Heavy Metal and Asbestiform Fiber Rules in the U.S. using the SAE J2975 and J866 Test Method 2013-36-0036

New rules in the states of California and Washington mandate the phase out of cadmium, copper, hexavalent chromium, lead, mercury, and asbestiform starting in 2014. These rules apply to most on-road vehicles with open brakes. The rules are similar in its end-goals (to minimize the environmental impact of heavy metals and asbestiform fibers on runoff waters and on air pollution). They are however different in key aspects regarding the timing, limits, and process to register the corresponding percent-by-weight of all formulations sold and installed in these particularstates. After a short background, the paper presents three key areas pertaining to the rules and its practical implications for the self-certification (declaration of conformity) process.

First, the paper elaborates on the main elements of both rules presenting a side-by-side comparison related to a timeline for specific limits by element, applicability, exceptions, and the actual process to declare conformity of a given product. The second part of the paper, elaborates on the actual SAE J2975 recommended practice, the testing process from debris extraction to formal registration, the inductively coupled plasma, and the polarized light microscopy method with examples. The third part of the paper elaborates on technical items related to concentration and percent-by-weight calculations and conversions, uncertainty of measurement applicable to the SAE J2975 methods, and determination of level of detection using ISO statistical methods. Concluding the paper, the outlook for industry proficiency testing activities is presented along with references and related documents and studies.