SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Final Staff Report for 

PROPOSED RULE 1144 – VANISHING OILS AND RUST INHIBITORS 

Dated: March 2009 

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 

VOC Rule Development 

Larry M. Bowen, P.E. 

Author: Mike Morris AQ Specialist 

Reviewed by: Naveen Berry Planning and Rules Manager 

 Linda Vogel Senior Deputy District Counsel 

 

Contributors Heather Farr AQ Specialist 

 John McLaughlin Senior AQ Chemist 

 Joan Niertit Principal AQ Chemist 

 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: WILLIAM A. BURKE, Ed.D. 

Speaker of the Assembly Appointee 

Vice Chairman: S. ROY WILSON, Ed.D. 

Supervisor, Fourth District 

Riverside County Representative 

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

MICHAEL CACCIOTTI 

Councilmember, City of South Pasadena 

Cities Representative, Los Angeles County, Eastern Region 

BILL CAMPBELL 

Supervisor, Third District 

Orange County Representative 

JANE W. CARNEY 

Senate Rules Committee Appointee 

RONALD O. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

JOSEPH LYOU, Ph.D. 

Governor’s Appointee 

JOSIE GONZALES 

Supervisor, Fifth District 

San Bernardino County Representative 

JAN PERRY 

Councilmember, 9th District 

City of Los Angeles 

MIGUEL PULIDO 

Mayor, City of Santa Ana 

Cities Representative, Orange County 

TONIA REYES URANGA 

Councilmember, City of Long Beach 

Cities Representative, Los Angeles County, Eastern Region 

DENNIS YATES 

Mayor, City of Chino 

Cities Representative, San Bernardino 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 13 

Cost and Cost-Effectiveness 15 

Incremental Cost-Effectiveness 17 

Comments and Responses 19 

Comparative Analysis 37 

Socioeconomic Assessment 37 

California Environmental Quality Act (CEQA) 38 

Draft Findings under the California Health and Safety Code 38 

References 38 

APPENDIX A – Vanishing Oil and Rust Inhibitor VOC Content Test Results 
Final Staff Report ________________________________

Proposed Rule 1144 1 March 2009

EXECUTIVE SUMMARY

Proposed Rule 1144 is designed to reduce VOC emissions from the use of vanishing oils and rust 

inhibitors used at industrial facilities during the manufacturing and assembly process of parts and 

products. 

Vanishing oils and rust inhibitors are categorized under miscellaneous solvent operations. A 

vanishing oil is a direct-contact lubricant or metal working fluid that comes into direct contact 

with the product or part during manufacturing or assembly to reduce heat and friction, prolong 

the life of tools and machinery, improve product quality or carry away debris. A rust inhibitor 

prevents or protects metal surfaces from corrosion. 

Most vanishing oils and rust inhibitors are currently subject to Rule 442 - Usage of Solvents, 

which addresses VOC emissions from VOC-containing materials that are not subject to VOC 

limits in any Regulation XI rule. A small subset of aerospace fastener lubricative coatings are 

subject to Rule 1124 – Aerospace Assembly and Component Manufacturing Operations. 

Although the California Air Resources Board (CARB) regulates consumer lubricants, currently, 

no other local, state or federal regulations or emissions restrictions specifically pertaining to 

industrial vanishing oils or rust inhibitors. 

The proposed rule will apply to VOC emissions from steel tube and spring manufacturers, steel 

mills, aerospace manufacturers, automobile part manufacturers and rebuilders and machine shops 

including broaching, drilling, drawing, forming, forging, grinding, heading, honing, milling, 

stamping, tapping, thread cutting and turning operations. 

Staff proposes the following requirements for Proposed Rule 1144: 

• Establish a VOC limit of 50 grams per liter (g/l) of material for vanishing oils and a VOC 

limit of 300 g/l of material for rust inhibitors effective January 1, 2010, with a further 

reduction to 50 g/l effective January 1, 2012. 

• Prohibit the sale of non-compliant vanishing oils and rust inhibitors. Exceptions are made 

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

Code of Regulations, beginning at Section 94507. 

• Allow vanishing oils and rust inhibitors manufactured prior to the appropriate effective date 

to be sold or applied for six months. 

• Require containers for vanishing oils and rust inhibitors to display the date of manufacture. 

• Exempt certain applications, including lapping, sinker electrical discharge machining (EDM), 

high profile aircraft corrosion inhibitors and aerosol aerospace rust inhibitors where 

alternative low-VOC formulations are not available. Exempt rust inhibitors subject to a 

military specification, military standard or Product Part Approval Process (PPAP) as well as 

consumer products from VOC limits until January 1, 2011. 

If approved, the proposed rule amendments will partially fully implements control measure CTS01 in the 2007 Air Quality Management Plan. The resolutions to the rule will include a 

technology review to be completed by July September1, 2009 to resolve technical issues with the 

VOC content test method, evaluate potential screening tools for high water content samples, and 

develop VOC limits for other direct-contact lubricants and metal working fluids besides 

vanishing oils. 
Final Staff Report ________________________________

Proposed Rule 1144 2 March 2009

As proposed, the rule will reduce emissions by 2.71 tons per day with an estimated annualized 

cost of $8.1 million dollars. The overall cost-effectiveness of the proposed rule is conservatively 

estimated to be $8,189 per ton of VOC emissions reduced. 

BACKGROUND

Nationally, some 1.2 million workers are employed in machine finishing, machine tooling, and 

other metalworking and metal-forming operations that use lubricants, metal working fluids or 

rust inhibitors. In its Fabricated Metal Sector Notebook (1995), EPA estimates 10.2 percent of 

the fabricated metal industry are located in California. According to listings in the California 

Manufacturers Register, the South Coast Air Basin accounts for approximately 70 percent of the 

industry in California. In 2008, there are more than 12,000 machine shops in the 4 county area 

serviced by AQMD. Of these machine shops, the U.S. Census (2002) estimates that 88 percent 

have fewer than twenty employees. Typical industries using lubricants, metal working fluids and 

rust inhibitors include: 

• Aerospace 

• Machine Shop (Job Shop) 

• Steel Mills 

• Auto Rebuild 

• Screw Machine 

• Steel Tubes (Pipes) 

• Steel Springs 

• Captive 

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

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

Metal working shops tend to be small businesses that generally do not use paints, coating, inks or 

adhesives, routinely use very low VOC content cleaning solvents, and have limited interaction 

with the AQMD. Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation 

II, exempts machining equipment that use lubricants, metal working fluids and rust inhibitors 

with VOC contents less than 50 grams per liter (g/l) or a VOC composite partial pressure of 20 

mm Hg. Nearly all lubricants, metal working fluids and rust inhibitors, including those with a 

high-VOC content, have a VOC composite of 5 mm Hg or less. Thus metal working shops 

rarely have permits with the District. Typical operations include: 

• Broaching – Gear manufacturing utilizing keyway, slots or spline. 

• Drilling – Producing cylindrical holes 

• 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. 

• Forming – Spinning metal until a desired thickness is achieved. 

• 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. 

• Grinding – Producing a fine finish using an abrasive wheel or belt. 
Final Staff Report ________________________________

Proposed Rule 1144 3 March 2009

• Heading – A metal forging process that 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. 

• Honing – Manufacturing of precision bores to improve the geometry, surface finish and 

dimensional control of the finished part. 

• Milling – Cutting using 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. 

• Rust Preventative/Inhibitor – Preventing corrosion on ferrous materials and some 

nonferrous materials 

• Stamping – Punching sheet metal strips using a press tool which is loaded on a press to 

form the sheet into a desired shape. 

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

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

• Turning – Producing cylindrical parts 

• 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). 

Lubricants, metal working fluids and rust inhibitors are complex mixtures of oils, emulsifiers, 

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

biocides, and other additives. 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 petroleum oils) to water-based fluids, which 

include 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 petroleum or vegetable oils. Straight oils are not 

designed to be diluted with water. 

• Soluble oil (emulsifiable 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 preparation for potential rule making activity, the AQMD and U.S. EPA Region IX cosponsored 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. Completed in 

2006, the report, 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 metal working 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. 
Final Staff Report ________________________________

Proposed Rule 1144 4 March 2009

PROPOSED RULE

Staff proposes the following requirements for PR 1144: 

Purpose and Applicability

The purpose of the proposed rule is to reduce VOC emissions from vanishing oils and rust 

inhibitors used at industrial facilities during manufacturing operations where the fluids come in 

direct content with the parts and products. Such operations will include metal working or metal 

removal activities during the manufacturing and assembly of products and goods. Examples of 

these activities include, but are not limited to, broaching, drilling, drawing, forging, grinding, 

heading, honing, milling, stamping, tapping, thread cutting, turning and wire drawing. Fluids 

used for rust and corrosion prevention and inhibition during manufacturing and assembly of 

products and goods are also included. 

Initially, the focus will be to limit solvent emissions from vanishing oils and solvent-based rust 

inhibitors. Vanishing oils are defined as lubricants or metal working fluids with a flash point 

less than 200 °F (93°C). In the near future, VOC limits will be established for direct-contact 

lubricants and metal working fluids. The proposed rule is not intended to regulate the use of 

vanishing oils or rust inhibitors for commercial, institutional or household use. Repair and 

maintenance activities are also not subject to the rule unless the parts on which the fluids are 

applied are resold. For example, parts taken from machinery or vehicles that are repaired using 

fluids and then placed back into the same machinery or vehicles are not covered by the rule. 

Likewise, general maintenance and rust inhibition of buildings, vehicles or equipment are not 

subject to the rule. Examples include motor oil, elevator grease, and care and maintenance of 

door hinges. Finally, vanishing oils that do not directly come into contact with parts and 

products during manufacturing, such as turbine oil, enclosed spindle oil and hydraulic fluids are 

not subject to the rule. 

Operations and substances already subject to VOC limits in Regulation XI will not be subject to 

the limits, labeling requirements and prohibition of sales proposed in this rule. Such substances 

include solid film lubricants, dry lubricative materials and barrier coatings subject to Rule 1124. 

Paints and coatings 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 

where applicable VOC limits are 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. 

 

A prohibition of sale is included in the rule. Thus, the proposed rule also applies to anyone who 

manufactures for use, supplies, solicits, sells or offers for sale vanishing oils and rust inhibitors 

subject to the rule. Consumer products subject to the CARB consumer products regulation found 

in Title 17 of the California Code of Regulations, beginning at Section 94507, are also exempted 

from the prohibition of sale. As noted above, the use of vanishing oils and rust inhibitors in 

households and general maintenance of buildings, vehicles or equipment is also not subject to 

this rule. But, consumer product vanishing oils and rust inhibitors used during manufacture and 

assembly of products and goods are subject to this regulation, effective January 1, 2011; facilities 

using such products must meet the applicable VOC content limits. 
Final Staff Report ________________________________

Proposed Rule 1144 5 March 2009

Requirements

The proposed rule will establish a VOC limit of 50 g/l of material for vanishing oils and a VOC 

limit of 300 g/l of material for rust inhibitors effective January 1, 2010, with a further reduction 

to 50 g/l effective January 1, 2012. The VOC content limits apply to the fluids as they are used, 

including dilution. Water or exempt solvents are included when calculating material volume. 

Thus, a rust inhibitor concentrate with a VOC content of 75 g/l that is diluted with water at a 

ratio of two parts water to one part lubricant concentrate (2:1) would have a VOC content of 25 

g/l. Many soluble, semi-synthetic and synthetic fluids are heavily diluted with water when used. 

Typical dilution ratios range from five parts water to one part concentrate to 40 or more parts 

water to one part concentrate. Evaporation and contamination during use will cause the VOC 

content to fluctuate. Manufacturers and suppliers believe the fluctuation could be as high as 30 

percent. This could cause fluids with 25 g/l VOC content to increase to nearly 35 g/l VOC 

content without regular monitoring. Monitoring the fluid beyond what is necessary to facilitate 

proper operating parameters will increase labor costs. 

 

An estimated 89 percent of lubricants and metal working fluids have a VOC content of 200 g/l of 

material or less after dilution. The soluble, semi-synthetic and synthetic metal working fluids 

have low VOC because of the high water content of those fluids. However, many straight oils 

have low VOC because they are essentially non-volatile. 

