Document B87Zpnxzrk0xRGEeyqvrgX6Dm
Initial Input to EU consultation related to the proposed PFAS restriction
Submission on 12 June 2023
BLUE FOOT 1 unbreakable membranes TM
Summary
Response to Public Consultation on PFAS
Table of contents
1 GENERAL INFORMATION _________________________________________________4 1.1 SCOPE OR RESTRICTION OPTION ANALYSIS ____________________________________ 4 1.2 HAZARD OR EXPOSURE ____________________________________________________ 9 1.3 ENVIRONMENTAL EMISSIONS ______________________________________________ 11 1.4 BASELINE_______________________________________________________________ 13 1.5 DESCRIPTION OF ANALYTICAL METHODS _____________________________________ 13 1.6 INFORMATION ON ALTERNATIVES __________________________________________ 14 1.7 INFORMATION ON BENEFITS _______________________________________________ 19 1.8 OTHER SOCIO ECONOMIC ANALYSIS (SEA) ISSUES ______________________________ 19 1.9 TRANSITIONAL PERIOD ___________________________________________________ 19 1.10 REQUEST FOR EXEMPTION_________________________________________________ 19
Response to Public Consultation on PFAS
1 GENERAL INFORMATION
1.1 SCOPE OR RESTRICTION OPTION ANALYSIS
PFAS type: Fluoropolymer: polyvinylidene difluoride (PVDF) (homo- and copolymer)
Main application/Sector: Water treatment*
Sub-use:
industrial filter / membrane filtration
Sector**:
E: WATER SUPPLY; SEWERAGE, WASTE MANAGEMENT AND REMEDIATION ACTIVITIES
36: Water collection, treatment and supply
- treatment of water for industrial and other purposes
* Water treatment is not mentioned as `main application' in the Annex XV restriction report (table 2 and table 9). ** Sector is defined according to Eurostat Reference And Management Of Nomenclatures (RAMON) Statistical Classification of Economic Activities in the European Community (NACE), Rev. 2 (2008), (https://ec.europa.eu/eurostat/ramon/index.cfm?TargetUrl=DSP_PUB_WELC)
GENERAL Industries: Dairy, Food & Beverage, Chemical & Pharma, Textile & Tannery, Petrochemical, Landfill leachate, Mining & metals, Soil remediation, Automotive, Animal rendering Applications: Membrane bioreactors (aerobic and anaerobic)
Industrial wastewater treatment Recycling of process water Membrane processes: Microfiltration (MF), ultrafiltration (UF), Membrane geometry: Flat sheet -woven supported sheets with Integrated permeate channels (IPC) Module configuration: Plate-frame module
Response to Public Consultation on PFAS
MEMBRANE MARKET FOR WATER TREATMENT In the following figure and table, market share and numbers are presented regarding membranes for water treatment, segmented to i. region; ii) application and iii) product type [GWI 2023]. It has to be noted, that these number are `just' related to membranes. Installations, electronics, sensorics, controls, amongst many others, are not included!! The total market for membranes for water treatment comprises 1.846 Mio $ (status April 2023). Membranes, made from polymeric material play a significant role in this sector. A considerable quantity of polymeric membranes consist of fluoropolymers (PVDF in particular). The share of PVDF membranes is addressed in `PVDF for membranes'. The overall water treatment installation market that uses PVDF membranes as a critical component has a size that is multiples from the membrane market as the membrane component represents 530% of the overall system cost. This will be elaborated on in a more detailed filing prior to the end date of the consultation. According to Global Water Intelligence report [GWI, ( Membrane market analysis for water treatment , April 2023] the vast majority of the membranes are used in wastewater treatment (market size of 1,475 Billion $). More than 90% of the membrane material is polymeric (Polymeric membranes 1,75 B$ and ceramic 0,13B$ market size). In wastewater treatment the key material to use for membrane is Polyvinylidene difluoride as will be explained further in this document.
Figure 1: Membrane market analysis for water treatment, segmented to i. region; ii) application and iii) product type; [GWI, status April 2023].
