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rECHA EUROPEAN CHEMICALS AGENCY
ECHA's firefighting foams restriction proposal: survey
1 (12) 6 May 2021
ECHA's firefighting foams restriction proposal: survey on the use of firefighting foams
Background
The European Chemicals Agency (ECHA) has been requested by the European Commission to prepare a restriction proposal under REACH for the use of perand polyfluoroalkyl substances (PFAS) in fire-fighting foams1'2. In this context a report on the use of firefighting foams was prepared for the European Commission and ECHA3, assessing two potential restriction scenarios. ECHA is now seeking additional information from the sectors using these foams in order to also investigate additional restriction options other than a ban. ECHA welcomes information on the following:
Foam annual usage and disposal rates Types of use of PFAS and fluorine-free ("F-free") firefighting foams Amount of firefighting foam stock in the EU Number of sites, installations, vehicles and fire incidents Risk management measures already in place and possible improvements Transitional periods
Why responding to the survey is important?
It can help determine which regulatory risk management measure would be most appropriate.
>. It can help identify sector-specific constraints in relation with transitional periods.
By responding to this survey, you give your consent that the submitted information can be made publicly available. If you plan to submit confidential information, please do so directly via ECHA's submission page. In this case, please indicate clearly which elements are confidential.
If some fields in the survey are irrelevant to you, feel free to skip them.
Please respond to the survey in appendix before 4 June 2021
1 See Registry of restriction intentions until outcome for dossier update https://echa.europa.eu/registry-of-restrictionintentions/-/dislist/details/0b0236e1856e8ce6 and the following page for generic information and timelines of the REACH restriction process: https://echa.europa.eu/restriction-process
2 Please note that other regulatory measures at EU level, which might impact the use of firefighting foams have already been initiated (e.g. the restriction on undecafluorohexanoic acid (PFHxA), its salts and related substances. Any information provided to ECHA in the context of the restriction work on PFAS in firefighting foams will only be used for this specific proposal and not for other regulatory measures. See status at https://echa.europa.eu/registry-ofrestriction-intentions/-/dislist/details/Ob0236e18323a25d 3 https://echa.europa.eu/documents/10162/28801697/pfas flourine-free alternatives fire fighting en.pdf/d5b24e2ad027-0168-cdd8-f723c675fa98
P.O. Box 400, FI-00121 Helsinki, Finland I Tel.
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ECHA's firefighting foams restriction proposal: survey
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You can also forward this survey to other relevant stakeholders you might identify. If you have any question regarding this survey, please contact us at
echa.euro a.eu
Thank you for your cooperation.
Risk Management Unit II European Chemicals Agency
P.O. Box 400, FI-00121 Helsinki, Finland I Tel.
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Appendix - ECHA's firefighting foams restriction proposal: survey on the use of firefighting foams
By responding to this survey, you give your consent that the submitted information can be made publicly available. If you plan to submit confidential information, please do so directly via ECHA's submission page. In this case, please indicate clearly which elements are confidential.
Contact information First name Last name Country Organisation E-mail
Telephone
1. Annual usage rates of PFAS-based firefighting foams across sectors
Compared to your annual purchase quantity of firefighting foam concentrates, please indicate the typical annual usage/disposal quantities for PFAS-based and fluorine-free foam concentrates used for:
- "in service use", i.e. to prevent or manage a fire (e.g. covering of flammable liquid leaks, fire incidents)
- Training purposes - Testing purposes, including testing of systems for their function (please
specify) - Disposed of because of having reached expiry date or because of having
been rendered non-functional due to improper handling (please exclude the quantities of PFAS C8 foams disposed of due to the POP Regulation requirements related to PFOA - please specify).