 

Low-VOC alternatives to vanishing oils are available, and in most cases exclusively used for 

broaching, drilling, drawing, forging, heading, honing, milling, tapping, threading, turning and 

wire drawing. Most cutting and grinding applications also use low-VOC products as well as 

nearly all coolants and lubricants. 

Light Oils

Light oils with viscosities lower than 20 centistokes at 40°C, but flashpoints greater than 200°F,

are used as viscosity additives, lubricants for older high speed spindle machines and as metal 

working fluids for other applications. Newer spindle machines use heavily water-diluted 

products and are designed to be resistant to water corrosion while older machines are not. 

Based on discussions with industry, and recognizing the use of light, high flash point oils as 

metal working fluids, VOC limits will be established after technical issues regarding the test 

method have been resolved. 

Vanishing Oils

Vanishing oils are designed to evaporate off quickly leaving no residue. They are typically 

comprised primarily of solvent such as kerosene or mineral spirits and commonly are just the 

neat solvent themselves. Conventional vanishing oils have VOC contents ranging from 600 g/l 

to 750 g/l with flash points below 200°F. Vanishing oils leave a light coating of lubricant on the 

part during processing and then evaporate shortly thereafter. They need to provide enough 

lubricity to prevent machinery and parts from seizing, but they provide very little protection to 

tooling. They are used because they evaporate and later cleaning operations are unnecessary. 

Vanishing oils should not leave behind tacky or gummy residues. Because parts on which 

vanishing oils are applied are not cleaned afterwards, the vanishing oil must not encourage 

corrosion and may even provide some small amount of corrosion protection. 

Alternatives to high solvent content vanishing oils include water-dilutable metal working fluids 

and straight oils. Water-dilutable metal working fluids used in a vanishing oil applications have 

sufficient rust preventative compounds to protect parts when the water evaporates. They provide 
Final Staff Report ________________________________

Proposed Rule 1144 6 March 2009

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. 

Use of a high flash point oil as a vanishing oil alternative could also provide acceptable results in 

certain situations. There would be little if any evaporation, but the residue would not be tacky or 

gummy and corrosion protection would be excellent. Cleaning would be required, however, and 

would increase to some extent, facility’s processing cost. Therefore, with consideration for the 

numerous compliant alternatives available, the proposed limits for vanishing oils have an 

implementation date of January 1, 2010. 

Rust Inhibitors

The rule will limit rust inhibitors, including rust preventatives and corrosion inhibitors, to a VOC 

content of 300 g/l or material by January 1, 2010, with further reductions to 50 g/l of material in 

2012. Some facilities use rust inhibitors that are nearly identical in composition and VOC 

content to vanishing oils. Metal parts are coated, usually by dipping or application by rag, with a 

formulation of solvent such as mineral spirits or kerosene that may also contain small amounts of 

heavier oils and/or wax. The solvent evaporates away, leaving behind a small amount of heavier 

oil, wax or trace amounts of the solvent that coats the metal surface with a water repellent or 

protective layer. The heavier oils and wax provide much more protection than does the 

evaporated solvent. 

Water-based rust inhibitors have very low VOC content after dilution and are formulated to leave 

behind a nearly invisible protective coating after the water evaporates. The protective coating is 

soluble in water but still protects steel, cast iron, and other ferrous parts from in-plant corrosion 

and outdoor shipping environments. An added benefit of the coating is that it can be easily 

removed using mild aqueous cleaners if required. Water-based rust inhibitors are comparable in 

price to the solvent-based rust inhibitors. 

Alternative high flash point straight oil rust inhibitors coat a metal surface with an oil that rejects 

water. Over a long time the oil may thicken into a nearly solid protective coating. These 

products provide excellent long-term protection and while they have a higher cost per gallon, 

they are superior in quality to most high VOC products. Straight oil rust inhibitors may contain 

small amounts of solvents, and the VOC content of such products tested ranges from less than 25 

g/l to 253 g/l. Laboratory testing results of rust inhibitors, using EPA Test Method 24, is 

summarized in Table I. 

Table I – VOC Content of Rust Inhibitors 

 Cleaner/Rust Inhibitor 121 – 765 g/l 

 Consumer/General 530 g/l 

 Rust Inhibitor 12 -420 g/l 

 Rust Inhibitor/Stamping 295* - 380 g/l 

*Before dilution 
Final Staff Report ________________________________

Proposed Rule 1144 7 March 2009

A use and sell-through provision has been included in this rule that will allow products 

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

the effective date. This will allow manufacturers, suppliers and users to deplete their existing 

inventories. To facilitate this provision, manufacturers and suppliers will be required to display 

the date or a date code of manufacture on the container beginning January 2010. 

Sale in the AQMD of vanishing oils and rust inhibitors, is prohibited unless they meet the VOC 

limits of this rule. The prohibition will not apply to products sold in this District for shipment 

outside of this District or for shipment to other manufacturers for repackaging. It will also not 

apply to fluids subject to CARB consumer products regulation, as set forth in Title 17 of the 

California Code of Regulations, beginning at Section 94507. These provisions will help to 

redirect some of the burden of determining the compliance status of products from the machine 

shops and other users to the manufacturers and suppliers who are more familiar with VOC 

determination. 

The prohibition of sale will apply to manufacturers and suppliers who manufacture for use, sell, 

offer for sale or distribute directly. Manufacturers that sell products through independent 

distributors may be able to discharge liability under this provision, provided they forewarned the 

independent distributors in writing about the compliance status of the product. However, 

independent distributors will be subject to the prohibition of sale. 

A provision has been included that allows a facility, if it so chooses, to use high-VOC vanishing 

oils and rust inhibitors where the emissions are vented to a control device that has a capture 

efficiency of 90 percent or more on a mass basis and a control efficiency of 95 percent or more 

on a mass basis, or to a maximum 5 ppm VOC by volume from the exhaust. While it is very 

unlikely that any facility will install a control device just to meet the proposed rule, some 

facilities already have control devices that control emissions from work areas that contain 

vanishing oils or rust inhibitors. In those instances, the emissions are already being reduced and 

further restrictions are unnecessary. 

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. Rule 109 – Recordkeeping for Volatile 

Organic Compound Emissions requires stationary sources using VOC containing materials to 

keep records to determine rule applicability and rule compliance. Records are usually required 

on a daily basis, but for most of the product categories the material VOC content of products in 

use are below 50 g/l. Products with VOC contents, after applicable dilution, of less than 50 g/l 

are “Super Compliant Materials” and qualify for exemption from recordkeeping at facilities that 

do not exceed four tons of VOC emissions in any calendar year, determined by annual 

recordkeeping. Facilities that emit more than four tons of VOC annually may qualify for the 

monthly recordkeeping option. 

Test Methods and Procedures 

While there is no formal regulatory requirement to use a particular test method for determining 

VOC content of lubricants, metal working fluids or rust inhibitors, the default method used is 

U.S. EPA Reference Method 24 (Method 24). Method 24 was originally designed to determine 

the VOC content of coatings and inks only. Since there is no other U.S. EPA approved test 
Final Staff Report ________________________________

Proposed Rule 1144 8 March 2009

method for determining VOC content of vanishing oils and rust inhibitors, Method 24 will be 

included as the approved test method. 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. Duplicates samples are run to validate the results. However, 

Method 24 does provide accurate and repeatable results for relatively high VOC content solventbased materials. Until technical issues regarding other test methods have been resolved, it will 

be used to determine VOC content. 

Future Alternative VOC Content Test Methods

An alternative method is SCAQMD Method 313 – Determination of Volatile Organic 

Compounds (VOC) by Gas Chromatograph/Mass Spectrometry (GC/MS), originally approved 

for use in 1991. The principle of this U.S. EPA-approved method is to inject a liquid sample into 

GC/MS and sum the concentrations of the individual compounds. The oven is initially at 50°C 

and kept there for five minutes. It is ramped up 15°C per minute until the sample reaches 200°C, 

then held at 200°C for fifteen minutes. The total specified sampling period is 30 minutes, and 

previous testing has indicated that methyl palmitate elutes at the 30 minute mark. All 

compounds, besides water and exempt solvents, that elute prior to methyl palmitate are 

considered to be VOC. 

In November 2008, the District revised the test method to SCAQMD Method 313L – 

Determination of VOC Hydrocarbon Compounds in Lubricants, primarily to accommodate 

equipment changes. The column type (DB624) and length of column (30 meters) have changed, 

thereby changing the times when various peaks appear. However, the order of the peaks remains 

unchanged and methyl palmitate will continue to be used as the marker compound defining 

volatility. The temperature in the GC oven will continue to be raised after the methyl palmitate 

peak is reached until the entire sample elutes. Only peaks that occur at or before the methyl 

palmitate peak are considered when determining VOC content by quantifying the peaks using a 

Flame Ionization Detector (FID). By specifying the column type and length, the flow and 

temperature may be varied without altering the VOC content results as long as the methyl 

palmitate marker compound is identified. This would be useful when trying to further resolve 

peaks especially when water or exempt compounds are present. The revised protocol is referred 

to as a GC/FID method. Method 313L has been used extensively for low-VOC solvents and 

consumer products certified by the AQMD in its Clean Air Solvent and Clean Air Choices 

Cleaner certification programs. The results from the certification program have shown the 

method to be reliable and accurate for both high water content and heavy, high flash point oil 

products. However, independent and industry laboratories are not familiar with this method and 

have requested round-robin testing, particularly with respect to high flash point heavy oils used 

as direct-contact lubricants and metal working fluids. VOC limits for those categories will be 

established after technical issues have been resolved. 

Industry has suggested thermogravimetric analysis (TGA) testing as an alternative method to 

determine VOC content. TGA determines changes in weight relative to time and temperature. It 

has been suggested that it would provide more repeatable results for heavy, high flash point oils. 

However, issues such as determining the parameters of the test (time and temperature) and high 

water content samples have not been resolved. The District will continue to review TGA testing 

as a possible alternative test method to Method 24. 
Final Staff Report ________________________________

Proposed Rule 1144 9 March 2009

The District has committed to conduct round robin testing of Method 313L and TGA. This will 

provide sufficient time to establish the validity of an alternative test method to Method 24. It 

will also determine the parameters to be used for TGA testing. During the round robin testing, if 

appropriate, a screening tool will be developed to minimize testing costs for high water content 

samples that would have negligible VOC. Many of the high water content samples are 

emulsions of high flash point oils and surfactants. As noted above, the VOC content of the high 

flash point oils are unresolved and, once resolved, will have an impact on what screening value 

to designate. It is also possible that Method 313L will be validated for high water content 

samples making a screening tool unnecessary. This commitment has been included in the 

Resolutions to be adopted with the proposed rule. 

Test methods to determine flash point and the capture and control efficiency of a control device 

are also included. 

Exemptions

Some highly specialized applications have been exempted from the proposed regulation. 

Lapping and sinker EDM are small usage applications (less than 0.01 and 0.03 tons per day of 

VOC emissions, respectively) where alternative low-VOC formulations have not been identified. 

Rust inhibitors and vanishing oils used on assembled aircraft and avionics will also be exempted. 

These fluids provide protection for flight instruments and major aircraft structures including 

upper edge floor beams, wheel wells, pressure decks and center wing sections. VOC emissions 

from these specifically exempted aerospace operations are less than 0.002 ton per day. Finally, 

small very specialized operations conducted on space vehicles components, where fluids may 

adsorb into coatings and adhesives and then off-gas when the spacecraft reaches outer space, will 

also be exempted. 

An exemption that expires January 1, 2011 has been included for rust inhibitors used in 

association with military specifications, military standards, Department of Defense documents or 

Production Part Approval Processes. Based on feedback from industry, especially end-users, 

additional time is necessary to conduct replacement trials, determine customer acceptability and 

to make changes to military specifications and/or PPAP specifications. 

Exemptions for consumer products to the rule’s labeling requirements and sales prohibition are 

included in the proposed rule. These products are already subject to Title 17 of the California 

Code of Regulations, beginning at Section 94507, also known as the California Consumer 

Product Regulation. The California Consumer Product Regulation includes statewide labeling 

requirements and a sales prohibition for consumer products, and the proposed rule will not add 

further requirements. The use of these products during the manufacture and assembly of 

products and parts, will also be exempted until January 1, 2011. Afterwards, consumer products 

used during manufacturing and assembly must meet the same VOC limits as industrial products. 

