Document RajJOe1QNe4JabkRJva3GnxQB

Report summary transportation 1 Contents 1. Uses / Applications.............................................................................................................................. 3 2. Main PFAS substances ........................................................................................................................ 5 3. Manufacturing & Market price + market development ..................................................................... 6 4. Emissions............................................................................................................................................. 6 5. Exposure (workers, consumers).......................................................................................................... 6 6. Alternatives ......................................................................................................................................... 7 6.1. Sealing applications...................................................................................................................... 8 6.2. Combustion engine system.......................................................................................................... 8 6.3. Lubricants..................................................................................................................................... 8 6.4. Coating and finishings .................................................................................................................. 9 6.5. HVAC-systems in transport vehicles (see also the summary report for F-Gases) ..................... 10 6.6. Interiors......................................................................................................................................11 7. Economic impacts in case of a full PFAS ban .................................................................................... 13 8. References ........................................................................................................................................ 14 2 1. Uses / Applications Products and articles used in the transportation sector containing PFAS are very diverse. There are several large and small components which itself are already high-tech devices. A large amount of PFAS containing products are articles which are subjected to extreme conditions like exposure to seawater, heat, UV-radiation or aggressive chemicals. In other cases, PFAS in products are necessary for a defined performance like in fire fighting foams or as part of fuels and lubricants. The PFAS containing products and articles in the transportation sector are divided into subgroups. The subgroups should be applicable to the different sectors of transportation: automotive, shipping, aviation and railway. The subgroups are presented in table 1. Table 1: Uses and applications of PFAS in transportation products and articles Transportation - subgroup Examples Body-, hull-, and fuselage Industrial feedstock for body-, hull-, and fuselage construction; construction Surface tension modifiers in plating processes during the body-, hull-, or fuselage construction (minimizing the generation of chromium mists); Release film for mold components from the manufacture of plastic parts (e.g. PTFE, ETFE). Sealing applications Sealing applications with fluoroelastomers (e.g. PTFE) (60% or more of the fluoroelastomers produced are used in sealing applications in the transportation sector (information received by stakeholder). Combustion engine system Lubricants O-rings; Seals in valves and gaskets; Shaft or piston seals; Seals for electronic devices such as NOX- and oxygen sensors in the exhaust monitoring; Seals for battery electrodes in Li-Ion or dry cell batteries. Sealing and coating applications Non-woven textiles as cover in the engine bay area as acoustic insulation inside the vehicle engine compartment (treated with PFAS to achieve oil repellence and high temperature resistance i.e. make them non-flammable). Lubricants based on fluoroelastomers (e.g. PTFE, PFPE) are used in transportation vehicles, mainly to reduce friction in a wide range of applications and over a wide range of temperatures. Hydraulic fluids Electrical engineering and information technology Bearings; Chain guide in automotive engines; Bushings (e.g. engine mount bush, stabilizer bush); Fill-for-life lubricant in small gearboxes, actuators, or hydraulic cylinders (e.g. clutch systems); Electric & Thermal protection of connectors in electronic systems; Weather strips; Sunroof guiderail. Steering systems; Brake systems; Systems for lifting and lowering of vehicle parts or cargo. PFAS play an important role in all electrical engineering and information technology in the transportation sector as they are an integral part of the manufacturing processes for semiconductors and in some cases also of the semiconductor itself. 