Document KReYQgvkyvaq34yG47MYR1Dk6

TRANEMO TEXTIL AB - ANSWERS Agenda point 1 - Critical properties (performance) for protective clothing Questions 1. Please describe quantitatively critical properties (performance) for protective clothing, see table 1, in the form of comparable measurements / studies between performance for fluorochemistry and alternative non fluorochemistry? See answer below in table 1 columns. Table 1: Critical properties (performance) vs Standards for protective clothing (CEN/TC 162) Critical Standards for protective clothing Tranemo Comments Q 2:4: Acceptable properties (CEN/TC 162) to Q 1:1: critical quantitative (performance) properties. measurement results/limits Electrostatics EN 1149 series N/A for fluorocarbons. N/A Antistatic properties are not reached by PFAS but with antistatic fibres. Liquid chemicals EN 13034:2005+A1:2009 Tranemo uses EN Depending on EN 14605:2005+A1:2009 13034 only (EN 14605 protection EN 16523-1:2015+A1:2018 and EN 16523-1 are needed. If only N/A). Based on protection customer's risk against small assessment most of splashes of low the garments still need concentrated acid PFAS DWOR to fulfil and alkaline is their demands. needed, a PFAS- free DWR could PFAS-free DWR can be sufficient. only be used if the customers risk However, if assessment allows customers risk that and that it passes assessment the chemicals needed demand within EN 13034 (PFAS protection free may today pass against other H2SO4 30% and NaOH chemicals and/or 10%, but not o-Xylene oil repellence or Butanol). And for oil then C6's is repellence there is no needed as of alternative available as today's existing of today's technology. technology. EN 13034 is The standard EN included in 13034 is under highest risk development and category 3 within there will be a new the PPE 1 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) Critical Standards for protective clothing Tranemo Comments Q 2:4: Acceptable properties (CEN/TC 162) to Q 1:1: critical quantitative (performance) properties. measurement results/limits one in the coming regulation, so it is years. We do not yet very important to know the extent of comply with the this new standard, but customer's the same chemicals demand. tested today seem to be involved also in the updated version. Protection EN ISO 17491-3, -4:2008 EN ISO 19918 is N/A For EN ISO 17491- against chemicals EN ISO 17491-4:2008 for Tranemo articles. 4 and EN ISO EN ISO 19918:2017/A1:2021 EN ISO 17491-4 and 6530 the same EN ISO 6530:2005 EN ISO 6530 are the answer as for EN test standard included 13034 applies. in EN 13034 and therefore relevant and the same answer as above is applicable here. Liquid and EN 464:1994 N/A for Tranemo N/A for Tranemo gaseous articles articles chemicals, including aerosols and solid particles Against rain EN 343:2019 Fluorocarbon will not PFAS-free DWR necessarily be needed provides good to fulfil EN 343. PFAS- protection for EN free DWR can provide 343 if only water a good enough repellence is protection against needed to fulfil water. the certification. There is a risk not However, included as fulfilling EN 343 if pre-treatment in EN the oil and fuel 343 is testing against pre-treatment oil and fuel. Tranemo cannot be made questions if this is a optional in the necessary pre- certification. treatment for the More evaluation garments we provide. and tests must be This pre-treatment is made to give probably more further applicable for rain qualitative or wear to be used quantitative offshore. information. EN 343 is PPE risk category 1 and 2 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) Critical Standards for protective clothing Tranemo Comments Q 2:4: Acceptable properties (CEN/TC 162) to Q 1:1: critical quantitative (performance) properties. measurement results/limits therefore a low risk and the essential need of PFAS is questionable. Splashes of EN 348:1992 A standard for gloves No information to molten metal protection. Tranemo be given at this uses this standard very stage. limitedly. No qualitative or quantitative information can be given at this stage in regards of the need of fluorocarbons For firefighting EN 469:2020 N/A for Tranemo N/A activities articles. High visibility EN ISO 20471:2013 Fluorocarbons will not EN ISO 20471 automatically be does not demand needed to achieve DWR/DWOR high visibility. Instead finish to achieve Tranemo recommends fluorescence and washing garments luminance. regularly to avoid Fabrics with getting them PFAS-free DWR, permanently dirty. or completely DWR-free could be sufficient to fulfil EN ISO 20471. Use, care and CEN/TR 14560:2018 Guidance for creating N/A maintenance CEN/TR 15419:2017 a risk assessment, CEN/TR 17330:2019 which are more directed to our customers. We have not any qualitative or quantitative information to give at this point. Others? EN ISO 11612 Since fluorocarbons This is overlaying EN 61482-2 are oil repellent there most of the other EN 11611 is additional standards since EN 14116 protection added with Tranemo must EN 407 (gloves) fluorocarbons since oil guarantee that and dirt can act as risk the eventual loss factors in regards of of PFAS's will not flammability. affect the However, to achieve flammability 3 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) Critical properties (performance) Standards for protective clothing (CEN/TC 162) Tranemo Comments to Q 1:1: critical properties. good flammability PFAS DWOR's are not a demand. The protection of flammability is reached by using inherent fibres which provide the protection. Q 2:4: Acceptable quantitative measurement results/limits badly due to removal of stain or oil repellence*. There is not enough data on this at today's stage to set any measurements or limits. 