Document 7RQe33kpQjQQynrkVRGKDJGDE

Additional notes An OECD report highlights how the term "PFAS" is a broad, general not specific term that does not inform on the harmfulness of a compound and is not a basis for regulation. In this regard precisely because of a nomenclature to be regulated, refrigerant gases are also considered PFAS. In a series of reports from 2016 to 2022, the United Nations Environment Program (UNEP) concluded that TFAs have been found at levels below what would be considered toxic to humans or the aquatic environment and will continue to be below these levels for decades. A recent publication on the toxicity of TFA in mammals concluded that the margin of exposure for most humans is between 4,000 and 476,000-fold, indicating that TFA levels in the environment are several times lower than what would be considered toxic. UNEP points out that it is known that perfluorocarboxylic acids have "fundamental chemical, physical and biological properties that become very different with increasing carbon chain length." It is therefore inappropriate to compare short-chain TFA with longer-chain PFCAs, which have very different chemical, physical and biological properties. Referring to substances containing the -C-F3 group (which includes many F-gases), the dossier proponents state that "most of these substances are expected to ultimately degrade in the environment to TFA." However, there is strong evidence that this is the case for only some conventional F-gases (https://www.fluorocarbons.org/wp-content/uploads/2020/10/EFCTC_HFCand-HFO-Substances-degradation-products-and-TFA-yields-Final-26_08_2020.xlsx). A generalization such as that used by the dossier's proponents is therefore not justified. Since there are a limited number of F-gases that decompose into TFA and conversion ratios vary between 0% and 100% (for a single substance), the exposure assessment made by the dossier proponents is therefore misleading and irrelevant. In reference to alternatives to fluorinated gases, particularly carbon dioxide, ammonia and hydrocarbons (propane, isobutane ..) called "natural substances," in reality, these are all produced on an industrial scale. These alternatives have a much lower cost than fluorinated gases, and it would be worthwhile to evaluate their end-of-life emissions, since the economic incentive for recovery, reclamation, and reuse is virtually absent. UNEP also maintains that TFA is neither bioaccumulative nor toxic at currently measured low or moderate exposures in the environment and believes that persistence should be considered a regulatory criterion only for substances that are moderately or highly toxic and bioaccumulative in organisms. HFOs are not PBT ( Persistence , biocculamative and toxic) or and have a very low GWP. HFOs contribute positively to meeting climate goals both because of their low GWP and their significant impact on reducing energy consumption and lifetime emissions compared to alternatives.