VENTURA COUNTY APCD 

FINAL STAFF REPORT 

Rule 74.31, Metalworking Fluids and Direct-Contact Lubricants 

Proposed Amendment to Rule 23, Exemptions from Permit 

September 23, 2013 

EXECUTIVE SUMMARY 

Staff is proposing to adopt a new rule to reduce the 

reactive organic compound (ROC) emissions from the 

use of metalworking fluids and direct-contact 

lubricants. This rule development will implement an 

All Feasible Measure as required by the California 

Clean Air Act (HSC Section 40914). The 2012 

Ventura County Triennial Assessment and Plan 

Update adopted by the Air Pollution Control Board 

on January 8, 2013, references this rule development 

as a feasible control measure. Moreover, this rule

adoption is supported by the Independent Lubricant 

Manufacturers Associations (ILMA), an industry 

association that worked closely with the South Coast 

AQMD in their rule adoption. 

Proposed ROC content limits for the use of 

metalworking fluids and direct-contact lubricants are 

based on existing South Coast AQMD Rule 1144, 

Metalworking Fluids and Direct-Contact Lubricants. 

The vast majority of fluids used during metalworking 

and/or metal forming operations are vanishing oils,

lubricants, rust inhibitors, and metalworking fluids. 

Examples of these operations include steel tube and

spring manufacturers, aerospace manufacturers, 

automobile parts manufacturers and rebuilders, as 

well as machine shops for broaching, drilling, 

drawing, heading, honing, forging, milling, stamping, 

tapping, threading, and turning. 

Staff is proposing to reduce ROC emissions by the 

substitution of high-ROC metalworking fluids with 

low-ROC fluids, which include medium napthenic 

oils, paraffinic oils, vegetable oils, synthetic or semisynthetic oils, and water-reducible fluids. Low-ROC 

products are available for substitution in each of the 

regulated metalworking fluid categories in the table 

of standards in the proposed new Rule 74.31. 

The ROC emission reductions focus on the light oil 

lubricants, vanishing oil lubricants, and corrosion

inhibitors. The estimated ROC emission reductions 

are 41 tons per year using control measure 

effectiveness of 54 percent and 76 tons per year 

source category inventory. This estimate is based on 

a comparative analysis of a source survey performed

by the South Coast AQMD, which showed 5.29 tons 

of VOC per day in 2006, and a VOC emission 

reduction of 3.97 tons of VOC per day in the South 

Coast district. 

The proposed new rule may affect four sources 

currently having APCD permits including Advanced 

Structural Alloys, Aluminum Precision Products, 

Arcturus, and Western Saw. The first three of these 

sources are forging operations and the last one is a 

steel saw manufacturer that currently uses a mineral 

oil quench tank (metal treating operation) to obtain 

the optimum product hardness. However, more than 

95 percent of the ROC emissions from this source 

category are from non-permitted area sources, which

include up to 300 machine shops operating in the 

county. The proposed amendments to Rule 23, 

Exemptions from Permit, will exempt equipment 

using Super Compliant (50 grams ROC per liter of 

material or less) metalworking fluid from APCD 

permit requirements, except metal forging operations 

will still be subject to permit requirements. In 

addition, specialized metalworking equipment, will 

continue to be exempt from permit requirements 

regardless of the ROC content of the fluid used. 

Equipment in this permit exempt category include 

lapping, Sinker EDM, carbide grinding machine 

tools, and machining of aluminum or magnesium in 

single or multiple spindle automatic machines. 

Rather than requiring permits of these machine shops, 

staff is proposing a Sales Prohibition enforcement 

mechanism to restrict the sale and supply of noncomplying high ROC lubricants. The proposed Sales 

Prohibition is modeled on the adopted version in 

SCAQMD Rule 1144. In the South Coast district, 

manufacturers and suppliers are playing the lead roles 

in rule compliance. 

The estimated cost analysis for replacing existing 

metalworking fluids with low-ROC versions was 

based on the 2006 technology assessment performed 

by the Institute for Research and Assistance (IRTA)

for South Coast AQMD Rule 1144 and SCAQMD 

Staff Reports dated March 2009 and May 2010. The 

cost-effectiveness for these fluid replacements ranged 

from a cost savings to $0.40 per pound of ROC 

reduced. High ROC metalworking fluids have 

already been reformulated by the lubricant 

manufacturing industry at a cost of several million

dollars in response to South Coast AQMD Rule 1144. 

However, these reformulations costs have not been 

passed on the end user, which will result in minimal 

costs to machine shops. 

Transitioning from light oil blends to medium 

viscosity straight cut oils results in little or no cost 

impacts. This indicates that the proposal is very costeffective especially relative to new sources, which

may be required under New Source Review to spend 
 Staff Report Page 2

up to $9 per pound of ROC reduced to install best 

available control technologies (BACT). 

This report contains five additional sections: (1)

Background, (2) Proposed Rule Requirements, (3) 

Comparison of Proposed Rule Requirements with 

Other Air Pollution Control Requirements, (4) Impact 

of the Proposed Rule, and (5) Environmental Impacts

of Methods of Compliance. The first section 

provides background information including 

regulatory history, latest air pollution control 

technology and source description. The second 

section explains the key features of the proposed 

requirements. The third section compares the 

proposed requirements with existing federal 

requirements and Best Available Control Technology 

(BACT). The fourth section is an analysis of the 

proposed amendment's effect on ROC emissions, 

cost-effectiveness, and socioeconomic impacts. The

last section examines the environmental impacts of 

compliance methods and the mitigations of those 

impacts. 

