Metalworking Fluids and REACH: How to Ensure Compliance with Legislation and Minimize Health and Environmental Risks

Photo: Ant Rozetsky / Unsplash

Metalworking fluids are an essential part of modern metalworking, but their use is subject to strict legislative requirements. The REACH and CLP/GHS regulations impose obligations on manufacturers, distributors, and users of chemical substances, including the obligation to provide safety data sheets (SDS) and correctly classify hazardous properties. In practice, this means that every metalworking fluid must not only be technically effective but also safe for employees and environmentally friendly. How can you navigate these requirements, and what should you specifically monitor when selecting and using fluids?

REACH and metalworking fluids: Basic obligations for manufacturers and users

Metalworking fluids, whether emulsions, synthetic, or semi-synthetic mixtures, fall under the REACH regulation as chemical substances or mixtures. This means that every manufacturer, importer, or downstream user (such as a metalworking company) must ensure the registration of substances contained in the fluids if their annual volume exceeds one tonne. REACH emphasises the identification of hazardous properties and their communication within the supply chain, which is reflected in safety data sheets (SDS) and labelling according to CLP/GHS.

For manufacturers of metalworking fluids, it is crucial to verify whether all components of the mixture have a valid REACH registration. If the fluid contains substances on the Candidate List (SVHC), this information must be clearly stated in the SDS and communicated to customers. Users of the fluids, in turn, must follow the instructions in the SDS, such as those regarding exposure scenarios, protective measures, or disposal methods. Failure to comply with these obligations may result in legal penalties and endanger the health of employees.

Safety Data Sheets (SDS): How to Read and Apply the Information Correctly

The Safety Data Sheet (SDS) is a fundamental document for working with metalworking fluids. It must be prepared in accordance with REACH and CLP regulations and contain 16 mandatory sections, including hazard identification, composition, first aid instructions, fire-fighting measures, or information on ecotoxicity. For metalworking operations, it is essential to pay attention to sections 2 (hazard identification), 7 (handling and storage), and 8 (exposure controls and personal protection).

A practical example could be working with liquids containing chlorinated paraffins, which are classified as hazardous to the aquatic environment. The SDS must provide specific handling instructions, such as the need to use closed systems or wastewater filtration. It is also important to monitor exposure limits (e.g., DNEL or PNEC) and ensure their compliance through technical measures, such as extraction systems or personal protective equipment. The SDS should be regularly updated and accessible to all employees.

Photo: Ümit Yıldırım / Unsplash

CLP/GHS: Correct labelling and risk communication

The CLP Regulation (Classification, Labelling and Packaging) harmonises the classification and labelling of chemical substances and mixtures in the EU according to the GHS (Globally Harmonized System). For metalworking fluids, this means that packaging must be provided with warning symbols, signal words ("Danger" or "Warning"), and standard hazard statements (H-phrases) and safety instructions (P-phrases). For example, a fluid with a high mineral oil content may be classified as flammable (H226) and irritating to the skin (H315).

For metalworking operations, it is important that employees understand the meaning of these symbols and phrases. Training should include practical demonstrations on how to handle fluids correctly, such as how to prevent skin contact or inhalation of aerosols. It is also necessary to ensure that all packaging is properly labelled and that fluids are not decanted into unlabelled containers. The CLP also requires that hazard information be available in the language of the country where the fluid is used.

Minimising Risks: Technical and Organisational Measures in Practice

To minimise the risks associated with metalworking fluids, metalworking operations should combine technical and organisational measures. Technical measures include, for example, the installation of enclosed machining systems that limit aerosol formation or the use of filtration units for waste fluids. It is also important to regularly monitor fluid quality, such as measuring pH or bacterial concentration, to prevent degradation and the emergence of health risks.

Organizational measures then include employee training, implementation of work procedures, and regular equipment maintenance. For example, when replacing fluids, it is necessary to follow procedures for their safe discharge and disposal to prevent environmental pollution. Furthermore, it is advisable to implement a system for monitoring employee exposure, for instance through regular medical examinations or measuring the concentration of harmful substances in the air. These steps not only ensure compliance with legislation but also enhance safety and operational efficiency.

Photo: Le Trung / Unsplash

Selecting machining fluids in compliance with REACH: Criteria and certification

When selecting machining fluids, it is crucial to consider their chemical composition and compliance with the REACH regulation. This means preferring products that do not contain substances listed on the SVHC (Substances of Very High Concern) candidate list or the list of substances subject to authorization. Manufacturers and suppliers should provide transparent information about the composition of fluids, including the concentrations of individual components, and confirm their registration in the ECHA database. It is also important to verify whether the fluid meets requirements for biodegradability and low toxicity to aquatic organisms, which is particularly relevant for water-dilutable emulsions and synthetic fluids.

Certifications such as Ecolabel or other environmental labels can serve as a useful guide for selecting more sustainable alternatives. These certificates often guarantee not only a lower environmental impact but also better working conditions for machine operators. When purchasing, it is advisable to request documentation from the supplier confirming compliance with REACH, including up-to-date Safety Data Sheets (SDS) and declarations of the absence of prohibited substances. This minimizes the risk of later complications during inspections or audits.

Management and Updating of Safety Documentation in Operations

Safety Data Sheets (SDS) and other documentation related to machining fluids must not only be available in the workplace but also regularly updated. According to the REACH regulation, suppliers are obliged to inform users of any changes in the composition or classification of substances within 30 days of their discovery. This means that operators must have a system in place for monitoring SDS updates and distributing them among employees, particularly those who work directly with the fluids.

It is recommended to keep records of all machining fluids used, including the date they were put into service and the date of the last update to the SDS. For water-dilutable emulsions, it is also necessary to monitor their quality and concentration, as degradation or contamination can lead to changes in their properties and thus their risk profile. Operational logs should include records of inspections, maintenance, and fluid replacements, which will facilitate traceability and demonstrate compliance with legislative requirements during potential inspections.

Employee Training and Risk Prevention Related to Machining Fluids

Effective minimization of risks associated with machining fluids requires not only technical measures but also systematic employee training. Every worker should be familiar with the content of the Safety Data Sheets (SDS) for the relevant fluids, including the identification of hazardous substances, proper handling, and procedures in case of spills or exposure. Training should include practical demonstrations of the use of personal protective equipment (PPE), such as gloves, safety goggles, or respirators, depending on the type of fluid and its application method.

An important part of prevention is also raising awareness about long-term health risks, such as dermatitis, respiratory issues, or allergic reactions, which can arise from repeated exposure. Employees should be trained to recognize the early symptoms of these problems and know how to proceed if they occur. Regular refresher training, at least once a year, will ensure that workers retain the necessary knowledge and are able to respond adequately to potential emergencies.

Need help with selection and documentation?

For every metalworking fluid, we provide complete safety and technical documentation in compliance with REACH and CLP. Our experts will advise you on selecting the right type, interpreting safety data sheets, and optimizing processes for maximum safety and efficiency. Contact us – or browse our catalog of over 1,300 products.