October Scares

The end of September saw Baere folks at the SAE E-34,  AMS -M, and E-38 Lubricant Meetings held in Nashville, TN.  And things were pretty much as expected; continuing to keep the aviation turbine and piston oils and lubricants standards up to date and correct, discussing the best practices for testing, and exploring communication.  There were, however, two major topics that were particularly pertinent to Baere and its clients.

     The first was the effort that has been underway to address piston engine oils.  SAE has two standards for aviation piston engine oils, an ashless dispersant oil (J1966), and a non-dispersant mineral oil (J1899).  These two standards have been under the US Navy purview for decades and the US Navy holds the qualified products list (QPL).  Back when the military decided to get out of the military specifications business, these two standards were moved over to SAE pretty much as written.  This included all the testing requirements to become a qualified piston oil.  For a very long time, this was not an issue as there was not much interest in entering new products into this market, changes that were made were to the same few products but they were not dramatic and were on the same known products, and to be honest, the piston aviation engine market wasn't evolving very much.  However, with the unleaded aviation gasoline efforts, it was recognized that there were likely to now be engine changes and possible engine oil changes.  And there were requirements to understand how the new fuels would impact the engine oils.  So a group of volunteers tackled updating the two standards.

     One of the things we learned was that there was a test required which could only be run by the US Navy, a business that they would like to not be in any more.  The second thing we learned was that if the US Navy was no longer going to be in the business of maintaining the QPL, well, SOMEONE needed to be.  And fortunately, SAE has the means to serve this function through a committee called the Qualified Products Group (QPG).  So our E-38 subcommittee has worked very hard to get everything in place to transition to the QPG.  This is not a trivial thing, as SAE and the industry volunteers take qualifying products pretty seriously.  OK, that will address the qualified products.  And we are still working on getting everyone comfortable with the testing that will now be required that will not have to be done by the US Navy.

     This is pretty important and timely, as it was discovered that there are oils being produced "out there" that are marketing as being "compliant" to the SAE standards.  They were products for which none of us had seen data, and given that there was testing that could only be done by the US Navy, which restricted access to US and NATO allies, we were pretty sure they had not done ALL the SAE testing.  This did not mean there is necessarily a problem with these oils, we literally do not know.  Given that SAE is standing up a QPG for the piston oils, and there is a better means of testing non-US oils, there is good reason to distinguish between producers that have done the work to be qualified, and those that have not.  This led the group to discuss how to make sure the owner/operator could easily and reliably identify that the piston engine oil they purchased was indeed a QUALIFIED product and not just a "compliant" oil.  This included things like better communication in the engine manufacturers' documentation and service bulletins, to label markings like those on automotive oils.  This topic is still under exploration, and if you have comments, let SAE, Subcommittee E-38 know.

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     The other rather Earth shattering discussion was that of the ECHA's intention to restrict around 10,000 per- and polyfluoroalkyl substances (PFASs). ECHA’s scientific committees began evaluating the proposal in terms of the risks to people and the environment, and the impacts on society in February, 2023.  Our SAE group was given a presentation on what this actually would mean to our industry by a representative from Chemours, a global producer of products containing these fluorinated compounds.  And it was eye-opening.  As the dossier was written (for which the comment period closed at the end of September), ANY product using a CF2 or CF3 molecule in its production or end-product would be banned immediately.  Products with "critical" use requirements and a "demonstrated lack of replacement" could be given a three (3) or eight (8) year delay in which to identify a suitable replacement.  This means many of the critical polymers: fluorocarbons (Viton tm), fluorosilicones, and polytetrafluoroethylene (Teflon tm), and lubricants: Krytox tm, Braycote tm, would be gone.  No Teflon back up rings, no Krytox high temperature greases, no fluorinated heat exchanger fluids.  This has been presented as a complete and total restriction. 

     According to the speaker, Dr. Vieira, this is being presented for all materials whether they are small, biologically available molecules or large NON-biologically available molecules.  Because PFAS are persistent, that is they don't break down (which is one of the reasons we use them), they stay in both the environment and in the human body.  And indeed, the bio-available PFAS molecules are known to be carcinogenic and have been banned in the US on a state by state basis for several years.  No one argues those molecules are a problem and should be restricted.  But the justification for the elimination of large molecule PFAS which are not bio-available, and thus cannot be carcinogenic, is unclear. 

     The good news, if there is any, is that ECHA has said they will read and review every response they received, including the provided data, and attempt to incorporate those deemed pertinent into a revised dossier.  Dr. Vieira said that ECHA had said that the new dossier, and thus new comment period, would open in November, 2023.  However, there has been a significant global response to the wide ranging and detrimental impact such a far-reaching restriction would have on the global economy.  This would dramatically impact defense, automotive, aviation, aerospace, medical, and clean energy industries among others at a crippling level.  And ALL of these industries responded from all around the world.  I asked what we should plan to do next and Dr. Vieira told us be ready to comment again, preferably in a coordinated way, through our representative organizations, our industry partners, and our governmental agencies.  I also asked would Chemours send people to talk to our groups, and she said most definitely, YES.  So, if you have questions, and I hope you do, then contact your fluorinated products provider.  Or contact the Lubricants and Surface Protection Solutions unit of Chemours and ask for them to explain this.  This is a big one and will dramatically change every industry on the planet, assuming it doesn't destroy those industries completely.