2018 AWT Winter Analyst

the Analyst The Voice of the Water Treatment Industry

Volume 25 Number 1

9707 Key West Avenue, Suite 100 • Rockville, MD 20850

Winter 2018

The Forgotten—An Assessment of the Impact and Value of Non-Ionic Functional Groups in Polymers for Deposit Control Managing Hazardous Material Regulations From OSHA and DOT Intellectual Property: Cornerstones of the Water Treatment Industry

Volume 25 Number 1 Winter 2018

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Table of Contents the Analyst The Voice of the Water Treatment Industry

Volume 25 Number 1

9707 Key West Avenue, Suite 100 • Rockville, MD 20850

Winter 2018

Cover

The Forgotten—An Assessment of the Impact and Value of Non-Ionic Functional Groups in Polymers for Deposit Control Managing Hazardous Material Regulations From OSHA and DOT Intellectual Property: Cornerstones of the Water Treatment Industry

Volume 25 Number 1 Winter 2018

Winter 2018

Volume 25

Published by

Number 1

30 The Forgotten—An Assessment of the Impact and Value of NonIonic Functional Groups in Polymers for Deposit Control Michael L. Standish and Chelsea L. Standish, Radical Polymers

For over 40 years, additive chemists in the water treatment industry have incorporated non-ionic functional groups to achieve targeted activity. Non-ionic monomers and functional groups can impart distinct functionalities such as efficacy for organics and hydrocarbons, improved performance for specific mineral scales and transition metal stabilization, activity for silica and silicate colloidal dispersion, incorporation of wetting/surface tension reduction properties, and enhancement of crystal modification. Further, some would go as far to claim that non-ionic groups can act as “spacers” that help direct and control polymer architecture. With all of these benefits to the incorporation of non-ionic monomers, there also can be drawbacks, such as increased cost, decreased sequestration capacity, and the potential for foam development at elevated concentrations. The purpose of this paper is to provide an overview of the commonly available polymers containing non-ionic functional groups, to demonstrate both the positive and negative potential impacts upon field performance, and to provide guidance to the AWT membership as to when such materials should be considered.

52 Managing Hazardous Material Regulations From OSHA and DOT Tim Barnes, Jake Sango, Logan Ray, and John Wobensmith, Chemtel, Inc.

The objective of this article is to clarify how hazardous material regulations are managed by OSHA and DOT. Here at ChemTel we’ve had many clients ask questions about what products are considered hazardous, how their packages should be labeled, and which classifications are applicable. Much of the confusion comes from the fact that different agencies regulate different parts of the product life cycle. In the first part of this paper, the basic requirements for OSHA and DOT will be given. The rules for Canada will also be discussed, since there are some exemptions and differences in the rules.

The second part will provide guidance on what to do when the regulations overlap or conflict. The information in this paper is taken from the regulations and our experience working with clients who have had difficulty complying with these regulations.

64 Intellectual Property: Cornerstones of the Water Treatment Industry

Timothy E. Keister, CWT, ProChemTech International, Inc., and Peter E. Greenlimb, Ph.D., CWT, Chemagineering Corporation

4

Calendar of Events

6

President’s Message

8

Message From the President-Elect

46 Association News 48 Membership Benefits 50 Industry Notes 55 Making a Splash 57 CWT Spotlight 59 Ask the Experts 61 T.U.T.O.R. 64 Capital Eyes 67 Business Notes 68 Financial Matters 70 Advertising Index

In this paper, the authors share their experiences in filing for U.S. patents and trademarks. Key discussion points include defining “Intellectual Property”; addressing the question “Why file for a patent?”; describing the patent process; selecting legal counsel; handling anticipated and unanticipated costs and expenses; proving the novelty of one’s invention to the patent application examiner; and defending the patent against competitive company claims and infringements. This paper concludes with a brief review of key patented inventions that have influenced and directed the water treatment industry over the past 50 years.

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the Analyst Volume 25 Number 1

9707 Key West Avenue, Suite 100 Rockville, MD 20850 (301) 740-1421 • (301) 990-9771 (fax) www.awt.org

2018 AWT Board of Directors President

Marc Vermeulen, CWT

Calendar of Events

Association Events 2018 Technical Training (West)

Secretary

February 28–March 4, 2018 Green Valley Ranch Resort Las Vegas, Nevada

Treasurer

2018 Technical Training (East)

President-Elect

David Wagenfuhr, LEED OPM

Thomas Branvold, CWT

March 21–25, 2018 Marriott Cleveland Cleveland, Ohio

Michael Bourgeois, CWT

Immediate Past President

Bruce T. Ketrick Jr., CWT

Directors

Matt Jensen, CWT Andy Kruck, CWT Bonnee Randall Andrew Weas, CWT

2018 Annual Convention and Exposition

Ex-Officio Supplier Representative

Kevin Cope

Past Presidents

Jack Altschuler John Baum, CWT R. Trace Blackmore, CWT, LEED AP D.C. “Chuck” Brandvold, CWT Brent W. Chettle, CWT Dennis Clayton Bernadette Combs, CWT, LEED AP Matt Copthorne, CWT James R. Datesh John E. Davies, CWT Jay Farmerie, CWT Gary Glenna Charles D. Hamrick Jr., CWT Joseph M. Hannigan Jr., CWT Mark R. Juhl

Brian Jutzi, CWT Bruce T. Ketrick Sr., CWT Ron Knestaut Robert D. Lee, CWT Mark T. Lewis, CWT Steven MacCarthy, CWT Anthony J. McNamara, CWT James Mulloy Alfred Nickels Scott W. Olson, CWT William E. Pearson II, CWT William C. Smith Casey Walton, B.Ch.E, CWT Larry A. Webb

Staff

Executive Director

Heidi J. Zimmerman, CAE

Deputy Executive Director

September 26–29, 2018 Omni Orlando Resort at ChampionsGate Orlando, Florida

2019 Annual Convention and Exposition

September 11–14, 2019 Palm Springs Convention Center and Renaissance Hotel Palm Springs, California

2020 Annual Convention and Exposition September 30–October 3, 2020 Louisville Convention Center and Omni Hotel Louisville, Kentucky

2021 Annual Convention and Exposition

September 22–25, 2021 Providence Convention Center and Omni Hotel Providence, Rhode Island

2022 Annual Convention and Exposition

Angela Pike

September 21–24, 2022 Vancouver Convention Centre Vancouver, Canada

Grace L. Jan, CMP, CAE

2023 Annual Convention and Exposition

Sara L. Wood, MBA, CAE

Senior Member Services Manager Vice President, Meetings Meeting Planner

Morgan Prior

Meeting Planner

Kristen Jones, CMP

Exhibits and Sponsorship Manager

Barbara Bienkowski, CMP

Exhibits and Sponsorship Coordinator

Brandon Lawrence

Marketing Director

Julie Hill

Marketing Specialist

Jeyin Lee

Director of Editorial Services

Lynne Agoston

Accountant

Dawn Rosenfeld

The Analyst Staff Publisher

Heidi J. Zimmerman, CAE

Managing Editor

Lynne Agoston

Advertising Sales

Heather Prichard, advertising@awt.org

October 4–7, 2023 Grand Rapids Convention Center and Amway Grand Hotel Grand Rapids, Michigan

Also, please note that the following AWT committees meet on a monthly basis. All times shown are Eastern Time. To become active in one of these committees, please contact us at (301) 740-1421.

Second Tuesday of each month, 11:00 am – Legislative/Regulatory Committee Second Tuesday of each month, 2:30 pm – Convention Committee Second Wednesday of each month, 11:00 am – Business Resources Committee Second Friday of each month, 9:00 am – Pretreatment Subcommittee Second Friday of each month, 10:00 am – Special Projects Subcommittee Second Friday of each month, 11:00 am – Cooling Subcommittee Third Monday of each month, 9:00 am – Certification Committee Third Monday of each month, 3:30 pm – Young Professionals Task Force Third Monday of each month, 4:30 pm – Standards Task Force Third Tuesday of each month, 3:00 pm – Education Committee Third Friday of each month, 9:00 am – Boiler Subcommittee Third Friday of each month, 10:00 am – Technical Committee Quarterly (call for meeting dates), 11:00 am – Wastewater Subcommittee

Other Industry Events The Analyst is published quarterly as the official publication of the Association of Water Technologies. Copyright 2018 by the Association of Water Technologies. Materials may not be reproduced without written permission.

Contents of the articles are the sole opinions of the author and do not necessarily express the policies and opinions of the publisher, editor or AWT. Authors are responsible for ensuring that the articles are properly released for classification and proprietary information. All advertising will be subject to publisher’s approval, and advertisers will agree to indemnify and relieve publisher of loss or claims resulting from advertising contents. Editorial material in the Analyst may be reproduced in whole or part with prior written permission. Request permission by writing to: Editor, the Analyst, 9707 Key West Avenue, Suite 100, Rockville, MD 20850, USA. Annual subscription rate is $100 per year in the U.S. (4 issues). Please add $25 for Canada and Mexico.

International subscriptions are $200 in U.S. funds.

AWWA, AWWA-WEF Utility Management, February 20–23, 2018, San Antonio, Texas AWWA, Membrane Technology Conference, March 12–16, 2018, West Palm Beach, Florida ACS, Spring National Meeting & Expo, March 18–22, 2018, New Orleans, Louisiana ASHE, PDC Summit, March 25–28, 2018, Nashville, Tennessee AWWA, Sustainable Water Management Conference, March 25–28, 2018, Seattle, Washington WQA, Aquatech Meeting, March 26–29, 2018, Denver, Colorado

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the Analyst Volume 25 Number 1

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President’s Message

By Marc Vermeulen, M.Sc., CWT

Empowering Members in Their Communities

the teacher with the lesson so the students get the full picture of the industry. Furthermore, we will be debuting templated ready-to-use promotional resources should you need things like flyers, posters, and other materials to become involved in career days and other community events. Both high school and college focus materials will be available. Member companies will be able to use these tools to gain more visibility in their communities, educate the next generation, and potentially find some new recruits to enter the field.

Over the last year, AWT has shifted a great deal of focus to advocacy within the new strategic plan. However, I wanted to take some time to explain what this means for you as a member and how these resources can help you to be successful. When the AWT Advocacy Center launched, we were able to add tools to help you with things like crisis communications planning, talking to the media, and effectively communicating with your elected officials. If you have not yet had the opportunity to take a look at these tools, I would encourage you to do so at https://www.awt.org/members_only/advocacy/ index.cfm. However, we aren’t stopping there. The next phase of this project is currently underway, and I wanted to take the opportunity to let you know how these additional resources will help make a positive impact in your local area.

Get Involved

Career resources will be available in early 2018 on the AWT website. However, if you would like to be the first to know about the release of the STEM kits, please email Sara Wood at swood@awt.org. We will send you a notification when they become available for purchase.

Give Back

The STEM Project to Debut

The STEM Task Force has been hard at work developing a kit that can be used in high school science classes.

Focusing on the science of scaling, the kit will include both materials for the lesson as well as a lesson plan for teachers. Furthermore, the lesson will include reading material designed for students to learn about the water treatment profession and how the science they learn can have a very practical application. These kits will be available for purchase in early 2018. Additionally, AWT will take the kits to the National STEM Festival in Washington, D.C., this April with the goal of getting both students and teachers excited about water treatment.

Educating Your Community

Please don’t hesitate to reach out and provide feedback on AWT. I can be contacted at president@awt.org.

You may be thinking, “a kit is great, but how can this help me?” As part of AWT’s Advocacy Center, stepby-step instructions will be available for how to navigate approaching local school systems. The lesson is structured so that a water treatment professional assists

In 2017, I had the privilege of going to Haiti with Pure Water For the World (PWW). Jason St. Cyr, CWT, and I traveled to Port-au-Prince Haiti, where we learned about the biosand filters that are used in the field. Because resources in this area are scarce, having an affordable and practical solution for water filtration is critical. These filters are easy to assemble and use low-cost materials, making accessibility and installation a realistic prospect in areas without any modern water infrastructure. We also visited the water-quality testing lab, where we learned about PWW’s current process and were able to provide valuable feedback from the perspective of a water treatment professional. It was a lifechanging trip, and I would encourage you to try to go on a PWW trip in 2018. You can find more information at https://purewaterfortheworld.org/donate/service-trips/.

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the Analyst Volume 25 Number 1

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Message From the President-Elect

By David Wagenfuhr, LEED AP O&M

Educational Program

Be sure to mark your calendar for the 2018 Annual Convention and Exposition, which will take place September 26–29, 2018, at the Omni ChampionsGate in Orlando, Florida. We’re looking forward to another great event.

We are currently putting together the program for the 2018 Convention and have some great abstracts from which to choose. In addition, we have reached out to members about what sessions they want to see at the meeting. Based on your feedback, we are developing several panel discussions. We hope to divide session content into three categories: technical theory, technical applications, and business sessions.

Keynote Speaker

We have a fantastic keynote speaker lined up. John Mattone is the world’s top authority on Intelligent Leadership (IL) and is respected as someone who can strengthen a leader’s talents, enabling them to realize four outcomes that they can leverage in their business and life: Altruism, Affiliation, Achievement, and Abundance (The 4 A’s). The 4 A’s are the seeds to achieving sustained greatness and creating a lasting legacy.

Golf Tournament

Travel to the golf course won’t take long, as it’s just a short walk or shuttle ride from your hotel room to the course on the hotel property. The International Golf Course was recently ranked no. 9 in the top overall ranked courses by GOLF Advisor. The 7,363-yard linksstyle course is home to sprawling greens and wind-swept dunes, featuring 18 of the most dramatic and challenging holes in the state. The course boasts a raw design of a rustic "down under" style of a coastal links course from Greg Norman's homeland, but with new turf surfaces that will allow conditions to be firm and fast for longer drives and will provide more challenging putting experiences on larger, more undulating greens.

In addition, John is widely regarded as one of the world’s leading authorities on corporate culture and culture transformation. He is a respected advisor and coach to CEOs who lead small to mid-sized entrepreneurial organizations as well CEOs who lead large global businesses, on how to create and sustain a leadership and talent culture that drives superior operating results. He is also the former executive coach to the late Steve Jobs and the former legendary CEO of PepsiCo, Roger Enrico.

Annual Reception and Awards Dinner

We’re also looking forward to a great Annual Reception and Awards Dinner, which will again take place on Thursday evening to allow more people to celebrate with us. We’ll be celebrating in style this year, with a Miamistyle event featuring champagne and cigars. It will be a fun event and a nice way to honor our award recipients.

John serves on the executive MBA faculty at Florida Atlantic University, where he teaches his enormously popular Global Leadership Assessment & Development course. He is also the author of eight books, including three best sellers: Talent Leadership, Intelligent Leadership, and Cultural Transformations: Lessons of Leadership & Corporate Reinvention. We look forward to an exciting presentation from John.

As we plan and prepare for Orlando, I welcome your input and feedback. I can be reached at dwagenfuhr@ h2oeng.com. Thank you for the opportunity, and I look forward to serving you!