2. Are these data available to us? See above explanations in table 1. Agenda point 2 - Standards for protective clothing need for PFAS Questions and remarks 3. Are there comparable quantitative test results between fluorochemistry and nonfluorochemistry available to us performed with the test standards listed in table 1 (or others, please specify)? Tranemo have a new FR collection which contain PFAS-free DWR. This protects against water and water-based stains and chemicals. It is tested and approved according to EN 13034 for sulphuric acid (30%) and sodium hydroxide (10%). Tranemo have both tested positive results internally and made standardized EN 13034 (according to EN ISO 6530) at accredited lab to make sure also the PFAS-free finish repels the acid and alkaline within the standard of EN 13034. The test report from the accredited lab is approved by our notified body who approves the CE-marking of the garments. Since our customer's risk assessment mostly demand EN 13034-certification and/or oil repellence it is not possible as of todays technology to fully substitute the PFAS DWOR's. Tranemo has made a wear trial of a trouser in comparing PFAS DWOR and completely DWRfree, one leg with PFAS C6 and the other leg without any DWR. After long use and dirt exposure, after washing the results on both legs were equally dirty/clean. The Tranemo thesis is that fluorocarbons therefore are not automatically needed to achieve better high visibility after washing, but instead Tranemo recommends washing the garments more regularly to avoid the permanent dirt. Tranemo will be part of a Master thesis project during spring 2022 (collaboration between Swedish School of Textiles, RISE IVF and Chalmers University) which will focus on testing the comparison between PFAS and PFAS-free finishes on protective garments. After that study is finished, Tranemo will have more quantitative test results. 4 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) 4. Please indicate which quantitative measurement results/limits are acceptable for your markets for the test methods listed in table 1 below (or others, please specify). Please see answers in right column in table 1. Important notice! Almost all the PPE-garments have several certifications, including from different areas within the PPE risk categories. For example, a jacket can be certified according to both EN 343 (cat 1, rain protection), EN ISO 20471 (cat 2, high visibility), EN 13034 (Cat 3, chemical protection) and EN ISO 11612 (cat 2 and 3). This means that the highest risk on a fabric should decide the need of PFAS's. Even if EN 343 can be achieved by PFAS-free DWR, EN 13034 might not be sufficient with PFAS-free finish. It probably needs a C6 to achieve demanded protection according to customer's risk assessment. For an explanatory list of standards divided into the three risk categories, please see table 2 at the end of this document. *The process of changing a component within a PPE-fabric is very complex. To even change a minor component, one is at risk to re-certify fabrics and garments again. This means that if PFAS's are to be changed to PFAS-free surface treatment, Tranemo and our fabric suppliers must secure the protection of all the certifications that the fabric holds. For example, if a fabric is certified: EN ISO 11612, EN ISO 11611, EN 61482-1, EN 13034 etc, all these certification tests is at risk to be updated with the new finish. First it must be approved by accredited lab on fabric level and then all the garments' certification must be updated according to the new fabric test results. This is both a very costly and a very time-consuming process. For an estimated summary of costs and time, please see table 3 at the end of this document. Agenda point 3 - Potential alternatives to PFAS In the ongoing restriction work of PFAS in EU/EEA, a range of non-fluorinated alternatives to PFAS have been identified Hyperbranched functionalized polymers (dendric polyurethanes) Paraffins (hydrocarbons) Waxes (fatty acid esters) Silicones (polydimethylsiloxanes abbr. PDMS) Polymeric compounds such as non-fluorinated (meth)acrylates Plasma treatment Graphene structures Other? Questions 5. For these above listed non fluorinated alternatives (and possibly other) to fluorochemistry, what are the biggest specific challenges to phase in those non fluorinated alternatives that may be feasible for your applications? Oil repellence and protection to chemicals - Some chemicals, e.g. acids and alkaline, in low concentration, can be repelled by PFAS-free DWR, but the others needs PFAS's based upon todays 5 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) knowledge and the technical limitations of the PFAS-free alternatives. 