BACKGROUND 

Metalworking Fluids: An ROC Emission Source 

Until recently, air pollution regulations for the 

metalworking industry focused on reducing 

particulate matter and opacity with minor emphasis 

on limiting the ROC content of lubricants used at 

forging operations in the county. With the adoption 

of SCAQMD Rule 1144 in 2009 and a new more 

reliable test method for ROC content in 2010, it 

became clear that this industry is a significant source 

of ROC emissions. In the past, these ROC emissions

were thought to be insignificant based on their low

vapor pressure and low volatility. However, test 

results from work done in the South Coast district 

revealed that a subset of these lubricants have a 

significant ROC emission potential including light 

oils, vanishing lubricants, and corrosion inhibitors. 

The size of this ROC emission inventory at 76 tons 

per year, and the fact that industry has already 

reformulated many of the high-ROC lubricant 

products that are currently being sold in the South

Coast district, are the reasons for proposing this new 

rule. As an ozone non-attainment area under the 

California Clean Air Act, Ventura County is required 

to adopt All Feasible Measures. Based upon the 

work done together by the South Coast AQMD and 

the Independent Lubricant Manufacturers Association

(ILMA), SCAQMD Rule 1144 is a reasonable and 

feasible control measure. ILMA supported the 

adoption of SCAQMD Rule 1144 and supports the 

adoption of Rule 74.31 in Ventura County. 

2006 Technology Assessment 

Metalworking operations encompass a wide range of 

manufacturing and metal machining processes. 

Manufacturing metal products is performed in the 

county, ranging from large metal forging operations

to small machine shops. Typical machine shop 

operations include broaching, drilling, drawing, 

heading, honing, milling, stamping, tapping, 

threading, and turning. 

In August 2006, the Institute for Research and 

Technical Assistance (IRTA) published a technology 

assessment for this source category called, 

“Assessment, Development, and Demonstration of 

Alternatives to VOC-Emitting Lubricants, Vanishing 

Oils, and Rust Inhibitors.” The term VOC (Volatile 

Organic Compounds) may be used interchangeably 

with ROC (Reactive Organic Compounds). 

Scientifically, ROC is a more accurate term since the 

organic emissions must be both reactive and volatile 

to form ozone under atmospheric photochemistry. 

This 2006 technology assessment first determined the 

feasibility of replacing high-ROC lubricants with lowROC counterparts. 

The 2006 Technology Assessment included case 

studies involving thirteen different facilities to 

determine the applicability of switching from highROC lubricants to similar performing low-ROC 

fluids. The initial testing examined one to five 

alternatives, and if a potential alternative performed 

well, more extensive or scaled-up testing for a period 

of one week to three months. Lastly, IRTA analyzed

the cost and the performance of the alternatives 

including any additional processes that may be 

required such as cleaning or blasting. An important 

point to remember when evaluating the 2006 

technology assessment is that alternatives were 

limited to those products available at the time and did 

not include recent reformulations. 

Case Studies- Vanishing Oils 

Vanishing oils are designed to provide lubrication for 

numerous metal forming operations, including 

drawing, forming, punching, and perforating. In 

addition, these oils evaporate from the work piece,

which explains the origin of the name of this 

category. Depending on the additives in the base 

compound, the residue on the part may be dry to the

touch, oily, sticky, or nonexistent. This residue 
 Staff Report Page 3

provides in-process rust protection without the need 

for additional application. 

The application method is very important to this 

operation. If too little lubricant is applied, the fluid 

may fail to evaporate before the machining is 

completed, which causes galling or tool wear. On the 

other hand, if too much is applied, the fluid may fail 

to evaporate, which can leave the parts wet when they 

are packed or arrive at the next operation. Vanishing 

oils are a separate category from Metal Protective 

Fluids, which includes rust inhibitors that are usually 

applied after the part is formed and prevents rust 

formation during storage or shipping. 

Vanishing oils consist mainly of mineral spirit type 

solvents, which are high-ROC emitters. The 

proposed rule ROC content limits will restrict the use 

of vanishing oils, and machine shops will be required 

to switch to other types of lubricants and/or processes 

that duplicate the function of these oils. The 2006 

IRTA study examined the replacement of vanishing 

oils at four machine shops in the South Coast, 

including Nelson Nameplate (stamping and cutting), 

Fred Rippy (stamping), Winders & LeBlanc 

(forming), and B & B Specialties (cutting). The 

results of these case studies for vanishing oil 

replacement are summarized in Table 1. The type of

lubricant fluid used to replace the vanishing oil is 

shown in the table along with the cost-effectiveness of 

the fluid replacement. 

Table 1 Case Studies –Vanishing Oil 

Facility Name Compliant 

Fluid 

CostEffectiveness 

B&B 

Specialties 

VegetableBased $0.52/lb of 

ROC reduced 

Fred Rippy Water-Soluble 90% Savings 

Nelson 

Nameplate 

VegetableBased 70% Savings 

Winders Water-Soluble 70% Savings 

Case Studies- Cutting Oil Lubricants 

Cutting fluids are used as lubricants in cutting, 

grinding, turning, and machining of metals. In such 

operations, the friction is very high because of close 

contact between the work piece and the tool, which 

generates a large amount of local heat. This high heat 

may overheat the tool, and it may lower its temper 

and hardness. Lubricants are used as cutting fluids to 

cool the tools to reduce wear and maintain hardness. 

