INTRODUCTION

The current environment within the European Union demands that the manufacturers and suppliers of metalworking fluids provide products that are both safe to use and ecologically acceptable. The potential exists for legislation and regulation to significantly affect the formulatory approach to these already complex products in the near future. As a result of these concerns, and in order to positively promote the technological advancements of this sector of the lubricants industry, the British Lubricants Federation, renamed United Kingdom Lubricants Association in 2005 initiated and supported the formation of a UK based Metalworking Fluid Stewardship Group.

BACKGROUND

During the last twenty years many of the most important modifications to metalworking fluids (MWF) within Europe have been related to either health, safety or environmental concerns. In par ticular, issues such as the disposal suitability of chloroparaffins and the health concerns related to the potential formation of nitrosamines, have been well documented. In the U.K., the reaction from the manufacturers and marketers of MWFs to these concerns has been varied and in the absence of legislation to outlaw specific components, some companies have continued with formulations which have their origins in the distant past. Whilst the Health and Safety Executive has been active in providing review documents relating to certain component concerns, the lack of significant trade union influence and the absence of any major 'green political presence has resulted in a marketplace which is at best confused in relation to many of the relevant issues. Other parts of Europe, in particular Germany and some of the Scandinavian countries have a much more proactive approach to the presentation of 'safe' MWFs. Committees developed in Germany to review and update the Technical Regulations on Dangerous Materials (TRGS) bring together representatives from MWF suppliers, end users, additive suppliers and health and safety experts to discuss and advise the whole of the Metalworking Industry, not just the suppliers, on their findings with respect to specific component issues. The knowledge from these groups, as a result of their long term history, provides obvious validity to any representation that is then made to EU legislators. EU regulation is becoming an increasingly common provider of UK legislation as can be observed with recent issues such as the labelling modifications being applied to hexahydrotriazines and the implementation of the 'Biocidal Products Directive'. It is important that these types of issues are followed from within the UK to allow a close involvement in the prescriptive aspects of the standards and to prevent the proliferation of costly and unscientifically proven legislation.

PURPOSE

The purpose of the Metalworking Fluid Stewardship Group concept has been to bring together those companies that have a commitment to the development, manufacture and marketing of safe and effective MWF products. The Group intends to assist in the education of end users, enhance the health and safety provision to both the members and their customers' employees, consider the protection of the environment and provide qualified, reviewed information to industry, trade unions, government and the general public.

THE CONCEPT OF PRODUCT STEWARDSHIP IS NOT NEW, HOWEVER.

As long ago as the late seventies, the Canadian Chemical Producers Association designed a programme of environmental management that became the forerunner to the Responsible Care Initiative within the Chemical Industry. This Responsible Care Programme, which was launched in Canada in 1986, was adopted in the UK as the first European country to commit to the initiative in 1989. Now recognised in 42 countries around the world, the companies that have signed up to the initiative account for 86 percent of the worlds' chemical supply.

THEIR DESCRIPTION OF PRODUCT STEWARDSHIP IS AS FOLLOWS:

'The chemical industry commitment to responsible care also means a continual improvement in Health, Safety and Environmental performance in products. This is achieved by managing the risks of existing products and developing products with even lower environmental impact. Product Stewardship addresses these challenges by seeking to identify the HS and E risks associated with a products use and the parties who design, develop, handle or use chemical products down the supply chain. Such a process requires a greater emphasis on a structured approach to hazard and risk assessment, followed by an effective communication strategy to ensure that such risks and the handling procedures necessary to minimise them are properly understood. Product Stewardship is also an effective means of bringing together supplier performance and customer interaction along with promoting co-operation for safe transportation, controlled use and efficient recycling and disposal of products. This is an excellent summation of Product Stewardship values and can apply equally to the approach that is being utilised by the new UKLA Metalworking Fluid Stewardship Group.

AIMS

The Specific Aims of the UKLA Metalworking Product Stewardship Group are:

1. For all members to work to a recognised Code of Ethics with respect to the development, manufacture and supply of metalworking fluids.

2. To liaise with Government Organisations such as the Health and Safety Executive and the Environment Agency to produce informative and educational material and to advise 'best practices' for the control and management of MWFs.

3. To establish a recognised centre of excellence for information relating to health, safety and the environmental aspects of MWFs.

4. To devise a programme of positive promotion to enhance the perception of MWFs with respect to technological improvements and engineering excellence.

5. To conduct a health and safety literature search of identified MWF components, both in the UK and the EU, with information readily accessible to all members.

6. To form a recognised, impartial information conduit between suppliers, end users, government organisations and UK and European Legislators.

MEMBERSHIP

Membership of the Stewardship Group is restricted to members of the United Kingdom Lubricants Association. The Group is funded by annual subscription and, by invitation, members of the Health and Safety Executive and the Environment Agency are included within the Committee. In order to qualify for membership a UKLA member company currently manufacturing or supplying MWFs must exhibit a commitment to health, safety and environmental issues that are evidenced in their supplied products.

ORGANISATION

The Metalworking Fluid Product Stewardship Group meets four times each year to discuss and debate many of the issues that currently affect the Metalworking Fluid Industry. The Organisation consists of a Chairman, Secretary and a nominated Committee Member from each of the Member Companies. Also present at the meetings are representatives of the Health and Safety Executive and the Environment Agency. Industry experts, with very specific background knowledge, are invited to individual meetings to provide a wider understanding of the more complex issues. The Group generates a Newsletter, which is currently available to members only, and liases with the HSE and EA with respect to impending and current legislation issues. Funding is also available for Research Work to be carried out into specific subject areas should it be considered necessary.

