Document O3OVywK6NeOjVdBML8w954Zz1
PFAS & THE AUTOMOTIVE INDUSTRY
TOOLS, PROJECTS AND CHALLENGES
FPP4EU Collaboration Platform Workshop
12th December 2022
Timo Unger & Mathieu Ben Braham
THE COMPLEXITY OF SUPPLY CHAINS AND RESULTING BUSSINES IS STILL TOTALLY UNDERESTIMATED
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IMDS - A GLOBAL ONLINE TOOL
www.mdsystem.com
Anmeldung I Neu im IMDS? I IMDS Informationsseiten I IMDS Advanced Solutions
WILLKOMMEN IM INTERNATIONALEN
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Das IMDS (Internationales MaterialDatenSystem) ist das Materialdaten-System der Automobilindustrie. Es ist eine gemeinsame Entwicklung von Audi, BMW, Daimler, DXC, Ford, Opel, Porsche, VW und Volvo. Weitere Hersteller sind dem Verbund inzwischen beigetreten, wodurch sich IMDS zum globalen Standard entwickelt hat, der von fast allen global agierenden OEMs genutzt wird. Auerdem werden mit weiteren Herstellern Gesprche ber die Teilnahme im IMDS gefhrt. Im IMDS werden alle Werkstoffe, die bei der Herstellung von Autos verwendet werden, gesammelt, gepflegt, analysiert und archiviert. Durch die Nutzung des IMDS ist es mglich, die Verpflichtungen zu erfllen, die Automobilherstellern und deren Zulieferern durch nationale und internationale Standards, Gesetze und Regelungen entstehen.
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THE GENERAL PROCESS OF SUBSTANCE REPORTING IN THE AI
To protect CBI, Material Manufacturers are allowed to ,,hide" up to 10% of their recipe behind so called "Jokers", e.g. "Further Additives"
BUT:
If a substance is listed on GADSL (= prohibited or declarable), it must not be hidden behind a Joker but has to be uncovered / reported
No CBI Protection for GADSL Listed Substances
GADSL has to be absolutely correct to ensure CBI Protection and allow for proper compliance
IMDS - LESSONS LEARNED
Data Quality
It costs many Billions to develop, maintain and optimize the system Including data input around 16 Billion have been invested, since 2000 The increase of data quality is the result of an intensive cooperation between
vehicle manufacturers, their suppliers and the chem. industry
It took years to train the supply chain = get reliable data!
2018
IMDS - A
Oct. 22: 200,000 Active Users
TRULY GLOBAL
Oct. 22: 96 Mio Datasheets
SOLUTION
Oct. 22: 194,000 Active Companies
ONE OF THE MAJOR CHALLENGES...
ShinShout
IMDS Data Quality Checks
Data Input Quality: Acceptable
X years
Data Output Quality: Less Acceptable
... the update of existing data due to engineering changes on supplier side ... unintentional contaminants (e.g. PFAS, PAH, ...)
AUTOMOTIVE INDUSTRY - PFAS
Summary of our major challenges:
We dont know exactly where... We dont know exactly why... We dont know exactly by whom... We dont know exactly how many and how much... We dont know which essential... We dont know exactly which...
We = Automotive Industry as well as most other End-User Industries (EUIs)
...PFAS are used in our supply chain
But according to our current limited knowledge we understand,
that the PFAS restriction is a major threat to our European business
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HOW TO "WHICH": PFAS IDENTIFICATION
The current approach (under testing) to reduce PFAS only to the commercially relevant ones.
- Process not yet approved by the responsible committees - Discussion also including non-automotive associations (e.g. Aerospace and Defense)
Declaration threshold
- Intentionally added including any degradation byproducts of PFAS - Triggered by the "US Maine Requirements"
HOW TO FURTHER REDUCE THE NUMBER OF PFAS CAS#?
Focus on Fluorochemical Manufacturers & Commercially available PFAS
Globally 50 + chemical manufacturers of PFAS
What are the odds of 50+ global chemical manufacturers using 400010,000 CAS numbers?
Chemical Manufacturers claim only a low percentage of CAS# are used This is potentially credible!?
Study indicates that only 256 (5.4%) out of 4730 CAS# on OECD list were used commercially by three diversified fluorochemical manufacturers**
Actual CAS# not listed in published paper (may be intellectual property
concern for chemical manufacturers)
% Commercialized
How to further reduce number of relevant PFAS?
Buy-in from other sectors appreciated!
5%
Commercial
Non-Commercial
**Buck, R et al, "Identification and classification of commercially relevant per-
95%
and poly-fluoroalkyl substances (PFAS). Integr Environ Assess Manag. 2021
Sep. Retrieved on 2/4/2022 from https://pubmed.ncbi.nlm.nih.gov/33991049/
SUMMARY AND OUTLOOK ON PFAS IN IMDS
Current:
We will inform all >150,000 global suppliers about their duty to report PFAS > 25ppb per article
We have updated our Global Automotive Declarable Substance List (GADSL) with >2000 PFAS
Existing relevant data needs to be updated (hopefully)
Coming Next:
We may add a requirement for material manufacturers to actively confirm (checkbox) that their materials are within the legal thresholds Request to chemical industry and material manufacturers:
Which PFAS test procedures and methods are available to be referenced? Are you interested in participation in this discussion?