Response to Public Consultation on PFAS
PVDF In the study by Korzeniowski et al. [Korzeniowski 2023] data are presented that PVDF is a Polymer of Low Concern (PLC). In this study, fluoropolymers were investigated (PVDF amongst others) according to widely accepted polymer hazard assessment criteria demonstrating that these polymers are to be considered PLC [OECD 2009].
PVDF FOR MEMBRANES PVDF is a semicrystalline polymer with repeated unit of -(CH2CF2)n-. It exhibits high mechanical strength, good chemical resistance and thermal stability as well as excellent aging resistance, which are very important for the actual application of separation membranes. Moreover, PVDF shows good processability to prepare all types of membranes [Lui 2011] [Kang 2014]. In our specific business, flat panel membranes are produced for the use is Membrane Bioreactor (MBR) technologies.
The relevance of PVDF-based membranes for membrane bioreactors (MBR) was shown by Prof. Simon Judd on his MBRsite-Website [Judd 2017]. He evaluated the MBR market intensively and he showed that nearly 60% of all applied membranes, with different configurations, in MBR is PVDFbased. This indicates the commercial relevance of PVDF membranes in this market. The reasons will further be elaborated further in the report.
The American Membrane Technology Association (AMTA) provided a very relevant and to-the-point position paper expressing their doubts and worries when PVDF for PVDF membranes is classified as PFAS [AMTA 2023]. Blue Foot Membranes completely supports the statements on PVDF and PFAS as elaborated in the position paper. The position of AMTA is as follows:
Response to Public Consultation on PFAS
FLAT SHEET UF MEMBRANE MODULE PRODUCTS FROM BLUE FOOT MEMBRANES More information about the company and the products can be found on the website: www.bluefootmembranes.com
Figure 2: Left, Flat sheet ultrafiltration membranes are made of Polyester textile and PVDF polymer by the company. Middle, membrane filtration modules with heights from 1,7m to 4,2 meter are manufactured by Blue Foot membranes Right: membrane modules are combined in a tank to filter the biologically treated wastewater to ensure good effluent qualities for discharge and/or reuse applications.
Flat Sheet UF MEMBRANE MODULES CONTAINING PVDF
Supply chain from Blue Foot Membranes' general documents will be added in the follow up
submission.
PVDF membrane manufacturing: PVDF membranes are formed by means of the non-solvent induced
phase separation. To achieve this, the PVDF is dissolved in a solvent resulting in a polymer solution.
This solution is pumped through a flat die on top of a 3D fabric. This combined envelope is
submerged into a non-solvent bath and a solid porous structure is formed by precipitation and
solidification of the polymer. This is called the porous membrane and most polymeric membranes are
made by this method. After several post-treatment steps, including drying, the PVDF-coated flat
sheet membrane envelope membrane is packed and potted into membrane modules as the final
product that we manufacture and sell. These modules are used to filter water out of wastewater
streams at a rate of 1-5 m3 treated water per module per hour.
Downstream users:
1.
Direct customers are original equipment manufacturers (OEMs),
2.
System integrators / plant builders
3.
Endusers (Carsberg breweries, Darling rendering plants, Kellogg's food company, municipal
wastewater treatment plants)
Response to Public Consultation on PFAS
REFERENCES
[GWI 2023] GWI water database, last update April 2023.
[Korzeniowski 2023] Korzeniowski et al., a critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluor- oplastics and fluoroelastomers, Integr. Environ. Assess. Manag. 19(2), 2023, 326-354 (https://doi.org/10.1002/ieam.4646)
[OECD 2009] Organization for Economic Co-operation and Development (OECD), Task Force on New Chemicals Notification and Assessment, Data analysis of the identification of correlations between polymer characteristics and potential for health or ecotoxicological concern, 2009 (https://www.oecd.org/env/ehs/risk-assessment/42081261.pdf)
[Kang 2014] Kang et al., application and modification of poly(vinylidene fluoride) (PVDF) membranes - A review, J. Membr. Sci., 463, 2014, 145-165 (https://doi.org/10.1016/j.memsci.2014.03.055)
[Lui 2011]
Lui et al., progress in the production and modification of PVDF membranes, J. Membr.