Regulation of VOC content at stationary sources falls squarely within the long-established 

authority of air districts. There is no reason to encourage their use, with corresponding higher 

VOC content, by providing a blanket exempt status. From a survey done of local machine shops, 

there will be a one year delay in approximately 0.007 tons per day of VOC emissions. 

Vanishing oils and rust inhibitors used in a controlled environment, where emissions are 

captured by a control device, are not subject to the VOC limits nor are they subject to the rule’s 

prohibition of sales provision. Pursuant to subparagraph (i)(5)(E), manufacturers and suppliers

of high-VOC vanishing oils and rust inhibitors should positively identify facilities that will be
Final Staff Report ________________________________

Proposed Rule 1144 10 March 2009

using their products in a controlled environment before selling otherwise non-compliant 

products. Likewise, vanishing oils and rust inhibitors manufactured or sold for use outside the 

District will not be subject to the labeling requirements of the proposed rule. The intent of the 

proposed rule is to regulate only the products being manufactured or sold for use inside the 

District. 

Finally, vanishing oils and rust inhibitors already subject to VOC limits in Regulation XI will not 

be subject to the limits, labeling requirements and prohibition of sales proposed in this rule. 

These will include solid film lubricants, dry lubricative materials and barrier coatings subject to 

Rule 1124. Paints and coatings intended to completely cure and leave a solid, permanent film to 

beautify and protect metal surfaces are also exempt. Paints and coatings are subject to other 

coating rules in Regulation XI. 

EMISSION INVENTORY

The overall national inventory of metal working fluids was taken from the International 

Lubricant Manufacturers Association (2003). It indicates that 117 million gallons were sold 

nationwide (see Table II). 

Table II – National Sales 

Lubricant and 

Metalworking 

Fluid Type 

Amount Sold 

(millions of 

gallons/year) 

Straight 27.3 

Soluble 49.3 

Semi-Synthetic 21.7 

Synthetic 18.9 

Total 117.2 

EPA, in its Fabricated Metal Sector Notebook (1995), estimates 10.2 percent of the fabricated 

metal industry is located in California. 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 industrial lubricants and metal working fluids were 

sold in the Basin in 2006 (see Table III). 

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

Lubricants and 

Metal Working 

Fluid 

Amount Sold 

Nationwide 

(millions of 

gallons/year) 

Amount Sold 

in California 

(millions of 

gallons/year) 

Amount Sold in 

South Coast 

(thousands of 

gallons/year) 

Straight 27.3 2.8 2,000 

Soluble 49.3 5.0 3,500 

Semi-Synthetic 21.7 2.2 1,500 

Synthetic 18.9 1.9 1,300 

Total 117.2 11.9 8,300 
Final Staff Report ________________________________

Proposed Rule 1144 11 March 2009

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

fluid manufacturers, suppliers and users. The survey data indicated that those local 

manufacturers and suppliers annually sold 4.2 million gallons of industrial lubricants, metal 

working fluids, rust inhibitors, vanishing oils and solvent in the Basin (see Table IV). 

Presumably, the solvents are used as vanishing oils, rust preventatives, for thinning other metal 

working fluids or cleaning. 

Table IV – Volume Surveyed 

Fluid Type 

Volume Surveyed 

(thousand gallons) 

Lubricants and Metal 

Working Fluids 2,564.6 

Light Oil 48.9 

100 SUS Naphthenic Oil 1,119.2 

Vanishing Oil 64.1 

Rust Inhibitors 155.7 

Solvent 238.0 

Total 4,190.5 

Approximately 30 percent or 71,000 gallons of the 238,000 gallons of solvents reported in the 

survey are used for cleaning applications subject to Rule 1124 and cannot be included in the 

VOC emission inventory for this rule making activity. 

Table V – Applicable Volume 

Fluid Type 

Applicable Volume 

Surveyed 

(thousand gallons) 

General MWF and Lubricants 2,564.6 

Light Oil 48.9 

100 SUS Naphthenic Oil 1,119.2 

Vanishing Oil 64.1 

Rust Inhibitors 155.7 

Solvent 167.0 

Total 4,119.5 

Of the 4.2 million gallons, only 11 percent of the sales were high-VOC light oils, vanishing oils, 

rust preventatives and solvents. However, an additional 27 percent are petroleum-based metal 

working fluids with relatively low VOC contents but in significant enough volumes to warrant 

future consideration. 

A serious drawback from the survey and national sales data was the lack of VOC information on 

the lubricants and metal working fluids. More than eighty percent of the volume surveyed listed 

the VOC content as “None” or not determined. Therefore, the AQMD sampled a broad range of 

products from local manufacturers and suppliers and performed VOC testing to establish a more 

accurate emissions inventory. The sample results for vanishing oils and rust inhibitors, using 

Method 24, are presented below in Table VI. 

Table VI – Test Results Using EPA Method 24 

Type VOC Content # of Samples 

Rust Preventatives 
Final Staff Report ________________________________

Proposed Rule 1144 12 March 2009

Cleaner/Rust Preventative <25 – 760 g/l 2 

Consumer/General 514 g/l 1 

Rust Preventative <10 – 560 g/l 4 

Rust Preventative/Stamping 51* - 125 g/l 2 

Vanishing 650 - 750 g/l 3 

*Before dilution 

Using the sales weighted average from the survey information and the EPA Test Method 24 

sample test results, the emission inventory for vanishing oils, rust inhibitors and solvent was 

determined. Vanishing oils reported in the survey had a sales weighted average VOC content of 

710 g/l. Solvent-based rust inhibitors had sales weighted average VOC content of 660 g/l. 

Using this methodology, the VOC emission inventory of vanishing oils, rust inhibitors and 

solvent is estimated to be 6.81 tons per day and is summarized in Table X. 

Table VII – Surveyed Emission Inventory 

MWF Type 

Volume Surveyed 

(thousand gallons) 

Sales Weighted 

Average VOC 

Content (g/l) 

Total VOC 

Emission (tons 

per day) 

General MWF and Lubes 2,564.6 TBD TBD 

Light Oil 48.9 TBD TBD 

100 SUS Naphthenic Oil 1,119.2 TBD TBD 

Vanishing Oil 64.1 710 0.52 

Rust Inhibitors 155.7 660 1.17 

Solvent 167.0 790 1.50 

Total 4,119.5 N/A 3.19 

TBD = data not available at this time

The AQMD survey correlated well with the ratio of lubricants to metal working fluids compared 

to national sales data. National sales data indicates 67 percent of applicable sales are industrial 

lubricant and 33 percent are metal working fluids. The survey data shows 63 percent of 

applicable fluids are industrial lubricants and 37 percent are metal working fluids. It appears that 

the survey of local manufacturers and suppliers conducted by the AQMD captured just over half 

of the metal working fluid sales predicted by the national sales figures. The survey data could be 

extended to regional and national manufacturers and suppliers if necessary. Extrapolating from 

national sales figures, the overall VOC emission inventory can be as high as 136.3 tons per day 

as seen in Table VIII. 

Table VIII – Emission Inventory from National Sales 

MWF Type 

Volume Projected 

(thousand gallons) 

Sales 

Weighted 

Average VOC 

Content (g/l) 

Total VOC Emission 

(tons per day) 

General MWF 

and Lubricants 5,081.1 TBD TBD 

Light Oil 96.8 TBD TBD 

100 SUS 

Naphthenic Oil 2,217.4 TBD TBD 

Vanishing Oil 127 710 1.03 
Final Staff Report ________________________________

Proposed Rule 1144 13 March 2009

Rust Inhibitors 308.4 660 2.32 

Solvent 330.8 790 2.98 

Total 8,161.8 N/A 6.33 

TBD = data not available at this time

EMISSION REDUCTIONS

The proposed rule will establish a VOC content limit of 50 g/l for vanishing oils effective 

January 1, 2010. Rust inhibitors will initially be limited to 300 g/l effective January 1, 2010, 

with further reductions to 50 g/l will be required in 2012. Exemptions are included for aerospace 

avionic and assembled aircraft rust inhibitors, military specification or PPAP rust inhibitors, and 

other small volume uses. 

For the majority of the total volume of direct-contact lubricants, metal working fluids and rust 

inhibitors, the proposed limits will have no impact. However, the rule will produce substantial 

VOC emission reductions from vanishing oils, rust inhibitors, and solvents used to dilute 

lubricants or metal working fluids or used directly as vanishing oils or rust inhibitors. The 

solvent usage is distributed over high flash point light oils, vanishing oils and rust inhibitors in 

the same ratio as the sales volume (20 percent, 23 percent and 57 percent respectively). 

Implementation dates, based on extensive discussions and feedback from end-users and 

suppliers, have been adjusted to focus on reductions in VOCs from solvents over the first few 

years. Future amendments to the rule, adopted after the VOC content test method technical 

issues for high flash point oils have been resolved, will address emissions from direct-contact 

lubricants and metal working fluids. This approach addresses many technical concerns 

expressed by industry and provides additional time for further analysis of the VOC test method 

results. 

Approximately ten percent of the volume (15,600 gallons) of rust inhibitors sold is used for 

specified operations such as military specification, military standards or PPAP according to the 

Independent Lubricant Manufacturers Association (ILMA). Those uses will be exempt until 

2011 and emission reductions (0.06 tons per day) from those uses will be realized in 2011. 

Limiting the VOC content of rust inhibitors, excluding specified rust inhibitors, and solvents 

used in rust inhibitors to 300 g/l will reduce VOC emissions by 1.93 tons per day by 2010 (2.00 

tons per day by 2011). Table IX, below, summarizes the emission reductions 

Table IX – Emission Reductions Realized in 2010 

(Vanishing Oils and Rust Inhibitors) 

Fluid Type 

Volume 

Surveyed 

(thousand 

gallons) 

Sales 

Weighted 

Ave 

VOC 

Content 

(g/l)** 

Proposed 

VOC 

Content 

(g/l) 

Percent 

Reduction

Total VOC 

Emission 

Inventory 

(tons per day) 

Total 

VOC 

Emission 

Reduction 

(tons per 

day) 

Rust Inhibitors 140.1 660 300 55% 1.06 0.58 
Final Staff Report ________________________________

Proposed Rule 1144 14 March 2009

Solvent (Rust 

Inhibitors) 95.2 790 300 62% 0.86 0.53 

Specified Rust 

Inhibitors 15.6 660 300 55% 0.12 0.06* 

Vanishing Oil 64.1 710 50 93% 0.52 0.50 

Solvent 

(Vanishing Oil) 38.4 790 50 94% 0.35 0.33 

Total 386.8 3.21 2.00 

* Realized January 1, 2011 

** Based on EPA Method 24 

Finally, in 2012, the limits for rust inhibitors will be lowered to 50 g/l. This will further reduce 

VOC emission from rust inhibitor operations by another 0.71 ton per day (see Table X). 

Table X – Emission Reductions Realized in 2012 

(Rust Inhibitors) 

Fluid Type 

Volume 

Surveyed 

(thousand 

gallons) 

Sales 

Weighted 

Ave 

VOC 

Content 

(g/l) 

Proposed 

VOC 

Content 

(g/l) 

Percent 

Reduction

Total VOC 

Emission 

Inventory 

(tons per day) 

Total 

VOC 

Emission 

Reduction 

(tons per 

day) 

Rust Inhibitors 155.7 300 50 83% 0.53 0.44 

Solvent (Rust 

Inhibitors) 95.2 300 50 83% 0.33 0.27 

Total 250.9 0.86 0.71 

At full implementation, PR 1144 will achieve 2.71 tons per day of VOC reductions based on 

survey results only. Projecting from the AQMD survey data to national sales figures, the 

potential emission reductions would nearly double to 4.96 tons of VOC emissions reduced, as 

summarized in Table XI below. 

