Document KeoEwvQBq512g577Q5adVDzo

CIRCOR ALLWEILER' ALLWEILER GmbH . Allweilerstr. 1 . D-78315 Radolfzell European Chemicals Agency ECHA Telakkakatu 6 P.O. Box 400 FI-00121 Helsinki, Finland ALLWEILER GmbH Allweilerstr. 1 78315 Radolfzell / Germany www.allweiler.com Your contact: Michael Leutner Product Com liance Tel: Fax: +49 7732 86 99 828 @circor.com 14. September 2023 Comment on Proposed Restriction of Per- and polyfluoroalkyl substances PFAS 1. Introduction Circor International Pumps is a provider of mission critical flow control products and services for the Industrial and Aerospace & Defense markets. The Pumps are essential for many applications in daily life, such as transport of drinking water and wastewater, production and packaging of food and beverage, production processes within chemical and pharmaceutical industry, processes in oil and gas, pulp and paper, mining and metals, heating, ventilation, and air conditioning applications. PFAS materials in our pumps are used, primarily for functions such as seals and inserts. Their remarkable attributes encompass exceptional chemical resistance, thermal stability, and a low coefficient of friction. PFAS materials are exclusively employed in scenarios where no viable substitute is currently accessible. Circor International Pumps has significant concerns about the proposed broad restrictions on the use of PFAS. The prohibition of PFAS components like polymers in pumps could potentially create unpredictable risks to the reliability and safety of many applications. Replacing PFAS with other materials that may be less suitable or completely unsuitable could result in rapid failures and leaks, posing the risk of releasing aggressive, toxic or high-temperature substances that could potentially harm humans and the environment. In addition, it is imperative to recognize that the use of PFAS in pumps is limited to professional and industrial settings where the proper handling, use and disposal of these products can be effectively controlled. It would be as exaggerated as it would be unjustified. After all, a whole series of PFASs, the socalled "polymers of low concern," are not a danger to the environment according to the OECD and must therefore be exempt from a ban. https://www.oecd.orq/enviehs/riskassessment/42081261.pdf Headquarter: Radolfzell Registered in Freiburg Breisgau/Germany HRB 707701 VAT-ID DE142 767 191 Chairman of the Supervisory Board: Daniel Stirpe Managing Director: Gunter Connert, Matthias Probian Hypo Vereinsbank, Frankfurt Bank code 503 201 91 EUR-Account no 21709158 SWIFT: HYVEDEMM430 IBAN: DE97 5032 0191 0021 7091 58 WEEE-Reg.-No. DE 90152698 Sparkasse Hegau-Bodensee Bank code 692 500 35 EUR-Account no 4040051 SWIFT: SOLADES1SNG IBAN: DE12 6925 0035 0004 0400 51 ALLWEILER is a Business Unit of CIRCOR I www.circor.com