8

the Analyst Volume 25 Number 1

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The Forgotten—An Assessment of the Impact and Value of Non-Ionic Functional Groups in Polymers for Deposit Control Michael L. Standish and Chelsea L. Standish, Radical Polymers

A Polymer Primer in Three Paragraphs or Less

In previous papers, the basics of polymers and their resulting functionality in controlling mineral scale and deposition in process water applications have been described in significant depth.1, 2, 3 For the purposes of this paper and understanding the role of non-ionic functional groups in water treatment applications, we need a working knowledge of polymers—a 30,000-foot view if you will. For this, we need to understand that polymers (Greek: poly “many”, mer “unit”) are molecules where repeating units, called monomers, are combined.

We can provide further details to our understanding by thinking about the differences between homopolymers and copolymers. Homopolymers utilize the same repeating units (monomers), and copolymers utilize two or more different types of repeating units. Visually, we can picture this by thinking of a train where several cars are connected to form a chain. This chain can either be of the same types of cars—say, all passenger cars—or one that has several types of units, such as passenger, bulk tank, flat bed, and box cars. So, the idea of polymers is pretty simple in that we are combining chains of monomer molecules either by utilizing one type of monomer to form a homopolymer or two or more types of monomers to form a copolymer.

We next need to know that the delivered end-use functionality of the polymers is defined by many variables.

These include how the polymer is put together (polymerization technique), the length of the polymer (molecular weight), and the types of monomers utilized (composition.) In the purest sense, the polymerization technique is mainly of interest to the polymer chemist since it defines the strategy of how to put the monomer(s) together to form a desired polymer. Polymerization technique can have a profound impact on both cost and performance. Molecular weight of a polymer can, and will, also have a dramatic impact on polymer performance. As a rule of thumb, most polymers employed for mineral scale and deposit control have an average molecular weight (Mw) of less than 10,000 Daltons. Further, we can add an additional rule of thumb that polymers with a Mw of about 3,000 or greater tend to be good solids dispersants, and polymers with a Mw of less than 3,000 tend to be better suited to increasing the solubility (threshold inhibitors) of common scale-forming minerals, such as calcium carbonate.

Polymer composition is the remaining variable to consider. We know from previous papers that while there are many types of compositions, each can be boiled down to polymers that contain carboxylate (COO-), sulfonate (SO3-), and/or non-ionic (various non-charged) functional groups. For perspective, the overwhelming majority (estimated to be greater than 80–90%) of all monomer utilized is carboxylate in type. This includes predominantly acrylic, methacrylic, and maleic acid monomers. These monomers provide base functionality for calcium carbonate scale, help build molecular weight for solids control and dispersion (specifically acrylic or methacrylic acid), and provide a relatively low cost source of functionality. Sulfonated monomers are the second most widely utilized monomers in mineral scale and deposit control. The sulfonate functional group primarily provides good stabilization properties for transition metals and calcium phosphate. Non-ionic monomers are somewhat sparingly utilized. Well known non-ionic containing polymers are utilized for enhanced phosphate and iron stabilization in both cooling and boiler applications. However, the role of non-ionic monomers has largely been neglected by polymer chemists due to limited incorporation capabilities in aqueous techniques, cost, and paradigms around functionality.

When thoughtfully and carefully incorporated, non-ionic monomers can enhance attributes of carboxylate- and sulfonate-containing copolymers and expand efficacy for difficult-to-control scales or deposits.

Put Me in Coach, I’m Ready to Play

Non-ionic monomers are woefully underutilized in scale and deposit control polymers. Less than 20% of all polymer offerings incorporate non-ionic functionality and, where utilized, non-ionic monomers are typically incorporated into polymers at levels between 5-10% on a molar basis. Given this, only about 1-2% (molar basis) of all polymer utilization for scale and deposit control contains non-ionic functionality. There are a few exceptions where incorporation is greater than 10%. These polymers tend to have noticeably enhanced properties in a wide variety of areas, such as calcium carbonate crystal modification, enhanced performance for phosphate and transition metal stabilization, expansion of functionality to include organic debris and deposits, online cleaning, silica and magnesium silicate control, and surface tension reduction/wetting.

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the Analyst Volume 24 Number 4

The Forgotten—An Assessment continued

Benefits of non-ionic monomer incorporation: Improved crystal modification Increased polymer stability in harsh waters Enhanced phosphate stabilization Excellent transition metal (Fe, Zn, Mn) stabilization Expansion of dispersion functionality to include organics Online cleaning Colloidal silica stabilization Magnesium silicate control Surface tension reduction and surface wetting With so many added benefits, why are non-ionic monomers utilized so sparingly? Cost is certainly a factor.

Simple non-ionic monomers such as acrylamide are economical but have limited benefits. More highly differentiated non-ionic monomers, which provide noticeable performance enhancements, can cost more than twice as much as carboxylates such as acrylic and maleic. However, cost never holds a good polymer scientist back. More practically, the utilization of non-ionics can require a very different polymerization strategy or technique that may not be available to the producer on a commercial scale. Said differently, non-ionic monomers by nature have limited or no water solubility. Given that most polymers utilized for mineral scale control are produced using aqueous polymerization techniques, the use of non-ionic monomers can be very difficult or impractical.

When non-ionic monomers can be incorporated in at appreciable amounts, a primary benefit can be surface tension reduction and wetting. In simple terms, wetting refers to the ability of a liquid to maintain contact with a solid surface. We have all heard the term “making water wetter” in the context of surfactants (surface active agents). The idea here is that the additive is making the water more surface active by helping it wet the surface more thoroughly. The same principle is applied with certain non-ionic containing polymers where there are distinct advantages to improving the wetting properties of water in a process application. Specifically, we can relate to the benefits of additives wetting solid surfaces and particulates as a means of improving performance.

For dispersion of solids, it is critical that the additive can adsorb and interact with the solid surface. Similarly, for online cleaning, wetting is required to help lift scale from a surface into the bulk water such that it 14

can be removed from the system. Wetting and surface tension reduction are also a necessity for functionality in controlling hydrophobic materials such as hydrocarbons or organic debris. The surfactant-like properties incorporated into high non-ionic monomer-containing polymers can produce extraordinary results when applied properly.

Understanding Surface Tension— Psychologist Not Needed

Surface tension can be observed in everyday life. The beading of morning dew on a flower petal (Figure 1) and the formation of the meniscus in a graduated cylinder (Figure 2) are two examples one might see on a regular basis out in nature or as a water treater. Surface tension is the result of the attraction of the molecules in a liquid. In most of the liquid, the molecules are pulled evenly in all directions (cohesive forces), which results in a net force of zero. The water molecules at the top of a glass of water do not have neighboring water molecules above them, only air. Therefore, the water molecules on top are attracted to neighboring water molecules to the right and left. This results in a stronger bond between the water molecules on top and is what causes extra energy to be required to move an object through the surface of water. These forces can be between two liquids or a liquid and a solid (interfacial tension), or between a liquid and a gas (surface tension) or a solid and a gas (surface free energy).4 Figure 1: Water droplets beading on the petals of a flower.

Figure 2: The formation of a meniscus in a glass graduated cylinder.

the Analyst Volume 25 Number 1

The Forgotten—An Assessment continued

Surface tension can be strictly defined as “The attractive force exerted upon the surface molecules of a liquid by the molecules beneath that tends to draw the surface molecules into the bulk of the liquid and makes the liquid assume the shape having the least surface area.”

—Merriam-Webster Mathematically, it can be characterized as: Eq. (1) where σ is surface tension, F equals force, L is the wetted length, and θ is the contact angle. Surface tension is reported in millinewtons per meter (mN/m).

Contact Angle and the Wettability of Solids

A lot of information can be gathered from surface tension. Specifically, the contact angle—the angle between the surface of a liquid and a solid with which it is in contact. The contact angle is a measurement of the wettability of a solid by a liquid. The term wettability means that a solid will form a common interface with a liquid that it encounters. A contact angle, θ, of 0Æ would mean complete wetting. If a solid has a contact angle between 0Æ and 90Æ, the solid is considered wettable by the liquid of interest. If θ is greater than 90Æ, the solid is not wettable by the liquid of interest (Figure 3).

Figure 3: Visual of decreasing contact angle and increased wetting.

When the contact angle of a solid in relation to a liquid is calculated, the surface free energy of that solid can be determined. Surface free energy, simply put, is the surface 15

tension of a solid and is reported in the same units as surface tension, mN/m (σ). Surface free energy can be further broken into dispersive and polar parts. Dispersive and polar parts can apply to both solids and liquids when looking at surface free energy and surface tension, respectively. The polar parts of the solid or liquid are related to the polar interactions of that substance. These forces are like those between water molecules—strong dipole-dipole interactions—where the electron density of the oxygen atom in the water is much greater than that of the hydrogen atoms. They are a permanent, not temporary, dipole moment. The dispersive parts of a solid or liquid are related to the dispersive interactions of that substance.

Dispersive interactions are static, temporary, and weak.5 These weak interactions are also known as London forces.

The polar parts plus the dispersive parts equal the total surface tension (liquid) or surface free energy (solid), as seen in Equation 2.

Eq. (2) Now that surface tension and contact angle have been defined in a technical manner, and a sliver of the information that can be gathered with it has been discussed, let’s apply these thoughts to water treatment and non-ionic functional groups. Pure water has a reported literature surface tension of 72.86 mN/m. This is the highest surface tension of any liquid except for mercury, which is 486.5 mN/m at room temperature (surface tension decreases as temperature increases; however, this will not be discussed in this paper). The greater the polar nature, the greater the surface tension of the liquid. As stated in the previous paragraph, polar parts of a substance are stronger forces. Non-ionic functional groups decrease the surface tension of the water they are in by creating a steric barrier. The non-ionic functional groups exert a pressure on the surface of the water, which in turn reduces the surface tension.[6] Calcium carbonate has a surface free energy of 33.10 mN/m, which is made up of 22.9 mN/m dispersive part and 10.20 mN/m polar part.[7] Water has a σ of 72.8 mN/m, with a dispersive part 21.8 mN/m and a polar part of 51.0 mN/m.[8] Now imagine a new polymer that has a surface tension of 26.50 mN/M with dispersive parts equaling 25.2 mN/m and polar parts of 11.3 mN/m (Figure 4).

the Analyst Volume 25 Number 1

The Forgotten—An Assessment continued

three methods can be performed using a tensiometer, an instrument specifically used to determine surface tension.

For our experiments, a Krüss K-100 force tensiometer was used. The Krüss K-100 force tensiometer can be used to determine not only surface tension but also interfacial tension, surface free energy, and contact angle.4

Figure 4: Visual representation of solid–liquid interaction between calcium carbonate (solid) and water (liquid, left) and a new polymer (liquid, right).

Eq. (3) Eq. (4) σl is the surface tension of the liquid and σs is the surface free energy of the solid. In Equation 3, where the surface tension of the liquid is greater than the surface free energy of the solid, less wetting occurs. In Equation 4, where the surface tension of the liquid is roughly equal to the surface free energy of the solid, wetting is more likely to occur. As the contact angle decreases, the liquid is being adsorbed onto the solid.

The contact angle (wettability) can be calculated using the following equation:

The Wilhelmy plate method was used for determining surface tension. In this method, 100 mL of the liquid being tested is placed in clean glass vessel with a known volume of 121.5 mL. A roughened platinum plate probe is handled carefully with gloves, flamed until slightly orange to remove any impurities on the surface, and placed on to a probe holder at the top of the Krüss K-100. The glass vessel is raised until the reflection of the plate can be seen in the liquid in the vessel (Figure 5). The Krüss Laboratory Desktop program is run, and the surface tension is determined by measuring the tensile force that is acting against the plate as it comes in contact with the liquid it is measuring. After the test is finished, the probe is rinsed thoroughly with DI water, isopropyl alcohol, and DI water again, and then flamed before being placed back into its casing.

Figure 5: Wilhelmy plate test configuration.

Eq. (5) where m is the mass, t is the time flow, c is the capillary constant of the solid being tested, p is the density of the liquid of interest, σ is the surface tension of the liquid, θ is the contact angle, and ƞ is the viscosity of the liquid.

In theory, in the example in Figure 4, the solid and liquid on the right would have a smaller contact angle. Therefore, the liquid would be able to wet out onto the solid more than the water on the left. Furthermore, because the polymer in the example above has similar dispersive and polar parts to that of the calcium carbonate, this increases its ability to wet out on the surface of the calcium carbonate compared to that of the water.

Methodology of Surface Tension Determination

There are many ways to determine surface tension: pendant drop method, ring tear-off method, the rod method, and the (Wilhelmy) plate method. The last 16

In this method, force is used to determine the surface tension reduction of the polymers being tested. Looking back at Equation 1 and at Figure 6, surface tension can be determined by force if L, the wetted length (perimeter of the plate), is known as well as the contact angle of the liquid to the plate being used.5 In this test, a plate made of platinum is used, due to the fact that the contact angle of any liquid to platinum is 0Æ. The cosine of 0Æ is 1; therefore, by measuring the wetted length of the plate and knowing that the contact angle of the liquid to the Analyst Volume 25 Number 1

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the plate will be 0Æ, the force exerted on the liquid can be used to determine σ, contact angle.4

The capillary constant for the solid being tested is first determined. The following equation is used:

Figure 6: Surface tension determination factors used for calculations for the Wilhelmy plate method.

Eq. (6)

Methodology of Contact Angle Determination

The contact angle (wettability) of powder can be determined, using the Washburn method, by utilizing the Krüss K-100. In this method, a powder of interested (e.g., calcium carbonate, pitch samples) can be packed into a glass sample holder. This holder is hollow and contains a replaceable filter base at the bottom so that when it is suspended over a liquid of interest (in this case, a non-ionic surfactant at an appropriate dosage that is in the glass vessel described above for the determination of surface tension), the liquid can be slowly raised to the sample holder, and the liquid sample can be pulled up into the sample holder via capillary forces, seen in Figure 7. To determine contact angle (wettability) of the liquid to the powder, Equation 5 from above is used.

Where h is the height that the liquid rises within the sample holder, σ is the surface tension of the liquid, θ is the contact angle, ρ is the density of the liquid, g is the acceleration due to gravity, and r is the radius of the sample holder (capillary). By using an optimal liquid with a contact angle of 0Æ (cos θ is equal to 1), as well as a known density and surface tension, the capillary constant can easily be determined. Returning briefly to the theory on dispersive and polar parts and low surface tension in relation to contact angle to achieve a contact angle of 0Æ, a liquid with no polar parts must be used.

For this experiment, hexane was used. With this information, the capillary constant can then be determined and used for following tests to determine contact angle of the solid with liquids with unknown contact angles.

The information can then be used to determine the surface free energy of the solid using different models provided in the Krüss Laboratory Desktop program.

For the Washburn method, there is a limiting contact angle for a liquid in the sample holder of 90Æ. If the contact angle is greater than 90Æ, cos θ is negative and the liquid is unable to rise into the capillary. Both the contact angle and the capillary constant of the powder being tested are the results of the linear regression of mass2 vs. time.4

Methodology of Dispersive and Polar Parts Determination

Once the contact angle is determined with at least one liquid with a known surface tension, the surface free energy of the solid regarding dispersive and polar parts can be determined in the Krüss Laboratory Desktop program.

