Classifying Finished Lubricants

How Do You Classify Your Lubricants?

 

The Challenges of Classifying Chemical Mixtures

The early twenty-first century introduction of global chemical control laws, like REACH, and global chemical substance inventories, like TSCA, has led to a significant increase in available substance test data. However, this increase has given significantly less consideration to addressing chemical mixtures. The presumption is that GHS calculation methodologies based on substance data are the solution. However, reality often proves less simplistic as using a substance-based calculation methodology tends to lead to more severe classifications than are accurate for a chemical mixture.

In addition to a presumptive “over classification” of a chemical mixture, any mixture classified using a calculation methodology is forever open to re-classification the moment new substance data is generated. Given the moving target of regulatory trends, formulators could easily anticipate reviewing, re-classifying and re-labelling their chemical mixture products frequently. 

Additionally, increased and inconsistent enforcement measures emphasize an apparent need for justification being incorporated into certain classification bases. Good record keeping is an obvious start to securing supporting data, but is there then a better way to approach a resolution of these issues?

Mixture Test Data 

The tiered approach used for the GHS classification of chemical mixtures, confirms an understanding that despite the ostensible agency focus on chemical substance testing under most chemical control regulations, GHS mixture classification first focuses on testing the chemical mixture itself, including use of read across test data from similarly structured chemical mixtures.

Relying on data points from mixture testing can lead to conclusions that the classification of chemical mixtures using this method will be:

• Correct, and probably less severe than substance-based calculation methods;
• Unlikely to alter for the tested endpoints; and  
• Justified and documented using an independent test report/summary. 

While chemical mixture testing can be expensive, where these mixtures can be grouped together (thus pooling testing resources), and the endpoints result in low hazard or environmental classifications, chemical mixture testing appears to present a rather attractive alternative proposition for chemical mixture manufacturers and distributors.

Applicability to Lubricants Manufactured with HiTEC® Performance Additives 

Afton groups lubricants based on each lubricant product’s use of HiTEC® Performance Additives at their approved treat rate per the bridging principles described in GHS. Testing can then be carried out to support the GHS classification for each group of lubricants. Many of the chemical mixture testing for the groups of lubricants noted (and based on the aforementioned elements) are now complete, and in many instances, Afton can provide test summaries to customers who require supporting information regarding GHS classification of their lubricant.

Conclusion

Maintaining test data supporting classification of your lubricant product offers: 

• Confidence that the GHS classification is complete;
• Reduced likelihood of changes to your labelling and any related disclosures; and 
• An established plan for inspections and compliance.

Because generating test data for each individually formulated lubricant is both time-consuming and expensive, Afton’s approach can provide customers with test data that can easily support the GHS classification of any of those lubricant products manufactured using Afton’s performance additive technologies and products.  

If you would like more information about this, please contact Afton through your sales representative or by using the email [email protected].