Document MQpVL55zDr7GD2MzJnGybjQ9

Public consultation for the preparation of a RMO analysis for restriction options for the PFAS group of substances (fluorinated substance(s) I. Substances Adressed are all substances (including polymers) that fit the following description: ,,fluorinated substances that contain 1 or more C atoms on which all the H substituents ... have been replaced by F atoms, in such a manner that they contain at least one aliphatic perfluorocarbon moiety such as -CnF2n-,, Please refer to the background document note accompanying this questionnaire and consultation for a non-exhaustive list of substance groups and examples. II. Reason for public consultation The federal authorities of several member states, namely Germany, Netherlands, Denmark, Sweden and Norway are currently planning to prepare an RMO restriction analysis for the group of fluorinated substances subject to the description above since all these substances are considered to be persistent. The consequences of this persistency i.e. non-retrievable and potential contamination of ground- and drinking water pose a risk to the environment. Many members of this group already occur ubiquitously in the environment and contaminate the ground- and untreated water due to their high mobility (e.g. ...). In addition, some of these substances accumulate in biota and/or are suspected to be toxic. In view of these properties, the federal authorities of Germany, Netherlands, Denmark, Sweden and Norway responsible for the REACH regulation are considering further measures to reduce the risks for the environment and humans. At this stage, in line with the results of previous RMO analyses of members of this substance group e.g. PFHxA, C9-C14 PFCAs, PFHxS, PFOA a comprehensive restriction comprising all uses is considered most appropriate. All uses (consumer uses of mixtures and articles, professional and industrial uses) are assumed to add to relevant emissions into the environment. Please refer to the background document for further details supporting restriction as risk management option for this group of fluorinated substances. This questionnaire is intended to generate further information for the decision as to the scope and conditions of a restriction are necessary and, if so, to identify the most appropriate restriction measures. It will also be used to identify essential uses, as well as alternatives in regard to substances or processes that could replace this group of fluorinated substances in the respective applications. III. Information on institute/organisation/person The following information marked with * on institute/organisation/person are mandatory fields. Data subject rights: Access, rectification, erasure, blocking, right of revocation By participating in this survey, personal data may be processed in terms of the General Data Protection Regulation (GDPR) of the European Union. "Personal data" is any piece of information that allows a natural person to be identified directly or indirectly, for example a name or a personified e-mail address. "Processing" may mean, for example, the collection, recording and storing of these data. There is no legal obligation whatsoever to grant such permission. Your permission is granted at your free discretion. Pursuant to Article 15 GDPR, you have at any time the right to request comprehensiveinformation on the stored personal data concerning you from the German Federal Institute for Occupational Safety and Health. According to Article 16 et seq. GDPR, you may ask the Federal Institute for Occupational Safety and Health at any time to rectify, erase and block individual personal data. According to Art. 7(3) GDPR, you furthermore have the right to withdraw this consent at any time. The withdrawal may be sent by post or by e-mail to the data controller named below: Bundesanstalt fiir Arbeitsschutz und Arbeitsmedizin / German Federal Institute for Occupational Safety and Health Division 5: Federal Office for Chemicals Postfach 17 02 02 44061 Dortmund E-Mail: =@baua.bund.de You can contact our Data Protection Officer under the postal address above or by e-mail to M@baua.bund.de. Should you be of the opinion that the BAuA does not process your data in accordance with applicable data protection regulations, you have the right to contactThe Federal Commissioner for Data Protection and Freedom of Information, Husarenstraf3e 30, 53117 Bonn When exercising your rights, you will not incur any costs other than postage or transmission costs according to current base rates. Should you withdraw your consent, your personal data will be deleted immediately after receipt of the withdrawal notice. A withdrawal shall not affect the lawfulness of the processing of your data up until the time of the withdrawal. Your personal data will be stored until the present survey has been fully evaluated and until no further questions may arise. Consent may be withheld, with the consequence of only participating in a survey without the option for asking the individual