RECENT REGULATORY CHANGES AFFECTING THE DISPOSAL OF USED OILS, TOGETHER WITH THE IDENTIFICATION OF SOME CHLORINATED PARAFFINS AS CARCINOGENS, SUGGEST THAT CHLORINATED PARAFFINS, THEIR USEFUL PROPERTIES NOTWITHSTANDING, WILL EVENTUALLY BECOME UNACCEPTABLE AS INGREDIENTS IN INDUSTRIAL LUBRICANTS. THIS PAPER DISCUSSES THE DEVELOPMENT OF A WATER-BASED, NON-SULFO-CHLORINATED LUBRICANT TO REPLACE A CONVENTIONAL OIL-BASED SULFO- CHLORINATED LUBRICANT, AND EXAMINES THE TESTING PROCESS TO WHICH THE NEW LUBRICANT WAS SUBJECTED. THE DEVELOPMENT PROTOCOL AND TEST METHODS DISCUSSED ARE GENERALLY APPLICABLE TO THE DEVELOPMENT OF REPLACEMENTS FOR ANY CONVENTIONAL METAL WORKING OR METAL FORMING LUBRICANT.