The cooling is also needed to prevent distortion of the 

metal work piece. Proper lubrication also reduces 

power consumption and improves the surface finish 

of the part. 

The 2006 IRTA study also evaluated a number of 

machining, metal removal, and metal forming 

operations to determine the cost impacts of replacing 

the light petroleum oils with vegetable-based ester

synthetic oils. As shown in Table 2, the cost ranged 

from a 70% cost savings to a cost-effectiveness of 

$0.90 per pound of ROC reduced. Thus, the cost is 

highly dependent on the type of machining process. 

Table 2 Case Studies – Cutting/Honing Oil 

Facility Name Compliant 

Fluid 

CostEffectiveness 

Fortner 

Engineering 

VegetableBased $0.90/lb of 

ROC reduced 

Hydro-Aire VegetableBased 48% Savings 

Nelson 

Nameplate 

VegetableBased 70% Savings 

S & H 

Machine 

VegetableBased 11% Savings 

Weldcraft VegetableBased $0.06/lb. of 

ROC reduced 

Vegetable-based lubricants may be applied to a wide

range of metalworking operations including metal 

removal, metal forming, and metal protecting. As a

proven and test technology since the 1960s, vegetable 

oils have been recognized for their superior 

lubricating properties compared to mineral oils. Until 

the last decade, vegetable oils were used as straight 

oil applications. 

More recently, water-miscible vegetable oil 

emulsions as cutting fluids were made possible with

additives including a new generation of emulsifiers

and stability agents. Use of these vegetable 

emulsions has resulted in significantly improved 

productions rates of 20 to 30 percent, and a 50 

percent or better increase in the tool life. In one 

example, vegetable oil-based coolant while drilling

automotive gears resulted in a threefold increase in 

tool life. Another application in tapping steel parts 

for another automotive application resulted in a 15

fold increase in tool life. 

Case Studies- Rust Inhibitors 

Rust preventive products are designed to protect 

metal parts from rust and corrosion throughout the 

stages of manufacturing, assembly, storage, and 

shipping. Rust preventive products can be applied by 

dip, brush, roller, spray, or flood method. These 

products may be designed for both indoor and 

outdoor storage requirements. 
Staff Report Page 4

The 2006 IRTA study evaluated a number of different

operations using rust (corrosion) inhibitors. At that 

time, the available complying products were waterbased or vegetable –based products, such as Soy 

Gold. The case studies were performed at the 

following companies: Dynaflex Products, Deltronic,

Tracy Industries, and Robinson Helicopter Company. 

The summaries of these case studies showed mostly 

cost savings except the one case study at Dynaflex 

Products had a cost-effectiveness of $0.24 per pound 

of ROC reduced. A table of these case studies has 

not been included because newer reformulated 

products have been introduced since that time, which 

make those comparisons out-of-date. 

Since 2006, major manufacturers such as Chem 

Arrrow Corporation have developed newer 

petroleum-based rust preventive products that 

displace the water or coolant on the part and comply 

with 50 g/l ROC super compliant status. These 

products remove slight dirt and offer the ability to dry 

parts quickly to be handled within a short period of 

time. These products provide excellent water 

displacement, pleasant odor, non-staining, and are 

designed for both indoor and outdoor storage. 

Emission Source Inventory and 

ROC Emission Reductions 

The vast majority of sources estimated up to 300 

facilities (mostly machine shops) are unpermitted by 

the District. There are just four district-permitted 

facilities that would be subject to proposed Rule 

74.31 as shown in Table 3. 

Table 3 Permitted Metalworking Facilities 

Facility Name Process ROC 

tons/yr 

Advanced 

Structural Alloy 

Forging 0.29 

Aluminum 

Precision 

Forging 

Press 

0.56 

Arcturus Forging 0.47 

Western Saw Quench Oil 1.47 

TOTAL 2.79 

All four permitted facilities and their devices are in 

the APCD point source emission inventory as sources

of particulate matter emissions. In the future, ROC 

emissions from this source category will be included 

in the inventory. Both Arcturus and Advanced 

Structural Alloys have forge operations using 

emulsion type lubricants that already comply with the 

proposed ROC limit of 75 grams per liter. 

Although there is no accurate accounting of 

metalworking fluids and direct-contact lubricants 

emission sources in Ventura County, it is possible to 

estimate the potential number of sources and their 

emissions using South Coast AQMD’s Final Staff 

Report for Proposed Amended Rule 1144. Proposed 

district Rule 74.31 is closely modeled on SCAQMD 

Rule 1144 and the ROC limits for all metalworking 

fluid categories in the South Coast became effective 

as of January 1, 2012. 

The SCAQMD Rule 1144 Staff Report contains an 

estimate of the baseline metalworking fluids 

emissions inventory subject to Rule 1144 and 

emission reductions expected from the rule. The 

baseline metalworking fluid emission inventory was 

based on a SCAQMD 2006 survey of local 

manufacturers, distributors and end-users of 

metalworking fluids and direct-contact lubricants. 