WHAT DOES THIS MEAN TO ME AS A USER OF METALWORKING FLUIDS?

Any company that currently uses metalworking fluids needs to be aware of the health, safety and environmental aspects of these fluids. From the protection of the workforce during use to the protection of the environment following disposal it is important to be continually aware of best practices that should be used to control these fluids. Members of the UKLA Product Stewardship Group will be in the most favoured position to offer the most up to date information, advice and knowledge about their fluids. With access also to HSE and EA, they will be aware of any impending legislation or restrictive activity. Most importantly of all, by adhering to the Groups Code of Ethics, you know that you will be working with a company that puts health, safety and environmental issues at the forefront of its development and supply of these products.

HOW DO I KNOW IF MY SUPPLIER IS PART OF THE METALWORKING FLUID STEWARDSHIP GROUP?

Simple! Look for the new United Kingdom Lubricants Association Metalworking Fluid Stewardship Group Logo on your supplier's literature. The Group logo has recently been initiated and will soon appear regularly in many forms. If you want to know now that you are working with a supplier who is a member of the Stewardship Group, simply look below.

United Kingdom Lubricants Association Limited
Tel: 01442 230589
Fax: 01442 249232
e-mail: enquiries@ ukla.org.uk
e-mail: rodparker@ukla.org.uk
Web: www.ukla.org.uk

Regulatory Organisation UKLA MWFPS Group members: -

Environment Agency
Tel: +44 (0)117 915 6287
Fax: +44 (0) 117 915 6244
email: richard.martin@environment-agency.gov.uk

Health & Safety Executive
Tel: +44 (0)151 951 4525
Fax: +44 (0)151 951 3595
e-mail: diane.llewellynl@hse.gov.uk

UKLA MWFPS Group supplier members: -

Arizona Chemicals

Tel: +31 (36) 546 2800
Fax: +31 (36) 546 2895
e-mail: colin.rogers@ipaper.com
Web: www.arizonachemicals.com

Blaser Swisslube

Tel: +41 34 460 0101
Fax: +41 34 460 0300
e-mail: A.Henderson@blaser.com
Web: www.blaser.com

Castrol Industrial

Tel:  +44(0) 1793 453639
Fax:  +44(0) 1793 453218
e-mail: whitehpn@castrol.com
Web: www.bp.com

Chemtura Europe Ltd

Tel:  +44(0) 1753 603097
Fax:  +44(0) 1753 603078
e-mail: Penny.Norridge@chemtura.com
Web: www.chemtura.com

Cimcool Industrial Products B.V

Tel:  +31 (0)1044 50063
Fax: +31 (0)1046 03240
e-mail: boomkamp.bert@cimcool.net
Web: www.cimcool.net

Cimcool Industrial Products UK

Tel:  +44 1536 200699
Fax: +44 1526 406119
e-mail: duncan.kevin@cimcool.net
Web: www.cimcool.net

Croda International plc

Tel:  +44 1642 435356
Fax: +44 1642 435344
e-mail: Andrew.Swallow@Croda.com
Web: www.croda.com

D. A. Stuart Limited

Tel:  +44 (0)1902 877600
Fax: +44 (0)1902 877617
e-mail: gtwiddle@dastuart.co.uk
e-mail: dneadle@dastuart.co.uk
Web: www.dastuart.com

Fuchs UK plc

Tel: +44 (0)8701 200400
Fax: +44(0)1782 284296
e-mail: Paul.Littley@fuchs-oil.com
Web: www.fuchslubricants.com

Houghton Plc

Tel:  +44 (0)161 874 5000
Fax:  +44 (0)161 877 9764
e-mail: kevin.goulden@houghtoneurope.com
Web: www.houghtoneurope.com

Kuwait Petroleum International Lubricants UK

Tel: +44 (0)113 226 5208
Fax: +44 (0)870 238 4678
e-mail: phil.davies@Q8oils.com
Web: www.Q8oils.co.uk

Lubrizol Limited

Tel:  +44 1332 845512
Fax: +44 1733 551915
e-mail: Tony.Jones@lubrizol.com
Web: www.lubrizol.com

Morris Lubricants - Metcut Metalworking Fluids

Tel(Switchboard): +44 (0)1743 232200
Tel (Direct): +44 (0)1743 237522
Fax: +44 (0)1743 245515
e-mail: ailitchfield@morris-lubricants.co.uk
Web: www.morrislubricants.co.uk

Nalco

Tel: +44 (0)1442 450404
Fax: +44 (0)1442 450402
e-mail: jbracher@nalco.com
Web: www.nalco.com

Polartech Limited

Tel: +44 161 876 5673
e-mail: btuoheyl@polartech.com
e-mail: rstubbs@polatech.com
Web: www.polartech.com

Quaker Chemical B.V

Tel: +31 (0)2 975 44431
Fax: +31 (0)2 975 44508 / 40076
e-mail: vosmerj@quakerchem.com
e-mail: reedk@quakerchem.com
Web: www.quakerchem.com

Schulke and Mayr UK Ltd

Tel: +44 (0)114 254 3500
Fax: +44 (0)114 254 3501
e-mail: mark.nicholls@schulke-mayr.com
Web: www.uk.schulke-mayer.com

Total Lubrifiants

Tel: +33 (0)1 41 35 52 74
Fax: +33 (0)1 41 35 51 78
e-mail: philippe.rigaud@total.com
Web: www.total.com

Total UK

Tel: +44 (0)1977 636200
e-mail: andrew.ward@total.co.uk
Web: www.total.co.uk