ILMA Compoundings – October 2019 - 34

However, managing public perception and effectively
explaining the role that the lubricants industry plays in the
phosphorus discussion is challenging. "The fact that not all
phosphorus exists in the same form and that different forms
have drastically different environmental profiles makes it
exceptionally difficult to message this accurately," said Julie
Thomas, global environmental health and safety manager
for Master Fluid Solutions. "This is consistent with the
issue that exists when trying to message the fact that not all
boron-, not all silicon- and not all chlorine-containing materials used in metalworking fluids are problematic."

Regulatory Action

Industries have been reducing phosphorus use since the
1960s. "Detergent was the first industry to really lower
its use," Burke said. "Then, industry said we'll treat for
phosphorus by putting in wastewater treatment to take
phosphorus out of our wastewater."
"Phosphorus in fertilizer has already been under voluntary
reduction initiatives, but the voluntary measures the farmers
agreed to [are] not working," Burke said.
One year after the Toledo drinking water crisis, elected
leaders in Ohio, Michigan and Ontario, Canada, committed
to a 40% reduction of phosphorus in Lake Erie by 2025.
The agreement included an interim goal of a 20% reduction
by 2020, the Alliance for the Great Lakes reported.
The U.S. Environmental Protection Agency (EPA), along
with Environment and Climate Change Canada, has already
passed a rule to reduce the amount getting into Lake Erie's
western basin by 40% by 2025 from the baseline year of 2008.
"If they put a ban of 40%, then people will just say you
have to reduce your phosphorus load in lubricants by 40%,
but we're not the major contributor, and it isn't the right
form of phosphorus," Burke said.
In addition, the Great Lakes Restoration Initiative (GLRI),
which was formed in 2010 and has sought $300 million
each year to fund its action plans, will receive full funding
next year. President Donald Trump's proposed 2020 budget
had cut GLRI's funding by 90%. The GLRI works with
federal agencies and states on establishing action plans, with
objectives such as controlling invasive species and restoring
the economic and ecological vitality of the Great Lakes.
"ILMA has been following the GLRI closely because of
the efforts to reduce phosphorus reaching the Great Lakes,"
said ILMA CEO Holly Alfano. "While most industrial discharges of phosphorus are already controlled, the initiatives
in the Midwest could affect members' use of the substance
in their products."
In February, Toledo voters passed the Lake Erie Bill of
Rights (LEBOR), a charter amendment that establishes

OCTOBER 2019

| COMPOUNDINGS | ILMA.ORG

"The fact that not all phosphorus exists in
the same form and that different forms have
drastically different environmental profiles
makes it exceptionally difficult to message
this accurately."
Julie Thomas, global environmental health
and safety manager, Master Fluid Solutions
the lake as a "person" and grants it the same legal rights as
a human being or a corporation. The LEBOR will allow
the citizens of Toledo to act as legal guardians for Lake Erie
and to sue polluters for cleanup, restoration and prevention
program costs.
In late 2018, the EPA announced the reestablishment of
its Great Lakes Advisory Board (GLAB). The GLAB was
initially established in 2012 pursuant to the Federal Advisory Committee Act, but its charter expired in June 2018.
The EPA is reestablishing the GLAB to provide advice and
recommendations to the agency through the Great Lakes
National Program Manager.
The GLAB will advise the EPA on matters related to the
GLRI and the implementation of the Great Lakes Water
Quality Agreement between the U.S. and Canada.
Thomas said any legislation that impacts functional performance, overall quality and cost is of importance to the industry.
"Over the last two to three decades, numerous classes of raw
materials have become unavailable for use in metalworking
fluids because of issues with compliance, to the point that the
number of chemical choices available to drive certain areas of
functional performance have been drastically reduced," she said.

The Need for Phosphorus

Those within the lubricants industry said it would be
extraordinarily difficult for the industry to remove phosphorus in all forms. "The phosphorus-containing materials that
are either water- or oil-soluble utilized in metalworking
Continued on page 37

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