Comment submitted by C. Tunick

While there is considerable interest in a solventless method for analyzing oil and grease in water, the current method is not field-portable and cannot be used for on-site measurements. It would be ideal for use in a laboratory environment but not for on-site use such as on off-shore and on-shore oil drilling platforms or in manufacturing industries using oil and grease in their process who want a quick, easy way to check their wastewater effluent prior to discharge without having to wait for lab results. There is a current ASTM Method D7066 using infrared analysis and S-316 as an extracting solvent for measuring oil and grease in water. This method is based on the tried and true EPA Methods 413.2 and 418.1 which have been used and accepted worldwide for the measurement of oil and grease in water for over 30 years. If the EPA is to consider ASTM D7575-10 as an alternate analysis and sampling method, they should give serious consideration to also approving and accepting ASTM Method D7066 as an additional alternate method. Infrared analysis for measuring oil and grease in water is accurate, cost effective, and easy to use by both non-technical personnel and skilled technicians but provides a method that can be used on-site, as well as in the analytical or testing laboratory. Today, it is still the most widely-used method worldwide for measuring oil and grease in water.