May 25, 2010

PQIA Takes up the Issue of Line Wash Misuse

JobbersWorld, the leading trade journal serving lubricant distributors, reported in its May 11th issue that it continues to field questions from marketers about Shell's sale of line wash (also known as flush oil) into the US market. (JobbersWorld Story)
For those that don't know, line wash is typically defined as the material in the pipes when a blender switches a blend from one type of lubricant to another. As an example, when a blender switches from making a 10W-30 to a 5W-30, there is a certain volume of lubricant in the lines while the change is made that is a mixture of both the 5W- and 10W-30 grades. While lines are flushed, the line wash is neither a 5W-30 nor a 10W-30. Instead, it's a mixture. But with some adjustments made by the introduction of base oils and additives, marketers say the mixture can be made to look like either a 5W-30 or 10W-30 engine oil that meets current specifications. Further they say, this material is sold for far less then on spec engine oil since it is no more than "flush oil" used to clear the lines between blends and would otherwise have little value. And from what they hear, flush oil is not a drop in the bucket.
In an effort to address marketer's questions concerning this issue, JobbersWorld went right to the source and asked Shell specifically about its sales of flush oil. To Shell's credit, rather than ducking or ignoring the issue, they responded directly to JobbersWorld.

PQIA agrees with JobbersWorld that line wash is an issue affecting the quality of lubricants in the marketplace. Since PQIA's mission is to serve the consumer of lubricants by reporting on the quality and integrity of lubricants in the marketplace. PQIA made the decision to take a closer look at line wash and report on it in our PQIA's first Newsletter.

Shell Responds to Questions About  Line Wash

The following is Shell's response to JobbersWorld questions about Line Wash.

"Flush oil is generated at our blending plants as part of our work to protect the quality and integrity of our Shell branded lubricants. We generate flush oil through many daily activities, such as moving additives or base oils from storage tanks to blending tanks, flushing lines moving product from blending tanks to storage tanks, or storage tanks to bulk trucks, and flushing lines between filling operations. We flush lines to ensure the integrity of our formulations. We have initiatives underway to continually reduce the flush oil output from our facilities. For example, we are making fluid-handling improvements to our largest facility that will result in a 75% reduction of flush oil produced.

In the meantime, we sell flush oil to be used appropriately by other companies. The amount we sell annually is around 3 to 4 million gallons, significantly less than the amounts suggested in the recent Jobber's World article. Flush oil is virgin product that is suitable for a variety of uses. We consider that selling this product to be repurposed (rather than having it hauled away by a used oil carrier) to be a responsible, sustainable approach to this by-product of our manufacturing and quality assurance processes.

Flush oil typically contains a mixture of various product streams (PCMO, HDEO, gear oil, industrial oils, ATF, base oils, additives). We clearly communicate to flush oil buyers the possible components of the material and do not make any guarantees regarding the substance's characteristics, because they vary from batch to batch. We also clearly communicate that the flush oils we sell are not to be resold under any Shell or Pennzoil-Quaker State Company trademark. It is our understanding that buyers typically use flush oil as a blend component in a hydraulic fluid, bar and chain oil, process oil or other such product, packaged under a private label. Others use flush oil as low-grade boiler or marine fuel."

PQIA applauds Shell for responding to questions about line wash and we appreciate Shell's efforts to help assure the quality of lubricants in the marketplace.

ILMA Responds to PQIA Questions about Line Wash

Shortly after JobbersWorld ran its story about line wash "Speaking of Shell"  the Independent Lubricant Manufacturers Association (ILMA) sent a letter to its members specifically addressing the issue of line wash. That letter included the following statement:

"ILMA received numerous complaints from members about "line wash" or "line flush" being sold by certain oil companies to third parties and then misrepresented by these third parties or their customers as finished lubricants - both refiner-branded and unbranded -- in a number of U.S. markets."
Understanding close to 30% of the lubricants sold in the US market are produced by independent lubricant manufacturers, the Petroleum Quality Institute of America contacted ILMA with questions about line wash and other lubricant quality related issues. ILMA was kind enough to respond.  Click here to read ILMA's Response

Of particular interest (and concern) to PQIA in ILMA's letter is the statement:

 "With regards to the line wash issue, ILMA has received member complaints for two or three years. However, the frequency of those complaints increased dramatically over the past six months. The initial complaints were referred to ILMA's counsel, who advised the affected member companies on how they could individually address the issue. In 2009 discussions with the State weights and measures officials on lubricant quality issues, ILMA identified the line wash issue as a growing member concern."

This statement certainly helps confirm PQIA's concerns that line wash is a quality issue requiring attention.

PQIA thanks ILMA for taking the time to respond to our questions about line wash and we appreciate their efforts to help assure the quality of lubricants in the marketplace.

Chevron Responds to PQIA Questions About Line Wash
According to Chevron, "Chevron accumulates flush oil at its plants as a result of its day-to-day manufacturing process. Flush oil is used by Chevron internally for lower grade mining hydraulic oil and chain bar oils. It is also sold to compound blenders and recyclers for similar products."

Chevron says, "This flush oil is sold under contracts containing strict prohibitions against the resale of such flush oil under any Chevron brand name. Such contracts further require the purchasers of the flush oils to conduct their operations in strict compliance with all applicable laws and regulations."

Further Chevron says, "Our marketers and customers depend on the purity and high-performance of Chevron Lubricant formulations to succeed in their businesses.  Flushing leftover product lines is necessary to maintain product integrity."

And maybe most importantly, Chevron says, "As part of our ongoing effort to increase the efficiency of our operations, our supply chain network is continuously working on developing and implementing processes - most significantly at our largest lubricants plant, in Port Arthur, Texas - to reduce our flush oil inventory."

PQIA thanks Chevron for taking the time to respond to our questions about line wash and we appreciate their efforts to help assure the quality of lubricants in the marketplace.

But what about the other Major Lubricant Manufacturers? Where does their Line Wash go?
Shell and Chevron responded to public questions about where their flush oil goes. In addition, both companies say they are taking action to reduce the amount of line wash they produce. But what about the other major oil companies? Where does their line wash go and are they too taking action to reduce the volume they produce and to assure their line wash is not misrepresented in the marketplace?

PQIA invites the other producers of finished lubricants to let us know what efforts they are making to assure that their line wash is not misused in the marketplace.

PQIA Proposes a Solution to Line Wash Misuse

The misapplication of line wash in certified motor oils has been an ongoing issue for many years.  While many industry organizations and participants have expressed concern and taken actions to curb such abuse, the problem apparently persists.  PQIA's question is , Can more be done to assure the certified products on the shelves at retail stores, in the bulk tanks at quick lubes, new car dealers, and other installers do not contain line wash?

The Petroleum Quality Institute of America (PQIA) believes the answer is YES, and the solution is relatively easy.

The way to start is for the producers of line wash  to put markers in their line wash that uniquely identify it as flush oil. Then organizations like API, PQIA, ILMA, the line wash producers, and others can look for these markers in their ongoing market sampling and testing programs, and offenders can be quickly identified and stopped.  Markers are already used  by some oil blenders to identify their oils in their ongoing quality control and market monitoring efforts, so adding another marker should fit well into existing programs.

Furthermore, the markers in line wash need not be quantified like other markers as their qualitative presence alone is enough to show that line wash was blended into the product.

If any of our readers have ideas  that could help in addressing this issue, please drop us a note.