Document EmxpvoZMEpb7kwB2ny1KXBej

DRAFT FOR DISCUSSION ONLY - NOT AN OFFICIAL ECHA DOCUMENT AND NOT TO BE CIRCULATED FURTHER Lengths of transitional periods and assessment periods 1. Lengths of transitional periods Length type of transitional period (related to substitution and emission potential)1 Long Medium Short Very short Sector/type of use (a). Facilities with large (atmospheric) tanks of flammable liquids with a total bunded area over 400m and installation needing to comply with SEVESO Directive2 (b). Any other type of use not already covered by the other categories (e.g. chemical, petrochemical, offshore oil and gas installations and other industries, civil aviation, aerospace, defence) (c). Municipal fire services, ready-to-use applications (e.g. fire extinguishers), marine sector (d). Training and testing, irrespective of the sector of use Range proposed by STO1 and other sources 8y (Equinor - offshore oil platforms) 10y (Lastfire) 12y (~PFHxA restriction) 8y (Equinor - offshore oil platforms) 5y: PFHxA restriction) 4y (US Defense law) Across sectors: 3-6y 5y: PFHxA restriction Immediate. 18 months (PFHxA restriction proposal) DS proposed sensitivity analysis 8y 10y 12y 5y 8y 10y 18 months 36 months 5y 18 months 36 months 5y DS possible specific suggestion (if needed) Scenario 1: 8y Scenario 2: 10y Sc1: 5y Sc2: 8y Sc1: 18 months Sc2: 3 years Sc1: 18 months Sc2: 18 months 1 Based on EC/ECHA report from stakeholders' consultation (see summary in section E.8.1 and E.8.2 pp. 177-179 of the pre-Annex XV report) and additional information sources such as contributions to the consultation to the PFHxA restriction proposal. 2 Directive 2012/18/EU on the control of major-accident hazards involving dangerous substances https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0018 DRAFT FOR DISCUSSION ONLY - NOT AN OFFICIAL ECHA DOCUMENT AND NOT TO BE CIRCULATED FURTHER Sectors of use and usage rates as identified in the EC/COM study: Table B.1 Industry splits and usage rates based on data from Eurofeu and Brooke et al (2004)* Sector Percentage share of total Annual usage rates (of total quantity sold annually) Live incidents (as a percentage of total use) Training (as a percentage of total use) Efficacy of bunding/control measures for training Military 6% 17.5% 7% 93% 90% Civil Aviation 9% 17.5% 7% 93% 97% Municipal Fire Services 13% 60% 93% 7% 90% Chemical/petrochemical 59% 17.5% 7% 93% 97% Marine Applications 12% 17.5% 7% 93% 0% Ready to use 1% 17.5% 100% 0% N/A applications *For live incidents a 100% release is assumed split evenly between releases to surface water and soil. In the case of marine applications this is a 100% release to sea. Possible Excel sheet design: Length type of transitional period Long Medium Short Very short Type of use LAST and Seveso Other industries, aviation and defence Municipal fire services, ready to use applications and marine applications Training and testing Sectors categories covered, as described in EC/ECHA report (Table B.1 page 97 of pre-Annex XV report) A percentage to be determined of "Chemical/petrochemical" (minus training and testing) Remaining percentage of "Chemical/petrochemical" "Civil aviation" (minus training and testing) "Military" (minus training and testing) "Municipal Fire Services" (minus training and testing) "Ready-to-use applications" "Marine applications" (minus training and testing) Training part of the above sectors Lengths of TP Several columns with other input parameters 8y 10y 12y 5y 8y 10y 18 m 36 m 5y 18 m 36 m 5y DRAFT FOR DISCUSSION ONLY - NOT AN OFFICIAL ECHA DOCUMENT AND NOT TO BE CIRCULATED FURTHER Note: Training and testing are claimed by industry to have been largely substituted with fluorinefree foams or simulants. Therefore, the Excel spreadsheet should allow an easy modification of the input parameters for proportion of PFAS foam considered for training and testing. Output: For the two restriction scenarios (1: ban on placing on the market only; 2: ban on placing on the market and use): Length Type of Emissions Costs Emissions Costs ... Total Total type of use year 1 year year 2 year emissions costs transitional 1 2 (y1-30) (y1-30) period Long LAST and Seveso Medium Other industries, aviation and defence Short Municipal fire services, ready to use applications and marine applications Very short Training and testing 2. Assessment period Scenario 1: ban on the placing on the market, with use-specific transitional periods (use continues to be allowed) Scenario 2: ban on the placing on the market and use, with use-specific transitional periods Considerations for scenario 1: Taking the sector with the possibly longest transitional period of 12 years, this would mean that purchase of PFAS foams will be allowed 12 years after the restriction entry into force (EIF)and its use legally allowed permanently, in practice used until the foam reaches expiry date (considered 15 years in our assessment). For simplicity one can consider a steady-state level of use (considering that no alternative become available and usable until the end of the transitional period), followed by a linear decrease after 12 years until 27 years after EIF (12 transitional period + 15y foam expiry date). DRAFT FOR DISCUSSION ONLY - NOT AN OFFICIAL ECHA DOCUMENT AND NOT TO BE CIRCULATED FURTHER Considerations for scenario 2: The difference with scenario 1 is that, for a given type of use, after a steady-state or slightly decreasing level of placing on the market and use, the emissions will stop immediately after the end of the transitional period. Taking the possibly longest transitional period of 12 years, this would mean a maximum assessment period of 12 years. For simplicity, we suggest considering for both scenarios a 30 years assessment period.