Figure 7: Washburn method test configuration.

To determine the dispersive and polar parts of a liquid, a few steps must be taken. First, the surface tension of the liquid of interest must be determined. This was done using the methodology described above for surface tension determination. Once the surface tension is known, the contact angle of that liquid to a solid can be determined. To determine contact angle and subsequently dispersive and polar parts, a solid with no polar

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parts must be used. In this experiment, polytetrafluoroethylne (PTFE, Teflon) was used. It has a reported literature surface free energy of 20.70 mN/m, meaning it has 20.70 mN/m of dispersive parts and 0.0 mN/m polar parts.9 The contact angle of the liquid to the solid can then be determined using a similar setup to that in Figure 5, where a small plate of PTFE is suspended above the liquid of interested, which is then slowly raised to the PFTE probe while the force is measured. These values can then be used to determine the contact angle of the liquid to the solid as well as the dispersive and polar parts of the liquid using the Krüss Laboratory Desktop program.5

Graph 1: Surface tension reduction by non-ionic functional groups.

Data and Results Surface Tension Reduction In Graph 1, a reduction in surface tension by polymers with increasing non-ionic can be observed, with an increase in reduction of surface tension as the active concentration of the polymer increases. As stated before, water has the highest surface tension of any liquid at room temperature (excluding mercury). In the graph, the polymer AA:SA, which does not contain any non-ionic, has little reduction in surface tension even at increasing dosages, with only a reduction of 1.352 mN/m from water. The two polymers with the AA:SPME:SMS:MMA and AA:SA:t-BAM I compositions reduce surface tension by roughly 4.287 mN/m and 4.483 mN/m, respectively, below water, with a slight increase in reduction seen as concentration increases.

The polymer with the AA:SA:t-BAM IV composition reduces surface tension significantly more than the previous three polymers containing non-ionic, as well, by 7.354 mN/m. The polymer with the AA:SA:NI composition reduces surface tension the most, by 9.38 mN/m, as expected due to the significant increase in non-ionic functional group in the composition of the polymer.

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In Table 1, the sample polymers evaluated above were tested for the surface tension of the neat product. The same trend as above is seen in the neat samples, where an increase in non-ionic in the polymer results in a decrease in surface tension.

Table 1: Surface tension of the neat product.

Liquid Water AA:SA AA:SA:t-BAM I AA:SPME:SMS:MMA AA: SA: t-BAM IV New Polymer: AA:SA: NI

Surface Tension (Neat Sample) 72.80 mN/m 69.63 mN/m 49.22 mN/m 46.19 mN/m 44.17 mN/m 38.36 mN/m

Decreasing Contact Angle (Increasing Wettability) The contact angle of the various polymers of interest was determined using the Krüss K-100 in relation to a solid with no polar parts (PTFE). This allowed for further determination of the dispersive and polar parts of said polymers. A reduction in contact angle was seen, as the increase in non-ionic increased in the polymer samples (Table 2). This reduction in contact angle is an increase in wetting of the polymer on to the solid surface.

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Dispersive and Polar Parts of Liquid and Solids Table 3 shows the distribution of dispersive parts and polar parts for each liquid tested. As the non-ionic content increases in the polymer, the polar part decreases as well.

Table 2: Reduction in PTFE contact angle.

Liquid Water AA:SA AA:SA:t-BAM I AA:SPME:SMS:MMA AA: SA: t-BAM IV New Polymer: AA:SA: NI

PTFE Contact Angle 116.62 105.50 100.04 97.14 93.08 81.81

Table 3: Distribution of dispersive parts and polar parts for tested liquids.

Photographs were taken of the polymer that did not contain any non-ionic functional group as well as the polymer that contained the highest amount, seen in Figure 8. Visually, a difference can be seen between the two polymers. The polymer on the left, which contains high levels of non-ionic has a smaller contact angle as well as increased wetting on to the PTFE surface. The polymer on the right has an increased contact angle to the PTFE, resulting in decreased wetting of the surface by the polymer.

Figure 8: Contact angle of AA:SA:NI and PTFE (left); Contact angle of AA:SA and PTFE (right).

The contact angles of the polymers on the PTFE surface were visually confirmed using the software ImageJ, as seen in Figure 9. These contact angles are consistent with those reported using the Krüss K-100.

Figure 9: Contact angle determination of AA:SA:NI and PTFE (left); Contact angle determination of AA:SA and PTFE (right) using Image J.

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Liquid

PTFE Contact Angle Polar Part

Water

116.62

50.98 mN/m

AA:SA:t-BAM I

100.04

26.90 mN/m

93.08

20.56 mN/m

AA:SA

AA:SPME:SMS:MMA AA: SA: t-BAM IV

New Polymer: AA:SA: NI

105.50 97.14

81.81

34.45 mN/m

24.08 mN/m 12.40 mN/m

The surface free energy of calcium carbonate has literature values of 25.10 mN/m and 33.10 mN/m, with the latter resulting in dispersive parts equal to 22.90 mN/m and 10.20 mN/m polar parts. When determining the surface free energy of calcium carbonate using the Washburn method on the Krüss K-100, results showed 28.3 mN/m total with dispersive parts equal to 21.7 mN/m and polar parts equal to 6.6 mN/m. This was consistent with reported literature values. When calcium carbonate was tested with water, the contact angle was found to be 84.2Æ, meaning the water has poor wettability onto the calcium carbonate. When calcium carbonate was tested with diiodomethane, the contact angle was found to be 72.1Æ, meaning that diiodo-methane has better wettability onto the surface of the calcium carbonate. This is in line with the idea that substances with similar surface free energy/surface tension and dispersive and polar parts can adsorb onto one another better than those with vastly different surface energy makeup.

Other reported literature values for surface free energy of typical scale-inducing components reflect a similar trend: high dispersive parts, low polar parts. Talc (magnesium silicate) has a reported surface free energy of 42.90 mN/m, comprising 42.20 mN/m dispersive parts and 0.70 mN/m polar parts. Iron oxide has a reported surface free energy of 32.90 mN/m, with dispersive parts making up 20.00 mN/m and polar parts making up 12.90 m/m. With this in mind, the increase of non-ionic functional groups resulting in an increase in calcium the Analyst Volume 25 Number 1

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phosphate stabilization, iron stabilization, and crystal modification, as well as increased wetting and surface tension reduction, makes a lot of sense when broken down into surface free energy and dispersive and polar parts.

Calcium Phosphate It is well understood that the incorporation of sulfonate functionality is required to provide calcium phosphate stabilization properties. The functionality can be greatly enhanced by the addition of certain non-ionic monomers.

These aspects and the following data have been discussed in detail in previous papers presented.1, 2 Graph 2 shows the dramatic enhancement in efficacy that can be derived when a non-ionic monomer is added to a standard AA:SA copolymer. The data show calcium phosphate stabilization for a new AA:SA:NI versus standard AA:SA copolymers of varying ratios.

less than 0.2 μm in size. It can be observed that the new polymer, which contains a higher level of non-ionic monomer, functions more effectively at a lower overall dosage. This comparison is especially prominent when observing the 9, 12, and 15 mg/l treatments for each polymer.

Figure 10: Iron stabilization properties of three nonionic containing polymers.

Graph 2: Calcium phosphate stabilization—non-ionic enhancement.

Iron stabilization The theory behind iron stabilization and the procedures for the results discussed below have been documented and explained in a previous paper.1 The images shown in Figure 10 show the iron stabilization properties of three non-ionic containing polymers relative to a blank (no treatment.) In these images, the amount of iron captured on the 0.2 μm membrane filter can be visually observed with increasing dosage. Less color collected on the membrane surface is an indication that the iron has been effectively stabilized and particles are sufficiently

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Crystal Modification Crystal modification and the following data and photographs have been expanded on in previous papers.1, 2, 3 In cases where effective crystal habit modification is observed, the mechanism requires the polymer to adsorb onto the surface of a forming crystal lattice (Figure 11). This allows the polymer to impede the directional growth of the lattice and subsequently promote the formation of precipitated crystals that are abnormal in shape, size, and overall appearance. The incorporation of non-ionic functionality can play an important role in impacting the degree to which crystals are modified by impacting both wetting and the conformation of adsorption onto a forming crystal surface. This can be seen empirically in Figure 12, where an enhanced polymaleic acid containing non-ionic functional groups shows exceptional distortion of calcite (cubic calcium carbonate.)

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References

Figure 11: Polymer interaction—adsorption onto forming crystal lattice.

1. M. L. Standish, Ground Up: Designing New Polymers for Independent Water Treatment Companies, 2014.

2. M. L. Standish, Rules of Three – Simplifying the Selection of Polymers, 2015.

3. M. L. Standish, Extending Performance: A New Product Treatment in ‘No Man’s Land, 2016.

4. "Krüss: Advancing Your Surface Science," 2017. [Online]. Available: www. kruss.de.

5. Krüss Laboratory Desk Software, 2.2 ed., vol. 3, Hamburg: Krüss GmbH, 2015.

6. M. Bumiller, Dispersing Powders in Liquid, Horiba, 2013.

7. C. K. Schoff, "Wettability Phenomena and Coatings," in Modern Approach to Wettability: Theory and Applications, NY: Plenum Press, 1992, pp.

375-395.

8. G. Ström, M. Frederiksson and P. Stenius, "Contact Angles, Work of Adhesion, and Interfacial Tensions at a Dissolving Hydrocarbon Surface," Journal of Colloid and Interface Science, vol. 119, no. 2, pp. 352-361, 10 1987.

Figure 12: Calcite crystal (left) and calcite crystal modification using an enhanced polymaleic acid (right).

9. C. D. Volpe and S. Siboni, "Some Reflections on Acid-Base Solid Surface Free Energy Theories," Journal of Colloid and Interface Science, vol. 195, pp.

121-136, 1997.

Michael Standish is founder of Radical Polymers, LLC, a business designed specifically to develop and provide technologies to the independent water treatment community. Chelsea Standish is the technical manager at Radical Polymers. They can be reached at (423) 316-9877 or mike.standish@radicalpolymers.com.

Conclusions

The benefits of the use of non-ionic monomers are apparent considering the information above. Though there can be an increase in cost, a decrease in sequestration capacity, and the potential for foam if overfed, the use of non-ionic monomers and functional groups still comes with a wide range of distinct functionalities.

The focus of this paper was the reasoning behind the increased benefits of non-ionic functional groups and monomers, especially regarding surface tension and contact angle, which in turn effect their use for target activity. Given the information presented, future work can be done to understand how other factors in water treatment can impact non-ionic functionality—from temperature to calcium concentration. ©2014 Radical Polymers, LLC

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Managing Hazardous Material Regulations From OSHA and DOT Tim Barnes, Jake Sango, Logan Ray, and John Wobensmith, Chemtel, Inc.

Introduction

The objective of this paper is to clarify how hazardous material regulations are managed by OSHA and DOT. Here at ChemTel we’ve had many clients ask questions about what products are considered hazardous, how their packages should be labeled, and which classifications are applicable. Much of the confusion comes from the fact that different agencies regulate different parts of the product life cycle. In the first part of this paper, the basic requirements for OSHA and DOT will be given.

The rules for Canada will also be discussed since there are some exemptions and differences in the rules. The second part will provide guidance on what to do when the regulations overlap or conflict. The information in this paper is taken from the regulations and our experience working with clients who have had difficulty complying with these regulations.

Occupational Safety and Health Administration (OSHA) HCS 2012 Classifications The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a system of classifications to effectively define and communicate hazards of chemical products for manufacturers, importers, and distributors. GHS was created by the UN and adopted by countries around the world. OSHA implemented the GHS standards in what they call the Hazard Communication Standard; also referred to as HazCom 2012 or HCS 2012. The full regulatory text is written in Title 29, Code of Federal Regulations, Part 1910.1200 (29 CFR 1910.1200).

The Health hazard classes are those hazards that present a danger to human health. There are 10 in total and include effects on the skin, eyes, organs, and both shortand long-term toxicity. The severity of these hazards is determined with consideration to the route of exposure, the amount (dosage) being exposed to, and, if applicable, whether it is a single exposure or repeated.

Physical hazards are those that pose an external threat by interaction of their chemical composition, physical state (solid, liquid, gas) or pressure which they are kept.

In total, there are 16 classes of physical hazards, mostly derived from the existing UN Model Regulation on the Transport of Dangerous Goods. In general, this includes flammable, oxidative, pyrophoric, corrosive, self-reacting substances; organic peroxides; and explosives. Again, each of these is further broken down to determine the severity of the hazard based on physical characteristics and available test data.

The final class of hazards is Environmental, and it’s actually regulated by the Environmental Protection Agency (EPA); therefore, OSHA doesn’t require it as a classification. However, as long as the OSHA classification doesn’t contradict the EPA classification, then you can include both on the Safety Data Sheet (SDS). There are only two subclasses within this class: acute aquatic toxicity and chronic aquatic toxicity. These are further divided on the basis of species that are affected: fish (LC), crustacean (EC), and algae or other aquatic plants (ErC). Chronic aquatic toxicity has a fourth point of interest that takes into account environmental fate data, such as degradation and bioaccumulation.

The overall classifications are divided into two parts: class and category. There are two hazard classes defined by HCS 2012 and a third optional class: Health, Physical, and Environmental. Within each class, subclasses are separated by the type of hazard and further subdivided based on severity using numbered categories (1 being the most severe) and letters (A being more severe than B and so on). The primary approach for classification is based on actual test data. If none is available, hazards can be calculated or estimated based on individual ingredients data, similar mixtures, expert judgment, or other scientifically valid methods.

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Here are all the hazards OSHA regulates: Health

Acute Toxicity

Skin Corrosion/Irritation

Germ Cell Mutagenicity

Carcinogenicity

Reproductive Toxicity

Aspiration Hazard

Explosives

Flammable Gases

Flammable Aerosols

Oxidizing Gases

Pyrophoric Liquids

Pyrophoric Solids

Self-Heating Chemicals

Water-Reactive Chemicals

Specific Target Organ Toxicity Single Exposure

Physical

Gases Under Pressure

Oxidizing Liquids

Serious Eye Damage/Eye Irritation

Respiratory or Skin Sensitization

STOT Repeated or Prolonged Exposure

Flammable Liquids

Flammable Solids

Oxidizing Solids

Organic Peroxides

SDS and Label Requirements OSHA requires every hazardous chemical to have an SDS. The SDS contains all the comprehensive information about the product for use in workplace chemical management. It is one of the primary means to communicate the hazards about particular chemicals.

The current SDS contains 16 headings, though sections 12–15 are optional for OSHA. The headings are as follows: 1. Identification (of substance/mixture and of supplier)—includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

2. Hazard(s) identification—includes all hazards regarding the chemical; required label elements.

3. Composition/information on ingredients— includes information on chemical ingredients; trade secret claims.

4. First-aid measures—includes important symptoms/ effects, acute, delayed; required treatment.

5. Firefighting measures—lists suitable extinguishing techniques, equipment; chemical hazards from fire.

6. Accidental release measures—lists emergency procedures; protective equipment; proper methods of containment and cleanup.

