Document 7Rva06ozEEvXL8yDeLJan9jEa
CCIEP PFAS Working Group - Kick-Off meeting - 14/03/2022
Attendees:
(FOD VVVL - DGAPF),
( FOD VVVL - DGEM),
(FOD
eco),
(FOD VVVL - DGEM),
(FOD VVVL - DGEM),
(FOD VVVL - DGEM),
(VL - DOMG),
(WL - SPW),
(VL -
OVAM),
(VL - DOMG),
(WL - SPW),
(VL - VMM),
(VL - DOMG),
(BXL - envi),
(WL - SPW),
(VL),
(VL - OVAM),
(FOD VVVL - DGEM),
(FOD
VVVL - DGEM)
Agenda
Discussion
Action Points
1.Introduction
1.1 Short overview of the current policy landscape on PFAS
1.2 CCIEP PFAS Working Group
: Intermediate situation at the moment. At the VL level under the scope of Karl Vrancken work the federal authorities are already included. Thinking about what the situation will be once this work will be terminated. Need to create a new situation at that level. This WG could be a good tool to keep including the national levels.
Important topics to include in the workings of the group:
- NAPED - Circular economy - Waste - Specific uses - EIONET contributions
Included that the link has to be made with health authorities. Also link to be made with other action plans, like the ED action plan (NAPED). Look at how the workings of this group can be included in the NAPED and the other way around to have some interactions.
: question about the focus and the main topics of this working group. What can we do on upstream level (concerning what we can do to prevent PFAS coming in the environment (product level, restrictions, risk assessment) and on the other hand everything concerning downstream (legacy of the PFAS compounds that are in the environment. Also extra level possible on federal level (being the product level). How would this group cooperate on these different levels?
: Indeed important to identify some concrete actions under this working group. One of the main goals identified in the mandate is the need for information exchange between the different authorities to facilitate informative policy action on PFAS. Important to keep in mind that this is a CCIEP group, meaning that the focus mainly entails EU and international policy.
: Also the aspect of Circular Economy. Not only historical contamination but also waste from legacy products is important. A number of waste related actions are also planned at the EU level. These are mostly regional but also some federal aspects. Certainly to be considered by this WG.
: Projects have been started on the alternative to PFAS: cf related to circular economy. Also substances of concern in
waste: these will develop specific guidelines/legislation for the handling these substances.
2.Tour de Table
2.1 Participants shortly present their competence regarding PFAS and priorities/vision for this working group
See word document:
Tour de Table CCIEP PFAS kick-off meeting.docx
Action Points:
Contact information will be shared with the members in order to facilitate information exchange.
Priorities of this WG for the members:
- Info exchange on activities between the regions
- Info on REACH and related projects
- Harmonize policy actions (limit values and regulatory actions) between the regions
3. PFAS report
3.1 Present status
Action Points:
3.2 Structure and proposed actions
3.3 Roles, contributions and planning
: important that we introduce information at the right
moment at the right level. Need some kind of inventory on the EU
processes running at the moment and who is taking the lead on
that. Known for example that
is working on IED and
BREFS, we know that Food and FCM are important. For REACH
there is a good structure, but for others this is not the case. How
do we ensure that the information we have can be useful to
certain EU processes.
: Indeed important to identify the EU and international process ongoing regarding PFAS to ensure that we can intervene where necessary. The CCIEP PFAS mailing list can be a helpful tool in this sense to facilitate info exchange. Members of the WG are working on specific legislation are invited to use the mailing list to inform other members on ongoing actions and to ask for information.
The report will be updated and specific info requests to the members will be identified by May 2022.
Members will be able to contribute until July 2022, after which the report will be finalized by September 2022.
Focus on identifying the different competent authorities working on PFAS.
Members are invited to share info on relevant policy actions ongoing regarding PFAS and to request information to the members using the CCIEP PFAS mailing list (
)
4.1 REACH restrictions data gathering
Action Points
4. Information exchange and data gathering: actions to be taken and future planning
explains the hotspot inventory work happening in the VL region. The data will be released by the end of March, together with a second report by the VL PFAS expert group. OVAM is working on a synthesis on the results to look at lessons learned from this exercise. This would be valuable information to share in the restriction process.
gives additional explanation of the different actions on PFAS under the CSS and some complementary information on the REACH restriction process. Can take action on use production and putting on the market for both health and environment. REACH has a basis for the harmonization of the market. Meaning that action cannot be taken on national level (this is possible but generates an obligation to produce a restriction and to prove a BE specific risk). Action cannot be taken at the waste stage, but can take action on risk generated by waste. Mentions that there is still a lot of uncertainty regarding the REACH review process happening at the moment.