Sci., 375(1-2), 2011, 1-27 (https://doi.org/10.1016/j.memsci.2011.03.014)
[Judd 2017] S. Judd, `the MBR site' website, the material question - choosing MBR membrane materials, https://www.them- brsite.com/blog/choosing-mbr-membrane-materials/
[AMTA 2023] American Membrane Technology Association (AMTA), position paper: Broad Definitions of PFAS may Classify PVDF Membranes as PFAS compounds, https://www.amtaorg.com/wp-content/uploads/AMTA-Fact-Sheet-32-PVDF-Position-Rev0.pdf, visited on 30.05.2023
Response to Public Consultation on PFAS
1.2 HAZARD OR EXPOSURE
PVDF (Polyvinylidene fluoride) is generally considered to be a polymer of low concern (PLC) in terms of its potential environmental and human health impacts. It is not considered to be a carcinogen, mutagen, or reproductive toxin. Additionally, PVDF is resistant to biodegradation and does not contribute significantly to environmental pollution. [Korzeniowski 2023] PVDF is not classified as a hazardous substance by major regulatory bodies such as the European Chemicals Agency (ECHA) or the U.S. Environmental Protection Agency (EPA).
The European Chemicals Agency (ECHA) has assessed PVDF and concluded that it does not
meet the criteria for classification as a hazardous substance under the Classification, Labelling and
Packaging (CLP) Regulation (EC) No. 1272/2008 [ECHA 2021].
The US Environmental Protection Agency (EPA) has classified PVDF as a polymer exempt from
premanufacture notification (PMN) requirements under the Toxic Substances Control Act (TSCA) [EPA
2023]. PVDF is flagged with XU, which indicates a substance exempt from reporting under the
Chemical Data Reporting Rule, (40 CFR 711). This means that PVDF is not considered to pose an
unreasonable risk to human health or the environment.
In line with the communication of our raw material PVFD supplier, we are stating the following in relation to the public concerns related to PFAS emissions: The PVDF polymer that BF uses for the production of IPC membranes is in a category far
removed from the Fluorosurfactants (PFOA, PFAS) that originally triggered PFAS concerns. The PVDF polymer is manufactured by our supplier without the use of Fluorosurfactants
as production agents. The surfactant that is used, is non-fluorinated and non-persistent. The PVDF is a polymer of low concern according to the OECD definition. A peer-reviewed
article has been published in 2022 with scientific proof points [Korzeniowski 2023]. The PVDF polymer is not bioavailable and not mobile. Even if its structure includes
Fluoride, its toxicity and ecotoxicity profile is different from small chain PFAS. The Blue Foot product made out of PVDF polymer will, at end of life, be managed
responsibly. More data will be added in a follow-up submission.
PVDF has proven to be a safe and successful membrane material that is very stable, inert, and highly resistant to breakdown. PVDF is made with a very high degree of purity. This enables
Response to Public Consultation on PFAS
PVDF products to satisfy stringent leachable limits and other national health regulations, ensuring that they are safe for use in drinking water treatment [AMTA].
REFERENCES [Korzeniowski 2023] Korzeniowski et al., a critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers, Integr. Environ. Assess. Manag. 19(2), 2023, 326-354 (https://doi.org/10.1002/ieam.4646)
[ECHA 2021] ECHA, Substance Infocard (last updated: 21.12.2021), Ethene, 1,1-difluoro-, homopolymer, CAS no. 24937-79-9, https://echa.europa.eu/de/substance-information//substanceinfo/100.133.181, visited on 12.04.2023
[EPA 2023] EPA, TSCA Chemical Substance Inventory. Database last created: 02/2023, ID:22570 CAS no. 24937-79-9, https://www.epa.gov/tsca-inventory/how-access-tsca-inventory, visited on 13.04.2023
[REACH 2023] REACH online, https://reachonline.eu/reach/en/title-viii-chapter-2-article-68.html,
visited on 05.05.2023
[AMTA]
AMTA-Fact-Sheet-32-PVDF-Position-Rev0.pdf (amtaorg.com)
Response to Public Consultation on PFAS
1.3 ENVIRONMENTAL EMISSIONS
FLUOROSURFACTANT-FREE MANUFACTURING It should be noted, that the used PVDF is manufactured without using PFAS-of-concern. This is confirmed by our raw material supplier (documentation in our follow-up submission). So, the argument of environmental emissions related to manufacturing aids does not apply here!