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ECHA's firefighting foams restriction proposal: survey
The submitted information is valid for: Tick the right box One site The whole company/organisation for sites located in the EU The sector as a whole at Member State level The sector as a whole at EU level 0 Other: please specify
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1.1 On-land use of fire-fighting foams
Life cycle stage/use type
In service use, i.e. to prevent or handle a fire Training Testing (e.g. testing of foam agents to evaluate their suitability on specific combustibles or testing of correct proportioning of firefighting foam concentrates but excluding testing of the firefighting systems for their function) Testing of the firefighting systems for their function Disposed of because of having reached expiry date or because of having been rendered nonfunctional due to improper handling (please exclude the
0/0 of PFASbased foams annual purchases
Amount of PFAS-based foams annual purchases
(T/Y) Discrete numbers or ranges: 110,10-100, 100-1000, >1000
0/0 of F-free foams annual purchases
Amount of F-free foams annual purchases
(T/Y) Discrete numbers or ranges: 110,10-100, 100-1000, >1000
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quantities of PFAS C8 foams disposed of due to the POP Regulation requirements related to PFOA - please specify)
ECHA's firefighting foams restriction proposal: survey
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1.2 Off-shore use of fire-fighting foams
Life cycle stage/use type
In service use, i.e. to prevent or handle a fire Training Testing (e.g. testing of foam agents to evaluate their suitability on specific combustibles or testing of correct proportioning of firefighting foam concentrates but excluding testing of the firefighting systems for their function) Testing of the firefighting systems for their function Disposed of because of having reached expiry date or because of having been rendered nonfunctional due to improper handling (please exclude the quantities of PFAS C8 foams disposed of due to the POP Regulation requirements related to PFOA - please specify)
0/0 of PFASbased foams annual purchases
Amount of PFAS-based foams annual purchases
(T/Y) Discrete numbers or ranges: 110,10-100, 100-1000, >1000
0/0 of F-free foams annual purchases
Amount of F-free foams annual purchases
(T/Y) Discrete numbers or ranges: 110,10-100, 100-1000, >1000
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2. Stocks of firefighting foam concentrates
Please describe the amount of firefighting foam concentrates you have in stock.
C8 PFAS foams
For on-land use
Stock (tonnes) Discrete numbers or ranges: 110,10-100, 100-1000, >1000
For off-shore use
Stock (tonnes) Discrete numbers or ranges: 1-10,10100, 100-1000, >1000
<C8 PFAS foams
Fluorine-free foams
3. Number of sites using firefighting foams, number of firefighting installations, vehicles and incidents
Can you indicate within your company or organisation the number of sites using firefighting foams (industrial sites, airports, ships, harbours, etc.), the average number of fire-related incidents per year handled with PFAS-foams (distinguishing small and large), the number of fixed firefighting installations and mobile firefighting equipment (e.g. fire trucks). If known, please also provide a total estimate for the whole sector in your Member State or at EU level. This information will be used to estimate costs related to e.g. clean-up of equipment and technical adaptations needed in equipment to use alternatives foams.
Please describe the amount of firefighting foam concentrates you have in stock.
On-land sites
Number of on-land sites using PFAS firefighting foams
Discrete number or range: 1-10,10-100, 100-1000, >
Type of site - select:
Industrial
0
manufacturing
site
Number of onland sites using fluorine- free firefighting foams
Discrete number or range: 1-10,10100, 100-1000, >
Type of site - select:
Industrial
0
manufacturing
site
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Military bases
Civil airports 0
Harbour
0
Municipal fire 0 brigades
Other: please u specify
Military bases u
Civil airports El
Harbour
0
Municipal fire 0 brigades
Other: please u specify
Do on-land sites using PFAS foams usually also use fluorine-free foams? (tick box)
Yes u No u Other (please specify) u
Please describe the amount of firefighting foam concentrates you have in stock. Off-shore sites
Number of off-shore sites using PFAS firefighting foams.
Discrete number or range: 1-10,10-100, 100-1000, >
Type of site - select:
Number of offshore sites using fluorine-free firefighting foams.
Discrete number or range: 1-10,10-100, 100-1000, >
Type of site - select:
Off-shore 0 industrial site (e.g. oil platform)
Off-shore
0
industrial
site (e.g. oil
platform)
Other
0
(please
specify)
Other
0
(please
specify)
Dp off-shore sites using PFAS foams usually also use fluorine-free foams? (tick box)
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Yes u No u Other (please specify) u
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On-land use
Number of small fire-related incidents per year handled with PFAS-foams
Number of large fire-related incidents per year handled with PFAS-foams
Number of small fire-related incidents per year handled with F-free foams
Number of large fire-related incidents per year handled with F-free foams
Amount of PFAS foam used per year for handling small fire-related incidents (T/y)
Amount of PFAS foam used per year for handling large fire-related incidents (T/y)
Amount of F-free foam used per year for handling small fire-related incidents (T/y)
Amount of F-free foam used per year for handling large fire-related incidents (T/y)
Off-shore use
Number of small fire-related incidents per year handled with PFAS-foams
Amount of PFAS foam used per year for handling small fire-related incidents (T/y)
Number of large fire-related incidents per year handled with PFAS-foams
Amount of PFAS foam used per year for handling large fire-related incidents (T/y)
Number of small fire-related incidents per year handled with F-free foams
Amount of F-free foam used per year for handling small fire-related incidents (T/y)
Number of large fire-related incidents per year handled with F-free foams
Amount of F-free foam used per year for handling large fire-related incidents (T/y)
Please describe below how you defined "small" and "large" incidents. If you have used F-free foams on large fire incidents, please describe how you would assess the performance of this use compared to using PFAS-based foams.