6. Have you evaluated other fluorochemicals / materials as substitutes for the currently used fluorochemistry? If so, please specify this chemistry. We have evaluated hydrocarbon based PFAS-free (paraffins) DWR at Tranemo. An important notice is the flammability potential of other DWR's than PFAS. When PFAS are applied onto fabric it does not pose as an additional risk, it does not increase flammability. If paraffins or other DWRs are being used the flammability of the finish must be evaluated to see if it's suitable. Paraffins are hydrocarbon based and are quite easily ignitable in their own. One must make sure that the finish applied onto the fabric does not pose as an additional risk for the flammability. Agenda point 4 - Quantities of PFAS in protective clothing Questions 7. What are the quantities of PFAS used in protective clothing applications in the EEA? No information in general, but for the Tranemo calculation of used PFAS (in kilogram) during period 20/21, please see table 4 at the end of the document. 8. Annex I of the PPE regulation (EU 2016/425) divides PPEs into three risk categories. What share of the quantities of PFAS are used in the three risk categories, respectively? Fabrics (by article, in approximate %): Cat 1 = 8 % Cat 2 = 18 % Cat 3 = 74 % Important notice: The percentual grouping of PPE-categories on fabrics is approximate since the same fabric can be used in both 2 and 3 depending on which certifications it holds. It is not definite that a fabric itself is either cat 2 or 3. The garments however are defined according to the highest PPE-level. It is therefore important to have the highest risk category in mind on the fabric level when evaluating if PFAS's are essential or not, even if the fabric is used in both category 2 or 3 garments. 9. Do you apply industrial re-impregnation of PFAS in your products? If so, what quantities of PFAS are used for industrial re-impregnation of your products? Tranemo recommends reimpregnation by at least every 5th wash on EN 13034 garments to fulfil protection also after washing. This service is not provided by Tranemo, but our partners in the industrial laundry business provides this reimpregnation to our customers. We also recommend heating (by tumbler for example) the garments after wash to re-activate the PFAS finish which will prolong the repellent functions in between re-impregnations. The reactivation and reimpregnation process will continuously be needed also for PFAS-free DWR's, for example if using hydrocarbon DWR's. For EN ISO 20471 certified garments there is no recommendation to reimpregnate garments to maintain stain-/oil-/dirt repellence. Industrial laundries do not automatically re- 6 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) impregnate garments where the highest risk is EN ISO 20471 (cat 2, PPE regulation) - as far as our knowledge extends. Agenda point 5 - Emissions and waste management 10. What are the quantities of emissions of PFAS from reimpregnation of your products? Tranemo can only recommend reimpregnation, but it is up to the industrial laundry partner to do so. Tranemo therefore has no informative number of emissions. 11. What measures can be taken to minimize the emissions from reimpregnation? What are the costs associated with these measures? Tranemo can only recommend reimpregnation, but it is up to the industrial laundry partner to do so. Minimize emissions from reimpregnation and their additional costs are questions for the industrial laundry partners. 12. How are your PFAS containing protective clothing dealt with at end-of-life? The producer's responsibility is not yet applied onto textiles. A reasonable theory would be to incinerate garment in high temperature (over 1000'C) to get rid of any PFAS. It is still under research at which temperature should be sufficient to remove the PFAS completely. 13. What are the quantities of emissions of PFAS from protective clothing in the waste phase? Tranemo has no information. 