Emissions are clearly identified in a recent Life Cycle Analysis of our IPC membrane module.
The membrane module fabrication allows two emission possibilities for fluoropolymers:
1.
Scrap during membrane production or casting solution preparation
2.
Process wastewater - the emitted process water is discharged into the sewerage.
3.
Membrane drying - membranes are dried in an oven. From the oven there is exhaust air into
the environment.
Scrap
Scrap is only produced as a byproduct waste stream when cutting the edges of the membrane sheet
in the right dimensions. This scrap is <5% of the overall raw material use. This is incinerated and
contains no low MW PFAS components only high MW fluoropolymer Sales [Sales 2022]. There is no
scrap in other production processes by design of the lean production process.
Membrane drying
Membranes are prepared by the phase inversion process where the membranes are immersed in
water. Before drying, the membranes are conditioned to avoid pore collapse during the drying
process with glycerine. Membranes are dried in an mild warm chamber with warm air. The water is
condensed and is part of the wastewater, the heat is recovered to the maximum to save energy and
some water vapor will leave as air emission. As the polymer is not water soluble and no fluoropolymer
is detected in these streams.
Process wastewater
Water samples of process water is discharged into the sewer within the granted volume and
restrictions. Testing for PFAS is not executed as it is known that no water soluble fluorinated
components (on any Mw) are part of the production process.
Incineration
The thermal degradation of fluoropolymers, and PTFE in particular, by incineration was investigated
by Sales [Sales 2022]. For PTFE, it was concluded that complete thermal decomposition is achieved at
a temperature of about 800C. Concerning incineration, data can be referred to PTFE (which is more
Response to Public Consultation on PFAS
intensively studied), because this fluoropolymer is thermally more stable than PVDF. additionally, incineration was studied by Aleksandrov et al. [Aleksandrov 2019]. They concluded that no significant evidence could be found of PFAS creation (of the 31 studied PFAS species) during the incineration of PTFE. Therefore, it can be expected that municipal incineration of PTFE (and therefore also PVDF) using best available technologies (BAT) is not a significant source of studied PFAS and should be considered as an acceptable form of scrap waste treatment and as a responsible form of end-of-life disposal.
DEGRADATION TO MICROPLASTICS The relation between PVDF and its global impact as microplastic (MP) in marine environment was investigated by means of the risk screening method [Yuan 2022]. Thirty-six different polymers were evaluated on global level by five different risk factors covering the probability of human exposure to, and the potential impact of, microplastics . PVDF was ranked las in this risk assessment which means that PVDF plays a minor role.
DEGRADATION TO PFAS-OF-CONCERN Finally, fluoropolymers are substantially different from the other polymeric PFAS in terms of potential emissions due to degradation into small PFAS molecules during intended use or under environmental conditions and, for this reason, they have no environmental impact. Fluoropolymers have a high molecular weight, little no water solubility and no volatility, therefore they are not expected to degrade to low molecular weight PFAS. Also, they are not expected to lead to the formation of longchain PFAS as a result of degradation. [Sales 2022]
PVDF MEMBRANES CONTRIBUTION TO PFAS EMISSION AND WATER TREATMENT IN GENERAL Membrane technology contributes to isolation and concentration of PFAS. This is extensively described by Das et al. [Das 2022]. Most PFAS-of-concern are short-chained substances which cannot directly by treated by ultrafiltration, but ultrafiltration is necessary as a pretreatment for Nanofiltration or Reverse Osmosis in order to technological and economical feasible operation.
