Banned to Aid the Environment: Oil in Your Shop!

Sounds like an excellent opportunity for entrepreneurship.

I noticed that the socio-economic assesment in 1144 is the shortest paragraph with absolutely no information.

Will definately give this a detailed perusal. Though I'm in Canada the rules will eventually apply here......with what I perceive to be a negative impact on manufacturing.

Thanks for the heads up Milo

http://www.pmpa.org/index.cfm?fa=viewArticle&b_id=557

In our comments on October 29, 2008, we reiterated the need for light viscosity oils for

machining in multiple spindle and single spindle cam type automatic machines. Our

comments were confirmed by other respondents and this requirement should be

recognized as settled fact. In the event that no Proposed Rule 1144 compliant light oils

are identified (none have been identified to date, despite Mr. Sam Atwood's comments to

the press) our only alternative would be aqueous metalworking fluids. We provided

evidence, again confirmed by others at the hearing, that the aqueous fluids would -1)

destroy our machines; 2) lower their value; 3) reduce our productivity; 4) raise our costs

for consumable tooling and accessories; and 5) require a transition cost many times the

v.1001081550

estimate provided by SCAQMD. Our experience, as related in the letter of Mr. Chuck

Tellas of Milan Screw Products, dated October 25, 2008, (attached) in which he

described his 1994 experience, documents a transition cost alone of $300,000 for his

multispindle shop. The socioeconomic costs of compliance used by the SCAQMD are no

where near the magnitude of the actual experience documented and presented in our

comments.

Testimony that even heavier oils than 60 SUS may fail the VOC test as viscosity is

achieved by blending

We noted that several speakers from the oil companies / suppliers attending the meeting

indicated that it was possible that even heavy oils (100SUS) could elute VOC's due to the

refineries' practice of blending to make up targeted viscosities. This practice could make

any of our shops noncompliant without our knowledge. The proposed rule as written does

not even recognize this as a possibility. Until the properties and formulations of

metalworking fluids are better understood by SCAQMD staff, it is best to omit oils from

the VOC limits proposed. Our entire industry........I suggest everybody involved in this industry read on.

Governments will, as governments do, undoubtedly use the proposed model (thoughtlessly) if there is no resistance to it. If machining is negatively impacted I cannot think of one industry that will not suffer as a result.

Seems to me that the time when the loss of 3000 more jobs in a region of 20M population could be just shrugged off ended last month. Now we've got 6.4% unemployment in the USA. Time to tell the SCAQMD and their political supporters to go back to their caves and leave the rest of us alone while we rebuild our economy and our national job base.

Or how about a $5/gallon air quality improvement mitigation tax on all laquer thinner and mineral spirits sold in hardware and home improvement stores. Then see if 3000 machinists threatened with losing their jobs can scream louder than a few grumbling do-it-yourselfers. The machinists could always try picketing the local Home Depots with "polluter" signs.

BTW do the same rules apply in the Antelope Valley just north of LA? I realize that Lancaster is not exactly the garden spot of the Earth; but then again it's really not the armpit either......

Ed Weldon

I think if this ruling goes through it will become a model for other government/county agencies to mimic. It's just a question of time till it becomes self-perpetuating.

GAWD am I glad I left California and came back to the Northwest!! It gets crazier every year!!

Bill

No wonder it cost so much to live in California. Let us run off all our manufacturing so we have to import it all at higher prices.

Sounds like greenwash to me. I wonder what the real agenda is?

Maybe someone poor coolant meets the new specs or even some one wants funding to develop a new coolant because they can't get any marker share any other way.

If not I'll have to take my planned manufacturing out of North America. That means: No taxes payed here; no jobs created; no need for local (US) services; special/emergency orders take days so major down time losses for customers; I'll make more profit and can afford to be even more environmentally conscience.

To change a system to the desired end you first need to have the fix in hand and then legislate the change. I don't see the need for the change and their fix will harm them more than terrorism ever has.

Brad

"If not I'll have to take my planned manufacturing out of North America."

Actually, Brad, given the environmental record of manufactiuring in China, That just amounts to "exporting" our Polution.

I am certain that the VOC load wherever they will be run if these jobs are exported will be more than 1.9 tons per day, and disposal may mean poured on the streets and parking lots for "dust suppression" so oils and solvents will get into ground water too.

But, "as long as it isn't in our 4 county air district, we wash our hands."