7. Handling and storage—lists precautions for safe handling and storage, including incompatibilities.

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Self-Reactive Chemicals Corrosive to Metals

8. Exposure controls/personal protection—lists OSHA’s Permissible Exposure Limits (PELs); ACGIH Threshold Limit Values (TLVs); and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS where available as well as appropriate engineering controls; personal protective equipment (PPE).

9. Physical and chemical properties—lists the chemical's characteristics.

10. Stability and reactivity—lists chemical stability and possibility of hazardous reactions.

11. Toxicological information—includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

12. Ecological information—(nonmandatory) includes ecotoxicity; persistence; degradability; bioaccumulation potential; other adverse effects.

13. Disposal considerations—(nonmandatory) description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.

14. Transport information—(nonmandatory) includes UN number; proper shipping name; transport hazard class(es); packing group; environmental hazards; bulk transport; special precautions.

15. Regulatory information—(nonmandatory) safety, health, and environmental regulations specific for the product in question.

16. Other information—including date of preparation or last revision.

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OSHA-compliant labels are required when a hazardous chemical is leaving the workplace and does not fall under the jurisdiction of another agency (EPA, CPSC, or FDA). The label is required to convey the matching information that is present on the SDS. This includes: 1.

2.

3.

4.

5.

6.

Product identifier Pictogram Signal word Hazard statements Precautionary statements Name, address, and phone number

Pictograms are assigned for each hazard class, and they’re required to have a red border, black symbol, and white background. Signal words are used to indicate the level of severity of a hazard. Two signal words are defined: “Danger” for more severe and “Warning” for less severe; only one is used for each product. Hazard statements are assigned phrases that describe the nature of the hazards; the given text is mandatory and can’t be modified. Precautionary statements are given to minimize or prevent adverse effects from the hazards and include relevant first aid information. Supplemental information can be included on the label, as long as it doesn’t contradict or detract from any of the required information.

Required Material for Training OSHA also requires training as part of employee safety compliance. The goal is to protect workers and prevent work-related injuries, illnesses, and deaths by setting standards and providing education. OSHA offers educational materials that provide brief safety and health information to help with training. There are no specified time limits for training or retraining. According to HCS 2012 the following must be included: 1. How to recognize the new SDS and label elements.

2. Methods to detect the presence or release of a hazardous chemical in the work area.

3. All hazards of the chemicals in the work area.

4. Measures employees can take to protect themselves from these hazards.

5. The details of the hazard communication program developed by the employer.

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Inspections At this point, all companies should be in compliance with the SDS requirements, labeling provisions, and training required by HCS 2012. Failure to meet these minimum requirements can result in citations during an inspection by a Compliance Safety and Health Officer (CSHO).

The inspector will want to see accurate information on the SDS with corresponding labels. They do have the authority to send a product out for testing, and if the test results don’t match the SDS, then a fine can be issued.

Records, or other proof, should also be available to show that the employees have been trained. During the inspection, the primary question the inspectors need answered will be, “is this a safe work environment?”

Department of Transportation (DOT) Transport Classifications DOT is responsible for regulating the transportation of hazardous materials that travel by highway, train, vessel, or aircraft within the United States. The regulations are written in 49 CFR Part 100-180. There are nine hazard classes, some of which have subclasses for more specific hazards. The level of hazard of each class is defined by one of three packing groups. The groups are represented by roman numerals, with “III” being the least dangerous, and “I” being the most. The hazard class and packing group for a product is determined by testing. If a product does not meet the minimum requirement for packing group III in any hazard class, then the product is considered nonhazardous for transport.

Each class is given here with a brief overview: Class 1: Explosives An explosive is defined as a product that is designed to function by explosion or is able to function in a similar manner, even if not designed to explode. This class is divided into six divisions: Division 1.1, 1.2, 1.3, 1.4, 1.5, and 1.6.

Class 2: Gases Pressurized or aerosolized products are considered gases.

This class has three different divisions: flammable gas (2.1), non-flammable, nonpoisonous compressed gas (2.2), and gas poisonous by inhalation (2.3).

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Class 3: Flammable Liquid and Combustible Liquid Liquids are classified as flammable when their flash point is below 60 °C (140 °F). Combustible liquids have a flash point above 60 °C (140 °F) and below 93 °C (200 °F).

Class 4: Flammable Solid, Spontaneously Combustible, and Dangerous When Wet Solid products that have the potential to start or spread a fire are in this class. There are three divisions: flammable solid (4.1), spontaneously combustible (4.2), and dangerous when wet (4.3).

Class 5: Oxidizer and Organic Peroxide This class has two divisions. Division 5.1 is for oxidizers, which cause or enhance the combustion of other materials by yielding oxygen. Division 5.2 is for organic peroxides, which pose severe fire and explosion hazards.

Class 6: Poison (Toxic), Poison Inhalation Hazard, and Infectious Substances Toxic and infectious substances are covered under Division 6.1 and 6.2, respectively. Division 6.1 covers materials, other than a gas, that are considered so toxic to humans that they present a health hazard during transportation. Division 6.2 includes materials that are known or reasonably expected to contain a pathogen.

Class 7: Radioactive This class covers materials containing radionuclides with properties exceeding defined limits.

Class 8: Corrosive A corrosive material refers to a liquid or solid that is capable of causing a full thickness destruction of human skin within a four-hour contact period, or a liquid that exhibits severe corrosion on steel or aluminum.

Class 9: Miscellaneous Products not covered by the other sections, including environmental hazards and lithium batteries are classified as miscellaneous. Looking up a chemical on the Hazardous Materials Table in 49 CFR is the easiest way to determine if a product should be in Class 9.

Packaging and Labeling Requirements DOT requires every hazardous material shipment to be marked, labeled, and packaged appropriately. Shipments are split into two size categories, bulk or non-bulk. Each 27

hazard class has their own set of rules for what type of packaging is acceptable, whether it’s boxes, drums, cylinders, jerricans, or tanks. In order to properly package a shipment, the size and package type must be considered.

Each package has to be built, filled, and closed in a way that prevents any spills during transport.

Marking and labeling are the terms DOT uses to describe how hazard information should be communicated on the package. The basic information on a fully regulated hazmat package is: 1.

2.

3.

4.

Full Name and Address of the Shipper or Consignee Proper Shipping Name UN or NA Number Hazard Class Label(s)

When smaller packages such as bottles, vials, and cans are packed into a larger package, these are called combination packages. The smaller packages are referred to as inner packagings in the regulations, and they are not required to have marks or labels.

In some situations, additional marks and labels are required.

Special permits allow the transport of shipments that fall outside the scope of the regulations, but still provide a level of safety equal to the safety level required under Federal hazmat law.

Orientation arrows show the proper package orientation for the closures of the inner packaging to be in the upright position. These are required for liquid dangerous goods.

Inhalation hazard labels are required for liquids that give off extremely toxic vapors under normal transport conditions.

EX numbers are required for shipments of explosives.

Marine Pollutant marks are used when a product contains 10% of substances listed as marine pollutants or 1% of substances listed as severe marine pollutants.

Limited Quantity marks note exemption from specific labelling, UN Specification Packaging, shipping paper, and placarding requirements. the Analyst Volume 25 Number 1

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Excepted Quantity marks are similar to Limited Quantity marks in that they note when the quantity of a product is small enough to be exempt from parts of the regulations.

includes classifying, packaging, labeling, etc. The initial training must occur within 90 days of employment, and retraining must occur every three years. The material covered during training needs to include:

Similarities With IATA and IMDG The International Air Transport Association (IATA) is an association of airlines and carriers who set guidelines for shipping hazardous materials by air. The International Maritime Organization publishes the International Maritime Dangerous Goods Code (IMDG), which sets the guidelines for shipping hazardous material by ocean. That means a U.S.-based company will follow DOT’s regulations for ground shipments, IATA for air, and IMDG for ocean.

1. General awareness/familiarization 2. Function-specific training 3. Safety training 4. Security awareness training 5. In-depth security training The training can be provided by anyone, as long as all the material is covered. Records of who was trained and when, the material that was used, and certification of completion need to be kept.

Classification of hazardous materials is based on the criteria laid out in the UN Recommendations on the Transport of Dangerous Goods–Model Regulations. Since the classifications are derived from the same source, the shipping name, UN number, and packing group will be consistent across all three transport regulations the vast majority of the time. However, there are a few exceptions to the rule that are caused by DOT not agreeing with international assessment of hazards for specific substances. The classification of methanol as nontoxic for domestic shipments is one such example. The reclassification of certain flammable liquids to combustible liquids is another example of a DOT classification that is not used for air or maritime shipments.

Required Material for Training Every employee who participates in a function of transporting hazardous materials needs to be trained; this

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Inspections at a Facility and During Transit DOT enforcement agents can inspect packages at the facility or in transit if there is reason to believe there are hazardous material violations. Primarily, the inspector needs to be sure that all packages leaving the facility are done in a safe and compliant manner. Generally, penalties are worsened if there is evidence that regulatory violations are willfully negligent. The penalties for violations may be a flat fee or based on company size, duration, and severity of noncompliance; if the violation is related to safety; or if the violation affected response efforts. Many of the penalties are arranged by packing group, with Packing Group III having a less severe penalty than Packing Group I. A full list of guidelines for civil penalties can be found in 49 CFR Appendix A of Subpart D of Part 107. Some of the issues a DOT inspector will be looking for are outlined in Table 1.

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Managing Hazardous Material Regulations From OSHA and DOT continued

Table 1: DOT requirements for hazardous materials.

General Requirements Registration Training Security Plans Notification to a Foreign Shipper Special Permits and Approvals

Company not registered as an offeror of hazardous material and didn’t pay registration fee.

Hazmat employer does not provide initial and recurrent training to hazmat employees, does not meet the training objectives outlined in the previous section, or maintain employee training records.

Company did not develop and adhere to a complete and updated security plan, and identical copies of the plan were not distributed in writing.

Foreign hazmat offeror or forwarding agent did not receive written information of HMR requirements.

Shipping hazmat requiring a special permit or approval without a current and valid permit, complying with all provisions, or using an approval or approval symbol issued to another person.

Offeror Requirements – All Hazardous Materials Undeclared Shipment Shipping Papers Emergency Response Information Package Marking

Package Labeling Placarding Packaging

Shipping hazmat without the proper classification on shipping papers, markings, labels, and placards. Offering or transport forbidden hazmat.

Failure to provide correct and complete shipping papers Incorrect emergency response information effecting response efforts, failure to include an easily accessed and continuously monitored emergency response telephone number.

Failure to mark the correct packaging elements, such as shipping name, identification number, “n.o.s.” descriptors, markings not easily visible, limited quantity or RQ marking, and bulk container marking.

It is considered a violation to mark a nonhazardous package as hazardous or listing a technical name that should not be listed.

Package labeling that is incorrect, incomplete, or placed in an inappropriate location. Placing a label on a package that is not considered hazardous for transport.

Placarding is missing or incorrect.

Use of packaging that does not comply with package testing requirements for small quantities, excepted quantities, de minimis, materials of trade, limited quantities, and ORM-D. Use of packaging that is insufficient for the safety and integrity requirements of the hazmat shipped.

Offeror Requirements – Specific Hazardous Materials Oxygen Generators Offers by Air Batteries

Shipping an unapproved oxygen generator, shipping without installing a means of preventing actuation, and shipping an oxygen generator as spent with the ignition and chemical contents still present.

Shipping batteries without appropriate testing and testing design records. Shipping batteries in unauthorized packages, have not been protected against short circuit, or failure to prepare batteries to prevent damage in transit. Offering lithium batteries for transport on a passenger aircraft or misclassifying them for air transport.

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the Analyst Volume 25 Number 1

Test for what matters to reduce disease risk The Legiolert® Test accurately detects and quantifies the pathogen that causes of 99% of Legionnaires’ disease Clinical causes of Legionnaires’ disease, 2009–2014 100% 90% 80% 70% 60% 50% 40%

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Outbreaks in Europe4

A positive Legiolert Test result detects what traditional plate methods can miss, Legionella pneumophila.5 And, because many species of Legionella thrive in similar environments,6,7 a positive result also signals to you that other types of Legionella may be present.

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This one species causes 99% of Legionnaires’ disease outbreaks.

No wonder advisors to the World Health Organization suggest testing that’s specific for this pathogen.8 To make sure your water management plan is effective, include routine monitoring with the Legiolert Test.

References 1. CDC. Surveillance for waterborne disease outbreaks associated with drinking water and other nonrecreational water—United States, 2009–2010. MMWR Morb Mortal Wkly Rep. 2013;62(35):714–720.

2. Beer KD, Gargano JW, Roberts VA, et al. Surveillance for waterborne disease outbreaks associated with drinking water—United States, 2011–2012. MMWR Morb Mortal Wkly Rep. 2015;64(31):842–848.

3. Benedict KM, Reses H, Vigar M, et al. Surveillance for waterborne disease outbreaks associated with drinking water—United States, 2013-2014. MMWR Morb Mortal Wkly Rep. 2017;66(44):1216–1221.

4. European Centre for Disease Prevention and Control. Surveillance Report: Legionnaires’ Disease in Europe, 2014. Stockholm, Sweden: ECDC; 2016.

5. Sartory DP, Spies K, Lange B, Schneider S, Langer B. Evaluation of a most probable number method for the enumeration of Legionella pneumophila from potable and related water samples. Lett Appl Microbiol. 2017;64(4):271–275.

6. Veterans Health Administration. Prevention of Healthcare-Associated Legionella Disease and Scald Injury from Potable Water Distribution Systems. Washington, DC: Veterans Health Administration, US Department of Veterans Affairs; 2014:C-4. VHA Directive 1061.

7. Van der Mee-Marquet N, Domelier AS, Arnault L, et al. Legionella anisa, a possible indicator of water contamination by Legionella pneumophila. J Clin Microbiol.

2006;44(1):56–59.

8. World Health Organization (WHO) Regional Office for Europe. Background Paper on Water Microbiologically Safe Water and Microbiological Parameters, Revision of Annex I of the Council Directive on the Quality of Water Intended for Human Consumption (Drinking Water Directive)[Draft for Consultation]. Copenhagen, Denmark: WHO Regional Office for Europe; 2016:27. © 2017 IDEXX Laboratories, Inc. All rights reserved. • 2077439-00 • All ®/TM marks are owned by IDEXX Laboratories, Inc. or its affiliates in the United States and/or other countries. The IDEXX Privacy Policy is available at idexx.com.

Learn more about the Legiolert Test or find a Legionella testing laboratory near you. idexx.com/LowerRisk or call 1-800-321-0207

Managing Hazardous Material Regulations From OSHA and DOT continued

Canadian Regulations WHMIS 2015 Workplace Hazardous Materials Information System (WHMIS) is a comprehensive system for providing health and safety information. The 2015 version contains the new requirements for labels and safety data sheets that replace the original WHMIS 1988. By December 2018 all suppliers (manufacturers, importers and distributors) and employers should be in full compliance with the new standards. During the transition, both the 1988 and 2015 requirements may be found in use.