It can be concluded that no short chain harmful PFAS leaves our manufacturing by solid of liquid waste streams
Response to Public Consultation on PFAS
REFERENCES [Aleksandrov 2019] Aleksandrov et al., Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly- Fluorinated Alkyl Substances (PFAS) in flue gas, Chemosphere 226, 2019, 898-906 (https://doi.org/10.1016/j.chemosphere.2019.03.191) [Yuan 2022] Yuan et al., Ranking of potential hazards from microplastics polymers in the marine environment, J. Hazard. Mater. 429, 2022, 1-19 (https://doi.org/10.1016/j.jhazmat.2022.128399) [Sales 2022] Sales et al., Fluoropolymers: The Safe Science That Society Needs, International Chemical Regulatory and Law Review (ICRL) 5(1), 2022, 13-23 (https://icrl.lexxion.eu/data/article/18600/pdf/icrl_2022_01_2022-11-02-12.39.059.pdf) [Das 2022] Das et al., A Review on Removal and Destruction of Per- and Polyfluoroalkyl Substances (PFAS) by Novel Membranes, Mem- branes 12(7), 2022, 662. (https://doi.org/10.3390/membranes12070662) (not attached due to large document size and the 20 MB upload availability)
1.4 BASELINE
Since water treatment by industrial filtration or membrane technology based on PVDF material (or other fluoropolymers) was not mentioned in the Restriction Proposal, baseline data for this important use of PVDF (or other fluoropolymers) are not available.
1.5 DESCRIPTION OF ANALYTICAL METHODS
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Response to Public Consultation on PFAS
1.6 INFORMATION ON ALTERNATIVES
Membranes generally comprise of a thin surface layer giving the required perm-selectivity on top of a more open, thicker support that provides mechanical stability. The membranes must be mechanically strong and will normally have some resistance to thermal or chemical attack. This means resistance to extremes in temperature, pH and/or oxidant concentrations is required [S. Judd]. The only technical and commercial relevant "lower quality" alternative to PVDF-based membranes in water treatment are PES-based membranes. However the large market of wastewater treatment and impaired water treatment membranes are outside-in module configurations. In this type of installation PVDF type membrane are used because the mechanical properties enable the high mechanical stresses on the PVDF membrane during operation [Wilf et al., 2010]. Furthermore, these application demand frequent chemical cleanings (NaOCl) and PVDF has a significantly larger Cl tolerance [Li et al., 2021 ] than PES . On top of that, both materials differ in fouling tendency and membrane morphology. In these applications of wastewater treatment (MBR technology), water reuse and filtration of impaired waters, PVDF clearly outperforms PES. In clean water filtration or RO pretreatment applications PES is advantageous as the feedwater is much cleaner (less need for chemical cleaning) and there is minimal mechanical stress during operation as these are operated inside-out [Li at al., 2008; Lesjean et al., 2004]. This is summarized in the Table 1 below which is published in WEF Manual of Practice No 36. [extracted from Wilf et al. 2010].
Response to Public Consultation on PFAS
Table 1: Summary of membrane material characteristics [Wilf et al., 2010]
MEMBRANE FOULING PVDF membranes exhibit a lower fouling potential than PES membranes. PES contains a negative charge and as such is the membrane surfaces prone to fouling, especially in difficult to treat water feed streams like wastewater, effluent water and impaired surface waters. In e.g. MBR, the fouling components consists of a very broad mixture of various substances with various charges [Lorhemen 2016]. Aging of the membranes result in higher tendency of membrane fouling and this is why membranes need to be cleaned chemically (extreme pH and/or oxidizing chemicals) and have to be exchanged when a certain level of irreversible fouling is reached. The fouling potential is a key aspect in the operational end economical evaluation of membranes is wastewater treatment and water reuse and PVDF gives a lower fouling potential.
CHEMICAL RESISTANCE Hypochlorite stability (cleaning agent / oxidizing chemicals) is of great importance because this ensures long lifetimes of the applied membrane modules and optimized economics and sustainability. Furthermore, these membranes are used in the open environment and as such an excellent weatherability and resistance to UV degradation is needed. On these three aspects; chemical stability, weatherability and UCV resistance, PVDF excels as a membrane forming polymer versus PES or PSU/ PVDF raw material supplier [Arkema website] highlights the chemical resistance clearly in Figure 3. Here, the impact of exposure to extreme pH and NaOCl on the mechanical properties of the polymers show that PVDF clearly outperforms PES, which is the main "other" polymer used for membranes in these applications.