participant specific follow-up questions. In this case, company information will have to be provided. PERMISSION FOR INFORMATION PURPOSES: I agree to the personal data I provide in the present survey, including my name and my e-mail address, to be collected, processed and stored for potential follow-up questions regarding this survey by the service provider of Bundesanstalt fur Arbeitsschutz und Arbeitsmedizin (BAuA), namely Webropol Deutschland GmbH, and to these being subsequently stored in the database of the Federal Chemicals Office. * Yes No Information on institute/organisation/person Name * Surname * Name of institute/organisation * E-Mail * Note: This questionnaire contains questions that are aimed at different target groups and stakeholders respectively. Dependend on your role and answer to the next question you will be directed to the sections containing questions relevant for you. Questions in section A) are addressed to manufacturers, importers and downstream users of PFAS substances . Questions in section B) are addressed to manufacturers, importers and downstream users of alternatives. ..... 1. Are you manufacturer, importer and/or downstream user of fluorinated substances or of alternatives (other substances and non-chemical or functional replacements)? Multiple choices are possible. * Manufacturer, importer and/or downstream user of PFAS substances Manufacturer, importer and/or downstream user of alternatives IV. Questions - Section A - manufacturers, importers and downstream users of PFAS-substance(s) 2. Are you a manufacturer, importer and/or downstream user of fluorinated substances? Manufacturer Importer Downstream user 3. Please list the fluorinated substance(s), with CAS and EC numbers, which you manufacture, import and/or use? 4. How is/are your fluorinated substance(s) produced (electrochemically or by other methods)? Describe any fluorinated NIAS (e.g. oligomers or impurities) which may be present in your substance(s). 5. Authorities consider all fluorinated substances fitting the description below to be persistent and therefore harmful to the environment. "fluorinated substances that contain 1 or more C atoms on which all the H .... substituents ... have been replaced by F atoms, in such a manner that they contain at least one aliphatic perfluorocarbon moiety such as -CnF2n-" Please describe/give arguments (additional data can be uploaded at the end of this questionnaire) why your substance(s) including known contaminants or possible breakdown products should not be considered persistent. 6. Are there any other hazards than persistency relevant for environment and human health known for your fluorinated substance(s)? 7. Which quantities of fluorinated substance(s) do you produce/import/use per year? If possible, please assign quantities to the individual fluorinated substance(s) you produce/import/use. 8. If you are a manufacturer, please indicate the number of sites your fluorinated substance(s) are used at? How many workers are handling the substances in question in your company/ at your customer's sites? 9. Please describe your relevant use(s) of the fluorinated substance(s). If possible, assign quantities and concentration to the individual uses and fluorinated substance(s). Question 9 could be designed in a way, that the uses we know already are listed and have to be ticked. With the tick of a box the questionnaire can jump to the section for different uses (in case we have already more specific questions per use instead of this very general one ...) Please note: Currently not all uses were added to the list here. This section of uses or product goups will have to be aligned to the actual work packages and discussions how to structure the uses. A tiered approach could be followed: first tier: workpackages - second tier: subcategories and third tier: further information with specific questions to products e.g. WP: Textiles, leather, Apparel and textile related products Subcategories: Outdoor clothing/textiles, sportswear, fashion, home textiles, upholstery etc .... Product specific question: How is intended use for consumer (e.g. spray, diluted before application) etc Please tick Firefighting foams Textiles, leather and apparel and textile related products Food contact materials and non-stick kitchenware Household products Paper and packaging Construction products Personal care products including cosmetics Other(s) 10. If you have ticked other(s), please specify the uses or areas of application respectively. 11. Please specify the end products (industrial, professional and consumer relevance) resulting from your uses for your fluorinated substance(s). Please indicate whether your substance(s) is/are a component of mixtures and/or products. List the nature of these products as precisely as possible. 12. To whom do you supply the products you manufacture? 13. For what purpose and under what conditions are the products referred to in question 11. used? 14. If possible, indicate the concentration (or concentration range) of fluorinated substance(s) in your products and uses. Are they impurities, residues or intended additives? 