Document 2QbG3mbraqyOm2V5gK7L2qb7

Document sent by owl to bmi reer) Ol, 11.01.2019 Contacmperrson:.amijottno Norwegian comments to documentI We thank the European Commission for the paper onI 1 I aalnidgnCedLVearnedcgoucnlaostoiirdodenirsn.tahtIaentdp.anatoveelra,rcahicngtstsratreegaychfiorngPaFAcStsosisdniefeedreedn,t tEhUatlggoieastiboenysoncdouthdebReEbAeCtHer 0 environment both within and outside of th EU. This s reflected i high -- number of scentfic studies leteevaerloftssdoinfermenet PnFAtSSein .n,tbhioetaaaandrdarirntki,ng swadteTr seourncesg. disrimpoorntanit tnhatguthtoorrtsiieosnand regulatoarse not slowing down this momentur. EE EE ane ofE th ef5oarttehesiGloowbefafl GPFCa | thhee rongeoilngistuynroantpeotdenptioallroegsisttroatbieonreelveavlaunattnionHof certain polymers undm er REACHm . We expect Postal address : PO Box 5672, Torgarden, N-7485 Trondh|eTieml: +47735805 00| Fax: +4773580501 ~The Norwegian Environment Agency has a national action plan for PFAS that addresses the main concerns associated with PFASs in Norway and coordinates the PFAS work carried out witthehagiencny. The actionplan includese.g.: regulatory work at the national, European and global level, polluted ground and remediation (fire-fighting training sites), follow-up of offshore activities that may include PFAS-containing fire-fighting foam, reguofilnduastrty emiissoionns, work with the water directives and PFAS, environmental monitoring and screening (including identification of sources to high PFAS-levels in lakes, e.g. Tyrifiorden), enforcement of regulations. ~The Global PEC group has summarised and tabulated national regulatoryactions for many countries. Norway's regulatory actions are also presented there. A new updated version of these risk reduction approaches will soon be published by the Global PFC group. Please find our updated information in the attachment ~The coordination in Norway relies on informal information exchange between different authorities whenever relevant. The Norwegian Environment Agency has been in dialogue with different authoritioens PFAS related matters during the past period. This includes the Food Safety Authority, the Norwegian Maritime Authority, the aviation sector, including Avinor and the Air Force, and the Norwegian Directorate for Civil Protection (058). ~ Coordination of the PFAS work ongoing within the Norwegian Environment Agency is ensured through the national action plan for PFAS, mentioned above. ~The Norwegian Environment Agencyhas a generalinterest in the PFASfield and in current `andfuture uses andpriorityareas. Currently, our PFAS resaoreumairnlycocceupised with the preparation of a restriction proposal for PFHXS and the preparationof a SVHC-dossier for PFBS. - I-- EE L__] EE. anticipate that the side-chain fluorinated polymers are highly relevant as polymers for which registration/evaluation could be required. ~ With regards to a potential futurestudy on PFAS in textiles, a project financedby the Norwegian EnvironmentAgency may be of interest. The aimis todevelop an analytical method with prior degradation of precursor substances, that may help in the quantification of precursors to simple PFASs present ina sample. ~ For PFASs, often imited data i availableforassessment of the isk to human health or the environment. In some cases, data may be lacking for one or afew members of a group of chemicals for which information for the remaining substances indicates a risk for human health and/or the environment. In such cases grouping and the precautionary principle. should be given considerable weight in order toenhance the regulatory efficiency. This could applyfor different subgrouopfs PFASs for which the chemical variability is high, and the number of closely related substances may be tens or hundreds. ~ We would ike to mention a report that Norway submitted to the International Maritime Organization (IMO) in 2018. The report was prepared by DNV GL on behalfofthe Norwegian Maritime Authority and assess the use of PFOS and other surfactants in fire-fighting foam onboard ships. The study estimates that approximately 17 000 ships worldwide has fixed firefighting foam tanks onboard. The volume of each tank ranges between 400 lites to 18700 litres. The firefighting foam contains PFOS, PFOA impurities and precursors, PFHXS or PFHXA or a mixture of these. According to thissurvey, almost 7000 ships are very likely to have PFOS inthe firefighting foam onboard. Approximately 5000 ships are likely to have PForOtraSces of PFOS in their firefighting foam. For newships delivered after 2010, itis assumed thata very small percentage of vessels may have PFOS in firefighting foams from the date of delivery. It appears that the volume of PFOS/PFAS onboard ships may still be a main source of emissiotnos the environment. This couldbe addressed inthefirefighting foam studies that ECHA and the Commission are launching. Submitting the report to the IMO was the first step in trying to implement the requirements from the Stockholm Convention into an appropriate IMO instrument, and Norway is planing to submit a more concrete proposal to a meeting in IMOs Maritime Safety Committee this summer (2019). - gn a i of the Norwegian plans for SVHC proposal for ill