Table XI – Emission Reductions from National Sales 

MWF Type 

Volume 

Projected 

(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) 

Vanishing Oil 127 710 50 94% 1.03 0.97 

Rust Inhibitors 308 660 50 93% 2.32 2.16 

Solvent 331 790 50 90% 2.99 1.83 

Total 8,166 14.00 4.96 

Multiple low-VOC commercially available products have been identified in numerous 

applications. In many applications, the only products in use are low-VOC products already in 

compliance with the proposed limits. Cold heading, drawing, honing, forging, milling 

machining and metal removal fluids as well as coolants and industrial lubricants were all found 
Final Staff Report ________________________________

Proposed Rule 1144 15 March 2009

to have low-VOC content products in widespread use. For applications where high VOC 

products were identified, aqueous-, bio- and petroleum-based technologies were identified and 

demonstrated in field testing. Those alternatives were analyzed and found to have VOC contents 

that would meet the proposed limits. 

The transition to low-VOC content vanishing oil alternatives and rust inhibitors is not expected 

to increase criteria pollutants or global warming gases. The substitution of one type of fluid with 

another will not have an impact on criteria pollutants other than VOC. The increased use of 

control equipment is considered very unlikely, and therefore not expected to be a source of 

increased pollutants. There may be some negligible decrease in global warming gases from 

shipping concentrates instead of ready-to-use products because concentrates weigh less, reducing 

fuel consumption during transit. 

COST AND COST-EFFECTIVENESS

The use of low-VOC alternatives to vanishing oils and rust inhibitors is expected to increase 

costs for machinery, including skimmers, decanters, mixers, sump cleaners and possibly cleaning 

equipment. In addition, there would be an overall increase in the cost of fluids. On an individual 

facility basis, the costs may be significant, insignificant or even a cost savings. 

 

For alternatives to vanishing oils, companies would ideally use a water soluble fluid that would 

not require cleaning. The soluble lubricants are heavily diluted with water and would likely cost 

less than a vanishing oil potentially resulting in a cost savings. They would have rust 

preventative compounds to prevent corrosion and evaporate leaving behind a light, corrosion 

protective film. 

However, the worst case scenario for shops using vanishing oils would be to use a product that 

would require subsequent cleaning. The shops would need to purchase cleaning equipment, 

automated handling equipment, cleaning chemistry, and pay for added electricity. 

For a typical shop using 240 gallons of vanishing oil annually, the shop would face an estimated 

annualized capital cost of $11,000, $2,900 in cleaning chemistry and disposal costs and $3,800 in 

increased electrical costs. The lubricant cost would decrease by $1,300 annually. The total 

maximum annual cost per typical facility would be $15,10016,400. 

Table XII – Maximum Increased Cost per Vanishing Oil Facility 

Annual Cost 

Capital (annualized) 

Cleaning Equipment $6,100

Automated Handling $4,900

Cleaning Chemistry $1,900

Disposal $1,000

Electricity $3,800

Lubricant <$1,300>

Total $16,400

Using the most conservative assumption for all vanishing oil usage (64,100 gallons), the 

maximum overall annual cost would be $4.4 million. 
Final Staff Report ________________________________

Proposed Rule 1144 16 March 2009

Total Volume of Vanishing Oil Typical facility usage Number of Facilities 

64,100 gallons 240 gallons 267 

Number of Facilities Cost per facility Total Annual Cost 

267 $16,400 $4.4 million 

The conversion from high VOC rust inhibitors to low VOC rust inhibitors would only involve 

changes in chemical formulae. The equipment (tanks) would remain the same and there would 

be no added electrical costs. Alternative formulae have a higher cost, but since many of the rust 

inhibitors are diluted with water, the cost would be much more comparable to the high VOC rust 

inhibitors. 

Again, the worst case scenario is evaluated and it is assumed that non-dilutable rust inhibitors are 

used. The cost of mineral spirits used as a rust inhibitor is approximately $3.60 per gallon. The 

alternative bio-based rust inhibitor sells for $8.30 per gallon, a $4.70 increase per gallon. The 

alternative rust inhibitor would be used in the same volume as the mineral spirits. The cost 

increase over 155,700 thousand gallons would be $0.7 million dollars annually. 

Total Volume of Rust Inhibitor Increased cost per gallon Total Annual Cost 

155,700 gallons $4.70 $0.7 million 

Solvent can be used as a vanishing oil, rust inhibitor or diluent for light oils. When determining 

costs, the solvent usage is distributed over high flash point oils, vanishing oils and rust inhibitors 

in the same ratio as the sales volume (20 percent, 23 percent and 57 percent respectively). Thus 

33,400 are attributed towards high flash point oils, 38,400 gallons are attributed towards 

vanishing oil, and 95,200 gallons of solvent are used as rust inhibitors. The same worst-case 

methodology is used for vanishing oil and rust inhibitors to determine the cost of replacing the 

solvent. The total cost for solvent replacement would be $2.9 million. 

Total Volume of Solvent 

Used as Vanishing Oil Typical facility usage Number of Facilities 

38,400 gallons 240 gallons 160 

Number of Facilities Cost per facility Total Annual Cost 

160 $15,100 $2.4 million 

 Likewise, 

Total Volume of Solvent 

Used as Rust Inhibitor Increased cost per gallon Total Annual Cost 

95,200 gallons $4.70 $0.4 million 

Some shops may be required to do additional record keeping demonstrating that their annual 

emissions remain below four tons. Four tons of emissions from vanishing oils and rust inhibitors 

at 50 g/l (0.4 pounds per gallon) would be equivalent to over 19,000 gallons used per year. Of 

115 machine shops surveyed, fewer than eight percent used vanishing oils and rust inhibitors in 

sufficient quantities to remotely approach the four ton annual limit. Of the more than 12,000 

affected facilities, an estimated 2,000 would require a more thorough review of annual records. 

From discussions and experience with facilities conducting record keeping, it is estimated that 
Final Staff Report ________________________________

Proposed Rule 1144 17 March 2009

the process of gathering the year’s purchase records would require about eight hours of labor per 

facility. At $20 per hour, the annual increase in record keeping costs would be $20/hour * 8 

hours/facility * 2,000 facilities = $0.1 million. Shops that use rust inhibitors with higher than 50 

g/l VOC content would be required to track additions to their fluid systems. There are an 

estimated 600 facilities that would need to track high VOC rust inhibitor usage. These systems 

are usually changed monthly or less frequently. At $20 per hour, the annual increase in record 

keeping costs for those shops would be $20/hour * 12 hours/facility * 600 facilities = $0.1 

million. The remaining facilities would require a negligible effort to demonstrate that their 

annual usage was below the four ton annual limit. The total annual increase in cost due to record 

keeping would be $0.2 million. 

Manufacturers and suppliers will also be required to determine the VOC content of their products 

and to label containers with the date of manufacture or date code. Manufacturers and suppliers 

offer several dozen rust inhibitors each. Many of those are similar with slight variations on the 

additives incorporated in the product. Manufacturers and suppliers 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 500 applicable rust inhibitors and every product would be laboratory tested at $350, 

there would be a one time cost of $0.2 million. Annualized over ten years, the additional annual 

cost to manufacturers and suppliers would be negligible. Most containers use computerized 

labels that can be altered by simple reprogramming. The cost to alter those labels is also 

considered negligible. 

As proposed, the rule will reduce emissions by 2.71 tons per day with an estimated cost of $8.1 

million dollars. The maximum overall cost-effectiveness of the proposed amendment will be 

$8,189 per ton of VOC emissions reduced on a conservative basis. However, studies conducted 

on the use of compliant rust inhibitors and vanishing oils actually showed an overall reduction in 

costs, yielding a cost savings to the facility. 

Table XIII – Maximum Cost-Effectiveness 

MWF Type 

Volume 

Surveyed 

(thousand 

gallons) 

Total VOC 

Emission 

Inventory 

(tons per day) 

Total VOC 

Emission 

Reduction 

(tons per day) 

Maximum 

Cost 

(millions) 

General MWF 3,683.8 1.05 0 $0.0 

Vanishing Oil 64.1 0.52 0.5 $4.4 

Rust Inhibitors 155.7 1.17 1.08 $0.7 

Solvent 167 1.50 1.41 $2.8 

Record keeping N/A N/A N/A $0.2 

Laboratory 

Testing N/A N/A N/A negligible 

Total 4,119.50 4.73 3.44 $8.1 

INCREMENTAL COST-EFFECTIVENESS

Health and Safety Code Section 40920.6 requires the AQMD to perform an incremental cost 

analysis when adopting a Best Available Retrofit Control Technology (BARCT) rule or feasible 
Final Staff Report ________________________________

Proposed Rule 1144 18 March 2009

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.” 

Proposed 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. 

Several alternative options were evaluated including three more stringent standards and one less 

stringent standard. The first alternative examined was to require all lubricants, metal working 

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 

established limits for all direct-contact lubricants, metal working fluids and rust inhibitors, and 

required testing and product labeling. This would add additional costs for recordkeeping and 

testing. Another alternative examined would have allowed vanishing oils and rust preventatives 

to meet a final VOC content limit of 200 g/l. This would have allowed some affected operations 

to dilute fluids with lower cost high flash point oils. However, they would have been required to 

maintain daily records, and vanishing oil operations would have continued to require a cleaning 

process. Finally, the installation and use of control devices to limit VOC content in lieu of a 

VOC content limit was analyzed. While no process changes would have been necessary, there 

would have been considerable costs from the installation of the control devices. Because the 

control device option was unlike the other alternatives, it was compared to the least stringent 

(200 g/l) option. 

The incremental cost analysis shows that lowering the limit to 25 g/l would have increased costs 

by $4.3 million over the proposed limit and only net another 62 tons per year (0.78 tons per day) 

of VOC emissions. The incremental cost would be rather high because of the additional labor. 

The analysis also shows that requiring control devices in lieu of VOC limits would have been 

cost prohibitive (more than $255,000 per ton of VOC reduced). Finally, the analysis indicates 

that it would be cost-effective to regulate direct-contact lubricants and general metal working 

fluids (see Table XIV below). The District intends to do so as soon as the VOC content test 

method technical issues have been resolved. 

Table XIV – Incremental Cost-Effectiveness 

VOC Limit (g/l) 

Emission 

Reductions 

(tons per year)

Annual 

Cost 

(million) 

Incremental Cost 

($ per additional 

ton reduction) 

Overall Cost 

Effectiveness 

25 1,273.9 $12.4 $54,795 $9,734 

50 (all categories) 1,211.8 $9.0 $4,042 $7,427 

50 (vanishing oil and 

rust inhibitor only) 989.2 $8.1 $4,215 $8,189 

200 (vanishing oil and 941.7 $7.9 $8,389 $8,389 
Final Staff Report ________________________________

Proposed Rule 1144 19 March 2009

rust inhibitor only) 

No Control 0.0 $0.0 N/A N/A 

Control Device 1,270.2 $324.0 $962,253 $255,078 
Final Staff Report ________________________________

Proposed Rule 1144 20 March 2009

COMMENTS AND RESPONSES

This section reflects the public comments received during the public workshop held September 

23, 2008, the public consultation meeting held October 29, 2008 and subsequent public comment 

periods and staff responses. 

Comment 1 

We request that SCAQMD delay the rulemaking process. The test method was only recently 

released and there is insufficient time to determine applications that may be affected. The 

current effective date, coupled with the aggressive rule making schedule, is infeasible. 

Thousands of companies may need to implement alternatives. Manufacturers and suppliers do 

not have sufficient support staff to test and implement alternatives. In addition to delaying the 

rule, we recommend delaying the effective dates for the proposed rule. We suggest an 

exemption for high flash point oils or to delay the effective date for metal working fluids, except 

vanishing oils, until 2012. The AQMD should also consider phased-in or staged limits. 

Response 

While not every potential product has had the VOC content definitively determined, it is clear 

that high-solvent content metal working fluids and rust inhibitors and straight solvents are within 

the purview of the rule. As part of the rule development process, staff has identified numerous 

commercially available products already complying with the proposed limits. Also, the Public 

Hearing has been moved from December 2008 to March 2009 to provide more time for public 

review and input. Nevertheless, to provide more time to resolve technical issues regarding the 

VOC content test method, the proposed rule has been modified to establish limits for vanishing 

oil and rust preventatives only. Direct-contact lubricants and general metal working fluids will 

be regulated after the test method technical issues have been resolved. Furthermore, an 

exemption has been added to delay the 300 g/l VOC limit applicable to rust inhibitors for 

products used under PPAP and military specifications by one year, providing a two year window 

requested by industry to revise the applicable specifications. Lastly, exemptions for certain lowvolume categories have been added to the proposed rule to alleviate reformulation efforts for 

those categories. 