3 Transportation - subgroup Examples Computer-based systems e.g. control systems, telecommunication, safety systems; Data transmission: Optical Fibres from fluoropolymers are used for data transmission where electromagnetic interference is a concern. The fluoropolymer serves as a low refractive index layer (potentially growing use with regard to vehicles getting "smarter", self-driving cars etc.); Batteries: fluoroelastomer seals are used to protect electrodes from aggressive electrolytes and achieve corrosion inhibition. F-Gases are used in HVAC-systems to cool down/heat traction batteries of electric vehicles. Fluoroelastomers are used as coating for the separator film in Li-Ion batteries; Fuel cells: Perfluoropolymeric Sulfonyl Fluoride Ionomers act as a binder and proton conductor in the catalyst layers in fuel cells. PTFE is part of the gas diffusion layer and controls the hydrophobicity of the components, which in turn regulates the water management of a fuel cell; Lighting; Electric propulsion engines; Other electricity-based processes specific to the transportation sector (e.g. disinfection of ballast water using UV-radiation). Fire prevention and protection Coating and finishings No information is available to the dossier submitters. Mainly fluoroelastomers are used in the transportation sector for coating applications e.g. PTFE, ETFE, Perfluoroalkoxy alkane (PFA), or Fluoroethylene vinyl ether (FEVE) General: Coating applications in the transportation sector; Coating of cables in the Selective Catalytic Reduction system for diesel engines (ad blue); Coating of diesel and gasoline particle filter hoses; Turbo charger hoses and coolant lines, engine coolant lines and oil cooler lines; UV-stable coatings (e.g. paint protection for transportation vehicles for cosmetic and protective reasons e.g. FEVE is used as coating for car wrappings); Automobile Brightness Enhancement Film matte films to achieve good matte coating quality and optics and also other trim materials in transportation vehicles are coated with fluoroelastomers to achieve good optics; Coating of insulation materials to lower their thermal conductivity resulting in better insulating properties; Glass surface treatment with fluoroalkylsilanes for non-stick properties to achieve permanent water and stain repellence and thus improve the visibility for the vehicle operator in bad weather conditions; High abrasion resistance in windshield wipers or brake pads. HVACR-systems in transportation vehicles (see also F-Gases summary) Heating, ventilation, air conditioning and refrigeration (HVACR)-systems. Use of F-Gases in the various HVACR-systems in transport vehicles for passenger cabin air conditioning or transport refrigeration; Special heat transfer fluids (e.g. Methoxyheptafluoropropanes) for the immersion-cooling/heating of electronic equipment; Use as processing aids in the fluoropolymer production; Use as cleaning fluids; Use as blowing-agents. 4 Transportation - subgroup Interiors Health protection and lifesaving equipment Other uses related to transportation Examples Use of fluoroelastomers for the coating of trim materials of transportation vehicles to achieve stain protection and give surfaces a valuable feel and look; Use in the treatment of textiles e.g. for seats, carpets, roof linings, to give the textiles water and dirt repellent properties (for the treatment of textiles usually side-chain fluorinated polymers are applied). airbags seatbelts (?) life jackets (?) life raft Reflective and protective coatings for traffic signs / roads o Surface-treated pavement marking tapes and beaded retroreflective sheetings (used for driver and pedestrian safety); o ETFE Film is used as an anti-graffiti overlay for traffic signage; Adhesive tape as paint replacements (e.g. for marking of aircrafts) product provides a chemical resistant surface for the aircraft, as well as reduces the aircraft's surface energy; Flotation fluids in gyroscopes (mainly used in aircrafts ("artificial horizon") but also in trains (inclination sensors), and road vehicles (Navigation system and control systems); Wheel weights: AFT (Acrylic Foam Tape; PFAS are used as stabilizing agent in production of tape) layer is used to affix the weight to the wheel surface. A fluoropolymer incorporated into in the weight provides weatherability and reduces the potential of the weight to corrode. 2. Main PFAS substances Substance information in table 2 is based on information collected in the Call for Evidence (CfE), via stakeholder disclosure and via publicly available information. Table 2: PFAS substance used in tranportation products and articles Group/substance EU market for transport (Tpa) Fluoroelastomers e.g. Unknown PTFE ETFE PFPE Perfluoroalkoxy alkane (PFA) Fluoroethylene vinyl ether (FEVE) Perfluoropolymeric Sulfonyl Fluoride Unknown Ionomers Fluoroalkylsilanes Unknown F-Gases R1234yf (Tetrafluorpropen) R134a (Tetrafluorethan) R-407C (blend of R-32 (difluoromethane), R-125 (pentafluoroethane), and 1,1,1,2tetrafluoroethane) Methoxyheptafluoropropanes Unknown Unknown C6SFP Unknown Source Information gathered by the dossier submitter Information gathered by the dossier submitter Information gathered by the dossier submitter Stakeholder disclosure and publicly available information (e.g. web pages of HVACR-system manufacturers). Information gathered by the dossier submitter Information gathered by the dossier submitter 5 3. Manufacturing & Market price + market development No information on manufacturing or market development and very little information on market prices is available to the dossier submitters. It is reported that the production of fluorine containing materials usually is more expensive compared to most other materials (e.g. PE 1/kg and PTFE 12.75 /kg, information received from stakeholder). 