Response to Public Consultation on PFAS
Figure 3: Chemical effect of chemical exposure to the elongation of PVDF, PES, PSu
Li et al. investigated the effects of hypochlorite aging various membrane properties of PVDF and PES membranes at different pH [Li 2021]. This is very relevant to do it on the membrane products because of the high contact surface area of these porous materials. During their use, all membranes in water and wastewater applications are often cleaned oxidatively. For the PVDF membrane, NaClO aging at pH 3-11 caused a moderate increase in permeability and decreased retention due to the oxidation and release of a membrane additive (non-PFAS related). For the PES membrane, NaClO aging at all pH values, resulted in chain scission of PES molecules, leading to deterioration of the membrane structure (very high permeability with very low retention).
Figure 4: Figure 8 and figure 9, taken from Li et al. showing the relative permeability and retention of PVDF (upper diagrams) and PES (lower diagrams) [Li 2022]
Response to Public Consultation on PFAS
FLEXIBILITY AND MECHANICAL STABILITY OF MEMBRANE LAYER Due to the operation of the flat sheet membranes in the membrane modules, elongation of the membrane enveloppe will take place and the membrane layer is subjected to mechanical stress. Arkema investigated and published the effect of various chemicals on the mechanical behavior of PVDF, PES and PSU [Arkema 2023]. PVDF showed the best mechanical properties in comparison to the others (Figure 5). This means PVDF will stay flexible after contact with chemicals or cleaning agents, resulting in less defects during operation. PVDF showed longer lifetime in halogenated environments.
Figure 5: schematic stress-strain curves comparing PES, PSu vs PVDF
MEMBRANE PERFORMANCE There are many studies where PES and PVDF are compared related to membrane performance. In many cases, pore sizes are not comparable or different membrane additives (determining the hydrophilicity of the membrane) are used, all resulting in apple- pear comparisons. Acarer et al. [Acarer 2021] studied to manufacturing and characterization of polymeric membranes and did a fair comparison between PVDF and PES (same amount of additive and comparable pore size. It was shown that permeability of PVDF membranes is approximately 2.5 times higher than PES membranes It is often dependent on many factors why a certain polymer membrane is chosen for a certain application. In some sectors/applications PVDF clearly outperforms PES, e.g. water treatment by MBR technology, in other sectors/applications PES is advantageous. The wastewater treatment membrane market is by far the largest market worldwide. (see above) Major reasons is that the MBR technology enables to achieve the stringent wastewater discharge limits and potential for water reuse.
Response to Public Consultation on PFAS
REFERENCES
Lesjean, B.; Rosenberger,S.; Schrotter, J.-C. (2004) Membrane-aided Biological Wastewater treatment - An Overview of applied Systems. Membrane Technology, 8, 5.
Li, N.N.; Fane, A.G.; Ho, W.S.W.; Matsuura., T. (2008) Advanced Membrane Technology and Applications; Wiley & Sons: Hoboken, New Jersey.
Wilf, M. et all (2010) The guidebook to Membrane technology for Wastewater Reclamation; Balaban Publishers: Rehovot, Israel.
WEF Manual of Practice No 36, Membrane Bioreactors, Water Environment Federation, Alexandria, Virginia (2011).
S Judd, Industrial MBRs, Membrane Bioreactors for Industrial Wastewater treatment, Judd and Judd Ltd, UK, 2014.
Lorhemen et al., Membrane Bioreactor (MBR) Technology for Wastewater Treatment and Reclamation: Membrane Fouling, Membranes 6(2), (2016), 33 (https://doi.org/10.3390/membranes6020033)
Li et al., Aging of PVDF and PES ultrafiltration membranes by sodium hypochlorite: Effect of solution pH, J. Environ. Sci., (2021), 104, 444-455 (https://doi.org/10.1016/j.jes.2020.12.020)
[Arkema 2023] Arkema, 2023, Kynar PVDF Water Filtration Membranes, https://hpp.arkema.com/en/markets-and-applications/water-and- environment/water-filtrationmembranes/,
[Acarer 2021] Acarer et al., Manufacturing and Characterisation of Polymeric Membranes for Water Treatment and Numerical Investigation of Mechanics of Nanocomposite Membranes, Polymers 13(10), 2021, 1661 (https://doi.org/10.3390/polym13101661)
Response to Public Consultation on PFAS
1.7 INFORMATION ON BENEFITS
We and the overall wastewater treatment industry sees the benefits of using PVDF as membrane material. This is shown exemplarily by the added case study emphasizing that the benefits are NOT limited to these business cases!
