Management Plan

Management of the metal removal fluid processes is the most important step in minimizing exposure and reducing health hazards. There are many factors that affect the generation of MRF mist, all interacting with each other, so an approach that takes the entire system into account will be the most productive and cost-effective. Addressing only one or a few of the issues will probably be ineffective, while dealing with all of the issues in a systematic way will benefit the machine builder or rebuilder, the MRF supplier, and the machine user.

The use of MRFs in metal machining operations, as well as the assessment and control of employee exposures, is exceedingly complicated. To date, no single cause of the symptoms associated with MRF exposure has been identified. For safe and effective use of MRF, all the aspects of the total system need to be addressed in a written MRF management plan. An MRF management plan can be simple or complex, but it should define how the systems involved will be maintained.

Statement of commitment and goals

This indication of management commitment and what goals it wants to achieve should include a broad reference to managing and controlling MRF, promoting product quality, and preventing health problems. It could also contain a definition of what is considered success.

Designation of overall responsibility for performance of the system

This generally should be an individual, but may be a team. The person(s) coordinating the fluid management program should receive input from all available sources along with information on finished part quality, production quantity, and production cost data. For those with overall responsibility for a system’s performance, a thorough understanding of the chemistry involved is important.

Designation of responsibility for adding materials

All system additions of any kind should be controlled and recorded by this individual or team. Such additions may include fresh biocides, MRF fluid additives or concentrates, and water or oils to make up volume lost through normal operation of the system.

A written standard operating procedure (SOP) for testing the fluid

Such a standard operating procedure (SOP) should include

where and when to collect the samples to be tested

how they should be treated after collection

which tests should be performed

a specific protocol for each test performed

who is responsible for performing and recording the tests

A data collection and tracking system

For more information on fluid condition, see Maintenance and Testing.

The data should include observations made at the system, laboratory analyses, and data on additions made to the system. This data should be tabulated in a manner that reveals relationships and trends in the data, and this information should be used to improve fluid management techniques. These techniques can often be generalized to smaller machines and systems with reduced laboratory testing to allow their successful management. Production and quality data may also supply useful information on the performance of the system.

The data collection and tracking system should be set up so that feedback on system condition allows corrective actions to be taken before the system develops problems. Factors recorded and tracked should be at the discretion of the MRF manager. These factors should be prioritized and customized for specific facility situations. For example:

1. concentration	6. biological contamination
2. pH	7. tramp oil and invert emulsions "cream" contamination
3. foaming tendency	8. biocide levels
4. water quality	9. corrosion resistance
5. system stability	10. emulsified oils

Employee
participation

The only way to effectively manage MRF is to enlist the aid of the people who work with the system every day. This should include personnel from manufacturing, maintenance, technical support groups, and MRF lubricant and machine tool suppliers. Workers who operate the machines are the real experts on the operation of the system, but usually they are not scientifically trained observers. They should be trained to understand how a MRF works and what affects it. System personnel should have a basic understanding of the laboratory tests and have the results available to them in an easy-to-read and understandable form. There should be a simple way that workers can submit their observations to those responsible for system maintenance. Worker observations should be documented and correlated with the laboratory data and any chemical additions.

Training programs

These should be designed to help workers understand the basic functioning of the system. For instance, what can affect the proper functioning of a particular MRF system and shorten or prolong its useful life? What are the warning signs of impending problems, and what happens when a system goes bad?

Please refer to the training section of this guide for details on what exactly such a program entails. See also the OSHA Hazard Communication Standard 29 CFR 1910.1200. Health and Safety Program also contains relevant information.

Guidance on when to DCR a MRF system

Even well managed systems eventually reach the end of their useful life. System managers should develop guidance on when a system needs to be drained and how this should be accomplished.