4. Emissions Limited information is available to the dossier submitter on the emission of PFAS from transport products and articles. The reported information for HVACR-systems is summarized in table 3. For more details please see the F-Gases summary report. Table 3: Emission information for PFAS substances used in transportation products and articles Subgroup Emission information HVACR-systems 9,000 t F-Gases to air# Source Stakeholder information in https://www.acea.be/statistics/tag/category/report- transportation vehicles-in-use vehicles (F- Gases) HVACR-systems 495,8 t/a F-Gases to air## Information gathered by the dossier submitter on F-Gases for transport refrigeration # Based on amounts of PFAS in HVACR-systems (ca. 0.6 kg/personal vehicle, ca. 1 kg / unit per truck and ca. 6 kg / unit per bus) and taking into account the total number of registered passenger cars (242,727,242), trucks (sum of light and heavy commercial vehicles: 34,340,233) and busses (692,207) in the EU (ACEA 2019) it can be assumed that a total amount of approx. 180,000 t of F-Gases are used in HVAC-systems for passenger comfort in road traffic. Assuming an emission of 5 % to air (ERC 9b Widespread use of functional fluid (outdoor), ECHA 2015), leads to an estimated total emission of 9,000 t/a of F-Gases from HVAC systems for passenger comfort in road traffic. ## The amount of F-Gases used in refrigeration transport are estimated as follows: 1,010 t/a filled into newly manufactured products and 9,916 t in operating systems. Following the same assumption as for the HVACR-systems for passenger comfort a total emission of 495,8 t/a of F-Gases from transport refrigeration is assumed (considering only the amount from operating systems). 5. Exposure (workers, consumers) Limited information is available to the dossier submitter on the PFAS concentrations and therefore also on the exposure to PFAS in transport products. The reported information on the concentration of PFAS substances or total amount used in road vehicles transportation products and articles is summarized in table 4. 6 Table 4: Information on the concentration of PFAS substances or total amount used in road vehicles transportation products and articles Subgroup PFAS concentration Source information / amount used Lubricants 0.1 - 0.2 g per component Information gathered by the dossier submitter Concentration of fluoroelastomer in greases: 1 - 15% Concentration in lubricating fluids: 50 - 100% HVACR-systems Ca. 0.6 kg / personal vehicle Stakeholder information in transportation vehicles (FGases) Ca 1 kg / Unit per truck Ca 6 kg / Unit per bus Total use: 180,000 t F-Gases# https://www.acea.be/statistics/tag/category/reportvehicles-in-use HVACR-systems Total use: 10,926 t F-Gases## Information gathered by the dossier submitter on F- for transport Gases refrigeration Sealing 111,104 t Fluoroelastomers# Feedback member states applications Stakeholder information https://www.acea.be/statistics/tag/category/report- vehicles-in-use # Taking into account the total number of registered passenger cars (242,727,242), trucks (sum of light and heavy commercial vehicles: 34,340,233) and busses (692,207) in the EU (ACEA 2019). For, ships trains and aircrafts no information on the amounts of F-Gases/fluoroelastomers used for HVACR-systems of passenger cabins/sealing applications was provided during the CfE. ## The amount of F-Gases used in refrigeration transport are estimated as follows: 1,010 t/a filled into newly manufactured products and 9,916 t in operating systems. 6. Alternatives The manufacturers of transportation vehicles usually do not prescribe the use of individual substances to their suppliers but rather stipulate performance requirements the individual parts have to meet. Performance requirements are laid down for example in industrial standards (e.g. DIN, EN, ISO), individual company standards, but may also be dictated by legal frameworks (e.g. Regulation (EU) 2018/858 or 2013/168). In an economically driven and competitive sector, such as the manufacture of transportation vehicles, suppliers are incited to provide the most cost effective solutions that still meet the performance requirements. Since the production of fluorine containing materials usually is more expensive compared to most other materials (e.g. PE 1/kg and PTFE 12.75 /kg, information received from stakeholder) it could be assumed that fluorinated materials are used only where performance requirements leave no other option. Information on alternatives is virtually non-existent. Information on alternatives is only available for a few subgroups to the dossier submitter. The subgroups with reported description of use and reported alternatives are presented below. The reported alternatives are subsequently summarized in table 5. 7 6.1. Sealing applications Description of the use of the restricted substances: Fluoroelastomers are used in sealing applications due to the following properties: durability against lubricants, fuels, diesel, cooling agents and/or other fluids good performance over wide range of temperatures good sealing properties (avoidance of permeation, impermeability to gasses) Function: protect from dust and aggressive chemicals (lubricants, fuels, diesel). Ensure functionality, reduce service intervals prevent leakage (Emission reduction) 6.2. Combustion engine system Description of the use of the restricted substances: In the core engine as well as in the exhaust system conditions regarding heat and pressure are extreme. Above that, petrol-based fuels and, partially also exhaust gases are aggressive and corrosive chemicals. So, the fuel system with storage tanks and fuel