1.8 OTHER SOCIO ECONOMIC ANALYSIS (SEA) ISSUES
To be added for the complete submission
1.9 TRANSITIONAL PERIOD
No information on this topic.
1.10 REQUEST FOR EXEMPTION
Fluoropolymers are part of the PFAS group by OECD definition. For this reason, we understand that fluoropolymers are included in the scope of the restriction proposal that is being developed in the European Economic Area. However, because of their different chemical structure and properties, they need to be considered as a separate family within the broad PFAS group, clearly distinct not only from the non-polymeric PFAS, but also from the other polymeric PFAS. These differences are relevant not only in terms of grouping but more importantly also in relation to the risk for human health and the environment that will be derived from their manufacture and use. The main differences between fluoropolymers and the other members of the large PFAS group of chemicals are based on the following 4 aspects:
Structural differences Safety and environmental considerations, Limited expected potential to degrade into small PFAS molecules during use and/or
disposal
Response to Public Consultation on PFAS
Unique combination of properties. This makes fluoropolymers extremely valuable and irreplaceable in extremely demanding uses in a wide variety of industrial sectors. Furthermore In line with the communication of our raw material PVFD supplier, we are stating the following in relation to the public concerns related to PFAS emissions: The PVDF polymer that BF uses for the production of IPC membranes is in a category far
removed from the Fluorosurfactants (PFOA, PFAS) that originally triggered PFAS concerns. The PVDF polymer is manufactured by our supplier without the use of Fluorosurfactants
as production agents. The surfactant that is used, is non-fluorinated and non-persistent. The PVDF is a polymer of low concern according to the OECD definition. A peer-reviewed
article has been published in 2022 with scientific proof points1. The PVDF polymer is not bioavailable and not mobile. Even if its structure includes
Fluoride, its toxicity and ecotoxicity profile is different from small chain PFAS. The Blue Foot product made out of PVDF polymer will, at end of life, be managed
responsibly.
PVDF has proven to be a safe and successful membrane material that is very stable, inert, and highly resistant to breakdown. PVDF is made with a very high degree of purity. This enables PVDF products to satisfy stringent leachable limits and other national health regulations, ensuring that they are safe for use in drinking water treatment2.
1 A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplasticsand fluoroelastomers Integrated Environmental Assessment and Management (Vol 9. No 2 P326354). S.H. Korzeniowski et al.
2 AMTA-Fact-Sheet-32-PVDF-Position-Rev0.pdf (amtaorg.com) Response to Public Consultation on PFAS
Blue Foot Membranes position on the matter
Based on all the data available, including recent positions expressed by different experts on the topic, it appears evident that PVDF and other fluoropolymers should not be grouped with other PFAS for risk assessment or regulatory purposes. If fluoropolymers are to be included in the upcoming PFAS restriction under the REACH Regulation, the most reasonable and proportionate decision would be to include a broad or time unlimited derogation to ensure continued use of these highly valuable materials3. For that reason, Blue Foot Membranes states clearly that it is necessary to add a time unlimited derogation on PFAS used in industrial settings to avoid banning the use of critical PFAS-containing pieces of equipment in industrial plants. The un-intended consequences by Banning PVDF without consideration of the important concerns from the membrane industry will have far reaching environmental impacts that turn back the clock to achieve water reuse targets and sustainability goals related to access to water for all. We are not against a restriction/limitation of hazardous PFAS-of-concern, and we support a scientific approach differentiating high and low risk substances based on risk assessment. In that way, it should be concluded that fluoropolymers should not be treated in a similar way as other PFAS substances and should be taken out the ECHA restriction dossier.
Polyvinylidene difluoride polymers SHOULD BE EXEMPTED FROM ANY REGULATORY ACTION UNDER THE REACH RESTRICTION
3 Fluoropolymers: The Safe Science That Society Needs (ICRL 2022) J. Sales, et al.
Response to Public Consultation on PFAS