Baseline emissions were calculated for individual 

metalworking fluid types in SCAQMD Rule 1144 

Staff Report Table III using volume of fluid used 

(thousand gallons) and sales-weighted average ROC 

content (g/L). Baseline emissions = 5.29 tons/day 

ROC in 2006, and overall ROC emissions reductions 

for Rule 1144 are 3.57 tons/day, amounting to 67% 

control efficiency. No ROC emission reductions are

anticipated from some Rule 1144 fluid categories 

such as direct-contact lubricants and some naphthenic 

metalworking fluids having sales-weighted average 

ROC content less than the rule ROC content. 

According to the SCAQMD Rule 1144 Staff Report, 

about 7,200 facilities in the South Coast, 

predominantly small businesses classified under 

NAICS Code 332 (fabricated metal product 

manufacturing), Code 333 (machinery 

manufacturing), Code 336 (transportation equipment 

manufacturing) and Code 324 (petroleum and coal 

products manufacturing) use metalworking and 

direct-contact fluids in the South Coast air basin. 

Fluids used for applications subject to the 

requirements of SCAQMD Rule 1124, Aerospace 

Assembly and Component Manufacturing Operations, 

are excluded. There is a similar exclusion in 

proposed Rule 74.31 for these sources subject to 

requirements in District Rule 74.13, Aerospace 

Assembly and Component Manufacturing Operations. 

Assuming the 2006 baseline emissions in SCAQMD 

Rule 1144 Staff Report Table III represent South 

Coast air basin sources, we can estimate the number

of sources and ROC emissions in Ventura County, 

based on the relative number of businesses and 

employment between the South Coast air basin and 

Ventura County using U.S. Census Bureau County 

Business Patterns data. There were 273 

metalworking fluid businesses in Ventura County in 

2010 according to County Business Patterns data. 
Staff Report Page 5

2010 ROC emissions from metalworking fluids in 

South Coast can be estimated using the 2006 baseline 

emissions = 5.29 tons/day in table III and assuming a 

25% decrease in activity based on the decrease in 

employment between 2006 and 2010. The SCAQMD 

Staff Report showed sales of naphthenic 

metalworking fluids representing about 39% of total

metalworking fluid volume in table V had declined by 

30-40% since the 2006 survey according to industry 

stakeholders. 

2010 South Coast metalworking fluids ROC 

emissions = 5.29 tons/day * (1 – 0.25) = 3.97 

tons/day. 

2010 ROC emissions from metalworking fluids in 

Ventura County can be estimated using the 2010 

employment ratio between Ventura County and South 

Coast. The estimated ROC emission reduction 

calculated below does not include any correction for 

less than 100 percent rule effectiveness. Since 95

percent of affected sources will be unpermitted, rule 

compliance will depend on the sales prohibition, 

which is typically a less than 100 percent enforcement 

mechanism. 

Ventura County metalworking fluids ROC 

emission inventory = 3.97 tons/day * 0.0524 

= 0.21 tons/day (= ~ 76 tons/year). 

PROPOSED RULE 74.31 REQUIREMENTS and PROPOSED AMENDMENTS TO RULE 23 

Applicability (Section A) 

Operations subject to this rule range from large 

forging operations to small machine shop operators. 

No small source exemption is being proposed 

because there are a large number of unpermitted 

operations that accounts for 95 percent of the 

emission reductions. Rather than requiring new 

APCD permits for these small operators, the 

proposed rule enforcement mechanism is a Sales 

Prohibition that will regulate the sale of noncompliant 

fluids by the manufacturers and suppliers. Thus, this 

rule applies to the manufacturers and suppliers as 

well as to the users of this material. 

The proposed rule applies to all types of 

metalworking fluids used for metal removal, metal 

forming, and metal treating. In addition both directcontact lubricants and corrosion inhibitors are subject 

to the ROC content limits in the rule. However, 

proposed Rule 74.31 does not apply to existing 

operations regulated by requirements of other District 

rules including Rule 74.13, Aerospace Assembly and 

Component Manufacturing Operations. For example, 

Rule 74.13 has an ROC content limit for solid film 

lubricant for fastener manufacturing of 250 gram per 

liter. Because this operation is already subject to a 

Rule 74.13 requirement, it would not be subject to 

proposed new Rule 74.31. Also, solvent cleaners are 

not subject to this rule because they are already 

regulated by VCAPCD Rule 74.6, Solvent Cleaning. 

Proposed ROC Content Limits(Section B.1) 

The proposed rule will reduce ROC emissions from 

the use of metalworking fluids, including lubricants, 

coolants, and corrosion inhibitors used for metal 

forming, metal removal, metal treating, or metal 

protecting. The proposed ROC content limits are 

summarized by fluid category in Table 4. Each of 

fluid categories is defined in the rule to clarify the 

applicability of each limit, and the proposed limits 

duplicated those adopted by SCAQMD Rule 1144. 

Table 4 Proposed ROC Content Limits for Metalworking Fluids 

Fluid Category ROC Content Limit –grams/liter (lbs/gal) 

Vanishing Oil 50 (0.42) 

Metal Working Fluid: 

 Metal Forming 75 (0.63) 

 Metal Removal (General) 75 (0.63) 

 Precision Metal Removal 130 (1.08) 

 Metal Treating 75 (0.63) 

 Metal Protecting (General) 50 (0.42) 

 Military Specified Preservative 340 (2.83) 

Direct Contact Lubricant 50 (0.42) 
Staff Report Page 6

Prohibition of Sale (Section B.3) 

The proposed sales prohibition is based on a similar 

requirement in South Coast AQMD Rule 1144, and 

the industry association (ILMA) supports this 

concept. As explained earlier, a prohibition to sell, 

offer for sale or supply noncomplying lubricants 

(which exceed Table 4 ROC Content limits), is 

needed to enforce the requirements where 95 percent

of the emission sources are unpermitted. 