14. What measures can be taken to minimize the emissions from the waste phase? What are the costs associated with these measures? Our idea: To recommend incineration for garments containing PFAS's - and to not allowing it to end up in land fill or extended life span outside our, our customers and our laundry partners, control. TRANEMO - additional comments - For Tranemo, the PPE garments containing PFAS's are today certified in accordance with EN 13034 Type 6 [PB]. Due to design demands the EN 13034 might not be reached, but the repellent function of the fabric still needs to be there. This is because EN 13034-garments are subordinate (in customers risk assessment) to the main protections: flame, electric arc, hi-vis, and anti-static. For example, if the design for EN 13034 contradicts another certification, then EN 13034 will be lost as certification in garment certification. However, having repellent fabrics is still very important for those garments. This is because the main idea of EN 13034 Type 6 Partial Body protective wear is to get oneself away from the danger in case of an accident - repellent fabrics gives additional reaction time to do so. By having the fabrics repellent to chemicals, the wearer gets more time to react and get oneself away from the danger and remove all the contaminated clothing. Workers are not supposed to continue working if an accident occurs. If that kind of protection is needed, then Partial Body protection Type 6 [PB] as certification is not sufficient and higher chemical protection must be evaluated in the customers risk assessment. It is the 7 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) same as when comparing EN 469 with EN ISO 11612 when you are deliberately exposed to risk (EN 469) compared to when a risk arises in the event of an accident (EN ISO 11612). - It is mentioned and suggested 3-10 years as transition time in the TULAC-report for removal of PFAS for PPE. Tranemo find it very unlikely to find a substitute for PFAS's when it comes to oil- and chemical repellence during this period. Tranemo is agreeing and supporting the broader ban of all PFAS. However, if the protection for the wearer using the garments is affected and reduced, there cannot a complete removal of PFAS's. The personal safety for workers must be Tranemo's number one priority. - One must also consider the safety stock of PPE garments. To be able to supply our customers with PPE we need a safety stock - which is we need to have several years of stock. If an alternative to PFAS with excellent properties against oil- and chemical repellence is found in the future, the transition time for the stock also must be taken into consideration. According to Tranemo's calculations, at least 5 years must be added to the transition time to make sure the stock is able to rotate from PFAS to PFAS free. Table 2: Standards divided by PPE category STANDARD EN 343 EN 342 EN ISO 20471 EN ISO 14116 EN ISO 11612 EN ISO 11611 EN 13034 EN 61482-2 CAT I X CAT II CAT III Comments X Only garment certification, not applicable on fabrics X X X X Depends on which code letter and/or level if it's cat 2 or 3. X X X 8 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) Table 3: Fabric and garment certification costs for one FR-collection GARMENT CERTIFICATION COSTS At Tranemo's expense Certification cost* 880 9 7 920 *Mean value is 9 certificates per collection EN 61482-2 Open Arc (1 layer) EN 61482-2 APC 1 (1 layer) Seam test (Strength, A1, A2) EN 61482-2 APC 2 (2 layer) Garment test APC 2 EN 61482-2 Open Arc (2 layer) Garment test Open Arc Garment cost for Skinsafe tests (jacket) Garment cost for Skinsafe tests (underwear) 1 600 2 670 2 2 200 2 1 200 2 85 12 750 670 1 150 3 200 1 340 4 400 2 400 1 025 8 30 240 23 095 FABRIC CERTIFICATION COSTS At our supplier's expense several EN ISO 11612 EN ISO 11611 Class 2 EN 61482-1-2 Box test EN 61482-1-1 Open arc EN 1149-3 EN 13034 EN 343 EN ISO 20471 1 541 262 1 850 1 642 288 1 041 744 1 715 50x 15795: Coordinates 20471, 1149-3, 11612 A1 TOTAL SUM FOR RE-CERTIFYING GARMENTS 34 373 2 195 11 278 Estimated time for completed garment certifications 6-8 months in average Estimated time for completed fabric certifications 3-4 months in average INFORMATION Please note that above calculations are if all certifications must be updated due to change from C6 to C0. Tranemo has over 10 FR-collections where the same calculation cost is applicable. 9 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS) Table 4: Estimated calculation for amount of PFAS amount in garments sold during July 2020 - June 2021 from Tranemo warehouse Fabric weight (g/rm) mean value (260g/m2 x 1,5m width) 390 Workwear fabrics (m) (sold running meters (rm) with PFAS-finish) 87 571 Approx. amount of PFAS added (%) mean value (range 2 - 6,7) 0,50% Flame Retardant fabrics (m) (sold running meters (rm) with PFAS-finish) 245 783 Running meters x weight x amount PFAS Workwear fabrics (kg) total weigh of PFAS C6 171 Flame Retardant fabrics (kg) total weigh of PFAS C6 479 SUMMARY Workwear fabrics: 171 kg as total PFAS in fabrics sold during 20/21 FR fabrics: 479 kg as total PFAS in fabrics sold during 20/21 Workwear fabrics (PFAS-fabrics in % by total running meters sold during 20/21) Flame Retardant fabrics (PFAS-fabrics in % by total running meters sold during 20/21) 31% 42% Total PFAS-fabrics in % by total running meters sold 20/21 38% INFORMATION - A 15% fabric waste rate is included in the calculation - This calculation includes all fabrics in garments sold from Tranemo warehouse during the period 2020.07.01 to 2021.06.30 - PPE fabrics are included in both workwear fabrics and FR fabrics. However, PPE cat 3 fabrics are only used in FR. 10 N/A = Not applicable, DWR = Durable Water Repellent (PFAS-free), DWOR = Durable Water and Oil Repellent (PFAS)