: request concerning the firefighting foams. Heard that 3M is focusing on NOVEC in production processes. But when looking at the SDS we see there is no data on mobility in soil, persistence is 2.9 years, etc. Asks to have a look at the SDS and the extended SDS to give some more information on this.
4.1
Excel file to contribute specific information will be shared with the members to update with data generated since May 2021.
PFAS expert group of will provide
information on the hot-spot analysis to be shared in the REACH restriction processes.
FOD VVVL REACH team will look into the (extended) SDS of NOVEC by 3M to see whether additional information is available and whether it is included in the restriction proposal.
Specific comment in the public consultation on PFAS in FFF restriction will be considered.
4.2 Contribution of the group to PFAS policy
: questions we can introduce at REACH-up etc., but not always clear if other members of this network are providing information to us. Interested to know how they are working on this topic.
: how do you see the role of scientific institutes and academy in the workings of this group?
responds that it's indeed important to try and involve scientific bodies in the information exchange. Scientific institutes have already contributed to the PFAS report, and this can continue happening in the future. However it is important to note that they cannot be included into the CCIEP working group, as this group can only consist of BE authority. However scientist can be invited as independent experts to contribute to the workings of this group.
Action Points
4.2
Point of attention to inform on how other EU Member States are working on the PFAS topic, would be interesting to get insight from them as well.
4.3 POP inventory obligations
presents the slides.
Action Points
mentions that Flanders has already provided some information on voluntary basis. Are aware that info is not covering the whole situation on the stockpiles. The inspectorate is launching a larger campaign to ensure that the main sources and stockpiles are being covered. Proposal was launched and it will be checked when this information can be shared with this group.
: discussions on the applicability of POPs in PFAS containing soils. Is there a minimal concentration above which Article 13 on stockpile notifications has to be applied?
4.3
Info on specific legal requirements will be shared with the WG members in order for them to set up the required monitoring and notification projects.
: limit set in annex I, for stockpile notification the limit is set on the UTC (unintentional trace contamination, defined in article 2.12 of POP regulation).
For PFOS UTC = 10 mg/kg (0,001 % by weight)
will share information on newly launched project regarding stockpile notifications for Flanders when available.
For PFOA UTC = 0,025 mg/kg (0,0000025 % by weight)
UTC means a level of a substance that is incidentally present in a minimal amount, below which the substance cannot be meaningfully used, and above the detection limit of existing detection methods to enable control and enforcement. Given that the objective of Article 5(2) of the POP reg is to control the permitted use of the listed substances in articles, it is justified that the UTC constitutes the minimum concentration to trigger the notification obligation of that Article.
will check whether colleagues have more information on POP notifications for the Walloon region.
will check for the Brussels region whether POP notification systems have been created.
extends on the revision of Annex IV and V of the POP regulation. These are waste related annexes that determine waste management. PFOA and related substances have been added to these annexes. Last Friday at COREPER a compromised proposal was reached for further discussions. Discussions ongoing on the content of the related compounds (limit would remain 50mg/kg, to be discussed with the EU Parliament as they want this limit to be lowered). On PFHxS, EU Parliament is pushing on adding this to go to the POP.
mentions the Walloon government has been asked by essenscia to who they had to send information. This was transferred to a colleague but no further information yet.
mentions he does not know about a notification system in Brussels, will contact the colleagues whether a procedure is being established.
4.4 Exchange of info and experience on regional activities
has question related to firefighting foams. Do you plan to have some specific meetings to share info on fire fighting foams and pollution related to these?
: yes this can be looked at, a separate meeting on this can be organized.
: are there activities planned/ongoing to actively support industry in substituting PFAS substances. Phase out will take until 2025/2026 however any innovative industries might already be looking at substitutions, maybe it's interesting to have some supporting actions on this? Could be a policy action.
: this is being advanced by FOD economy.
: BE submitted a recovery plan, part of this plan is focused on BE builds back circular, one of its projects is focused on financing research for substitution. Companies can thus send in applications, which will be evaluated and then financed if accepted.
Action Points
4.4
Look at the possibility of organizing a meeting specifically on the firefighting foams to share info between the regions and look at contributing to the REACH restriction proposal.
will send out presentation by ECHA on the PFAS in firefighting foams restriction proposal.
Information will be shared on planned projects regarding substitution of PFAS on federal level.
Together with FOD VVVL decided to explicitly exclude PFAS. A distinct study on substitution of PFAS is being looked at within the FOD VVVL.
: presentation on PFAS in fire fighting foams restriction can be distributed to the members
: on alternatives don't only have info on the EU level, but also on the OECD level. Important to share that info within the group as well.
5. AOB and next meeting proposal