An important point to remember when determining 

compliance with this provision is that the ROC 

content of the fluid for water reducible material is 

adjusted for the minimum recommended dilution 

ratio, as shown on product labels or data sheets. Thus 

this compliance determination is based on the 

recommended usage rather than the package ROC 

content for these emulsions. 

Another issue concerns the sale of noncomplying 

products by independent distributors. Manufacturers 

or suppliers may not be liable if noncomplying 

products are sold provided they have notified the 

independent distributor in writing that the product

may not be sold in the district because it would 

violate the rule sales prohibition. 

The proposed sales prohibition does not apply to any 

metalworking fluid that is controlled by an ROC 

emission control system. Since this rule development 

is based on sources using product substitution instead 

of add-on control equipment as the control measure,

it is not anticipated that this exemption will be 

employed. It is important to remember that 

particulate matter control devices may not qualify for 

this exemption. 

Depletion of User Inventory (Section B.2) 

Although staff is not proposing a sell through 

provision for manufacturers or suppliers, users may

deplete their inventory of lubricants purchased prior 

to the effective date of the ROC content limit for up 

to one year after that date. Purchase records, sales 

invoices or bills of sale may be used to verify 

eligibility for this provision. The purpose of this 

provision is to allow users to deplete existing stocks 

to avoid unnecessary hazardous waste generation. 

Control Equipment (Section B.4) 

As an alternative to meeting the ROC content limits

for a metalworking fluid, the operator may elect to

install an ROC emission control system. This system 

must be able to capture at least 90 percent of the ROC 

emissions generated by the device, and the control 

system must reduce the ROC emission by 95 percent, 

by weight, or the output of the control device is no 

more than 5 ppm ROC by volume, calculated as 

carbon with no dilution. If an operator elects to 

install this emission control system, then a written 

Authority to Construct and Permit to Operate from 

the Air Pollution Control Officer is required. 

Administrative Requirements (Section B.5) 

The recordkeeping requirements are needed to assist

both the machine shop operators and APCD 

compliance staff to determine the compliance status

of the metalworking fluids being used. The 

recordkeeping consists of two parts. First, the 

operator must maintain an inventory compliance list, 

which lists all of the applicable metalworking fluids 

used at the shop, the corresponding ROC content of 

each fluid, and the ROC content category and ROC 

limit for that category. The purpose of this list is to 

verify the compliance status of each of the fluids 

used. 

The second part of this administrative requirement is 

to maintain monthly purchase records of each of the

metalworking fluids used. No separate usage logs are 

required that must be dated and signed as is required 

by SCAQMD Rule 1144. Instead monthly purchase 

records may be used for complying with this 

provision as long as the following information is 

printed on the record: Manufacturer name, product 

name, product number or ID code, and quantity 

purchased. VOC information (VOC and ROC may 

be used interchangeably) is not required on the 

purchase record. The monthly purchase records may 

be used to verify the comprehensiveness of the 

inventory compliance list. All records must be 

maintained for a minimum of two years, and shall be

made available to District personnel upon request. 

An exemption from the recordkeeping requirement in 

Subsection C.5 is being proposed for those 

metalworking fluids that are super compliant (less 

than 50 g/l ROC). For most of the fluid categories, 

super compliant fluids are readily available. So if a 

small machine shop uses only super-compliant 

materials, then neither a permit nor recordkeeping is 

required. However, if a machine shop uses both 

super-compliant and higher ROC materials, then the 

recordkeeping requirements still apply to the higher 

ROC content metalworking fluids. 
Staff Report Page 7

Container VOC Labeling (Section B.7) 

This requirement to have the VOC content displayed 

on metalworking fluid containers facilitates both the 

rule compliance by affected industry and enforcement 

by APCD inspectors. According to metalworking 

fluid manufacturers, the industry has already 

complied with this provision based on a similar 

requirement in the South Coast AQMD Rule 1144. 

Exemptions (Section C) 

Subsection C.1 exempts Air Resources Board (ARB) 

regulated consumer products (Title 17 CFR, Section 

94507) from both the sales prohibition and the 

administrative requirements. According to ARB 

consumer products regulation, if a product such as a 

lubricant is sold directly to the user from the supplier 

and is labeled “For use in manufacturing only,” then 

it is not a consumer product subject to ARB 

regulations. 

Subsection C.2 exempts hand-held pressurized 

aerosol lubricants that are subject to ARB consumer

regulations from the ROC content limits in Rule 

74.31, provided 100 can or fewer per calendar year 

are used based on purchase records. This exemption

is not currently in the South Coast AQMD Rule 1144. 

The limit of 100 cans per year is being proposed to

encourage sources to switch to low-ROC products 

which can actually result in a cost savings. Robinson 

Helicopters from Torrance, California, was using 414 

aerosol cans per year of an aerosol lubricant. 

Other exemptions from rule ROC content limits are 

proposed for the purpose of maintaining or repairing 

operator-owned machine tools (Subsection C.2.c) and

research operations (Subsection C.2.d). 