We have started with two external projects / studies...
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How to "where", to "by whom", to "why" & to "how much"?
Both CLEPA and ACEA are highly impacted by the coming PFAS restriction :
Many fluoropolymers and fluoroelastomers used in car and automotive devices - joints, o-ring, wire etc. F-gas used as refrigerant Short chain PFAS used in many products - lubricants, cleaning products, surface treatment etc.
ACEA and CLEPA commissionned Cetim, the French Technical Center for Mechanical Industry, on two studies to enhance their knowledge on PFAS and have relevant data to submit for the public consultation:
A socio-economic analysis of the replacement of R-1234yf A PFAS inventory on 5 selected automotive parts, focusing on short chain PFAS
The main objective of the study is to assess the presence (or not!) of short chain PFAS in the materials and manufacturing processes of the selected pieces :
Chassis : Shock Absorber, strut assembly Traction Battery : Battery Cell scrim binder Fuel Line : Fuel injector sleeve and O-ring MAC : Compressor bearing shaft, rotor, filter Harness wire cable
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Automotive supply chain study : PFAS inventory
For each parts :
Gathering suppliers contact information from CLEPA / ACEA members Conducting interviews with tier I suppliers, check their uses of PFAS, a questionnaire was developped with
ACEA Reach for tier II, III etc. suppliers to assess their uses
Try to establish which PFAS are used, why, the quantities, the exposure, etc... Data are collected and displayed anonymously
... Tier X supplier
Tier II supplier
Tier I supplier
Manufacturer
Still expecting feedbacks from suppliers
First results will be available in december Further results and feedbacks will be added once they are available to further strenghtened the study
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Automotive supply chain study : PFAS inventory
Quick results overview : case of the wire cable
ACEA established the use of FEP and PTFE in the cable 3 tier I suppliers contacted and interviewed
Thanks to 1 tier I supplier, 10 tier II suppliers responded, 16 expected to send some feedback soon Chemical companies responded to sollicitation and agreed for meetings
General feedback :
-Tier I suppliers are using fluoropolymers, no
Tier I
short chain PFAS in the processes
Manufacturer
Tier I
Tier I
x3
Tier II Tier II
x10
Chemists
x2
-Short chain PFAS used : 4,4'-[2,2,2-trifluoro-1-
(trifluoromethyl)ethylidene]diphenol ~1,8% in rubber seal -Other fluoropolymers identified : PVDF-HFP (rubber seal) Modified ETFE (corrugated tubes) MFA (corrugated tubes)
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Socio-economic analysis on replacement of R-1234yf in mobile air conditionning
Mobile air conditionning is mainly using R-1234yf as a refrigerant. It is identified as a PFAS and thus face a possible ban according to the definition given for the restriction proposal.
In Extenso Croissance Innovation (IEIC) has been commissionned to conduct a socio-economic analysis on the replacement of R-1234yf in MAC by alternative refrigerants, especially on R-744 The objective is to identify and structure relevant data on the challenges for the automotive industry suche as :
Substitution Impact on supply chain of R-1234yf replacement Assessment of health impact for substitutes Benefits/disadvantages for current technology and substitutes
A framework of the SEA was set-up to structure the data collected
Focus on R-744 scenario
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Socio-economic analysis on replacement of R-1234yf in mobile air conditionning
The study is structured in two main phases :
Analysis of available data and structuration of them Further analysis of relevant data and reports
General schedule
First phase done by September 2022 Health and environment reports deliver, commented
and in revision Economic, trade and social reports to be delivered in
the coming weeks
Refrigerant producers
Logistic of the refrigerant
Auto-parts manufacturers
Car manufacturers
Maintenance and repairs
Retail sales of auto-parts
Car users
Recycling of end-of-life vehicles
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Socio-economic analysis on replacement of R-1234yf in mobile air conditionning
During phase 2, IEIC managed to interview several key actors of the supply chain
16 interviews were conducted, including 3 auto-parts manufacturers
Preliminary results
R744 based systems are larger and not sufficient enough in hot weather
Incompatibility between curent R-1234yf system and alternatives based systems
Suppliers wouldn't be able to propose large-scale production of new systems on a mid-term schedule Impact on employment is limited if investments are made
Mainly R&D, retrain of the labor force, aftermarket service personnel difficulties of deployment in short period of time
EU car manufacturers already invested for last transition from R-134a : low benefits from their technological advance on this matter
Technological advance gains through this new regulation is not guaranty to turn into a competitive advance on foreign markets if the latters won't make the transition (example: R134a is still used in several areas)
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Difficulties and lessons
Data are not readily available, many scientific publications focus on health and environment impact
The whole supply chain for each industrial sector is affected, so they need to mobilize and share information
Many suppliers are not fully aware of the extent the PFAS restriction will have
There is a need to support your suppliers and customers Again, sharing data is a key point for such studies
Timing is very short, especially on such a broad family of substances
Industrial and professionnal association need to carry these studies ASAP, to have some hard data to provide for the public consultation
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