Comment 2 

Special consideration should be given for applications specified for operations where fluid usage 

is dictated by military specification, PPAP or customer specifications. We believe a one year 

delay should be allowed to determine which fluids are affected, contact customers to advise them 

of the rule making and initiate replacement trials. We also ask for an additional year beyond the 

delay to determine customer acceptability. 

Response 

High-solvent content metal working fluids and rust inhibitors, light, high flash point oils and 

straight solvents will be the affected formulations and while manufacturers have a large number 

of products, only a small subset will require further testing to determine compliance. However, 

until the technical issues regarding the test method have been resolved, only vanishing oils and 

rust inhibitors will be regulated. We agree that replacement trials to determine customer 

acceptability and changes to military specifications and/or PPAP specifications will take 

additional time. Therefore, as noted above, the proposed rule has been modified to delay the 

effective date to provide more transition time for manufacturers to reformulate and test their 

products, as well as amending specifications. An exemption has been added to delay the 300 g/l 
Final Staff Report ________________________________

Proposed Rule 1144 21 March 2009

VOC limit applicable to rust inhibitors for products used under PPAP and military specifications 

by an additional year. 

Comment 3 

There was insufficient notice for the public workshop. Many shops had not received notice of 

the meeting until the weekend before the workshop. 

Response 

All stakeholders in staff’s distribution list that had expressed an interest in participating in the 

public workshop and rule development process were notified by e-mail ten days in advance of 

the September 23, 2008 meeting. Staff also asked the stakeholders to forward the meeting notice 

to others who may be interested. Notices were mailed to over 7,000 potentially interested 

entities that were not included in staff’s distribution list. Newspaper notice in all four counties 

was also provided. Sufficient notice was provided to meet statutory requirements for notice of 

the Board hearing. However, an additional meeting, a Public Consultation Meeting, was held in 

late October with sufficient notice provided by mail for potentially impacted facilities. This 

provided another opportunity for the regulated community to provide comments regarding the 

proposed rule. Further, in addition to the public workshop and consultation meetings, staff will 

continue meeting with representatives of the impacted industry through its ongoing working 

group meetings to continue addressing any pending issues. 

Comment 4 

The referenced test method remains a draft and has not been validated, peer reviewed and/or 

accepted by testing organizations such as American Society for Testing and Materials (ASTM), 

American Oil Chemists Society (AOCS), American Chemical Society (ACS) for metal working 

fluids. A poor test method is the worst thing that could happen in this regulation. Has 

SCAQMD Test Method 313L been validated for VOC testing of neat oil or emulsion samples? 

Labs that can conduct this method have not been identified and their experience with the method 

has not been evaluated. 

Response 

Method 313L was developed to accurately test high-VOC solvent-based as well as higher water 

content low-VOC products. However, based on comments presented by industry, especially lack 

of repeatability in non-AQMD laboratories, it has been replaced with EPA Test Method 24. 

EPA Test Method 24 has been shown to be acceptable for relatively high solvent products 

including vanishing oils and solvent-based rust preventatives and will be used for those 

categories. However, it does not produce repeatable results for high water content or heavy 

(high flash point) oils. The AQMD has committed, in the Resolutions to be adopted along with 

the proposed rule, to conduct round robin testing on Method 313L and TGA. Once Method 

313L, TGA or another method has been shown to be adequate, limits will be established for high 

water content fluids and high flash point oils used as direct-contact lubricants and general metal 

working fluids. 

Comment 5 

A possible alternative to GC/FID analysis is the use of TGA to determine VOC levels. This 

analysis methodology can accurately and efficiently determine the volatility characteristics of a 

sample, both neat oil samples and emulsion samples at any desired temperature. 
Final Staff Report ________________________________

Proposed Rule 1144 22 March 2009

Response 

The TGA test method is very similar to EPA Method 24 with respect to its strengths and 

weaknesses. It would provide accurate and repeatable results for high-solvent or petroleumbased oil products, but will not provide acceptable results for low-VOC products that contain 

high water content. To utilize TGA testing, time and temperature parameters must be 

determined and an enforceable way to handle high water content must be established. The 

District agrees to continue reviewing the merits of TGA testing with interested stakeholders and 

considering it as an approved test method if further data provides sufficient evidence. 

Comment 6 

It may be possible to mimic the test results of the SCAQMD GC/MS procedure using a capillary 

GC unit equipped with FID and could produce a comparable chromatograph to the GC/MS 

results. This form of VOC testing was documented by California Polytechnic State University in 

a progress report from 2006, under sponsorship of CARB and Cal EPA, in the development of a 

new VOC analysis method for architectural coatings. Results from the new headspace method 

were compared using the standard direct sample injection method (ASTM method 6886). 

Results reported seem to indicate the static headspace analysis method to provide results 

comparable to direct injection analysis method for compounds showing GC column elution times 

prior to an industry recognized reference standard. 

Response 

Test Method 313L utilizes a capillary GC unit equipped with FID as described in the comment. 

We agree that the results are comparable to other methods using methyl palmitate as the 

reference standard. Head space analysis would require very high temperatures to ensure that the 

sample would completely volatilize for the compete chromatograph to be analyzed. Lower 

temperatures would provide an incomplete chromatograph and potentially give an artificially low 

VOC result. In addition, numerous other factors in headspace analysis, such as liquid to vapor 

ratios and sample transfer, suggest that headspace analysis would be less reliable than direct 

injection. However, based on comments received, Method 313L has been replaced with EPA 

Test Method 24, as suggested by several members of industry. 

Comment 7 

Methyl palmitate is not normally classified as a volatile compound, but SCAQMD uses it to 

define what constitutes a VOC. What is the basis for this decision, and are any other regulatory 

agencies in agreement with the decision? 

Response 

Test Method 313L is a modified version of SCAQMD Method 313 – Determination of Volatile 

Organic Compounds (VOC) by Gas Chromatograph/Mass Spectrometry (GC/MS) which has 

been accepted by CARB and U.S. EPA for AQMD rule implementation and in air districts in 

California and Arizona since 1991. In this method, the total specified sampling period is 30 

minutes. Previous testing has shown that methyl palmitate elutes at the 30 minute mark. The 

AQMD includes all compounds, besides water and exempt solvents, that elute prior to methyl 

palmitate, to be VOC. The modifications streamline the test significantly, reducing cost and 

labor as well as allowing the use of commercially available GC columns. In modifying the test, 

the compounds elute out in the same order and methyl palmitate remains the endpoint 

determining volatility. However, based on comments received, Method 313L has been replaced 

with EPA Test Method 24, as suggested by several members of industry. 
Final Staff Report ________________________________

Proposed Rule 1144 23 March 2009

Comment 8 

The data reported by AQMD was calculated based on the manufacturer’s recommended dilution 

of the product after testing of the neat product. Since in-use samples will be used to determine 

customer compliance, the results should correlate to actual dilutions and real world conditions 

versus calculated dilutions. The results varied by 100 percent for one sample and 33 percent for 

another. A validated test does not have such variability, especially when critical to both 

compliance and enforcement. 

Response 

Testing to verify that results from dilute samples correlate to earlier results from neat samples 

calculated based on the manufacturer’s recommended dilution has been completed and shows 

that Method 313L results correlate very well when testing neat and diluted samples. These 

results have been shared with the public and included as Table XV – Dilute Sample Results 

below. While the commentor criticizes the results as having large percentile differences, these 

differences equate to less than 20 g/l. These are very small values and all samples tested would 

fall well within the VOC limits proposed. Additionally, it is routine enforcement policy to 

recognize a margin of error for sample results equal to +/- 20 percent for VOC limits of 50 g/l or 

less. 

Table XV – Dilute Sample Results 

Sample ID 

(Dilution ratio) 

Neat Predicted Tested 

Sample 001 (8%) 20 g/l 2 g/l 2 g/l 

Sample 002 (10%) 140 g/l 14 g/l 10 g/l 

Sample 003 (20%) 140 g/l 28 g/l 8 g/l 

However, based on comments received, Method 313L has been replaced with EPA Test Method 

24, as suggested by several members of industry. Industry’s proposal TGA method also has 

similar limitations for testing dilute samples with high water content. 

Comment 9 

The high temperature (200°C) at the injection port for the FID is not reflective of real world 

conditions. Glycerin may break down at such a high temperature giving false results. A lower 

temperature, such as 40°C would be better. 

Response 

The temperature at the injection port is not intended to reflect real world conditions but to 

provide a complete chromatograph of the fluid for further analysis. While much of the fluid will 

elute at that high temperature, only the portion occurring before methyl palmitate is considered 

when determining VOC content. There has been no indication that glycerin or any other 

chemical compound breaks down giving false results. A lower injection port temperature could 

potentially leave some volatiles in the injection port giving an artificially low result. However, 

based on comments received, Method 313L has been replaced with EPA Test Method 24, as 

suggested by several members of industry. 
Final Staff Report ________________________________

Proposed Rule 1144 24 March 2009

Comment 10 

The proposed test method utilizes direct injection. We believe head space analysis is more 

accurate than direct injection. 

Response 

Head space analysis would require very high temperatures to ensure that the sample would 

completely volatilize for the compete chromatograph to be analyzed. Lower temperatures will 

provide an incomplete chromatograph and potentially give an artificially low VOC result. In 

addition, numerous other factors in headspace analysis, such as liquid to vapor ratios and sample 

transfer, suggest that headspace analysis would be less reliable than direct injection. However, 

based on comments received, Method 313L has been replaced with EPA Test Method 24, as 

suggested by several members of industry. 

Comment 11 

The inventory figures, particularly from vanishing oil applications, are inaccurate and outdated. 

Many assumptions are based on census data from 1995 and 2002. Sales are down and there are 

fewer companies using these fluids when they were reported in 2006. The survey captured 95 

percent of the sales at that time and the national sales estimates are far too high. A new 

inventory survey should be conducted before the rule is heard. 

Response 

The inventory figures were provided by surveying local manufacturers and suppliers. Those 

figures were for annual sales in the District for 2004, 2005 and part of 2006. The results are 

relatively consistent over the survey period, and national sales confirm relatively stable sales. In 

response to the comment, earlier survey respondents were contacted and invited to revise earlier 

annual sales or provide new sales data if they wished. None have provided any additional data. 

Census assumptions regarding national sales data confirm survey sales data, but only the 2006 

survey sales data collected for the South Coast have been used for making emission estimates. 

Based on discussions with industry pertaining to solvents used as lubricants, metal working 

fluids, vanishing oils and rust inhibitors, the local survey may underestimate the volume and 

associated emissions. While the local survey and the national sales figures were used as 

reference points to establish the baseline inventory for rulemaking, staff is cognizant of the 

limitations of initial surveys and intends to refine them by periodically conducting future 

surveys. 

Comment 12 

There is known interference in the proposed test method (Method 313L) from surfactants used in 

the suggested alternative metal working fluids. Will the proposed test method give accurate 

results? 

Response 

The proposed test method has been shown to give accurate, repeatable results for a wide range of 

products, including those that contain surfactants. Surfactants are commonly found in cleaning 

products. Cleaning products submitted for Clean Air Solvent and Clean Air Choices Cleaner 

certification are reliably tested using the proposed test method. However, independent and 

industry laboratories are not familiar with this method and have requested round-robin testing, 

particularly with respect to direct-contact lubricants and metal working fluids. Therefore, VOC 

limits for those categories will be established after the technical issues have been resolved. 
Final Staff Report ________________________________

Proposed Rule 1144 25 March 2009

Comment 13 

The costs for manufacturers and suppliers will have to test each and every product costing 

$60,000 to $150,000. They will also have costs for research and development and technical 

support staff. The projected emission reductions only represent 0.5 percent of the VOC 

emissions in the basin. Additional strain will be placed on small businesses hard pressed by 

severe economic conditions. Companies cannot afford to modify processes. Many companies 

are leaving the basin and additional costs will accelerate their departure. The proposed rule will 

have huge costs for little gain. 