Both the sales prohibition and the ROC content limits 

are proposed to be exempt from the following 

machining operations: 

• Lapping 

• Sinker EDM (Wire EDM using water 

based dielectric fluids are still subject to 

rule requirements) 

• Avionics, assembled aircraft, or any 

assembled aircraft components 

• Space vehicle components 

• Fluids utilizing the ROC emission control 

systems 

These exemptions were determined by the South 

Coast AQMD Rule 1144 to be necessary because 

complying replacement lubricants did not provide 

adequate performance or the machines were not 

amenable to replacement lubricants. 

Test Methods (Section D) 

Choosing an adequate test method for determining 

ROC content of lubricants, which are semi-volatile 

materials, was a challenging task. Both the South 

Coast AQMD and ILMA (industry association) had 

many meetings and performed round robin testing 

over a period of years to define an accurate and 

repeatable for test method for these materials. The 

normal EPA test method for coatings, solvents, and 

adhesives is Method 24, which involves heating a 

sample for one hour at 110oC. However, this test 

method was unable to provide repeatable 

measurements for these semi-volatile materials. 

As a result of all of the work in the South Coast 

district, ASTM E 1868-10, Standard Test Method for 

Loss-On-Drying by Thermogravimetry, was adopted 

in SCAQMD Rule 1144 as the reference method for 

determining ROC content compliance. This method 

was able to produce very repeatable ROC content 

readings for a variety of lubricants. It is similar to 

Method 24 in that heat is applied and samples are 

weighed to determine evaporative losses. It is more 

precise because the testing parameters are more well 

defined using a programmed heater that heats the 

sample to 81oC for 110 minutes. This test method 

was found to be simple, repeatable, efficient, and 

cost-effective. 

Permit Exemptions (Rule 23, Section B.4) 

The proposed amendments to Rule 23, Exemptions 

from Permit, will exempt equipment using 

metalworking fluids that are Super Compliant (50 

grams ROC per liter of material or less) from APCD 

permit requirements. This proposed exemption will

not apply to metal forging operations. Although 

APCD permits are usually required for point sources

subject to rule requirements to insure compliance, 

staff is proposing the sales prohibition as an alternate 

compliance mechanism. This will reduce the 

regulatory burden and eliminate potential permitting 

costs for the metalworking industry that until now has 

not been regulated as an ROC emission source. 

In addition, the following equipment using any 

metalworking fluid is exempt from permit 

requirements regardless of the ROC content of the 

fluid being used: 

• Lapping 

• Sinker Electrical Discharge Machining (EDM) 

• Carbide grinding machine tools where the 

machine tool manufacturer specifies the viscosity 

of the fluid 

• Machining of aluminum or magnesium in single 

or multiple spindle automatic machines. 
Staff Report Page 8

Since both lapping and Sinker EDM operations are 

exempt from the ROC content requirements, APCD 

permits are not needed as an enforcement mechanism. 

In the case of carbide grinding machine tools and 

machining of aluminum or magnesium, the proposed 

sale prohibition will be used to enforce rule 

compliance for these operations. Since these 

operations are not currently required to have APCD 

permits, this proposed exemption will not change 

their current status. 

COMPARISON OF PROPOSED RULE REQUIREMENTS 

 WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS 

Health and Safety Code Section 40727.2 requires 

Districts to compare the requirements of a proposed

revised rule with other air pollution control 

requirements. These other air pollution control 

requirements include federal New Source 

Performance Standards (NSPS), federal National 

Emissions Standards for Hazardous Air Pollutants 

(NESHAPS), Best Available Control Technology 

(BACT), and any other District rule that applies to

the same equipment. In addition, Section 183(e) of

the Clean Air Act authorized EPA to regulate VOC 

emissions from consumer and commercial products 

via a national rule or a Control Techniques Guideline 

(CTG). At this time, EPA has not adopted a national 

rule or a CTG to reduce VOC emissions from 

metalworking fluids. A review of current BACT 

determinations from the South Coast AQMD and 

California Air Resources Board indicates that BACT 

for this source category has not been defined for any 

VOC emissions. Instead BACT for particulate matter

emissions from metalworking operations have been 

published, but this is not relevant to this rule 

adoption. 

IMPACT OF THE PROPOSED RULE 

ROC Emissions Impacts 

The estimated ROC emission reductions of 41 tons 

per year from this source category are significant, and 

all emission reductions are needed to reach the 

federal and state ambient ozone air quality standards. 

The availability, feasibility, and cost-effectiveness of 

the replacement low-ROC metalworking fluids 

including lubricants, and corrosion inhibitors make

this proposal worthwhile. 

Cost-Effectiveness 

According to the IRTA technology assessment case 

studies as summarized in Tables 1 and 2, the cost 

ranged from a cost savings of 90 percent to a costeffectiveness of $0.90 per pound of ROC reduced. 

Another source of cost information was the 

SCAQMD Rule 1144 Staff Report, which showed 

costs ranging from a cost savings to $0.40 per pound 

of ROC reduced. This indicates that the proposal is 

very cost-effective especially relative to new sources, 

which may be required under New Source Review to 

spend up to $9 per pound of ROC reduced to install 

best available control technologies (BACT). 