The WHMIS requirements covers all hazardous products used in the workplace. Some exclusions are explosives, cosmetics, drugs, foods, pest control products, consumer products, nuclear substances, and tobacco products which are regulated by other acts. WHMIS 2015 is similar to the regulations set forth in the United States HCS 2012, with several key differences when it comes to the label and SDS. Examples of those differences are as follows: Language—Label and SDS must be provided in English and French.

Supplier Info—Canadian distributor may omit the name of initial supplier if they use their own. An importer can retain the name of a foreign supplier only if the imported product is being used in their workplace.

Carcinogens—Above 0.1% require a label and SDS. Physical or Health Hazards Not Otherwise Classified—Require label elements and for a health hazard greater than 1%, disclosure must also be on the SDS. Biohazardous Infectious Materials—A hazard class that is not regulated by U.S. HCS 2012.

Transportation of Dangerous Goods Transport Canada is the Canadian agency that regulates the transportation of hazardous materials into and throughout Canada. The transportation of such products is regulated under the federal Transportation of Dangerous Goods Act (TDG). The TDG Regulations establish the safety requirements for the transportation of dangerous goods. There are nine classes of dangerous goods that products can fall into: explosives, gases, flammable liquids, flammable solids, oxidizing substances, poisonous and infections substances, radioactive materials, corrosives, and miscellaneous products, which include those dangerous to the environment and dangerous wastes.

Transport Canada’s Transport Dangerous Goods Directorate has various components that work closely with federal and provincial agencies to implement the safety program. Several branches of the Directorate handle dedicated operations such as Regulatory Affairs, Research and Evaluation, and Compliance and Response. CANUTEC is the Canadian Transport Emergency Centre, which provides 24-hr bilingual emergency advisory and regulatory information for determining immediate and general onsite response to accidents involving dangerous goods.

Training The use of hazardous products in the workplace requires workers to participate in education and training programs. The Canadian Centre for Occupational Health and Safety (CCOHS) provides generic worker training courses. Topics covered during training include the hazards and safe use of products, necessary labeling and SDS preparation, proper use of labels and SDS, access to the most current SDS and ability to locate pertinent information, and continual review whenever work conditions or hazard information changes.

Employers are required to educate and train workers about WHMIS 2015. Although this responsibility is unchanged, the revised education and training programs ensure a smooth transition period, particularly if employers continue to have WHMIS 1988 labels and MSDS in the workplace. Training on these documents must continue throughout the transition time.

Water Activated Toxicants—Included in the Acute Toxicity hazard class if product releases gases that are fatal/toxic/harmful if inhaled.

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Managing Hazardous Material Regulations From OSHA and DOT continued

Overlaps and Conflicts Classification Differences From the OSHA and DOT sections earlier in this paper, it’s shown that there are more hazard categories for OSHA than there are for DOT. However, most DOT hazards are included within OSHA, so there are going to be overlaps and conflicts. The regulations already address how these should be handled. In general, OSHA takes precedence for products in the workplace, and DOT takes precedence during transport.

There will be many situations where a product will be hazardous according to OSHA but nonhazardous according to DOT. Almost all of these differences will occur under health hazards. DOT only regulates poisons (Class 2.3 and Class 6), whereas OSHA regulates a wider variety of health hazards such as skin irritation, sensitization, and carcinogenicity. What this means for the SDS is there will be hazards listed in Section 2, but none in Section 14. Here’s an example: A product’s HCS 2012 classification is: Eye Irritation Category 2 Therefore, Section 2 will have: Signal word: Warning Pictogram: Exclamation point Hazard classification: Eye Irritation Category 2 Hazard statement: Causes serious eye irritation.

Precautionary statements: Four total Section 14 will have: DOT: Not regulated TDG: Not regulated IMDG: Not regulated IATA: Not regulated

classification should be easier to determine. The recommended test methods for OSHA are the same as the ones for DOT. Find the matching classifications for transport, or look at each DOT class to determine if the product fits in any class. A step-by-step process for this would be: 1. Determine hazards for each individual ingredient.

2. Gather information for hazards of the overall product based on the formula, tests, and/or calculations.

3. Classify appropriately according to the HCS 2012 system.

4. If any hazard classification matches in the transport system, include it as part of the DOT classification.

5. Double check the other DOT classes to make sure the product doesn’t additionally fit anywhere else.

6. Determine the transport classification, including the UN number, proper shipping name, class, and packing group.

Labeling and Packaging To understand labeling, there needs to be a clear distinction between which label an employee sees when they’re working with a product and which label a transporter sees when moving a package. The employee is required to see the OSHA compliant label when using the product; this includes bottles, cans, bags, etc. Even when the product is in a large package (such as a drum) it will need to have an OSHA label. During transport, the DOT label has to be used; this includes for boxes, crates, totes, and drums. To demonstrate the differences, here are some examples.

If someone were to ask if the product is hazardous, the answer is yes. However, it should be made clear to drivers and customers that the product isn’t regulated for transport.

In the first example, assume there is a product filled into large bottles, and four bottles are packed into one shipping box. The product is classified as Flammable Liquid Category 2 and Acute Toxicity–Oral Category 4. Two different labels are required in this situation: the HCS 2012 label for each bottle and the transport label for the box. Here is the required classification information that will appear on each label:

To make sure a product is classified correctly, start with the OSHA classification. Hazards should be fairly clear based on the hazards of the ingredients used, but final classifications should come down to testing or using the provided calculations as part of the HCS 2012. After the product has an OSHA classification, the transport

HCS 2012 label: Danger

Exclamation mark pictogram

Flame pictogram

Harmful if swallowed

Highly flammable liquid and vapor

16 precautionary statements

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Managing Hazardous Material Regulations From OSHA and DOT continued

Transport label: Class 3 (flammable) symbol

UN number

Proper shipping name Notice the transport label makes no mention of the acute toxicity hazard, but both labels require the flammable warning.

For the next example, a product is packed in a bag, which is then placed in a box. It’s classified as Sensitization–Respiratory Category 1A. In this case, only one label is required: the HCS 2012 label on the bag. Here’s what will be on it: HCS 2012 label: Danger

Health hazard pictogram

May cause allergy or asthma symptoms or

breathing difficulties if inhaled

Five precautionary statements Transport label: No label required Since the product is not hazardous for transport, only the HCS 2012 label is required. Also, the HCS 2012 label is not required on the box because the product is not intended to be used while in the box. The employees will only see the bag when they’re using the product.

In the last example, a liquid product is filled into a drum, and is classified as Oxidizing Liquid Category 1. Since the drum will be visible during transport and when the product is being used, it will need to have a transport and HCS 2012 label. The information required on the drum includes: HCS 2012 label: Danger

Flame over circle pictogram

May cause fire or explosion; strong oxidizer

Nine precautionary statements

Combining the information about different classifications, and the requirements for labeling, a simple process will ensure that the correct information is provided on the SDS, labels, and shipping documents: 1. Determine the HCS 2012 classification.

2. Determine the transport classification.

3. Make sure the classifications are included on the SDS in Section 2 (HCS) and Section 14 (transport).

4. Label the container that will be visible when employees use the product with the OSHA information.

5. Label the package that will be visible during shipping with the DOT information.

6. Create shipping documents based on the transport classification and label.

Exceptions A major difference between DOT and OSHA is that DOT allows for exceptions based on volume and weight. Since DOT is only concerned with the safety of a product while it’s being transported, small quantities become less dangerous. When Limited Quantity or Excepted Quantity exceptions are used for ground shipments, the labeling requirements are reduced, and there is no requirement for shipping documents. OSHA requires an SDS and label regardless of the product's volume or weight. The only way to reduce or remove the classifications for OSHA is to provide proof that the product is less dangerous.

As an example, if there is a product packaged in a 0.5 L bottle that is classified as Skin Corrosion Category 1B for OSHA, the information that would be displayed on the SDS and labels is as follows.

Classification in Section 2: Skin Corrosion Category 1B Classification in Section 14: Class 8, Packing Group II (a note for Limited Quantity eligibility can be included) HCS 2012 label: Danger

Corrosion pictogram

Causes severe skin burns and eye damage

12 Precautionary statements Transport label: Limited Quantity symbol (no paperwork required)

Transport label: Class 5.1 (oxidizer) symbol

UN number

Proper shipping name The information can be separated, as long as both are visible on the drum.

The information on the HCS 2012 label makes the product look significantly more dangerous than the 35

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Managing Hazardous Material Regulations From OSHA and DOT continued

information on the transport label; however, this is correct due to the volume of the liquid. At 0.5 L, the product won’t cause many issues during transport, and the limited quantity exception actually goes up to 1 L per inner package for packing group II materials in Class 8.

Canada In Canada, WHMIS 2015 is comparable to OSHA HCS 2012, and TDG is comparable to 49 CFR. The same differences between the workplace and transport that were discussed earlier still apply. WHMIS should be used whenever employees are working with a product, and TDG should be used whenever a product is being transported. However, when shipping a product from the United States into Canada, there are some exceptions.

A shipment that is labeled according to 49 CFR can be shipped into or through Canada without being reclassified or relabeled. The only exceptions to this rule are in the following cases:

1. The product is forbidden for transport by the TDG Regulations.

2. The product is regulated by the TDG Regulations but not by 49 CFR. 3. DOT granted an exemption (Special Permit) issued in accordance with 49 CFR. 4. The package has a mark or packaging exception from 49 CFR that is not permitted by the TDG Regulations.

Conclusion

Taking the time to understand each set of regulations and where the agencies have jurisdiction will help clarify the classification and labeling of hazardous materials.

For anything related to the workplace, the HCS 2012 system should be used for SDSs and labels. For any product being transported, DOT shipping documents and labels should be used. When sending products into Canada, as long as they’re not being reshipped or redistributed, then the U.S. information will suffice.

Compartmentalizing the different agencies and their requirements is necessary to ensuring all the proper regulations are being followed.

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the Analyst Volume 25 Number 1

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Intellectual Property: Cornerstones of the Water Treatment Industry Timothy E. Keister, CWT, ProChemTech International, Inc., and Peter E. Greenlimb, Ph.D., CWT, Chemagineering Corporation

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the Analyst Volume 25 Number 1

Abstract

The evolution of the water treatment industry as well as that of all intellectual disciplines has been, in part, dependent on individuals sharing the novelty of their creativity with others. The issuance of a U.S. patent to an individual or individuals grants to the holder(s) a legally enforceable monopoly over the commercial use of the disclosed invention for a finite period of time.

In this paper, the authors share their experiences in filing for U.S. patents and trademarks. Key discussion points include defining “Intellectual Property”; addressing the question “Why file for a patent?”; describing the patent process; selecting legal counsel; handling anticipated and unanticipated costs and expenses; proving the novelty of one’s invention to the patent application examiner; and defending the patent against competitive company claims and infringements.

This paper concludes with a brief review of key patented inventions that have influenced and directed the water treatment industry over the past 50 years.

Introduction

Article 1–Section 8 of the U.S. Constitution states1 that Congress shall have power “to promote the progress of Science and useful Arts, by securing for limited times to authors and inventors the exclusive right to their respective writings and discoveries.” Moreover, the Constitution grants and guarantees a monopoly to authors and inventors for advancing the state of the art. New and innovative ideas potentially will contribute greatly to the growth and commercialization of our global society.

Successful applications of industrial water management programs for boilers, cooling water systems, and waste water treatment facilities demand supervision by creative service technicians, field engineers, salesmen, and business managers, each with a broad knowledge and experience base in the science, engineering, and mathematics disciplines. Each individual who services and manages water treatment programs wears a wide variety of “hats” in his or her daily activities in their respective sales territories.2 U.S. patents are invaluable to our industry because they most often disclose new and innovative ways and methods of minimizing water management problems. In addition, they stimulate the creative minds of others within our 41

industry perpetuating new ideas and technologies, thus sustaining industry growth. Our government agrees to grant to the inventor 20 years of exclusivity commencing with the date of filing a patent application in return for the disclosure to the public of his or her invention. At the conclusion of this term the subject matter of the invention falls into the public domain for use by anyone.

Some examples of expired patented technologies in our industry that we might well utilize in our water management programs on a daily basis include: Polyphosphate3 scale and corrosion inhibitors, Synthetic organic polymeric scale inhibitors and dispersants,4 Organophosphonate5 scale and deposit inhibitors, Stabilized Halogens,6 and Fluorescent chemical treatment tracers.7

The Patent Process The Idea First and foremost, the inventor must determine if his or her idea is truly novel, is not obvious, and is potentially patentable. Initial costs and expenses can be controlled by undertaking your own literature search of U.S. patents on the government’s U.S. Patent and Trademark Office website (www.uspto.gov) or conducting a search on the Internet (www.goggle.com/patents).

Patent Law8 states that an invention cannot be patented if: “(1) The claimed invention was patented, described in a printed publication, or in public use, on sale over a year prior to filing, or otherwise available to the public before the effective filing date of the claimed invention” or “(2) The claimed invention was described in a patent issued [by the U.S.] or in an application for patent published or deemed published [by the U.S.], in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.” “(3) The claimed invention is a natural process or law of nature such as E=MC2 .”

Other methods to determine the patentability of one’s invention include: (1) A detailed review of ‘The Official the Analyst Volume 25 Number 1

Intellectual Property continued

Gazette for Patents, a USPTO weekly publication which contains bibliographic text and representative drawings from each patent issued that week; and (2) A thorough review of technical society proceedings of associations within the realm of your specific interest that could have published a paper pertaining to your innovative idea (ASHRAE, ACS, AWT, CTI, AIChE, WEF, NACE, IWC, etc.).

A patent issued to J. W. Stoll9 in 1977 briefly illustrates the simplicity and uniqueness of a patentable idea. In the application of concentrated caustic soda solutions (f.p. 52–54 °F) as boiler water alkalinity builders in colder northern climates, lower temperature conditions complicate the storage and application of these types of products. However, the addition of caustic potash to caustic soda dramatically lowers the freezing point of the resulting mixture (0 °F) without significantly compromising the strength of the finished product.

Types of Patents There are several different types of patents: A process or utility patent discloses a novel process for producing an object or material.

A composition of matter patent details a novel composition of matter, a means to make it, and applications for it.

A design patent describes a novel item and how to manufacture it.

Issuance of a patent does not mean that the process, composition, or design actually works, but rather that the patent examiner has found no prior art. Thus there are many patents for devices and materials that simply do not work as described in the patent.

The Market If at the completion of your literature search you have been unable to find anything pertaining to your proposed invention that would be considered “prior art,” evaluate the potential market for your invention, noting that perhaps the only expense that you have incurred thus far is “time past.” Important questions to consider include: Does your invention address an existing marketplace need?

42

Is your invention a “profitable” idea?

What is the potential market size for your invention in terms of customers and annual sales dollars?