Response 

The sixteen million Southern Californians residing in the South Coast Air Basin experience the 

nation’s worst air quality. Proposed Rule 1144 partially fully implements control measure CTS01 of the 2007 AQMP, which reflects the South Coast Air Basin’s comprehensive strategy to 

improve air quality and meet the state and federal air quality standards. CTS-01 is a vital 

component of the stationary source VOC control strategy. When implemented, Rule 1144 will 

reduce approximately 2.7 tons of VOC per day, a significant level of emission reductions. While 

staff acknowledges that there are costs associated with the implementation of Rule 1144, staff 

has attempted to craft a rule that minimizes such costs, while maximizing emission reduction 

benefits. The analysis included in this staff report shows that the revised staff proposal is 

technologically feasible and very cost-effective. The proposed rule does not require that each and 

every product be tested. Calculations of VOC content for formulations with compounds of 

known VOC contents are acceptable. The cost-effectiveness analysis conservatively includes the 

cost to test 500 rust inhibitor samples. Costs for research and development and technical support 

staff are considered in the higher cost of low-VOC alternatives and included in the costeffectiveness calculations in the Staff Report. Companies have the option to use alternative 

products that may not require process modification. However, the Staff Report includes a costeffectiveness analysis using the most conservative assumptions. The analysis shows the 

proposed rule is cost-effective. Case studies of facilities that have used these alternative 

products and modified processes may even realize a cost savings. A SocioEconomic assessment 

of PR 1144 has been conducted to evaluate employment impacts. 

Comment 14 

Cost effectiveness and incremental cost effectiveness calculations have not been provided. The 

District is specifically required by statute to consider, and make available to the public, its 

findings related to the cost-effectiveness of a control measure it proposes to adopt. The District 

is also required to assess the availability and cost-effectiveness of alternatives to the proposed 

rule. Moreover, the District is also required to calculate the incremental cost-effectiveness of 

potential control options that achieve the emission reduction objectives of the proposed rule. 

Response 

Cost effectiveness calculations were provided in the Preliminary Draft Staff Report as well as the 

Draft Staff Report. Incremental cost-effectiveness of potential control options are included in the 

Draft Staff Report, and were discussed at working group meetings and presented at the Public 

Consultation Meeting. 

Comment 15 

VOC standards and test methods should be consistent statewide and nationwide. 
Final Staff Report ________________________________

Proposed Rule 1144 26 March 2009

Response 

Nationally, EPA Method 24 is the default method to determine VOC content of fluids subject to 

regulation under the rule. Statewide, the only applicable standard is for consumer product 

lubricants, CARB Method 310 – Determination of Volatile Organic Compounds (VOC) in 

Consumer Products and Reactive Organic Compounds in Aerosol Coating Products. CARB 

Method 310 is a GC/MS method that exempts solvents with a vapor pressure less than 0.1 mm 

Hg. While this may be a satisfactory standard for consumer products, the AQMD does not 

exempt low vapor pressure solvents, since VOCs are released over time and interact to form 

ozone and secondary organic aerosols. 

Comment 16 

The proposed limits are unachievable and there is no documentation supporting the conclusion 

that alternatives are available. The Institute for Research and Technical Assistance (IRTA) 

report referenced in not available to the public and neither is the survey data collected by the 

AQMD. 

Response 

Staff estimates, according to information provided by manufacturers and suppliers, that over 89 

percent of the 4.2 million gallons of lubricants, metal working fluids and rust inhibitors sold in 

the AQMD already meet the proposed limits. The specific sales volume information is 

considered confidential and will not be provided to the public, but, the consolidated information 

is included in the Staff Report. Manufacturers and suppliers have provided hundreds of material 

safety data sheets for products that are used in nearly all machining applications. In the limited 

instances where high-VOC solvents uses were indentified, IRTA conducted a technical 

assessment of available alternatives that included case studies where alternatives were 

demonstrated to be successful in production settings. The IRTA report is referenced in this 

document and is available online at www.irta.us. Applications where high flash point light oils 

are used may require further time to implement alternatives and the effective date for those 

applications have been extended based on the requested time frame. Some exemptions have also 

been included where deemed appropriate. 

Comment 17 

A limit of 50 g/l should be considered in lieu of the 25 g/l proposed. Many tested products may 

meet the proposed limit in laboratory settings but routine evaporation and contamination may 

make the products non-compliant. Considerable labor would be necessary to constantly verify 

that the product remained below 25 g/l at all times. 

Response 

The revised staff proposal sets the VOC limits at 50 g/l to address commentor’s concerns. While 

many of the products tested would meet the originally proposed 25 g/l limit, the added labor 

involved to monitor products in use to ensure that applicable fluids remain compliant would add 

considerable cost with minimal emission reductions. 

Comment 18 

High flash point light oil use with high VOC content should be exempt for aluminum, stainless 

steel, copper, brass, and titanium cutting and high speed grinding, coolants, EDM, fast 

quenching, honing, lapping, milling, and rolling oils. Special consideration should be given to 

lubricants specified by machine manufacturers where deviation may cause the warranty and 

service contract to be voided. 
Final Staff Report ________________________________

Proposed Rule 1144 27 March 2009

Response 

Light oils with viscosities less than 20 cSt (100 SUS) and flash points greater than 200°F that 

have a VOC content greater than 50 g/l include lubricants for spindle machine oil, cutting fluids 

for aluminum, stainless steel, copper, brass, and titanium, lapping and sinker EDM applications. 

The other applications use heavier oils or aqueous-based metal working fluids that have VOC 

contents below the proposed limit. Due to their very low usage and lack of available 

alternatives, sinker EDM and lapping operations have been exempted. The high speed spindle 

oils specified by machine manufacturers do not come into direct contact with parts or products 

being manufactured or assembled, and therefore are not subject to the proposed rule. High speed 

spindle oils account for approximately 5,000 gallons used per year. Slightly heavier, but lowVOC oils, are a viable alternative for cutting fluids. Testing and possibly some equipment 

changes are necessary to use these products. However, VOC limits will be established after 

technical issues regarding the VOC content test method have been resolved, and are not covered 

by the revised proposed rule language. 

Comment 19 

Assembled aircraft require specialized corrosion inhibitors and lubricants and should be 

exempted from the proposed rule. 

Response 

PR 1144 has been revised to exempt the specialized lubricants and corrosion inhibitors for 

assembled aircraft which represent less than 0.002 ton per day of VOC emissions. 

Comment 20 

Lubricants and metal working fluids used during the manufacture and use of aircraft fasteners 

should be exempted from the proposed rule. 

Response 

Limits for lubricants and metal working fluids will not be established until technical issues 

regarding the VOC content test method have been resolved. Regardless, lubricants and metal 

working fluids subject to Rule 1124, including barrier coatings, dry lubricative coatings and solid 

film lubricants are exempt from the provisions of this rule. Vanishing oils and rust preventative 

applications not subject to Rule 1124 will be subject to the proposed rule. 

Comment 21 

Straight oils are often used and provide valuable lubricating functions. Water-based fluids 

involve more maintenance, down time and tooling will wear out faster. They also cannot be 

skimmed from aqueous cleaning baths meaning additional waste generation and costs. Are there 

petroleum-based rust inhibitors that comply with the regulation? 

Response 

The proposed rule does not require the use of water-based alternatives. The majority of straight 

oils will comply with the proposed limits. Facilities where high-VOC solvents are utilized will 

generally have the option to choose between heavier straight oils or aqueous-based, soluble, 

semi-synthetic or synthetic metal working fluids. The AQMD has tested several petroleumbased rust inhibitors that comply with the proposed limits. Review of material safety data sheets 

provided by suppliers and manufacturers indicated that most carry a compliant petroleum-based 

rust inhibitor. The AQMD cannot recommend specific suppliers but can provide a list of 

suppliers.
Final Staff Report ________________________________

Proposed Rule 1144 28 March 2009

Comment 22 

A more precise applicability statement and definition of terms is necessary. It is not clear which, 

if any, maintenance and repair activities are exempt from the rule. Proposed Rule 1144 should 

be clarified to also exclude research and development. 

Response 

The applicability statement has been modified to further improve clarity. Additional definitions 

have been included to clarify the scope and intent of the proposed rule. The rule applies only to 

the manufacture and assembly of products and parts. Repair and maintenance activities are not 

applicable to the proposed rule. Neither are research and development activities that do not meet 

the definition of “manufacture” in the proposed rule. 

Comment 23 

We strongly believe that there is no “necessity” for the AQMD to regulate consumer and 

commercial products since CARB exercises continuous regulatory jurisdiction over these 

products. Dual regulation by CARB and AQMD is contrary to state Legislature’s intent to 

establish a uniform set of regulations for consumer products. Additionally, it is not clear which 

provisions of the rule apply to consumer products. 

Response 

Consumer products are exempt from the prohibition of sale provision of the proposed rule. Use 

of consumer products by households, institutions and commercial operations, and consumer 

products used for maintenance and repair activities are also exempt. However, the use of 

consumer products during the manufacture and assembly of parts and products must meet the 

same limit as industrial products specifically formulated for those operations. Regulation of 

VOC content at stationary sources falls squarely within the long-established authority of air 

districts. According to CARB, “[I]t was certainly not the purpose of the ARB regulations to 

deprive districts of their long-standing authority to regulate pollution-generating activities 

occurring at stationary sources, just because these activities may involve the use of consumer 

products.” Walsh, Kathleen. CARB General Counsel. "Interpretation of Health and Safety 

Code Section 41712 (f)." Letter to William Wong, Senior Deputy District Counsel. February 20, 

2001.

Comment 24 

All aerosol product uses should be exempt from the proposed rule. 

Response 

Aerosol products are not normally used for most manufacture and assembly operations. There is 

no reason to encourage their use, with corresponding higher VOC content, by providing a 

blanket exempt status. 

Comment 25 

The AQMD should consider a small container (one quart or less) exemption. 

Response 

Small containers are not normally used for most manufacture and assembly operations. 

Providing an exemption would encourage wasteful packaging and provide a loophole for noncompliant products. 
Final Staff Report ________________________________

Proposed Rule 1144 29 March 2009

Comment 26 

The AQMD should consider a small use exemption (i.e. 55 gallons per facility annually). Some 

parts require thread locking compounds, sealants, mask, hardeners, layout fluid, hand applied 

tapping compounds and other essential fluids that may contain VOC but should not be included 

in the proposed rule because of their small usage. 

Response 

Applications such as sinker EDM, lapping, rust inhibition for avionics and assembled aircraft, 

where there is low usage and alternatives are unavailable have been included exempted in the 

rule. Thread locking compounds, sealants, masks, hardeners, and layout fluids do not meet the 

definitions for vanishing oil or rust inhibitor and the rule will not be applicable to those uses. 

Tapping fluids, applied by hand and by machine are metal working fluids and subject to the 

VOC limits in the rule, if they have a flash point less than 200°F. Low-VOC products are 

available for tapping applications and there are liquid, paste and aerosol versions of the lowVOC hand tapping fluids. A general small use exemption would require shops to maintain 

extensive records to verify if the small use exemption applied and is unnecessary when 

compliant alternatives are readily available. 

Comment 27 

A longer sell-through period is necessary to ensure that products in the supply chain at the 

effective date are able to be used in a timely manner. 

Response 

While consumer products may remain on the shelf for an extended period of time, most fluids 

used for industrial applications are consumed within six months after purchase. Extending the 

sell-through period would allow high-VOC products to be stockpiled for a longer than normal 

period. 

Comment 28 

Local labeling is a challenge for consumer products that are sold locally, nationally and 

internationally. 

Response 

The labeling provision of the rule has been removed until technical issues regarding the VOC 

content test method have been resolved. Even so, the District intends to exempt consumer 

products from any future labeling requirement. 

Comment 29 

Language should be included in the rule describing the enforcement protocol for sampling 

products in use and directly from shipping containers. 

