STLE held our annual meeting in Dallas two weeks ago. During the meeting I had the pleasure of chairing the MWF 210 – Metalworking Fluids Hot Topics course. Too many hot topics to cover in a blog post, so I’ll focus on my course module: Microbicide Regulatory Roulette Wheel.
The metalworking industry is facing a regulatory tsunami. The EU’s Biocidal Products Regulation (BPR; replaced the Biocidal Products Directive in 2012 and became effective in September 2013). Two items of particular note about the BPR. First, as with all chemicals under REACH, products are evaluated based on their assessed hazard instead of the risks they pose (risk is a function of inherent hazard AND exposure; for example: molten lava is extremely hazardous, but only if you are exposed – get close enough – to it). Second, the definition of “biocidal” is astonishingly broad; “Any substance or mixture, in the form in which it is supplied to the user, consisting of, containing or generating one or more active substances, with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on, any harmful organism by any means other than mere physical or mechanical action.” AND “Any substance or mixture, generated from substances or mixtures which do not themselves fall under the first indent, to be used with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on, any harmful organism by any means other than mere physical or mechanical action.” I’m left wondering what might be left in terms of MWF additives. I’ll write more about what is happening in the US in my next post.
