ILMA LubeTrends Virtual Town Hall: 2023 Year-End Wrap-Up
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Last week, a group of industry experts met with ILMA members in a town hall webinar to discuss the most important issues of the past year and preview the challenges ahead in 2024.
Moderated by ILMACEO, ILMA’s LubeTrends Virtual Town Hall: 2023 Year-End Wrap-Up featured insights from Jim Carroll, executive vice president of operations and ILMA Board member, ILMA General Counsel Jeff Leiter, and ILMA consultant and President of GHS Resources John Howell.
Alfano noted that ILMA is watching or engaged with more than 30 different issues on behalf of members. Panelists touched on just a handful during the webinar.
HCS Updates
Leiter reported that updates to the Hazard Communication Standard (HCS), or “purple book,” are with the Office of Management and Budget – the last step before a final rule is published. Some questions noted by Howell include whether or not OSHA will adopt new concentration ranges in line with what has been adopted by Health Canada; whether OSHA will adopt issues of foreseeable emergencies vs. normal conditions of use; and whether or not a date released for shipment will be required on labels – a change ILMA has argued against.
To be prepared, said Howell, members ask how their SDS authoring software providers will respond to thechanges. Companies that don’t use software will need to have a plan, as it’s likely that every SDS willneed to be amended in some form because the updates rearrange the physical properties in Section 9.
He also noted that Canada’s three-year transition to its updated HCS ends on Dec. 14, 2025.
Used Drum Reconditioning Rule Changes
Leiter addressed a notice of proposed rulemaking (ANPRM) the EPA issued on August 11 that would modify or eliminate the RCRA empty container rule, require rinsing drums before they are turned over tore conditioners, and add labeling and recordkeeping requirements. Read more about the rule in the November issue of Compoundings.
In response, ILMA has put together a task force, surveyed members, met with the EPA, and engaged with other associations (RIPA, IPANA, ACD, others). ILMA submitted detailed comments to the EPA on Nov. 22that push back against the proposed changes and offered to work with the EPA to develop non-regulatory guidance and “best practices.”
Engine Oil Specs
Carroll provided an update on heavy-duty and passenger-car engine oil standards that are in the pipeline, including PC-12 and ILSAC GF-7. He reported that the International Fluids Consortium (IFC)’s GEO-1and GEO-2 are complete except for base-oil read-across guidelines, while GEO-3 – which will focus on energy conservation – is being developed.
Carroll also noted that OEMs are concerned about the slow pace of new specification development and have requested a faster and simplified process.
Oily Wastewater
Leiter gave an overview of an ANPRM that was expected in early 2024 addressing potential changes in used oil management standards, specifically mixtures of used oil and wastewater. After the webinar, ILMA received welcome news that the EPA no longer intends to seek comments on the subject.
Much More
Questions from attendees prompted discussions on the Mexico import ban, extended producer responsibility and whether or not lubricant containers are covered, PFAS, chlorinated paraffins, and more.
Special thanks to ILMA’s official LubeTrends sponsor, Chevron Oronite.