An important point is that the main cost of 

compliance has already been spent by the fluid 

manufacturers including reformulation and testing 

costs in order to comply with South Coast AQMD 

Rule 1144. In most cases, end users will experience a 

cost savings or marginal costs to comply with 

proposed Rule 74.31. 

Incremental Cost-Effectiveness Analysis 

Health and Safety Code Section 40920.6(a) requires 

districts to identify one or more potential control

options, assess the cost-effectiveness of those options, 

and calculate the incremental cost-effectiveness. 

Health and Safety Code Section 40920.6 also requires 

an assessment of the incremental cost-effectiveness

for proposed regulations relative to ozone, carbon 

monoxide (CO), sulfur oxides (SOx), nitrogen oxides

(NOx), and their precursors. 

Incremental cost-effectiveness is defined as the 

difference in control costs divided by the difference 

in emission reductions between two potential control 

options achieving the same emission reduction goal 

of a regulation. The proposed adoption of Rule 74.31 

will require the most stringent viable ROC limits and 

no other viable control option can achieve the same

amount of emission reductions. Therefore, the 

incremental cost-effectiveness analysis does not apply 

to this rulemaking. 

Socio-Economic Impacts 

Assembly Bill 2061 (Polanco), which became 

effective January 1, 1992, requires that the District 

Board consider the socioeconomic impacts of any 
Staff Report Page 9

new rule. The Board must evaluate the following 

socioeconomic information on proposed new Rule 

74.31. 

(1) The type of industries or businesses, including

small business, affected by the rule or 

regulation. 

 The adoption of amendments to these rules may 

directly affect the four permitted operations in 

the county (see Table 3). Processes affected by 

the rule include metal forming, metal machining, 

and metal treating operations. All machine 

shops, regardless of size, will be affected. Staff

estimates that approximately 300 machine shops 

in the county may be impacted. 

(2) The impact of the rule amendments on 

employment and the economy of the region. 

 Revisions to these rules are not expected to have 

a negative impact on either employment or the 

economy of Ventura County. According to the 

cost analysis of the proposed revisions, some 

companies may benefit from reduced material 

costs, which should help economic growth. 

Worst-case cost estimates for the end user are 

not significant enough to impact employment. 

Use of environmentally-friendly lubricants will 

also provide for a cleaner work environment, 

which should positively impact job 

performance. 

(3) The range of probable costs, including costs to

industry or business, including small business, 

of the rule or regulation. 

 Cost reductions were noted for several case 

studies from the 2006 technology assessment. 

Based on the SCAQMD staff report, a 

maximum cost-effectiveness of $0.40 per pound 

of ROC reduced may be expected for 

replacement of high-ROC lubricants and 

corrosion inhibitors with low-ROC counterparts. 

(4) The availability and cost-effectiveness of 

alternatives to the rule or regulation being 

proposed or amended. 

 The proposed new rule is the most cost-effective 

control option, which involves metalworking 

fluid replacement. An alternative to require 

add-on control equipment is a much more costly 

approach. 

 (5) The emission reduction potential of the rule or 

regulation. 

 The anticipated emission reduction potential of 

the proposed rule is about 41 tons per year of 

ROC emissions. These emission reductions 

result from the use of low-ROC metalworking 

fluids and corrosion inhibitors. 

(6) The necessity of adopting, amending, or 

repealing the rule or regulation in order to attain

state and federal ambient air standards pursuant 

to Chapter 10 (commencing with Section 

40910). 

 Ventura County is classified as a serious 

nonattainment area for the federal Ambient Air 

Quality Standards for ozone. These proposed 

rule amendments will reduce ROC emissions 

that are precursors to the formation of ozone. 

According to the 2007 AQMP, these emission 

reductions will help the District in its effort to 

attain the standards. California Health and 

Safety Code Section 40914(b)(2) requires that 

the District adopt every feasible measure to 

reduce ozone precursors. 

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE 

California Public Resources Code Section 21159 requires the District to perform an environmental analysis of the 

reasonably foreseeable methods of compliance. The analysis must include the following information on proposed 

new Rule 74.31: 

(1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance. 

(2) An analysis of the reasonably foreseeable mitigation measures. 

(3) An analysis of the reasonably foreseeable alternative means of compliance with the rule or regulation. 

Table 5 lists all reasonably foreseeable compliance methods, the environmental impacts of those methods, and 

measures that could be used to mitigate the environmental impacts. 
Staff Report Page 10

Table 5 

Environmental Impacts and Mitigations of Methods of Compliance 

Compliance Methods (including all 

reasonably foreseeable alternative 

means of compliance) 

Reasonably Foreseeable 

Environmental Impacts 

Reasonably Foreseeable 

Mitigation Measures 

Reformulation of metalworking fluids

 

Air Quality Impacts: Reformulation 

may result in the use of toxic 

materials. 

Operators may use reformulated 

products with less or no toxic 

materials. 

 Water Impacts: Improper disposal of 

fluids may cause water impacts 

Compliance with wastewater 

discharge standards and waste 

disposal requirements will 

mitigate these impacts. 

 Human Health and Safety Impacts: 

Metalworking fluids may be replaced 

with products containing more toxic 

or more flammable compounds. 

Compliance with OSHA safety 

guidelines (e.g., personal 

protective equipment, prevention 

and response, emergency first aid 

procedures) reduces these 

impacts. 

This analysis demonstrates that the adoption of new Rule 74.31will not have a significant effect on the environment 

due to unusual circumstances. 