pipes as well as seals and valves have to be protected from destruction by fuels. PFAS containing materials are robust materials which are resistant against heat, pressure and corrosive chemicals. Further, these materials are much lighter than e.g. using metal-based materials. Therefore, these materials are used in large quantities in combustion engine systems. The main use of PFAS containing materials in combustion engines are in sealing and coating applications (see other sections in this summary report). Non-woven textiles are applied as cover in the engine bay area of many vehicles as acoustic insulation inside the vehicle engine compartment. They are treated with PFAS to achieve oil repellence and high temperature resistance i.e. make them non-flammable. Alternatives: Lines and hoses: Alternative construction with Nylon fails to fulfil the emission requirements, and all-metal fuel lines did not meet crash test standards (information received from stakeholder). 6.3. Lubricants Description of the use of the restricted substances: Reducing friction over a wide range of temperatures Offer extended lifetime performance in particular at elevated temperatures Combustion prevention at contact points Reduce or avoid the need for lubrication of the finished components Good material compatibility to elastomer, plastics Alternatives: No information on alternatives regarding transportation applications was provided so far 8 6.4. Coating and finishings Description of the use of the restricted substances: Fluoroelastomers are used in coating applications in the transportation sector because of their good performance over a wide range of temperatures (anti crack resistance), abrasion resistance, fire resistance and resistance to aggressive chemicals. In some special coating applications fluoroelastomers are used due to their dielectric properties, low thermal conductivity, non-stick properties and UV-stability. As coating of cables in the Selective Catalytic Reduction (SCR) system for diesel engines (ad blue) or coating of diesel and gasoline particle filter hoses fluoroelastomers also function as part of the emission reduction systems. Examples for coatings to achieve heat resistance, and resistance to aggressive chemicals are turbo charger hoses and coolant lines, engine coolant lines, or oil cooler lines. UV-stable coatings are used for example as paint protection for transportation vehicles for cosmetic and protective reasons e.g. FEVE is used as coating for car wrappings. Similarly, fluoroelastomer coatings are used as automobile Brightness Enhancement Film (BEF) matte films to achieve good matte coating quality and optics and also other trim materials in transportation vehicles are coated with fluoroelastomers to achieve good optics. Insulation materials are coated with fluoroelastomers to lower their thermal conductivity resulting in better insulating properties. For non-stick properties glass surfaces are treated with fluoroalkylsilanes to achieve permanent water and stain repellence and thus improve the visibility for the vehicle operator in bad weather conditions. The fluoroalkylsilanes form a chemical bond with the glass surface while the perfluorinated alkylchain provides the water and stain repellence. An example for coatings to achieve high abrasion resistance are windshield wipers or brake pads. According to stakeholder information fluoroelastomers provide better brake efficiency and help absorb pressure compared to non-fluorinated brake pad coatings. Alternatives: There are some fluorine free materials available which can be used to achieve a protective coating Silicone based chemicals Sulfosuccinates Propylated aromatics Fatty alcohol polyglycol ether sulphates Alkyl acrylates Polyurethanes and -acrylics o A disadvantage is their higher layer thickness and that they cant be used for applications with high temperatures because of cracking (information received from stakeholder). 9 6.5. HVAC-systems in transport vehicles (see also the summary report for F-Gases) Description of the use of the restricted substances: F-Gases are commonly used as heat-exchange media in HVAC-systems of transport vehicles due to their following properties: Good thermal capacity Wide range of operating temperatures Low-/Non-flammable Lower global warming potential (GWP) and toxicity than chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs) Zero ozone depletion Chemical inertness Non-corrosivity For the immersion-cooling/heating of electronic equipment the dielectric properties of the heat exchange medium are of high relevance. For such applications special heat transfer fluids are used (e.g. Methoxyheptafluoropropanes). Alternatives: A discussion on the alternatives to F-Gases as heat transfer media is provided in the separate summary report on F-Gases. This includes also alternatives for vehicle air-conditioning, transport refrigeration and electronics cooling. Thus, only a brief overview over the available alternatives and possible advantages and disadvantages will be given here: The following non-PFAS heat transfer agents are available for the uses described above: Air Water Ethylene glycol Mineral oils Silicone oils Alcohols Natural gases: HC-600 (n-butane), R-717 (Ammonia), R-744 (CO2) Non-PFAS heat transfer agents can have one of the following disadvantages (According to stakeholder information): Electrically conductive Create corrosion More energy necessary to reach low temperatures Flammable