The Preliminary Application If your searches have found no prior art, and the invention addresses a need, and if there is good market potential for your invention, the next step is to proceed in the filing of a “Preliminary Patent” application. A Preliminary Patent application provides one year of protection prohibiting anyone else from filing a patent on your invention idea. During this period, you can more thoroughly investigate market potentials, manufacturing processes, sales approaches, and other commercial aspects of your invention. In the event that you do not proceed to the filing of a full patent application, your Preliminary Patent application prevents anyone else from obtaining a patent on your invention in the future.

The Full Application Filing a full patent application typically requires that a patent attorney, and perhaps a patent draftsman, be retained. It is not unreasonable to expect that the expenses for these professional services could run in the range between $20,000 and $50,000 during the filing process of a typical patent application.

Patent attorneys initially conduct their own formal search of prior art as it pertains to your invention, then advising you on both the verification of the novelty of your idea and the patentability of your invention. As they commit your invention to statements in the patent application, they reduce your invention to a set of specific independent and dependent claims.

In the Stoll patent9 cited above, his invention is summarized with one specific claim: An aqueous solution of alkali metal hydroxides comprising a 50% by weight aqueous solution of sodium hydroxide (A), and a 45% by weight aqueous solution of potassium hydroxide (B), with the weight ratio of A to B being 2:1, said aqueous solution of the alkali metal hydroxides having a freezing point of about 0 °F.

The Patent Examiner Upon submission of your application to the USPTO, a patent examiner is assigned the review task. In the United States, Thomas Jefferson, while the secretary of state, made up this country’s first Patent Examination the Analyst Volume 25 Number 1

Intellectual Property continued

Panel with Henry Knox and Edmund Randolph. At the age of 23 and early in his career, Albert Einstein worked for the Swiss Patent Office (1902–1909). It was while working for the Patent Office that Einstein came up with his Theory of Relativity.10 While there have been many notable individuals who have spent a portion of their careers as patent examiners, not all individuals who perform this task are a Jefferson or Einstein. While perhaps harshly stated, do not be surprised if the examiner assigned to your patent refuses many, or all, of your patent claims during the initial stage of the patent process. It is very likely that several exchanges with the examiner will be required to convince him that your claims are new art. During this process you may need to “educate” the examiner in your specific area of technology.

The patent application process will also require considerable patience on behalf of the submitter. It is not unusual for a patent application to take two to five years from filing to patent issue. As an early draft of this paper was penned, the following notice was issued by the USPTO (April 4, 2017)11: Earlier today the United States Patent and Trademark Office tweeted the following: “Follow Einstein’s and Jefferson’s footsteps…become a #Patent Examiner. Apply to the USPTO by Nov. 1.” Yes, the USPTO is hiring more examiners, which is very good news.

The fiscal year 2011 results are now in, and the backlog of untouched patent applications as of the end of FY 2011 was 669,625, so there is plenty of work to be done, and hiring more patent examiners has to be a part of the solution.

The Patent Issuance After you have spent considerable time, effort, and resources in the pursuit of a patent application, your invention has been officially patented. Sincerest congratulations! Early in the patent application process when you were evaluating the marketability of your invention, you should have given some significant thought as to whether or not you wanted to manufacture and sell your invention directly to the end-user, license the technology to other companies in lieu of royalties, or use the patent as a marketing tool to establish your technical expertise in the industry as “state of the art.”

43

The Patent Enforcement The U.S. Government–Inventor contract scope of protection provides the inventor the right to exclude others from making, using, or selling the subject matter of the patent for 20 years from the date of filing a patent application. Having been granted a patent is an arduous task in its own right, but additional tasks may well await.

It is important to note that during the term of your monopoly, you as the patent holder are solely responsible for the enforcement of the patent. Key items to be aware of include: 1. If someone believes that your patent has been improperly granted, they can file an ex-parte request with the patent office to challenge your claims. Ex-parte requests simply state the basis for challenging your claims and can be filed by any individual without the assistance of an attorney for less than $2,000. Defense of an ex-parte request would typically involve retaining a patent attorney, and possibly expert witnesses to counter the request.

Such actions could easily cost at least $10,000.

2. An individual may decide to infringe on your patent by using the invention in their business without paying you for its use. The holder of the patent has the right to file for patent infringement in federal court.

If successful, the patent holder would be entitled to triple damages. An infringement filing will require assistance from an experienced attorney at a cost in excess of $10,000. If the infringement involves chemical technology, additional costs of approximately $20,000 could be spent in a discovery proceeding to simply establish if an infringement even exists!

3. Patent law litigation is, of course, a very risky proposition, during which there are usually no winners. Any legal action can either favor your position or not. A patent can either be totally invalidated or just specific claims.

Key Water Treatment Inventions Create…Discover…Invent There are many inventions covering virtually all aspects of the industrial water treatment industry. In the complication of a “short-list” of such inventions, there will always be vital works not included due to the scope the Analyst Volume 25 Number 1

Intellectual Property continued

of such a list. The following tabulation is compiled and embellished based on the input of fellow association members, for which the authors acknowledge.12

Water Was water invented?… Discovered?… Created? Urey and Greiff “discovered” Heavy Water in 1935.13 Theoretically, heavy water could be utilized as a neutron moderation material serving as a precursor in the production of a nuclear weapon. To have any conceivable use in fission chain reactions, however, there needed to be a process of concentrating the deuterium oxide naturally present in water at approximately 0.014%. They applied for a patent on such a process in 1942, and a U.S. patent was granted eight years later.14 Was water created? If man did not invent water how did it come to be? One ancient literature source describes water’s creation as follows: Genesis 1: The Story of Creation. 1 In the beginning, when God created the heavens and the earth — 2 and the earth was without form or shape, with darkness over the abyss and a mighty wind sweeping over the waters.15

Polymeric Sludge Conditioners Scale prevention in the earliest steam boilers relied on natural organic products to condition and disperse boiler water sludges, thus “preventing incrustations” in boilers.16 Wood chips, bark, and sawdust as well as starches, potatoes, and bran have been utilized. Initial applications of approximately 5 pounds of oak chips per boiler horsepower, or a peck of potatoes per steam boiler per week, evolved into the applications of refined tannins, lignosulfonates, and potato starches, which proved to be good sludge conditioners.

halogens.” Actually, stabilized halogens were invented by researchers at DuPont6 many years before the Nalco and Albemarle patents were issued. How did this happen?

The patent examiner did not discover the prior art during the patent examination process. This error was corrected by an ex-parte action decision in 2007. The lesson here is to do your own research, as patent examiners are often overworked and lack expertise in specific fields such as industrial water treatment.

Other Patents Depending on one’s individual water technology interests, one or more of the following U.S. patents may serve as a starting point in developing that novel water management product idea to further serve a client’s need or enter a unique market segment. Azoles as Corrosion Inhibitors,18 Biodispersants,19 Erythorbate Oxygen Scavengers, 20 Steam/Condensate Neutralizing Amines, 21 Boiler Water Filming Amines, 22 and Organophosphonates23 are some examples.

References

1. The U.S. Constitution: A Reader, Hillsdale College Press, Hillsdale, MI (2012).

2. AWT Technical Training Seminars, Service Technician Training (2014).

3. I.T. Godlewski, J.J. Schuck, and A.S. Chisarik, U.S. Patent 4,288,327 (1981).

4. F.B. Crum and J.F. Wilkes, U.S. Patent 2,783,200 (1957).

5. R.R. Irani, U.S. Patent 3,234,124 (1966).

6. W.C. Golton and A.F. Rutkiewic. U.S. Patent 3,749,672 (1973).

7. G.N. Sethumadhavan and B.S. Johnson, U.S. Patent 2006/0160227 A1 (2006).

8. R.A. Brown, HPAC Engineering, p. 77 (Feb. 2000).

9. J. W. Stoll, U.S. Patent 4,064,065 (1977).

10. "Albert Einstein," Encycopaedia Britannica Online (2017).

11. USPTO Tweet April 4, 2017.

12. D.S. Krack, S. Lowe, C. Golden, and G. Garcia, Personal Communications (2017).

13. H. C. Urey and L. J. Greiff, J. Am. Chem. Soc., 57: 321 (1935).

In 1957, the first U.S. patent on organic polymeric sludge conditioning and dispersing agents was granted to CrumWilkes.4 Their polyacrylate polymers were proven to be more effective at inhibiting water-side crystal growth and scale formation versus the natural organic precursors.

This patent has led to the development of a multitude of organic polymeric sludge conditioning and dispersing agents of co-polymers and terpolymers17 and many others.

14. H. C. Urey, N. J. Leonia, and A. V. Grosse, U.S. Patent 2,690,379 (1954).

Stabilized Halogens One would think based on several patents issued to Nalco and Albemarle that they invented “stabilized

22. J.L. Walker and T. Edward, U.S. Patent 3,931,043 (1976).

15. The New American Bible, St. Joseph Edition, Catholic Book Publishing Company, New York, NY (1992).

16. W. B. Dick, Dick's Encyclopedia of Practical Receipts and Processes (1873).

17. D.R. Amick, W.M. Hann, and J. Natoli, U.S. Patent 4,711,725 (1987).

18. L.H. Flett, U.S. Patent 2,469,378 (1949).

19. R.M. Donlan, D.L. Elliot, N.J. Kapp, C.L. Wiatr, and P.A. Rey, U.S. Patent 6,039,965, (2000).

20. C.W. Crowe, U.S. Patent 4,317,735 (1982).

21. G.C. Claver, U.S. Patent 2,687,442 (1954).

23. B. Blaser and K.H. Worms, U.S. Patent 3,214,454 (1965).

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the Analyst Volume 25 Number 1

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Association News

AWT Training Seminars

The AWT Training Seminars provide water treatment professionals with the opportunity to further expand their knowledge; these seminars teach the field’s best practices and offer tools and techniques to help enhance your professional skills.

Courses offered are:

Dale Carnegie Training

AWT has partnered with Dale Carnegie Training to deliver its Leadership Academies. These live online courses are limited to 30 enrollees, allowing participants to have real-time conversations with each other. Courses are offered multiple times each month, so you can select the time that best fits into your schedule.

The two academies are:

1-Day Sales Training 1-Day RO Training 3-Day Fundamentals and Applications Training 3-Day Water Treatment Training

AWT Managerial Development Academy (7 courses, 17 hours) AWT Sales Training Academy (10 courses, 22 hours)

Courses are taught by experienced water treatment professionals and Certified Water Technologists (CWTs); attendees receive access to electronic PDF copies of course content, an invaluable tool for continued learning. Register today at https://www.awt.org/tt2018/.

46

The world renowned Dale Carnegie Training was established in 1912 and has assisted companies of all sizes in meeting their business challenges by helping employees develop into confident, empowered, and enthusiastic individuals. To date, more than 8 million people have used the training to strengthen interpersonal relations and handle fast-changing workplace conditions. The courses focus on communication, creative problem-solving, and leadership. Now you can take advantage of this training, at low cost through your AWT membership, to enhance your work force and grow your bottom line. Sign up today at https://www.awt.org/education_events/online_business_courses.cfm.

the Analyst Volume 25 Number 1

Association News continued

CEU Tracker for Current CWTs

Current CWTs can now upload their requests for Continuing Education Units (CEUs) using the CEU Tracker button located on their personal profile page on the Members Only portion of the website. AWT staff will continue to automatically record CEUs earned from AWT events such as the Annual Convention, Training Seminars, and AWT webinars attended in real time. Recertification quizzes should continue to be taken online; a score of 80% or higher will result in the CEU amount being automatically recorded in your CEU Tracker. CEUs earned from AWT webinars viewed from the Members Only page and non-AWT events can also be uploaded for approval. Once the CEU requests are received and approved by staff, the CEU amount being claimed will appear in your CEU Tracker.

A progress bar on your CEU Tracker will increase in percentage each time an approved CEU is added to your record. Once the bar hits 100%, you are eligible to recertify. The progress bar is a nice visual for keeping track of your CWT details and recertification records.

Listserv

Are you currently signed up for the AWT listserv? These interactive discussion groups allow you to submit a question to a specific email list, which in turn transparently sends it on to the email addresses of the list subscribers.

Each conversation comes directly into your inbox, so you can read and reply. Need advice? Have a question?

Use the listserv! In all, 15 different members-only AWT listserv groups cover topics from business to technical, education to international, and legislative to women in water treatment. You can sign up for just one or more, but do sign up. You can enroll at https://www.awt.org/ members_only/index.cfm.

Don't miss out on this excellent resource, often cited as one of the best AWT member benefits. It’s a useful and beneficial tool for your professional needs.

We hope you are pleased with this new feature to help with your recertification status and your CEU count. As always, your feedback is welcome and can be submitted to apike@awt.org.

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the Analyst Volume 25 Number 1

Membership Benefits

Many water treatment companies have experienced tremendous professional and financial growth through their association with AWT. As we embark on the 2018 membership year, here’s a small reminder of why companies choose to retain their AWT membership:

Education

Discounts on comprehensive and cost-effective educational opportunities like our Technical Training Seminars.

Discounts on specialty publications relating to the water treatment industry through the bookstore.

Resources

A complimentary subscription to the Analyst, AWT’s quarterly magazine featuring new technologies in the industry, for each employee listed with your company.

Industry news and business tips through the monthly AWT Gram.

Networking

Volunteer positions to influence the association and industry.

The ability to consult with peers around the world through the listserv.

For just a few dollars a day, your company and its employees enjoy the increased marketability, knowledge, and financial success that comes from being a member of AWT, the organization that truly cares about the independent water treatment professional. Thank you for your involvement and continued support; we look forward to serving you in 2018!

Helpful marketing and business techniques and materials to assist you in promoting yourself and your company.

Monetary savings on health insurance, liability insurance, shipping, credit card processing, and more through our members only discount programs.

48

the Analyst Volume 25 Number 1

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Industry Notes

H2O LANXESS Offers New Mixed-Bed Exchanger for Demineralizing Water

Specialty chemicals company LANXESS has developed the Lewatit NM 3367 mixed-bed ion exchange resin to demineralize the water used to charge and top up modern hot water heating systems. “The custom-designed mixed-bed system not only prevents scale formation in the parts of a heating system that convey water but also provides lasting protection against corrosion,” explains Hans-Jürgen Wedemeyer, manager of technical marketing at LANXESS Deutschland. “This can’t be achieved simply by softening the water,” he adds.

Lewatit NM 3367 differs from other mixed-bed systems on the market in several respects. The specific mixing ratio takes into account the fact that anion exchange resins generally have a lower capacity than cation equivalents. Were this not allowed for, further anions could react with the hydrogen ions released by the still active cation exchange resin after total loading of the anion exchanger. Carbonic acid would thus be generated from hydrogen carbonate anions, and even more aggressive mineral acids from chloride, nitrate or sulfate. “The higher proportion of anion exchange resin ensures a long service life and thus highly efficient demineralization with the new mixed bed,” explains Wedemeyer.

The system also owes this high efficiency to a special process for reloading the anion exchange resin used, which results in a hydroxide ion loading of over 90 percent. “Because this high loading cannot be reproduced during conventional mixed-bed regeneration, we advise against using regeneration,” continues Wedemeyer.