Thats what is so aggravating- the pontius pilate smugness while indifferent to our jobs.

milo

Sorry not China and one does not have to make pollution to manufacture. These idiots would ban CO₂ from beer and wine. I suspect their motivation and their fix. Coolant waste both liquid and gaseous can be dealt with. Eliminating them is economical suicide.

Then again we could arrange for a large milling of magnesium for their pleasure without oil emulsion coolant.

One can not ban a problem like this, it doesn't work. Deal with it, fix it or die. Silicon Valley would have to move unless cheap effective replacement coolants can be had.

As for China's pollution it is but a drop compared to Europe's and America's over the last 200 years. Forget the CO2 but Sulphur, mercury, lead, pesticides, PCBs and fertilizers to name a few. China has one thing we did not. The knowledge available to know why it is bad and how to fix it. They are learning at a speed we never had the access to.

Profit will force them to change. short term polluting makes them money. Long term it cost them more than they made short term. They have a surplus of labor but when their skilled labor is having heath problems they will come around. It's not like they have to learn the cause. Hopefully they will be more proactive but politicians rarely are. Nor do I think these are in California. May time prove me wrong.

Brad

What do you think international 'fact finding missions' are! The few I've been involved with are nothing other than legislative committees attempting to butter their own bread courtesy of the public trough.

No butter.... no bread. Hopefully the post mortem will be headed by a review panel.

Pork barrel politics at its finest. The norm not the exception.

I'm guilty of wanting McCain to Leave Palin as president for what ever reason and she would route out some of the scum from the system.

Oh well the fleecing of America goes on.

Brad

Maybe it is time to challenge the very legitimacy of the SCAwhatever board.

Not everything, that a couple holier than thou's cobble together should be allowed to stand just because it was said. Just for starters I bet, that the natural oil seepage in the ocean puts somewhere 100 to 100thousand times volatile compounds into the air, then your whole local industry. Let them try to regulate that first. Then maybe next foreign ships, then the navy, then trains, etc, etc. Oh, and let not forget pine trees. They exhale hydrocarbons in quite respectable amounts.

If they can't or won't regulate mother nature, and the big users wont give them the time of the day, I do doubt, a court challenge - preferably with a threat of personal liability - for singling a "small fish" out, could not let them see the light. Calling it willful harrassment - that is not permissible for local officials - is a good start to make it personal. I know a couple of builders. They told me stories with that kind of tit -for-tat going on regularly.

Some dense tinpots see reason only when their own ass or pocketbook is on the line.

Your comments are rooted in fact, The indians called the LA basin the "valley of the smokes" long before the gold rush brought California into world prominence in 1849...

The truth is that the valley would not be in compliance with federal air quality standards even if all the people were moved out because of the areas geography and naturally occuring hydrocarbons (La brea tar pits to name one) and fires from lightning strikes, dust, etc. (

Its a charming fiction, these attempts to regulate what will never be in compliance...

milo

If I was a satirist, then I'd probably make some comments about looking beyond your own yard and see what's happening worldwide.

VOC regulation has been on the books for over 10 years in Europe and the limits that you are talking of seem to match their expectations. Painting systems worldwide have been working towards VOC elimination, soldering fluxes have moved into VOC free world, and the rest of the world is choosing to move along the path to eliminate VOC contamination. If you haven't been watching, then I'm sorry.

What makes you think that your particular industry is so important that you should be exempted from the necessary progress?

(This question is partly tongue in cheek, I've been on at least five implementation committees to eliminate some chemical processes from our facility and there are always challenges when faced with the inevitable.)

There may need to be some process changes to overcome the difficulties, but you will find the path forward. Sometimes the changes "forced" on us cause us to find commercially better methods. That's part of our challenge as Engineers rather than merely maintain the status quo.

We used to use 200L of MEK per day back in 1998, it took us a year to get there, but we got to a point of the site now being MEK free and also reduced cycle time around 20% and operators no longer had to wear breathing aparatus on that job and the cleaning consumables became almost nothing.

You've had your winge, now put on your engineers hat and find the solution to this challenge. (Because the Europeans are well and truly ahead of both our countries at the moment.)

Thanks. I accept your good will and admire your thinking to engineer this to success.

