather high. One 

cannot extrapolate column life expectancy based upon analysis of simple organic mixtures. 

AQMD Response

ILMA’s implied call for a thin-film column is at odds with their call for splitless injection, since 

a thin-film column would be overloaded. 

Comment 

When real samples are analyzed, many high molecular weight components (surfactants, 

polymers, polyol esters, sulfonates, etc.) will not elute from the column and remain trapped in 

the inlet liner or at the head of the column. This may lead to “ghost peaks” in subsequent runs, 

which in effect is the appearance of compounds not present in sample proper, but slow 

volatilization of the “leftovers”. Single inter-run “bakeouts” may not fully address this issue. 

Response 

The current method requires an inter-sample solvent injection, which eliminates carryover in a 

normally clean system. However, as with any analysis of complex samples, the injection port 

liner should be replaced and possibly the first loop of column trimmed. AQMD does replace 

injection port liners about once every six months, but has not yet had to either trim or replace a 

column. Laboratories are also encouraged to perform periodic maintenance which may include 

and overnight bakeout to clean out contamination. 

ILMA Reply 

Again, inter-sample solvent injection is helpful, but cannot guarantee elimination of sample 

carry-over. This “hope for the best” approach, particularly when dealing with contract 

laboratories unfamiliar with lubricant/metalworking fluid formulations, may lead to 

chromatography problems and artificially high calculated VOC values that will not be 

immediately obvious to the inexperienced analyst. Sample carry-over is one problem, another 

problem is reactive interference. Reactive interference occurs when the residue left in the 

injection liner from one sample adversely reacts with the compounds of a different sample when 

the new sample is injected for analysis. 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 10 May 2010

AQMD Response 

Regular injection of blanks would flag long-term contamination, if it occurs. Reactive 

interference would be suspected when very light compounds appear in a chromatogram, 

indicating sample fracturing. So far, this problem hasn’t been observed with lubricant samples. 

However, AQMD recommends changing injection port liners according to manufacturer 

recommendations. 

 

Comment 

Automated integration performed by a given chromatography software program, will have a 

difficult time handling the complex baseline placement issues for natural oils described above. 

The notion that any and all contract analytical labs will successfully navigate this issue (via 

manual integration) is hopefully optimistic, at best. 

Response 

Method 313-L contains sufficient quality control to determine whether integrations have been 

performed properly. 

ILMA Reply 

Method 313-L, when performed as written with good analytical practice, is clearly not as 

efficient as the TGA method. The embedded quality control procedures in Method 313-L are 

useful in detecting abnormalities in individual injections, but do not account for proper 

integration of oil-based unknowns, the most critical issue at stake in the analysis. Proposed 

changes to Method 313-L will require months of additional study/research to determine their 

effectiveness at mitigating the myriad problems with the method staff has admitted to. This is an 

unnecessary expense of time and money, when a rapid, reproducible, and accurate TGA method 

has already been developed and validated. 

AQMD Response 

The issue of integration and efficiency has been addressed in previous comments. Improvements 

to the method based on the first interlaboratory have been incorporated, much like the changes 

that were made to the TGA method. The last revision to Method 313-L was to parallel TGA 

results. The remaining step is to determine how well the revised method will work in other 

laboratories. Since the first round met program goals (with the exception of one laboratory) and 

revisions made the method simpler and more accurate, it is expected that the second 

interlaboratory evaluation will prove to be successful. It also should be pointed out that should 

the development and validation of Method 313-L be completed, it would be staff’s intent to 

include Method 313-L in the rule as an alternative to the TGA-based test method and not as a 

substitute to it. End users that find the TGA method preferable to work with should be able to 

continue employing it as their test method of choice. 

In summary, Method 313-L is at least as efficient as TGA in terms of output. But Method 313-L 

includes quality control procedures which reveal whether the final results are accurate. In 

addition, the Method 313-L shows greater potential for analyzing water-based samples more 

accurately than the TGA method, which depends on a secondary water analysis which has not 

been validated for metalworking fluids. Proposed changes to the Method 313-L protocol are 

expected to mitigate many of the concerns listed above. This protocol will be revised prior to 
Final Staff Report - Appendix B

Proposed Amended Rule 1144 11 May 2010

initiating another round robin, and staff will share any changes with ILMA and other 

stakeholders.