REFERENCES 

1. Acculube Lubricants and Metalworking Fluids, 

Dayton, Ohio. (Distributor). 

2. American Research Products, Palos Verdes 

Estates, CA. Syn-Tec Synthetic Metalworking 

Fluids and Protectsol Rust Inhibitors. 

3. Ballard, Alan, “Metalworking Fluid ROC 

Emission Inventory in Ventura County,” 

January 25, 2013. 

4. Burke, John, Michael Pearce, Bob Blithe, and 

John Howell, “A New Method for the 

Determination of VOCs in Metalworking Fluids, 

Vanishing Oils, and Rust Inhibitors.” 

5. Burke, John, and Alan Cross, “Advantages & 

Disadvantages of Low-VOC Vegetable-Based 

Metalworking Fluid,” South Coast AQMD 

Symposium: Metalworking Fluid VOCs Today 

and Tomorrow. March 8, 2012. 

6. Canale, Lauralice C.F.,Ester Carvalho de Souza, 

and George Totten, “Quenchants Derived from 

Vegetable Oils as Alternatives to Petroleum 

Oil,” Industrial Heating. August 31, 2011. 

7. Cassel, Bruce R., “Determining Volatiles in 

Polyethylene Terephthalate using the Q5000 IR 

Thermographic Analyzer,” T.A. Instruments. 

8. Castro Industrial – Lubricants and 

Metalworking Fluids, Naperville, IL. 

9. Chem Arrow Corp –Lubricants and 

Metalworking Fluids, Irwindale, CA. 

10. Cimcool Fluid Technology, Cincinnati, OH. 

11. W.S. Dodge Oil, Metalworking Fluids and 

Lubricants, Maywood, CA. 

12. The Dow Chemical Company: Ucon Fluids, 

Lubricants, and Quenchants, Midland, MI. 

13. Frederick, Paul, “The Practical Application of 

Non-chlorinated Ultra Low VOC Metalworking 

Fluids Using Renewable Resource Based 

Technology,” South Coast AQMD Symposium: 

Metalworking Fluid VOCs Today and 

Tomorrow. March 8, 2012. 

14. Fretz, Mark, “Rule 1144 Customer Impacts,” 

South Coast AQMD Symposium: Metalworking 

Fluid VOCs Today and Tomorrow. March 8, 

2012. 
Staff Report Page 11

15. Housel, Tyler, “VOC Assessment of Synthetic 

Ester Fluids,” South Coast AQMD Symposium: 

Metalworking Fluid VOCs Today and 

Tomorrow. March 8, 2012. 

16 IHS Global, Industrial Oils and Fluids. 

17. Independent Lubricant Manufacturers 

Association: Letter to SCAQMD dated Feb 23, 

2012, Re: Rule 1144 – Metalworking Fluids 

and Direct Contact Lubricants. 

18. Ineman, Jennifer, “Regulations Drive New 

Advancements in Rust Preventives: Aqueous 

Low VOC Rust Preventive Solutions.” South 

Coast AQMD Symposium: Metalworking Fluid 

VOCs Today and Tomorrow. March 8, 2012. 

19. Lowery, Steve, “The Next Generation of VOCFree Vanishing Lubricants,” 

www.thefabricator.com. 

20. Krahenbuhl, Ulrich, “Cutting Fluids: VegetableOil-Based Coolants Improve Cutting 

Performance,” Blaser Swisslube Inc, Goshen, 

NY. 

21. Mackenzie, D.S., L. Gunsalus, and I. Lazerov, 

“Effects of Contamination on Quench Oil 

Cooling Rates,” Houghton International. 

22. NIOSH Manual of Analytical Methods, 4Th

Edition, Metalworking Fluids – All Categories. 

Method 5524, March 15, 2003. 

23. Pearce, Paul, “Reformulating to Comply with 

Rule 1144,” South Coast AQMD Symposium: 

Metalworking Fluid VOCs Today and 

Tomorrow. March 8, 2012. 

24. South Coast AQMD Staff Report: Proposed 

Rule 1144, Vanishing Oils and Rust Inhibitors, 

March 2009. 

25. South Coast AQMD Staff Report: Proposed 

Rule 1144, Metalworking Fluids and Direct 

Contact Lubricants, May 2010. 

26. Shenoy, Srikar, “Eco-Friendly Hot Forging 

Lubricant ESPON-GLF7 Used on 1000 Ton 

Hot Forging Press,” YouTube (video). 

27. Timely Solutions, “An Unexpected &Timely 

Solution: Murphy’s Oil Soap,” South Coast 

AQMD Symposium: Metalworking Fluid VOCs 

Today and Tomorrow. March 8, 2012. 

28. Uyen T. Vo, “VOC Content Test Methodology: 

Past, Present, and Future,” South Coast AQMD 

Symposium: Metalworking Fluid VOCs Today 

and Tomorrow. March 8, 2012. 

29. Wolf, Katy, Mike Morris, and Jan Zavdil, 

“Assessment, Development, and Demonstration 

of Alternatives to VOC Emitting Lubricants, 

Vanishing Oils, and Rust Inhibitors” IRTA. 

August 2006. 

DISCLAIMER 

This report contains references to company and product names to illustrate product availability. Mention of these 

names is not to be considered an endorsement by the Ventura County Air Pollution Control District.