15. Is your application of fluorinated substance(s) an application/use that can lead to emissions into the environment? If not, please explain why; e.g. by what measures are possible emissions controlled? 16. Is your application of fluorinated substance(s) an application/use that can lead to exposure of workers? If so, please describe the way of application, e.g. spraying, dipping, rolling and time of exposure. 17. Would it be possible for the application referred to in question 15. to switch it to an application without environmental emissions? 18. Please describe alternative substances or alternative technologies for your uses of fluorinated substance(s). 19. Do you use the alternative substance(s)/technology yourself? 20. What would be the technical and economic implications for you and your customers if you used the alternative substance/technology? 21. What would be the ecological implications if an alternative substance/technology were used instead of the respective fluorinated substance(s). 22. What time frame would the changeover take?/ In which time frame could the changeover be completed? 23. What would be the cost of the switchover? 24. Are there use(s) where it is not possible to switch to alternative substance(s) or technologies? If so, what are they and why is it not possible? 25. Please describe the measures you are taking to reduce emissions of fluorinated substance(s) into the environment. Please quantify the degree of efficiency of the emission reduction measures. 26. Please describe the measures you are taking to reduce worker exposure of fluorinated substance(s). Are these measures described in your safety data sheet and would you be willing to provide it to authorities in the scope of this consultation? 27. Which emission reduction measures do you specify in your safety data sheets in order to reduce entries into the environment under the intended conditions of use (please do not specify any measures for behaviour in "accident situations" here)? V. Questions - Section B - manufactures, importers and downstream users of ALTERNATIVES 28. Are you a manufacturer, importer and/or downstream user of an alternative for any member of the fluorinated substance(s) group? Manufacturer Importer Downstream user 29. Is your alternative a chemical or non-chemical or functional replacement to fluorinated substance(s)? chemical non-chemical 30. Please list your chemical alternatives i.e. the substance(s), with CAS and EC numbers, which you manufacture, import and/or use? 31. Please list your non-chemical alternatives e.g. technical solutions etc ....? 32. Which quantities of each alternative do you produce/import/use per year? Please note: same applies here as the remarks to Question 9 abobe! 32. To which of the following uses/use areas your alternative can be used as replacement for PFAS substances. With the tick of a box the questionnaire can jump to the section for different uses (in case we have already more specific questions per use instead of this very general one ...) Firefighting foams Textiles, leather and apparel and textile related products Food contact materials and non-stick kitchenware Household products Paper and packaging Please tick Construction products Personal care products including cosmetics Other(s) 33. If you have ticked other(s) please specify the use(s) and/or areas of application. 34. Are there any known hazards (for human health and/or environment) of your alternative(s)? 35. Do you possess data on the performance of your alternative in an application for which normally fluorinated substance(s) are used? Please indicate here and submit further data at the end of this questionnaire. 36. Are releases to the environment expected from your alternative(s)? What ecological implications would result? 37. Is relevant worker or consumer exposure expected from your alternative(s)? VI. Additional Information Please attach additional information below. Data labelled a confidential will be treated as confidential business information. All Data will be transmitted encrypted and saved on an external server. In case you prefer not to transmit data electronically, you may send them to the Federal Office for Chemicals at the BAuA per postal mail (see below). Attachment You can attach one or more files from your computer to your response. To attach a document, click the button below and browse for the file. Select the file and click "Open". To delete a file, click on the recycle bin icon. The attachment must be type of doc, docx, pdf, xls, xlsx. Weitere Informationen und Anhnge Postal Address In case you intend to submit confidential information by postal mail please use the following address Bundesanstalt fr Arbeitsschutz und Arbeitsmedizin (BAuA) Bundesstelle fr Chemikalien Friedrich-Henkel-Weg 1-25 44149 Dortmund Thank you very much for your participation. With your answers you support the preparation of a RMO analysis.