Response 

Enforcement procedures are normally not included in rules. Sampling of products in use is 

typically done at the application source. Verification of VOC content of fluids in shipping 

containers is normally done by testing the product from a sealed container. However, because of 

variations in circumstances the procedures may be altered as necessary. 
Final Staff Report ________________________________

Proposed Rule 1144 30 March 2009

Comment 30 

The District has routinely regulated the aerospace industry separately due to its unique status and 

it should continue to do so. Rule 1124 is specifically designed to reduce VOC emissions from all 

aerospace manufacturing and assembly operations and other applications have been routinely 

been exempted from multiple other District rules. 

Response 

Aerospace machining operations that have applicable limits in Rule 1124 have been specifically 

exempted in the proposed rule. Metal working operations at aerospace facilities that have no 

specific limits in Rule 1124 are subject to Rule 442 as an unregulated source of VOC emissions. 

It is possible that at some future date Rule 1124 will be amended to include general machining 

operations that would immediately exclude them from the provisions of this rule as provided by 

paragraph (h)(3) of the proposed rule. However, many operations at aerospace facilities, 

including solvent degreasing and plating, are subject to Reg. XI rules in addition to Rule 1124. 

Until Rule 1124 has specific limits for vanishing oil and rust inhibitors applications, proposed 

Rule 1144 will apply. 

Comment 31 

Isopropyl alcohol is necessary for cutting applications on critical space vehicle components 

where the cutting fluid may penetrate coatings, adhesives and substrates and be off-gassed when 

exposed to the vacuum of space. 

Response 

An exemption for space vehicle components is included in the revised staff proposal. 

Comment 32 

Denatured alcohol is used for a high speed precision CNC milling machine used for aluminum 

nameplates with graphics already printed upon them. Using an exempt solvent would be costprohibitive and using a heavier metal working fluid would require the parts to be cleaned 

afterwards. The manufacturer of the equipment has said that a recirculating flood coolant 

process cannot be used or retrofitted. An exemption is requested for this application. 

Response 

Staff does not believe that an exemption is warranted for this vanishing oil operation. A higher 

flash point fluid is available as a low-VOC alternative. We acknowledge that using a low-VOC 

alternative metal working fluid would require additional cleaning and have included such costs 

in calculating the cost-effectiveness of the proposed rule. The alternative would not necessarily 

need to be a flooding system and can be applied in the same manner as the alcohol is applied. 

Comment 33 

Users of consumer products should not be required to keep records. CARB already gets sales 

data of consumer products directly from manufacturers and suppliers and this puts an additional 

and unnecessary burden on users of these products. 

Response 

While CARB has consumer products sales records for emission purposes, records of consumer 

products used at an individual facility is necessary to determine compliance with permit 

conditions, rule requirements and possible exemption status. Alternative record keeping is 

available for consumer products with a VOC content below 50 g/l pursuant to Rule 109. 
Final Staff Report ________________________________

Proposed Rule 1144 31 March 2009

Comment 34 

CARB currently has a rule that regulates lubricants used by household, institutional and 

commercial establishments that do not manufacture products. The proposed rule has wording in 

the applicability statement which conflicts with the CARB rule. The wording “commercial” and 

“institutional” should be removed. The section should be reworded to accurately describe the 

intended target audience of this regulation 

Response 

Agreed. “Institutional” and “commercial” have been removed and the applicability section has 

been clarified. 

Comment 35 

The AQMD relied on one study that is limited to 13 specialized shops. More in depth work 

should be done before one limit is proposed for all lubricant and rust inhibitor uses. 

Response 

While the AQMD used the IRTA study for some aspects of the cost-effectiveness calculations, 

the rule’s limits are based primarily on testing that has been conducted on the range of fluids 

addressed in the rule. The results indicate that 89 percent of the fluids have a VOC content 

below the proposed limits. For the 11 percent of the fluids with higher VOC content, the AQMD 

has reviewed applicable operations to determine appropriate VOC content limits and effective 

dates, and has incorporated those changes into the proposed rule. 

Comment 36 

None of the tested alternative low-VOC rust inhibitors or lubricants discussed in the staff report 

are feasible for use in aerospace manufacturing and assembly. Even if replacement fluids were 

available, which is not likely, the process for identifying, qualifying and obtaining approvals is 

difficult and time consuming and could not occur within the Rule’s compliance deadline. 

Response 

The aerospace industry has been using low-VOC lubricants, metal working fluids and rust 

inhibitors on the vast majority of their metal working applications. Vanishing oils are highly 

uncommon in aerospace applications. Many tens or even hundreds of thousands of gallons of 

metal working fluids used on aerospace products are the aqueous-based or high flash point oils 

that the staff report identifies as low-VOC alternatives to high-VOC products. Many compliant 

products are specially designated to have aerospace approvals. In three site visits and several 

conversations with aerospace facility industry representatives, only minor uses of moderate to 

high-VOC fluids were identified. These minor uses have been provided extended rule effective 

dates or exemptions as appropriate to compensate for the difficult and time consuming process to 

obtain approvals. 

Comment 37 

Proposed Rule 1144 should include a vapor pressure limit as an alternative to a VOC 

concentration limit. Rule 219 exempts equipment from requiring a permit if the VOC content is 

below 50 g/l or the vapor pressure is less than 20 mm Hg at 20 °C. 

Response 

Nearly all vanishing oils and rust inhibitors, including those with high VOC content, have a 

VOC composite of 5 mm Hg or less. Measurement of vapor pressure for complex chemical 
Final Staff Report ________________________________

Proposed Rule 1144 32 March 2009

blends is very difficult for low vapor pressure materials. Additionally, the vapor pressure of 

fluids does not directly correlate with VOC content. 

Comment 38 

Small quantities of mineral spirits should be allowed for the sole and express purpose of quality 

control of machined parts. Metal working fluids need to be removed to precisely measure parts. 

Response 

Proposed Rule 1144 does not apply to cleaning applications. Those activities are subject to Rule 

1171 – Solvent Cleaning Operations. 

Comment 39 

The proposed rule allows vanishing oils and rust inhibitors to be used in conjunction with a 

control device but prohibition of sales provision does not allow their sale. The prohibition of 

sale should include an exemption for products to be used in conjunction with a control device. 

Response 

The revised proposed rule exempts products to be used in conjunction with a control device, in 

terms of VOC content, as well as the sales prohibition. 

Comment 40 

A mechanism should be provided in the rule for variances or waivers for products and uses when 

substantial justification exists. 

Response 

Regulation V provides a procedure whereby a company can apply for a variance to allow it to 

continue temporarily operating without penalty while in violation of AQMD rules, while it takes 

appropriate steps to meet air pollution control requirements. Variances can only be granted by 

the AQMD Hearing Board. 

Comment 41 

Manufacturers of certain machine tooling require the use of specific brands of oil otherwise the 

warranty and service contract may be voided. 

Response 

The limits for general metal working fluids and direct-contact lubricants have been removed 

from the rule while test method issues are being resolved. VOC limits will apply to vanishing 

oils and high VOC rust inhibitors only. 

Comment 42 

CARB’s regulations are predicated on an emission inventory of all consumer products sold in the 

state. If a CARB-regulated product (e.g., multi-purpose lubricant) is used in a permitted 

stationary source (e.g., automobile repair facility), the emission reduction from that particular 

product has already been included in CARB’s calculation of necessary state-wide reductions 

required to attain state and federal ambient air quality standard. To impose additional 

restrictions on a CARB-regulated product would result further regulation of a product that has 

already been subject to a standard deemed to achieve maximum feasible reductions in VOCs. 

Moreover, any attempt to impose additional District regulation on such products would result in 

a double-counting of the emission reductions achieved by the statewide regulation. 
Final Staff Report ________________________________

Proposed Rule 1144 33 March 2009

Response 

Emissions from consumer products were not included in the inventory or emission reduction 

analysis for PR 1144, so there is no double-counting. The purpose of including consumer 

products was to limit and restrict the use of consumer products at stationary sources. However, 

based on discussions with industry, these products are exempted until January 1, 2011 from the 

VOC limits. 

 

Comment 43 

Please accept a request that the time period for written comments be extended until March 1, 

2009. 

Response 

Extending the comment period from two weeks to five months would unnecessary delay the rule 

making activity. Nevertheless, staff will continue accepting feedback from all stakeholders up 

until the Public Hearing that will be held by the AQMD Governing Board. 

Comment 44 

The machining industry has been actively involved in an effort to recycle oils in the Southern 

California basin for the past 12 years. They sometimes require a solvent additive to reduce the 

viscosity of the cutting oil so that it can continue to be used in the application. Leakage in the 

machines results in ever increasing volumes of oil in the sump and ever increasing viscosity. If 

left unchecked, the oil will become unusable for the application and will have to be disposed. 

We can use a higher viscosity additive but this would compound the increasing volume problem 

and significantly contribute to oil disposal. Even though the elimination of this solvent based 

additive would contribute to the reduction of VOCs, it would be minimal in comparison to the 

increased waste generation over the next 12 years. Please consider the allowance of high VOC 

solvent additives used to recycle oil. 

Response 

Staff agrees that recycling of oil should continue. As long as the viscosity additive does not 

cause the flash point of the recycled oil to drop below 200°F, it can continue to be used. Once 

technical issues regarding the VOC content test method have been resolved, further limits will be 

established for direct-contact lubricants and general metal working fluids. Those limits will 

reflect the District’s desire for oil recycling to continue. 

Comment 45 

The District should consider not regulating lubricants or only regulating lubricants that come into 

direct contact with parts or products during manufacturing or assembly. Lubricants have little 

VOC content and have widespread use in many applications not under consideration by the 

District. 

Response 

The intent of the rule was to regulate fluids that come into direct contact with parts or products 

during manufacture or assembly. In accordance with the recommendation, the proposed rule has 

been revised to only fluids that come into direct contact during manufacturing. This would 

initially apply only to vanishing oils and limits for direct-contact lubricants will be established 

after issues regarding the VOC content test method have been resolved. 
Final Staff Report ________________________________

Proposed Rule 1144 34 March 2009

Comment 46 

The lighter, volatile chain lubricants, for which the VOC limit would preclude, provide a number 

of great benefits to the end users. They are designed to penetrate to the inner parts of the chain 

links in small volumes and provide a film of solid lubrication to all moving surfaces. The only 

alternative fluids which would meet the proposed VOC limits would be higher viscosity 

lubricants. These fluids would have less penetration of the chain leading to overall poorer 

lubrication of the internal parts of the chain and ultimately a much shortened chain life. These 

are typically large conveyor chains (hundreds, if not thousands of feet long) which are critical to 

the manufacturing process for moving parts throughout a facility. The cost to replace a chain is 

typically 6 figures and this would not include any related downtime. 

Response 

The intent of the rule was to regulate fluids that come into direct contact with parts or products 

during manufacture or assembly. As the commentor points out, chain lubricants are used for 

conveyors that move the parts along during manufacturing but normally do not come into direct 

contact except for an incidental drip or splash that may occur. An incidental drip or splash 

would not be considered direct contact and chain lubricants would not be subject to the rule 

unless they came into direct contact with the part or product during manufacturing. 

Comment 47 

Some definitions could be clarified to eliminate confusion. “Lubricants” should apply to 

“machine tools” instead of just “tools”. “Metal Working Fluids” could be clarified by stating 

that metal working fluids function in the “tool and workpiece interface.” Finally, the types of 

metal working fluids; straight oil, semi-synthetic, synthetic and soluble; should be defined in the 

rule. 

Response 

Staff agrees with the recommendation for “Lubricants” and “Metal Working Fluids” and has 

revised the definitions accordingly. The types of metal working fluids are used in the staff report 

but not in the rule language. Those terms are defined in the staff report but are not necessary in 

the rule because they are not used there. 

Comment 48 

A higher VOC limit is necessary for water displacing/fingerprint suppressing and “Domestic and 

International” formulations. These cannot be reformulated at present, even using the best 

currently available technology and represent a small fraction of total RP usage. 

Response 

Low-VOC water-based and vegetable oil based alternatives have been identified for these 

applications. These alternatives have been available for several years and, in some cases, for 

several decades. 

Comment 49 

We suggest an annual technology review, including a joint ILMA/San Joaquin Refining/AQMD 

study of Test Method 313L, to determine technological feasibility of future rule limits and test 

methods. 
Final Staff Report ________________________________

Proposed Rule 1144 35 March 2009

Response 

We recommend a regular meeting schedule of the working group to continue discussions 

regarding issues that arise during the implementation of the rule and the revision of 

specifications. The working group will be able to make recommendations for rule limits, test 

methods, definition clarifications, inventory review and other aspects of the rule as issues might 

arise. This recommendation will be included as a resolution in the rule package. 

