Regulatory Updates

     California Proposition 65

     EPA stated that it will have a proposed rule signed pertaining to regulation of
     hazardous substances under Clean Water Act (CWA) Section 311 by June 2018,
     and a final, court-mandated rule by 2019. The practical impact could be to expand
     EPA's Spill Prevention, Control and Countermeasure (SPCC) Rule to include
     tanks that contain “hazardous substances.” Facilities subject to
...  (READ MORE)

     OEHAA Response to ILMA, 7/16/18
    ILMA Letter to OEHAA5/17/18
     Final Comments from Coalition to CA Chamber of Commerce, 6/6/16                        
     ILMA Prop 65 Comments, 1/25/16
     California Chamber of Commerce Prop 65 Comments, 1/25/16
     ILMA / SHERA Letter to Monet Vela 2 (OEHHA), 4/8/15
     ILMA / SHERA Letter to Monet Vela 1 (OEHHA), 6/13/1

The National Toxicology Program (NTP) completed a two-year study of the
     metalworking fluid, TRIM® VX. ILMA retained toxicologist Dr. 
Wally Dalbey
     to assist in the Association’s review of that study. It questioned...  (

     Letter to Dr. Yun Xie (NTP), Final Tech Report for TRIM® VX, 3/18/16     
     Letter to Dr. Yun Xie (NTP), Abstract and Posted Presentation at
     Society of Toxicology Meeting, 2/29/16
     Master Chemical Comments on NTP TRIM® VX, 2/18/16
     ILMA NTP TRIM VX Presentations, 2/18/16

     Toxic Substances Control Act – TSCA

     EPA is at a crossroads in implementing the "Frank R. Lautenberg Chemical
     Safety for the 21st Century Act" at the two-year anniversary of then-President
     Obama signing the measure into law on June 22, 2016. The 2016 amendments
     were historic, as they were the first substantive overhaul of the primary chemical
     control law in the United States since TSCA was enacted in 1976. 

   EPAs Risk Evaluation Rule Finalized
     EPA has finalized its TSCA risk evaluation rule that describes the internal proce-       
     dures the Agency will utilize to conduct risk evaluations of high 
     chemicals or for substances for which industry requests an... (

     Spill Prevention, Control & Countermeasure – SPCC

   Hazardous Substances Tank Rule
     EPA stated in its Fourth Bi-Annual Update that it will have a proposed rule signed
     pertaining to regulation of hazardous substances under Clean Water Act (CWA)
     Section 311 by June 2018, and a final, court-mandated rule by 2019. The practical
     impact could be to expand EPA's SPCC Rule to include tanks that contain
     "hazardous substances." Since the court approved the settlement... 

     Chlorinated Paraffins

     ILMA Opposes Chlorinated Paraffin SNURs, 9/17/18
     Chlorinated Paraffins Overview                     
     Regulatory Status of MCCPs and LCCPs, 7/6/16

     Chinese Tariffs      

View slides  and a Q&A from a webinar presented by ILMA's new International
     Trade Consultant James Eggenschwiler, addressing the Chinese tariffs' impact on 
     lubricants and additives.

     Globally Harmonized System for Classification
     and Labeling of Chemicals – GHS

The Trump Administration indicated that OSHA will launch a rulemaking by
     February 2019 to update its Hazard Communication Standard (HCS) that was last
     amended in March 2012 to incorporate provisions of the Globally Harmonized
     System for the Classification and Labeling of Chemicals (GHS). OSHA's
     update ostensibly would be to align the HCS with the latest...

    Letter to Health Canada re: WHIMIS 2015 Provisions, 5/23/16                    
     Letter to OSHA re: HCS 2012 Compliance Concerns, 3/18/15
     ULMA GHS Survey Summary, 4/10/14 

     Obsolete Oils


     DOL Overtime Rule
     The Department of Labor (DOL) issued a “request for Information” (RFI) to solicit
     feedback on its overtime regulation. DOL says it intends to issue a proposed rule in      
     January 2019 and speculation is that the salary threshold in the new proposed rule
     will be in the $30,000-$35,000 range. The invalidated Obama administration rule
     that was stayed nationwide in November 2016 would have more
... (READ MORE)      

     Waters of the U.S.

The Environmental Protection Agency (EPA) and the U.S. Army Corps of
     Engineers (Corps) issued their final “Waters of the U.S.” in 2015. The final rule
     identifies six types of waters that are within the two agencies’ jurisdiction and
     two categories of waters for which a case-by-case determination is required.
     While EPA and the Corps contended that they have merely
...  (READ MORE)            

     ATF Transmission Fluid Labeling Requirements

     On January 1, 2018, updated labeling and documentation mandates for trans-
     mission fluids go into effect automatically in 19 States based on amendments to            
     NIST Handbook 130 adopted this past summer by the National Conference on
     Weights and Measures (NCWM). The regulations recognize that many oil
     marketers make and sell "suitable for use" or "multi-vehicle..."  (

     Federal Trade Commission (FTC)  – Recycled Oils Rule

     The Federal Trade Commission (FTC) sought public comment on the costs and
     benefits associated with its Recycled Oil Rule (Rule) in 2018. The Rule,
     promulgated in 1995 pursuant to the “Energy Policy and Conservation Act”
     (EPCA), permits manufacturers and other sellers to represent on a recycled engine-
     oil container label that the oil is substantially equivalent to new...  (READ MORE