However, because this is limited to 4 counties, THESE AFFECTED SHOPS WILL NOT be competitive, and will die because of this technologically uneven environmental rule. Even if a legal replacement were available at say three or four times the cost of conventional fluids, this would make these shops non competitive with shopsoutside the 4 county area.

Just because something has been done in europe doesn't make it right. We have been getting opportunities to bid on european jobs precisely because the europeans can no longer afford to make them under their increasingly more difficult environmental rules.

The fact is that this local rule is illconceived, not science based, and piecemeal in effect, rather than part of a rational, holistic minimum total impact plan.

So 300 jobs and 111 companies shouldn't be crucified on this lousy piece of commitee work.

Thanks for your appeal to engineering reason.

PS, I have been watching. I've seen the results of those VOC free paints you mentioned. They rust through far faster than the VOC paints they replaced. And while hexavalent chrome ban isn't VOC ban, the trivalent replacements for hex Cr are totally inadequate to the task, thats why even the Europeans exempt Cr6 for certain military applications; same with lead solders for miltary electronics. So meaning no disrespect to the Europeans, I ask is the world really safer/ better off less Loss to the common good after these rules? It has not been proven to be yes. Well meaning? Yes actually better off???? I don't think 300 unemployed machinists will say yes. nor their kids.

milo

Milo -- I saw the number 300 in your post and thought it was a typo. Then I saw it a second time. Is the estimated number of potential lost jobs 300 or 3000?

Ed Weldon

Sorry for the typo its 3000 based on 111 shops in NAICS 332721 in those 4 cointies per Harris Directory and 27 jobs per shop per US census. It is a deliberatley low estimate- Mag Instruments maker of (mag flashlight) employs over 1000 alone. When one is advocating against the powers that be, overreaching does not give credibiliy, only vulnerability

Other metal working shops (metal stampers screw nut and bolt, cold headers0 jobs all are in addition to my 3000..

milo

Thanks Milo,

And that does not include their customers who are dependant on quick turnover parts for both R&D and repair. How many of them will become non-competitive by this? And how many services depend on them and the 111 shops for business?

As greenies they should understand complex dependencies of dynamic systems, nature is full of them. Of course I don't expect analytical thinking from emotional courtiers.

From Wiki - In modern literature, courtiers are often depicted as insincere, skilled at flattery and intrigue, ambitious and lacking regard for the national interest.

Brad

Interestingly, the fuel vapor recovery system parts we see at our gas stations nationwide, not just in California, are produced by some of our shops there. Can that business be moved? Yes. Would such a development be ironic? You betcha. Where else but in Southern California would eliminating the manufacture of devices that clean the air be seen as a victory for clean air?

milo

It seems that nearly everyday you here of some stupid thing some idiot that has probably never worked a honest day in his life came up with. I will guarantee that the guys that come up with this crap are not really seeing the full consequences of there proposals. The real scary thing is that they know how manipulate the system to get what they want. I feel sorry for anyone who has a shop or industry in California and don't see why anyone would ever think about starting one there.

pipewelder

The last production shop that I worked in had the machines ducted into Smog Hog condensers. The smoke that at one time would have been vented out the windows was reclaimed into 55 gallon drums and reused. The result was noticably cleaner air and less money being spent on cooling oil. I see no reason why this couldn't be extended to mineral spirits and the like.

As post #1 said: "Sounds like an excellent opportunity for entrepreneurship."

Perhaps if an honest effort was made to reduce the emissions a ban wouldn't be necessary. We would also reduce the purchases of what has become a very expensive commodity.

Thanks for sharing your experience,Wingnut. Most of our shops already have smog hogs and the like. Many for a number of years. They are not acceptable control technology to rule 1144 as they are not 95% efficient in recovery. To get to that efficiency would require expense FAR IN EXCESS of the implementation cost claimed by SCAQMD.

We are not opposed to technological fixes, but to be mandated to implement business killing restrictions whose cost is not fairly recognized is a showstopper. If the SCAQMD promulgated the rule based on honest costs per ton to implement, rather than their current lowball estimate, they would NOT BE BANNING OILS< ONLY SOLVENTS. Based on their current draft, there will be a large loss of metalworking jobs, and its not because of lack of entrepreneurship... Its because of lack of understanding, and the fact that this rule will make this area noncom-petitive in the world market. Its the "let them eat cake" mentality, writ large.

Interestingly, the SCAQMD does not recognize acetone as a VOC... So it is unregulated. Go figure.

milo