and/or explosive Higher levels of toxicity Higher global warming potential (GWP) levels Not thermally stable High working pressure Water reactive Require periodic replacement and need to be disposed of However, there are also some advantages associated with the use of non-PFAS alternatives, especially regarding the use of "natural" alternatives i.e. air, water, CO2 etc. They are widely available, cheap, have no or only a low GWP and are easier to handle during service and end of life. Modern HVACsolutions with natural alternatives may even be more energy-efficient than the use of F-Gases. An aircycle system for a train HVAC-system was reported to render up to 28 % of annual energy savings 10 compared to R-134a systems (UBA, 2019). Another UBA report shows, that the use of R-744 instead of R134a can reduce the fuel consumption of a passenger car HVAC-system from 14-54 %, depending on the ambient temperature (UBA, 2009). 6.6. Interiors Description of the use of the restricted substances: Car seat fabrics are treated with C6SFP to achieve stain protection. Fluoroelastomers are used for coated trim materials Alternatives: For car seat treatment: see summary report of Textiles. In general protection from grease and oil cannot be achieved on the same level as provided by treatment with C6SFPs. Some alternatives provide good water protection. Fluoroelastomers are used for coated trim materials: there are no alternatives to fluoroelastomers that provide an equivalent level of performance. However, it is questionable if the high level of performance provided by fluoroelastomers is necessary for the coating of trim materials. Table 5: reported alternatives for PFAS substances used in transportation products and articles Sub use Non PFAS Function Advantage / disadvantage alternative? Combustion Nylon Nylon fails to fulfil the emission engine system requirements (lines and hoses) All-metal fuel lines All-metal fuel lines did not meet crash test standards (information received from stakeholder). Coating and Silicone based Protective coating finishings chemicals Sulfosuccinates Propylated aromatics Fatty alcohol polyglycol ether sulphates Alkyl acrylates Polyurethanes and -acrylics A disadvantage is their higher layer thickness and that they cant be used for applications with high temperatures because of cracking (information received from stakeholder). 11 Sub use HVAC-systems in transport vehicles Non PFAS alternative? Air Water Ethylene glycol Mineral oils Silicone oils Alcohols Natural gases: HC-600 (nbutane), R-717 (Ammonia), R744 (CO2) Interiors Function Advantage / disadvantage Heat transfer agent Disadvantages: Non-PFAS heat transfer agents can have one of the following disadvantages (According to stakeholder information): Electrically conductive Create corrosion More energy necessary to reach low temperatures Flammable and/or explosive Higher levels of toxicity Higher global warming potential (GWP) levels Not thermally stable High working pressure Water reactive Require periodic replacement and need to be disposed of Stain protection Advantages: Air, water, CO2 etc. are widely available, cheap, have non-low GWP and are easier to handle during service and end of life. Modern HVAC-solutions with natural alternatives may even be more energy-efficient than the use of F-Gases. General: protection from grease and oil cannot be achieved on the same level as provided by treatment with C6SFPs. Some alternatives provide good water protection. Fluoroelastomers are used for coated trim materials: there are no alternatives to fluoroelastomers that provide an equivalent level of performance. 12 7. Economic impacts in case of a full PFAS ban The economic impact assessment is still in the beginning stages. Information on use quantities is partly available for the automotive industry. Table 6: Summary table on uses, tonnage, indicative trend and alternatives Emission Subuses Indicative trend (tonnes (incomplete) Tonnages/y (--/-/0/+/++) PFAS) Non PFAS alternative available? General Numbers stated below only refer to road vehicles (cars, trucks, busses) Body-, hull-, and fuselage ? construction SEALING APPLICATIONS Lubrication ? HYDRAULIC ? FLUIDS electrical engineering and ? information technology Coatings and finishing (Incl. Interiors and related ? applications e.g. coating of road signs) HVACR-Systems 111,104 184,130 Unknown Unknown Yes, at least partly. For coatings and finishings: Silicone based chemicals Sulfosuccinates Propylated aromatics Fatty alcohol polyglycol ether sulphates Alkyl acrylates Polyurethanes and -acrylics For HVAC systems: Air, Water, -Ethylene glycol, Mineral Oils, Silicone Oils, Alcohols, naturals gases e.g. HC-600 (n-butane), R-717 (Ammonia), R-744 (CO2) Health protection and lifesaving ? equipment (incl. fire prevention and firefighting) In general: research is still going on. There is quite some information on cars (and other road vehicles), much less on trains, ships and aircrafts 13 8. References ECHA (2015): ECHA Guidance on Information Requirements and Chemical Safety Assessment Chapter R.12 Version 3.0. UBA Hintergrundpapier (2009): Natural refrigerants - CO2-based air conditioning system put to practical testing. Retrieved from: https://www.umweltbundesamt.de/publikationen/naturalrefrigerants-co2-based-air-conditioning UBA (2019): UBA texte 120/2019 Environmentally friendly air conditioning for trains - Field data measurement and analysis on the ICE 3 air-cycle system. 14