To ensure this high OH- loading is maintained over a long period during transportation and storage, the anion exchange resin must be protected against carbon dioxide, as bound hydrogen carbonate would otherwise form. Toward the end of the exchange cycle, this would then be displaced by anions with a higher binding affinity, which in turn would enable acid to form. “We 50

use special gas-tight aluminum-coated film packaging to prevent any such subsequent formation of bound hydrogen carbonate. We also offer the mixed-bed system in a handy, relatively small container size of 12.5 liters,” says Wedemeyer. Once containers are opened, 2 4 the contents can thus be quickly transferred to smaller gas-tight units such as cartridges or used in their entirety to fill a standard exchanger container.

H SO

The main advantage of demineralization for treating water in the heating circuit is that it removes not only the hardening alkaline earth cations but also their counterions, thereby producing salt-free water with a very low residual conductivity. “Even in the presence of oxygen, there is normally no significant corrosion with conductivities in the 1 µS/cm range,” reveals Wedemeyer. With such low conductivities, however, pH measurements are no longer meaningful because most pH meters require the medium to have a minimum conductivity that would no longer be achieved in this case. Furthermore, even the tiniest quantities of carbon dioxide or ions—from the sides of the glassware, for example—would significantly interfere with any measurement in open systems.

“Conductivity is clearly the all-important evaluation criterion in this range,” says Wedemeyer.

If the conductivity increases to a typical switchoff point of 100 µS/cm toward the end of an exchange cycle, however, relevant standards such as VDI 2035 stipulate that a pH window of 8.2 to 9.5 must be complied with to prevent any corrosion. “Our tests revealed that this is ensured when using Lewatit NM 3367,” confirms Wedemeyer. If the parts of the heating circuit conveying water are made of aluminum, this pH window is even smaller, extending from 8.2 to just 8.5. In such cases, the switchoff point would need to be brought forward to a conductivity of around 5 µS/cm so as to remain within the pH tolerance referred to. Detailed information about products from the LPT business unit can be obtained online at http://lpt.lanxess.com/en/home/. the Analyst Volume 25 Number 1

Industry Notes continued

Banyan Water Partners With HydroTech to Optimize Cooling Tower Water Use

Banyan Water, the leading provider of data-driven water conservation for enterprises, today announced a partnership with HydroTech Solutions, LLC, a commercial water conservation service provider, to enable commercial and industrial properties to streamline water use in cooling towers, boilers, potable water systems, and graywater storage. The partnership provides commercial enterprises with unparalleled insight into their water use.

"Banyan has the ideal platform for collecting and analyzing our sensor data at customer locations, with analytics that differentiate from other solutions," said Brent Mulliniks, president of HydroTech. "Our water conservation technologies are validated with real-time reporting and provide predictive analytics that save operating and capital costs. Our complementary relationship with Banyan provides key operating data for sustainability or facility managers, and easy integration with building automation systems. Our customers are able to conserve water, reduce costs, and increase asset value."

HydroFLOW—HydroTech's physical water conditioners for cooling towers—forces dissolved calcium to crystallize in the water stream, preventing scale from forming on equipment and allowing circulating water to be used two to three times longer without scale accumulation and with 75 percent fewer chemicals. The Total Water Management service includes eco-friendly solid chemistry, side-stream filtration, and monthly site visits for program compliance.

Banyan's software platform—available in real time on secure desktop- or mobile-accessible dashboards— collects and visualizes data from HydroTech's hardware.

Monthly reports detail cost savings, performance analysis, and evaporation credit data that can be submitted to municipalities for rebates on monthly water bills.

"Our partnership with HydroTech couldn't come at a more appropriate time," said Gillan Taddune, CEO of Banyan. "HydroTech's leading hardware solutions, combined with Banyan's advanced real-time analytics capabilities, represent a next-generation opportunity for enterprises and even entire cities to implement new methods of conserving water while saving money in the process."

51

Founded in 2011, Banyan Water is the leading provider of data-driven water conservation for enterprises. Using smart devices and real-time monitoring and analytics, Banyan protects Earth's most precious resource while generating untapped revenue for clients. Since the company's inception, Banyan has saved more than 2.3 billion gallons of water, enough to meet the water needs of more than 16,000 households for a year. For more information, visit www.banyanwater.com.

HydroTech Solutions was founded in 2015 with a focus on providing water conservation technologies for commercial and industrial facilities. Using proven technologies that physically condition water for cooling towers, boilers, and potable water systems, HydroTech's Total Water Management program conserves millions of gallons of water per year per building. Cost savings of water, chemicals, and energy pay for the service, and the range of sensors allow operators to monitor water use to improve efficiencies and costs. To learn more, please visit www.hydrotech.solutions.

Endress+Hauser Acquires Blue Ocean Nova

Endress+Hauser is further expanding its portfolio of products, solutions, and services in the field of process analytical measurement. The group has acquired Blue Ocean Nova AG, a manufacturer of innovative inline spectrometers for monitoring quality-relevant process parameters. The company's 15 employees located in Aalen, Germany, will be retained.

Blue Ocean Nova will operate under the umbrella of Endress+Hauser's center of competence for liquid analysis headquartered in Gerlingen, Germany. "The intelligent process sensors developed by Blue Ocean Nova will enhance our offering in the field of process analytical measurement, adding a strategic building block," says Dr. Manfred Jagiella, managing director of Endress+Hauser Conducta GmbH+Co. KG. As a member of the group's executive board, he is also responsible for the analytics business.

The process sensors developed by Blue Ocean Nova cover the relevant optical spectroscopy regions of UV-VIS, NIR, and MIR to analyze liquids, gases, and solids inline. The innovative technology allows the spectrometer to be directly integrated into the measurement probe, the Analyst Volume 25 Number 1

Industry Notes continued

even in explosion-hazardous areas. The sensors can furthermore be automatically cleaned and easily integrated into process control systems.

The systems from Blue Ocean Nova are utilized in the food & beverage, oil & gas, chemicals, and life sciences industries for applications such as concentration and moisture measurements and for measuring relevant quality parameters. The technology enhances the group's portfolio, which already encompasses Raman spectroscopy, tunable diode laser absorption spectroscopy (TDLAS), and process photometers.

Blue Ocean Nova was founded by Joachim Mannhardt and Stefan Beck in 2015, bringing extensive product development experience in the field of industrial spectroscopy and process analytical measurements to the company. "Endress+Hauser opens the door to international markets and customers for us," explains Stefan Beck. Joachim Mannhardt adds, "We're convinced that our technology will be an ideal enhancement to Endress+Hauser's optical portfolio."

Endress+Hauser acquired Blue Ocean Nova effective 31 October 2017. Both parties agreed not to disclose the details of the transaction. Joachim Mannhardt and Stefan Beck will remain on the management team of the innovative company. "With this acquisition, we are continuing to pursue our strategy of strengthening the process analytical measurement portfolio and in the future supporting our customers from the lab to process," says Manfred Jagiella.

Veolia Opens New Sustainable Chilled Water Plant in Baltimore

Veolia Energy Baltimore Cooling LLP, a subsidiary of Veolia North America, the world's leading provider of environmental solutions and optimized resource management, recently opened a new chilled water plant, the result of a successful collaboration among Veolia, the city of Baltimore, the Baltimore Convention Center (BCC), and the Maryland Stadium Authority (MSA). The project represents a victory for sustainable district energy infrastructure and the potential for green technology to improve energy efficiencies and customers' quality of life while also stimulating the local economy.

The 5,400 ton capacity Plant 1 facility, housed inside the BCC, will provide chilled water to the Convention Center and Camden Station at Oriole Park, as well as more than 50 major customers in Baltimore, ranging from commercial buildings to hospitals and government facilities. As part of an integrated system, Plant 1 connects with three other chilled water plants operated by Veolia, increasing chilled water reliability and redundancy.

This chilled water infrastructure supports a sustainable future for the city of Baltimore. The plant will deliver a positive environmental impact by both reducing the city's greenhouse gas emissions and improving air quality.

In addition, by eliminating 60,000 pounds of R-22, an ozone-depleting refrigerant, the new infrastructure is alleviating potential safety concerns. Contributing to the city's goal of reducing greenhouse gas emissions by 15 percent by 2020, equipment efficiencies at the plant have reduced the city of Baltimore's carbon footprint by an additional 6,137 tons per year—the equivalent of removing 1,177 cars from the road annually.

Plant 1 will also contribute to Baltimore's economic sustainability, saving the city an estimated $189,172 in annual electricity costs due to the plant's new efficient infrastructure. By utilizing nighttime electricity reserves to produce up to 48,000 ton-hours of ice storage capacity, the plant maximizes additional equipment efficiencies while also taking pressure off the grid during peak day-time hours.

The facility represents an $11.8-million-dollar investment into green energy and the community by Veolia and its partners, with an additional 80,000 man-hours of green jobs generated during construction of the plant.

The project also came in $2.1 million under budget thanks to expert project management and the strategic partnership among Veolia, the city of Baltimore, the BCC, and the MSA. "A cornerstone to the success of this project was the close collaboration of public and private partners—a relationship that has spanned over a decade," said William J. DiCroce, president and CEO of Veolia North America. "This project illustrates how great things can happen when people come together under a common Continued on page 56

52

the Analyst Volume 25 Number 1

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Making a Splash

Mark T. Lewis, CWT

Southeastern Laboratories, Inc. Rock Hill, South Carolina

I began my water treatment career in 1988 at Premier Water and Energy Technology, Inc. with no knowledge that water treatment was even a career. My wife Cathy and I were on vacation visiting some friends; one of them, Steve Robson, asked me if I would like to come to work for him. I told him I didn’t know anything about water, except that you need 6–8 glasses a day. He informed me that it wasn’t that kind of water treatment and he’d teach me. My background was in electrical, not chemistry, biology, or mechanical. If I had to guess, probably half of those in the water treatment industry today happened upon it by chance. The other half are following in their parents footsteps. No matter how we got here, we can all agree that it’s a great industry to be in.

I have learned from my peers, from training seminars, from reading, and from just plain old experience. When faced with an obstacle, be determined not to let it get the better of you; that’s the best kind of learning. I was 20 when I began my career. I had to earn the respect of my customers and prove myself every day. I was lucky to have great mentors who explained why things worked and what I could expect if they didn’t. They explained the how AND the why; that is very important. Thank you Gale Fillinger, Tom Brandvold, Steve Robson, and Chuck Brandvold; you influenced my early beginnings.

In 1994, I took the CWT exam in Orlando; I was determined to be the youngest CWT ever. When I received the results, I learned that I didn’t know as much as I thought I did; more knowledge was required before I could realize that dream. I tried again in Atlanta in 1997, and this time I passed. On completion of the application process, I became CWT #98.

55

In 2000, I joined the Education/Certification Committee.

My initial project was to moderate the Regional Training Session in Atlanta in 2001 and, determined to impress my peers, I conducted my own evaluation and provided Bruce Ketrick with data regarding the attendees and the sessions.

Later that year, Tony McNamara asked me to chair the new breakaway Certification Committee. I didn’t realize how much work needed to be done, but the journey was well worth it. Leadership in my first year was challenging, but I learned, and if I asked for help, help came.

The committee accomplished a great deal that year. We performed a cut score for the newly written CWT exam and then completed the CWT credential accreditation process. Later that year, I learned that the AWT board had considered cancelling the CWT program if we hadn’t accomplished what we did. If I had known that, I would have never signed up for the job. Several years later, then AWT president Steve MacCarthy asked if I would be willing to change committees. I agreed as long as it wasn’t Membership. In 2005, I became chair of the Membership Committee. Over the next few years, the committee put together great new benefits of membership and streamlined processes.

Because of my involvement in AWT, when my wife and I relocated to Charlotte, North Carolina, I reached out to a fellow AWT member and was able to continue my career with Southeastern Laboratories, Inc. In 2008, I was elected to serve on the AWT board of directors, which allowed me to learn much more about how AWT functions. As a board member, I helped set the direction of the association; this was a rewarding time for me. In 2012, I became AWT president. After my stint on the board

the Analyst Volume 25 Number 1

Making a Splash continued

Industry Notes continued

ended, I rejoined the Education Committee and was asked to help revamp the Technical Training Seminars basic training program, now known as Fundamentals and Applications. Being able to work on projects with my peers is very rewarding.

vision—conserve energy, create jobs, reduce carbon pollution, and improve the community's green energy infrastructure."

For more information, visit www.veolia.com.

In addition to teaching the Fundamentals and Applications class at the seminars, I am working with Trace Blackmore on “Scaling Up,” a podcast by water treaters for water treaters.

Cortec® Presents Sound, Environmentally Friendly Water Treatment Alternatives in New Additives Brochure

So, if you ask my advice on how to advance your water treatment career, I’d say be active in your profession, your learning, and your trade association. Always try to be a better water treater tomorrow than you were today.

Water treatment keeps me busy, but not enough to stop me enjoying my other passions in life: Cathy, my wife of 31 years; my son Erik and his wife Gabbie; my two grandbabies, Marley and Delilah; the many children we have fostered over the years; and the ones who continue to be in our lives even though they weren’t in our direct care (we call these bonus children).

Professionally, and personally, I’m a very happy and fulfilled gentleman.

Cortec’s new brochure on “VpCI® Building Blocks and Additives for Water Treatment Formulations” focuses on the prevention of both corrosion and scale buildup in process water. Additives for boilers, heat exchangers, cooling towers, and condensate lines can be instrumental in lengthening the life of a system and reducing maintenance. Additionally, Cortec’s corrosion inhibitor additives make great building blocks for full water treatment formulations.

When multi-phase protection is necessary, Cortec® offers VpCI® Technology options that protect in the vapor phase, contact phase, and at the air-water interface. These VpCI® molecules diffuse throughout the enclosed space and adsorb on metal surfaces below and above the surface of the water, forming a thin, molecular, corrosion-inhibiting layer that protects against oxygen, chlorides, and other corrosive elements.

Protecting and cleaning boilers, heat exchangers, cooling loops, and other water systems is an important step for in-process maintenance and protection during seasonal layup. Rather than using more hazardous treatments, Cortec’s additives include several “greener” or lower toxicity alternatives to effectively protect and maintain equipment.

Cortec® additives are an innovative way to add corrosion protection, not only to water systems, but also to a range of deicing salts and fluids, coatings, cleaners and degreasers, fuels, plastics, elastomers, and more. To read the entire version of this brochure, please visit: http://cortecadditives.com/wp-content/uploads/2017/09/ VpCI_Additives_Building_Blocks_Water_Treatment. pdf.

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the Analyst Volume 25 Number 1

CWT Spotlight

Benjamin Shriner, CWT

Tasco Water Works, Inc. Capitol Heights, Maryland

What prompted you to obtain your CWT, and when did you begin the process by taking the test?

After graduating college, pursuing my CWT was the next step in my professional career. I wanted to continue learning the different aspects of water treatment, however unfamiliar they may be. In addition, since I grew up in the industry, it was always a personal goal of mine to take the test and become a CWT. It is also a highly regarded certification in our company.

What advice would you give those thinking about taking the exam?