Comment 50 

Blending is necessary for viscosity ratings and new oil purchased could exceed VOC content 

limits. 

Response 

VOC limits for high flash point light oils used as direct-contact lubricants and general metal 

working fluids will be established after the technical issues regarding the VOC content test 

method have been resolved. 

Comment 51 

Members in attendance of the Public Consultation meeting requested a definition for light oils. 

The AQMD did little research on this evidently feeling replacement fluids were readily available. 

Further consideration of this could satisfy both sides. 

Response 

The AQMD’s interest in fluids used as lubricants, metal working fluids or rust inhibitors is their 

VOC contribution. The AQMD is very much aware of the concerns regarding the use of high 

flash point light oils and has requested details regarding potentially impacted applications. 

While staff does conclude that alternative low-VOC products are available, staff has agreed that 

additional time may help industry to identify, test and implement the alternatives. Light oils are 

defined by their viscosity which does not always translate directly to VOC content and thus the 

AQMD has not tried to define “light oil” in a regulatory sense. 

Comment 52 

The latest draft of the rule exempts special interests such as aerospace, small canisters using 

propellants and consumers. We are requesting the same exemptions due to the negative 

economic consequences the proposed rule will have on the area economies. 

Response 

The proposed rule does include exemptions for some small applications where alternative 

products have not been identified. These uses include rust inhibitors for assembled aircraft and 

space vehicles, sinker EDM and lapping applications, and fluids used in conjunction with control 

devices. Consumer products are exempt from the prohibition of sales provisions, but the VOC 

limits still apply if used in a manufacturing application. Consumer uses are already subject to 

CARB consumer product regulations. While staff acknowledges that there are costs associated 

with the implementation of Rule 1144, staff has attempted to craft a rule that minimizes such 

costs, while maximizing emission reduction benefits. The analysis included in this staff report 

shows that the revised staff proposal is technologically feasible and very cost-effective. 

Comment 53 

San Joaquin Refining uses GC/FID routinely to monitor our refining process and consider 

GC/FID analysis to be an acceptable means to characterize petroleum hydrocarbons by carbon 
Final Staff Report ________________________________

Proposed Rule 1144 36 March 2009

distribution and type. We agree with others the need for refinement of Method 313L, 

particularly the necessity of determining repeatability and reproducibility. It appears that methyl 

palmitate was selected as the marker from earlier research work to characterize a series of methyl 

esters as biofuels that are subject to much higher temperatures than metal working fluids. 

Consideration should be made for n-tetradecane (C14H30) as a marker for determining the 

volatility endpoint. 

Response 

Staff agrees that a GC/FID method such as Method 313L is an appropriate test method. As 

discussed in Comment 7 above, methyl palmitate was the endpoint eluted during a related EPAapproved test method to determine VOC content using a GC/MS method. Staff is unaware of the 

association of the endpoint with biofuels. Currently there is no evidence suggesting that ntetradecane would be a better endpoint for determining volatility, while SCAQMD Test Method 

313-91 has been used for more than a decade to determine VOC content with methyl palmitate 

eluting at the endpoint of the test. However, based on comments received, Method 313L has 

been replaced with EPA Test Method 24, as suggested by several members of industry. 

Comment 54 

Quantitative aspects of Method 313L should be revised or made clearer, particularly in defining 

a non-arbitrary method of peak group integration when dealing with broad mineral oil “peak 

humps” that may bisect the methyl palmitate marker for the terminus of the chromatogram. 

Response 

The quantification method provided in the method summary sufficiently explains the technique 

to determine VOC content when “peak humps” bisect the relative response times of the marker 

compounds including methyl palmitate. Specifically, the portion of the peak hump eluting prior 

to methyl palmitate is calculated as VOC while the portion of the peak hump eluting after the 

methyl palmitate marker is not. However, based on comments received, Method 313L has been 

replaced with EPA Test Method 24, as suggested by several members of industry. 

Comment 55 

Coalition for Clean Air applauds AQMD’s efforts to reduce emissions of VOC in lubricants, 

metal working fluids and rust inhibitors. We encourage you to reject industry’s requests to halt 

and/or delay this important rule. In the process of developing this rule, AQMD has been very 

considerate of industry’s comments and concerns and we feel that the timeline established in this 

draft can be met by industry. 

Response 

The AQMD has made every effort to balance achieving needed emission reductions in a timely 

manner, while allowing sufficient time for industry to identify, test and implement low-VOC 

alternatives. Staff is committed to considering all interested stakeholders concerns when 

developing the provisions of this regulation. 

Comment 56 

The rule should be bifurcated into two parts. The first covering solvents and be effective January 

1, 2010. The second, covering high flash point light oils, should be exempt or with an effective 

date of January 1, 2012 allowing further study and development of alternative low viscosity oils. 

This would allow the AQMD to realize most of the emission reductions (2.67 tons per day) and 

delay the more problematic and complex affected applications. 
Final Staff Report ________________________________

Proposed Rule 1144 37 March 2009

Response 

Staff agrees and the proposed rule has been modified to delay establishing limits for metal 

working fluids and direct-contact lubricants, except vanishing oils. Vanishing oils will have a 

VOC limit of 50 g/l, effective January 1, 2010. Limits for metal working fluids and directcontact lubricants will be established once the technical issues regarding the VOC content test 

method have been resolved. 

Comment 57 

Several applications utilize lubricants, metal working fluids and/or rust inhibitors where there 

has been insufficient time to determine if they will meet the proposed rules. These operations 

include cupper lubricants, bodymaking fluids/coolants, necker lubricants and can and end 

making press lubricants used in can manufacturing. It also includes wire bunching and 

stranding, tool grinding, cubic boron nitride grinding, aluminum fin stamping, wire drawing, 

screw and bar machines, magnesium machining, temper rolling, cold rolling, hot thread rolling 

oil, penetrating oils, coating or slushing oils used for rust inhibition, water displacing rust 

preventatives, salt spray rust inhibitors, long term rust inhibitors and marine shipment rust 

inhibitors. Given the uncertainty, we feel compelled to request exemptions for these operations 

before knowing if they are necessary to protect ourselves. 

Response 

Limits for metal working fluids and direct-contact lubricants will be established once the 

technical issues regarding the VOC content test method have been resolved. The AQMD will 

continue discussions with interested stakeholders through working group meetings to receive 

data and information. Further evaluations will be made with respect to VOC limits and 

exemptions when evidence has been presented demonstrating necessity. 

Comment 58 

We recommend extending the deadline to 2013 for consumer products in conjunction with 

CARB’s consumer product regulation. We have worked extensively and successfully with 

CARB but the District’s current proposed regulation has provided no time for consumer products 

to reformulate. 

Response 

An exemption for consumer products has been added to the rule that will allow additional time, 

until 2011, for reformulation. The estimated annual usage is relatively minimal but the District 

does not want to encourage users to switch to higher VOC consumer products because they are 

exempt. Additionally, industrial facilities present an opportunity to develop market share and 

customer acceptance for low-VOC consumer products. 

Comment 59 

We recommend an exemption for aerosol food grade silicone lubricants. While the silicone 

lubricant itself does not contain any VOC, the solvents used as diluent and/or propellants will 

makes these products non-compliant. 

Response 

Limits for direct-contact lubricants and general metal working fluids will be established after 

VOC content test method issues have been resolved. 
Final Staff Report ________________________________

Proposed Rule 1144 38 March 2009

Comment 60 

It is recommended that heavily diluted aqueous fluids with greater than 90 percent water content 

be exempted from the rule. It is difficult to measure the VOC content of such products and it is 

clear that they have very little VOC content. In addition to the high water content, these types of 

products contain surfactants, oils and synthetic fluids limiting the potential amount of VOC 

contained in the product. 

Response 

High water content fluids do present additional challenges to accurately measuring the VOC 

content. The AQMD laboratory, however, has had extensive experience testing such materials 

with accurate, repeatable results. Industry has the option to test the fluids before they are diluted 

avoiding the laboratory challenges. Additionally, industry may calculate the VOC content rather 

than conduct the actual test procedure. As part of the adopting resolution, staff will be 

committing to work with industry in validating Method 313L and/or TGA through round-robin 

testing. During the round robin testing, if appropriate, a screening tool will be developed to 

minimize testing costs for high water content samples that would have negligible VOC. Many of 

the high water content samples are emulsions of high flash point oils and surfactants. As earlier 

noted, determining the VOC content of the high flash point oils is still unresolved and, once 

resolved, will have an impact on what screening value to designate. It is also possible that 

Method 313L may provide an alternative tool for testing high water content samples. 

 

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 vanishing oil and rust inhibitor operations. Most vanishing 

oils and rust inhibitors are categorized by the AQMD under miscellaneous solvent 

operations. They are currently subject to Rule 442 - Usage of Solvents, which addresses 

VOC emissions from VOC-containing materials that are not subject to VOC limits in any 

Regulation XI rule. Material or equipment subject to Rule 442, such as vanishing oils 

and rust inhibitors, are allowed to emit up to 833 pounds per month (five tons per year) of 

VOC emissions per facility without restriction. 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, paints and coatings 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 Rule 1144 has been performed. A draft report will be 

released no later than 30 days prior to the AQMD Governing Board hearing. 
Final Staff Report ________________________________

Proposed Rule 1144 39 March 2009

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 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 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 Rule 1144 – Vanishing 

Oils and Rust Inhibitors, 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 Rule 1144 – 

Vanishing Oils and Rust Inhibitors, is in harmony with, and not in conflict with or contradictory 

to, existing statutes, court decisions, federal or state regulations. 

Non-Duplication - The AQMD Governing Board has determined that Proposed Rule 1144 – 

Vanishing Oils and Rust Inhibitors, 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

“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). 

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 Rule 1144 40 March 2009

California Manufacturers Register. Twinsburg: Harris Infosource, 2006. 

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. 

SCAQMD Method 313-91 – Determination of Volatile Organic Compounds (VOC) by Gas 

Chromatography/Mass Spectrometry (GC/MS). SCAQMD, February 1997 

“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. 

Popoli, William (2000). Spindle Bearing Basics. Manufacturing Engineering Vol.125 No. 5 

Saalmuller, Mark (2001). Evolving From Cam Multi-Spindles to CNC. Production Machining. 

Zelinski, Peter (2006). Seeing More for CNC Multi-Spindles. Production Machining. 

Sedelmeier, Gregory (2008). Managing Water Contamination to Maintain Effective Steel Mill 

Lubrication. Machinery Lubrication Issue Number: 200807 

Federal Energy Management Program. “FEMP Designated Product: Gas Water Heaters” 

available online at http://www1.eere.energy.gov/femp/pdfs/pseep_gaswtrheaters.pdf (Accessed 

August 27, 2008). 

Walsh, Kathleen. CARB General Counsel. "Interpretation of Health and Safety Code Section 

41712 (f)." Letter to William Wong, Senior Deputy District Counsel. February 20, 2001.
Preliminary Draft Staff Report - Appendix A ________________________________

Proposed Rule 1144 A - 1 March 2009

Appendix A – Lubricant, Metal Working Fluid and Rust Inhibitor VOC Content Test 

Results (EPA Test Method 24) 

Type Application Results

Rust Inhibitors 

Water-based Rust Inhibitor/Stamping 295 g/l* 

Straight/Consumer Consumer/General 530 g/l 

Straight Rust Inhibitor/Stamping 380 g/l 

Synthetic Corrosion Preventive 471 g/l 

Mineral Anti-Rust 253 g/l 

Vegetable Cleaner/Rust Inhibitor 121 g/l 

Unknown Cleaner/Rust Inhibitor 765 g/l 

Straight Rust Inhibitor 119 g/l 

Straight Rust Inhibitor 420 g/l 

Straight Rust Inhibitor 12 g/l 

Vanishing Oils 

Straight Stamping 597 g/l 

Straight Stamping 686 g/l 

Vanishing Vanishing/Stamping 729 g/l 

* Before dilution