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Fixed firefighting systems (systems not being able to move from one place
to another to reach the incident site) Number of fixed firefighting systems using PFAS foams
Number of fixed firefighting systems using F-free foams
Do the fixed firefighting systems using PFAS foams usually also use fluorine-free foams? (tick box) Yes u No u Other (please specify) u
Mobile firefighting systems (systems being able to move from one place to
another to reach the incident site, e.g. fire trucks)
Number of mobile firefighting systems using PFAS foams (e.g. fire trucks)
Number of mobile firefighting systems using F-free foams (e.g. fire trucks)
Do the mobile firefighting systems using PFAS foams usually also use fluorine-free foams? (tick box) Yes u No u Other (please specify) u
Additional information Insert your reply here
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4. Risk management measures already in place
Do your sites have installations or mechanisms to collect firewaters run-offs in case of fire-related incidents? If yes, can you describe them (e.g. bunded areas, waterproof ground, pumps, etc.) and evaluate the share of firewaters generated during a large accident which is possible to collect by such means?
If firewaters are collected, can you describe if and how they are handled and treated, including an estimate of their effectiveness in preventing releases to the environment? (e.g. sent to wastewater treatment plant, use of activated carbon filters, use of PFAS precipitating agents, incineration in municipal domestic waste incinerators or in hazardous waste incinerators). Supporting justification for effectiveness estimates (e.g. monitoring studies, scientific papers) should be provided.
HiserL your reply riere
5. Possible improvements of risk management measures
On-land use of firefighting foams
If continued use of PFAS foams would be allowed for your sector if linked to appropriate risk management measures including e.g. :
the mandatory presence of waterproof bunded areas around the tanks/installations at fire risk able to retain all firewaters in case of a major fire accident or to direct them to a waterproof storage place;
the mandatory presence of waterproof storage places for all firewaters in case of a major fire accident (storage until adequate treatment of the firewaters is completed);
onsite or access to off-site treatment facilities for effective treatment / disposal of firefighting foam concentrates and
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firewaters using techniques that would minimise potential releases to the environment (e.g. high temperature incineration in hazardous wate incinerators);
what would be the necessary technical adaptations (e.g. enhanced waterproofing of bunded areas, installation of pumps or storage tanks for firewaters, installation of firewater pre-treatment devices, etc.), the associated costs, the implementation timeline and expected effectiveness? Please identify any appropriate risk management measures in addition to those identified above.
Please, specify if these adaptations would be technically and economically feasible for all or only for part of your sites?
Insert your reply herL
Off-shore use of firefighting foams
If continued use of PFAS foams would be allowed for your sector for a certain period of time if linked to appropriate risk management measures, what would be the possible improvement of these risk management measures to minimise the emission of PFAS in the environment? Can you describe what would be the necessary technical adaptations the associated costs, the implementation timeline and expected efficiency?
Insert your reply her
6. Transitional periods
The report made for EC-ECHA depicts different substitution potentials and possible transition periods towards fluorine-free foams for different sectors or types of uses (see pages 191-194). Do you have any comments on the impacts of different transitional periods? Could substitution to fluorine-free
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foams take place during the proposed periods?
Please describe if the situation is different for on-land and off-shore use of firefighting foams?
Insert your reply here
7. Techniques and costs for firewaters handling and site clean-up
If you have experience with both PFAS and fluorine-free foams, could you describe if there is a difference between these two in terms of procedures and costs in handling and treating the firewaters and in cleaning-up the site after the use of foams? "Clean-up" is defined here as the cleaning activities undertaken at a site shortly after firefighting foam has been used (as opposed to "remediation" which refers to the decontamination of historical pollution).
On-land use
PFAS foams
Description of the technique used for handling and treating firewaters
Firewaters treatment costs (per L or per foam use instances, please specify)
Average volume of firewaters generated by a foam use instance (L)
Description of the technique used for the site clean-up
Site clean-up costs (per tonne of foam concentrate used or per instance of foam use, please specify)
Average amount of foam concentrate used per foam use instance (tonnes)
Fluorine-fee foams
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8. Specific comments on EC-ECHA report
If you have specific comments on report made for EC-ECHA we invite you to send them, referring to the concerned paragraphs and substantiating your arguments with evidence.
Insert your reply here
Do you agree that ECHA contacts you for any follow-up questions on the topic of use of firefighting foams? (Tick box)
Yes u
No u
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