My advice would be to set a test date and map out several months in advance how you are going to study and process the information. For me, that meant going through the entire AWT Technical Reference and Training Manual one chapter at a time and typing out notes on what I felt was important. Of course, that led to several pages per chapter, but it was a great way to learn and retain the information. Studying really comes down to taking your time and not rushing through the information.

How did you prepare for the test?

The AWT Technical Training Seminars, as well as reading all the pertinent books from the AWT store, are key to really submerging yourself in the information.

Even with the expensive price tag, the books were an investment in not only my, but also fellow employees’ education. With that being said, I mainly focused on the above-mentioned AWT Technical Reference and Training Manual because I could take out the chapter I was working on at the time and it wouldn’t feel as overwhelming.

Why do you feel this credential was important to have?

Becoming a CWT is important not only to show your customers that you are competent, but also so you can remain competitive. It has become a requirement on more specifications within RFPs, and you can miss out on opportunities without it.

What was the most difficult aspect of the exam?

Overall, the hardest part was the extensive amount of information that the test could cover and knowing that there may be only one or two questions on a section I spent several hours learning. I was lucky to have over 10 years of experience in the industry before taking the test, but that didn’t help me on the clarification questions because I rarely deal with coagulants and flocculants in my day-to-day activities.

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Ask the Experts

The discussion below occurred on AWT’s listserv and/ or LinkedIn page. Be sure to join to be part of the conversation!

Free Chlorine Monitor Question: We have a customer who is using chlorine for odor control on an air scrubber. They want us to install an ORP system to help monitor the chlorine residual but the problem is they have to run 10 ppm of free chlorine.

In conversations with our equipment distributors at that high of a level it will be hard to control with ORP due to pH issues, etc.

Do any of you know of any reliable chlorine analyzers/ monitors out there that can handle this high of a level of free chlorine? Thanks in advance.

Answer 1

That is a challenge testing for that high of a level of chlorine. You should look at the FAS DPD method for verifying 10 ppm of free chlorine without dilution.

Answer 3

There is no way ORP is going to work for 10 ppm free chlorine. There are 0–20 ppm free chlorine sensors available (contact your equipment supplier). However, if you go that way, the water will need to be filtered for particulates. Use this ahead of an oil/grease removal cartridge or filter bag, if necessary, to remove as much as possible. Both filters are recommended to reduce fouling of the direct reading sensor membrane. Orientation of the sensor in the manifold may also need to be adjusted to reduce air bubbles on the membrane (if sample is highly aerated). Note: IF the sensor does not see any free chlorine for “too long,” it will “go to sleep” and need to see measurable free chlorine for a period of time before it works well again. Not a problem if the process is basically 24/7.

Answer 2

It could be done if there was pH control along with the ORP. Wouldn't really matter what the pH was just as long as it is consistent. Think this may be a little more complicated than you or your customer may want but may be the only way to do it.

My second thought is does it really take 10 ppm to control odor? There may be other issues, such as a dirty scrubber, etc.

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T.U.T.O.R.

Technical Updates, Tips, or Reviews

Water-Testing Interferences by: Chris Golden, CWT, Taylor Technologies, Inc.

With so much at stake, it’s imperative that water treaters thoroughly understand the water chemistries in a treated system. We need to be the expert consultants, and proper water testing in the field is the foundation for becoming that expert. There are “interferences” which can keep a water treater from obtaining accurate results on the condition of the water in a system. Understanding these interferences will enable us to offer the best consultation.

During my presentation at the 2017 convention in Grand Rapids, I mentioned the fact that water treaters are often the largest source of interference. Poor techniques in sample collecting and testing methods can steer you away from the correct test results. Remember, meters need to be calibrated or proved accurate. Reagents need to be fresh. Show those reagents some respect; they don’t like cooking in the trunk of your car or being subjected to freezing temperatures. And if you refill your reagent bottles from larger bottles to save money, it’s a good practice to periodically replace the dropper tips. Finally, observe any waiting times required for a test method; they are there for a reason!

In addition to the problems we ourselves can bring to the testing arena, here are some common interferences you might encounter:

Sulfite tests We’ve all collected hot samples out of a boiler’s sight glass or blowdown line. But did you know testing that sample while it is hot will give you a false-high sulfite reading? The sample must be cooled in a sealed bottle and allowed to reach room temperature before performing the test. Allowing to cool in an open container will result in a false-low reading.

Hardness tests Metals like iron and copper interfere with the endpoint color development in hardness tests. The titrant for hardness tests is EDTA chelant. Chelants prefer metals more than they do calcium and magnesium hardness, so 61

the chelant preferentially reacts with the iron and copper in a sample. The result…a “fading endpoint.” The sample will probably go from red to blue, but in a second or two it will turn back to red. Many additional drops of titrant will need to be added before the sample remains blue. To remove this interference, simply add two or three drops of titrant first, followed by the buffer and indicator; then do the titration. Remember to include those first two or three drops in the total when calculating the test results.

Ampule tests The ampules used for testing residual oxygen in boiler feedwater samples can often give a false-high reading, but not because of their chemistry. This relates to letting a sample flow long enough to reach equilibrium while flushing out any oxygen in the sample tubing. The longer you let an unbroken ampule sit in the flowing sample, the more accurate the results will be.

Chlorine tests High chlorine levels can bleach out the DPD indicator and prevent a pink color from developing. This usually occurs at chlorine levels over 10 ppm, which explains why we rarely see this in the industrial world. This bleaching interference could lead you to think there is not enough chlorine in the system, so you add more.

A telltale sign that this is occurring is when you see a flash of pink in the sample when the DPD is added, but then the sample goes back to colorless. Dilution with a non-chlorinated water is necessary to determine the correct chlorine levels in these waters.

Total alkalinity tests When a sample goes from blue to yellow instead of green to red after adding the total alkalinity reagent, this indicates an excess amount of chlorine is present in the sample. Although a yellow endpoint is still accurate, it is unexpected. To counter this unusual color change, add two drops of sodium thiosulfate to the sample before adding the indicator. The thiosulfate will remove the chlorine interference. the Analyst Volume 25 Number 1

T.U.T.O.R continued

Phosphonate drop tests Interferences in this type of test are frequent in the industry. First, phosphonate drop tests require the pH to be in the method’s spec range.

The sample pH must be correct (2.6‒3.0). No one buffer handles all waters. Without confirming the sample has the correct pH level, the test result could be compromised.

Second, fluoride is a positive interference with this test. Most municipal drinking-water systems add fluoride, which then cycles up in cooling waters. Without the addition of a fluoride masking agent, the test results will show higher levels than are actually in the cooling water. This will lead to undertreatment and poor results. Ortho- and polyphosphates are also positive interferences for this test method, while iron is a negative interference.

Iron and copper These metals interfere with each other and with many other tests. If your corrosion rates are not under control, then your test results can lead you further from desired results.

Conclusion Water treatment requires the water treater to be an expert on the water systems. There are mechanical and chemical aspects of these systems; water treaters need to understand both. The chemical side begins with having an accurate knowledge of the water chemistries and understanding testing interferences that can lead to the true conditions in the system.

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Capital Eyes

Trump Administration Has Impacted Reach of Regulations Since taking office, Donald Trump has made cutting the reach of federal regulations a priority. And we are seeing a difference, especially in the environmental arena. A recent survey released by the Business Roundtable found that for the first time in six years, executives did not cite regulations as the top cost pressure facing their companies.

Overall Impact

In total, the administration has so far revoked 67 rules.

Another 635 planned regulations were withdrawn, 244 regulations that had been proposed were put on inactive status, and 700 regulations were delayed. Other White House reports inflate these numbers, but the bottom line is that the scope of regulations has been decreased.

Most of the regulatory rollback has come through Congress, which has used a power known as the Congressional Review Act to eliminate more than a dozen Obama-era initiatives. This act, which had only been used once before the Trump Administration, can mollify federal regulations for 60 legislative days after they have been finalized with a simple majority vote.

The Trump administration also has limited the regulatory reach of federal agencies by appointing many business leaders as Cabinet secretaries, who then have greatly decreased the number of new rules introduced.

During the first year of the current administration, about 50 new rules have been proposed in the Federal Register. During Obama’s first year, approximately 190 64

were proposed, and during each of the Clinton and Bush first years, about 180 were published.

Another means of reining in regulations is less severe enforcement of existing rules. For example, civil penalties levied by the Environmental Protection Agency (EPA) for environmental violations through July 31, 2017, were 60 percent smaller under Trump on average compared to the first year of the three previous presidents.

Environmental Regulations

Of the 67 rules that have been reversed under the Trump administration, 60 of them were environmental in nature. Below are some that could have impacted the water treatment industry: Fracking on Public Lands – On the last business day of the year, a 2015 Obama rule was rescinded that would have set new environmental limitations on hydraulic fracturing on public lands. The regulation would have tightened standards for well construction and wastewater management, required the disclosure of the chemicals contained in fracking fluids and most likely have driven up the cost for many fracking activities.

Greenhouse Gases in Environmental Reviews – These guidelines advised federal agencies to account for possible climate effects in environmental impact reviews.

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Capital Eyes continued

Reducing Pollutants at Sewage Treatment Plants – This rule required sewage treatment plants to further regulate emissions, including hazardous air pollutants, at these plants.

Safety at Chemical Facilities – This rule was a response to a 2013 explosion at a fertilizer plant that killed 15 people. The implementation of these standards have been delayed until 2019, but 11 states are now suing the Agency over the delay.

Janet Kopenhaver is president of Eye on Washington and serves as the AWT Washington representative. She can be reached at (703) 528-7822 or janetk@ eyeonwashington.com.

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Business Notes

Should you change your business—or transform it?

As its market and technological needs evolve, every company needs to change. There’s even a formal term for the undertaking: “change management.” From an operational standpoint, change involves opening up the hood and switching out old engine parts for new ones. Even if it affects the business as a whole, change means focusing on specific areas and making alterations over relatively short periods.

At some point in the existence of many companies, the organization needs to go beyond change to transformation. This is much different. Business transformations aren’t so much about switching out parts as overhauling the entire engine, possibly modifying the frame and even applying a new coat of paint. Let’s look a little more closely at the distinction.

Reinvent yourself

Say a large commercial construction company was having trouble meeting its sales goals because of environmental regulations. So, it decided to augment its sales teams with environmental engineers who could better assess the compliance impact. The company applied change management principles—such as building a case for the idea and adjusting its business culture—and was successful. This was no doubt an important change, but the business itself wasn’t transformed.

The objective of a true transformation is to essentially reinvent the company and implement a new business model. And that model needs to be a carefully, formally devised chain of interlocking strategic initiatives that apply to the entire organization.

67

Perhaps the most obvious and universal example of a business transformation is Apple. The technology giant, once a head-to-head competitor with IBM on the personal computer market, found itself struggling in the 1990s. So, under the tutelage of the late Steve Jobs, it transformed itself into a mobile technology company.

It still makes computers, of course, but the company’s transformative success can really be attributed to its mobile devices and operating systems.

Think and act wisely

Every business transformation differs based on the history, nature and size of the company in question. But there are best practices to keep in mind. For example, start with your customers, visualizing what they need (even if they don’t know it yet). Also, build a chain of initiatives, so you’re not trying to do everything all at once. And use metrics, so you can track specific dollar amounts and productivity goals throughout the transformation.

Above all, be ready for anything. Even the best-planned transformations can produce unpredictable results. So keep expectations in line and take a measured, patient approach to every initiative involved.

Bring along help

Successful business transformations can be spectacular and profitable. But, make no mistake, the risk level is high.

So if you decide to embark on this journey, bring along your trusted financial, legal and strategic advisors. © 2017 Thomson Reuters

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Financial Matters

How to steer clear of tax issues related to shareholder loans Owners occasionally need to borrow funds from their businesses. If your business is structured as a corporation and it has extra cash on hand, a shareholder loan can be a convenient and low-cost option—but it’s important to treat the transaction as a bona fide loan. If you don’t, the IRS may claim you received a taxable dividend or compensation payment rather than a loan.

Taking a closer look

A corporation can make de minimis loans of $10,000 or less to shareholders without paying interest. But, if all of the loans from the corporation to a shareholder add up to more than $10,000, the advances may be subject to a complicated set of below-market interest rules unless you charge what the IRS considers an “adequate” rate of interest. Each month the IRS publishes its applicable federal rates (AFRs), which vary depending on the term of the loan.

Right now, although interest rates are starting to rise, they’re still near historic lows, making it a good time to borrow money. For example, in July 2017, the adjusted AFR for short-term loans (of not more than three years) was only 1.22% (up from 0.71% in July 2016). The rate was 1.89% (up from 1.43% in July 2016) for midterm loans (with terms ranging from more than three years to not more than nine years).

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The AFRs are typically below what a bank would charge.

As long as the corporation charged interest at the AFR (or higher), the loan would be exempt from the complicated below-market interest rules the IRS imposes.

The interest rate for a demand loan — which is payable whenever the corporation wants to collect it — isn’t fixed when the loan is set up. Instead it varies depending on market conditions. So, calculating the correct AFR for a demand loan is more complicated than it is for a term loan. In general, it’s easier to administer a shareholder loan with a prescribed term than a demand note.

Staying under market

If a corporation lends money to a shareholder at an interest rate that’s below the AFR, the IRS requires it to impute interest using the below-market interest rules.

These calculations can be complicated. The amount of incremental imputed interest (beyond what the corporation already charges the shareholder) depends on when the loan was set up and whether it’s a demand or term loan. There are also tax consequences for this imputed interest to both the corporation and the shareholder.

Additionally, the IRS may argue that the loan should be reclassified as either a dividend or additional compensation. The corporation may deduct the latter, but it will also be subject to payroll taxes. Both dividends and additional compensation would be taxable income to the shareholder personally, however.

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Financial Matters continued

Making it bona fide

When deciding whether payments made to shareholders qualify as bona fide loans, the IRS considers a variety of factors. It assesses the size of the loan, as well as the corporation’s history of earnings, dividend payments and loan repayments. It also looks at the shareholder’s ability to repay the loan and power to make corporate decisions.

In addition, the IRS will factor in whether you’ve executed a formal, written note that specifies repayment terms—including the interest rate, maturity date and collateral.

Getting started

Under the right circumstances, a shareholder loan could be a smart tax-planning move to make this year. Contact our firm to help you set up and monitor your shareholder loans to ensure compliance with the IRS rules.

© 2017 Thomson Reuters

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Advertising Index

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Albemarle Corporation

53 AMSA, Inc. 30 AquaPhoenix Scientific Inc. 58 Bio-Source, Inc.

Pulsafeeder, Inc.

63 Environmental Safety Technologies, Inc.

7

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31 IDEXX

24 The Lubrizol Corporation

62 Brenntag North America 70 Browne Laboratories, Inc.

60 Chem-Met Company

2

34 Lovibond Tintometer

65 Bionetix

38 Bulk Systems, Inc.

65 Cortec Corporation

36 Myron L Company 10 North Metal & Chemical Company 5 OxiKing

49 Sanipur US LLC 60 Scranton Associates Inc. 72 Special Pathogens Laboratory 39 Univar 45 Walchem, IWAKI America Inc. 71 Water Science Technologies 66 WaterColor Management

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