WHERE HAVE ALL THE MICROBICIDES GONE? LONG TIME PASSING…
How many of you recall the Bob Seeger song: Where have all the flowers gone? It seems that it might be time to modify the lyrics by replacing the word flowers with biocides approved for use in metalworking fluids (MWF). I admit, that’s a mouthful, but the reality is comparable to that behind the original song. The list of active substances for which Biocidal Products Regulation (BPR) dossiers have been submitted includes a mere 27 actives intended for use in MWF. Less than 10 years ago, there were more than 100 options. The dust hasn’t yet settled in the USA, but once the US EPA’s Office of Pesticides Programs rules on the maximum permissible dosage of triazine in MWF later this year, it’s likely that the ASTM E2169, Table 2 list of active ingredients approved for use in MWF will be a fraction of its original length. Perhaps, when compared with our European friends, we are still lucky in the USA. A literal reading of the BPR’s definition of a Biocidal Product suggests that all MWF are Biocidal Products. The UEIL is advocating that MWF be formally recognized as Treated Products (the cost impact is an estimated $250,000 U.S. per MWF formulation – not trivial). Regulators have promised to give UEIL’s arguments full consideration, but nothing has yet been put in writing. I reviewed the latest state of affairs in my January 2016 TAE presentation. Please contact me if you are interested in receiving a copy of the manuscript: Impact of Biocidal Product Regulation on Microbial Contamination Control in Metalworking Fluids.
