Document Rp2zeEbYvr7KrDb0z46NBnJ58
06/09/2023
FPG Responsible Manufacturing Programme for European Manufacturmg sites
Smce the 2021 adoption of the responsible manufacturing pnnciples, ail Fluoropolymer Products Group (FPG) members are engaged in concrte actions related to responsible fluoropolymer manufacturing practices
The undersigned members of the Fluoropolymer Products Group (FPG) hereby commit to an mdustry Responsible Manufacturing Programme for European Manufacturing sites The programme is compnsed of three pillars
1 A voluntary commitment to reduce non-polymenc PFAS missions from our fluoropolymer manufacturing,
2 A platform to promote the adoption of commercially available state of the art technologies to minimise non-polymenc PFAS missions in our manufacturing, and
3 A commitment to mform downstream users of fluoropolymers on their safe handlmg and use
1. Voluntary commitment on non-polymeric PFAS missions rduction
The voluntary commitment focuses on the mission rduction of non-polymenc PFAS Chemicals from European fluoropolymer manufacturing
The undersigned PE-FPG members commit for their European Fluoropolymer manufacturing sites to
Achieve the followmg Average Emission Factors of non-polymenc PFAS residues from polymrisation aid technology that is used m the fluoropolymer manufacturing process
o By end 2024 0 009% to air, 0 001% to water
o By end 2030 0 003% to air, 0 0006% to water
Average Emission Factors are calculated as follows (m percentage) Annual mission of non-polymenc PFAS residue from non-polymenc polymenzation aid technology [added or generated]//total annual amount of fluoropolymers produced on site 1
The achievementofthese Average Emission Factors is indpendant ofwhetherfluonnated, non-fluonnated or no polymenzation aids2 are bemg used m the production of fluoropolymers, at each of our sites
To continue mvestigatmg and developmg R&D programs for the advancement of technologies allowmg for the substitution of PFAS-based polymenzation aids dunng fluoropolymer production, and where proven techmcally feasible, environmentally sound,
1 Method of calculation of mission factor based on the Equation 1 Calculation of mission factors from Annex B of PFAS restriction proposai p 227 (Submitted restrictions under considration - ECHA (europa eult 2 Polymrisation aid is as defined m ECHA's PFAS restriction proposai Annex A "Polymrisation aid is the term used to descnbe a surfactant or emulsifier, fluonnated or non-fluonnated"
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meeting the performance and processmg requirements and viable at an industrial and commercial scale, to substitute the use of PFAS-based polymenzation aids
Recogmsmg the unique charactenstics of each manufactunng site, the signatones of this document also commit to mdividually cooperate with their National Competent Authonties regardmg non-polymeric PFAS missions to air and water from their European fluoropolymer manufactunng sites by the end of 2024
Contmuously improve understandmg of non-polymeric PFAS missions to air and water, that are not captured or destroyed, by use of targeted and non-targeted analytical techniques
2. State of the art technologies platform
In addition, we will launch a platform to promote the adoption of commercially available State of the art technologies in the followmg areas of our manufactunng
Contmuous improvement of nsk management measures to further improve industrial hygiene Controls for Chemicals used in the fluoropolymer manufactunng process
Management Techniques (e g management Systems) Techniques to minimise non-polymeric PFAS missions to air, mcludmg quantification and
management of fugitive missions (e g missions control of exhaust air, leaks from connections, ) Monitormg missions to air Techniques to minimise non-polymeric PFAS missions to water, mcludmg quantification and management of fugitive missions Momtonng missions to water Techniques to reduce, capture and re-use unconsumed raw matenals and waste Momtonng raw matenal consumption and waste gnration Momtonng and quantifymg the rduction, capture and re-use of unconsumed raw matenal and waste
Reflectmg the volution m commercially available state of the art technologies m missions control, the platform will work on an ongomg basis
It is up to each company to implement the technologies that it considers appropnate notably m light of the specificities and usages of their manufactunng process
3. Downstream users
We also commit to helping mform downstream users of fluoropolymers on their safe handlmg and use by providmg additional information on safe fluoropolymer processmg and prvention of environmental release m the Guide for the Safe Handlmg of Fluoropolymer Resms
Implmentation No later than the 31 December 2023, the members will approve a programme framework agreement to start the protected shanng of information among compames
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To report and momtorthe implmentation of the programme work, the programme participants shall mstitute an exchange forum with key stakeholders and legislators This exchange forum guarantees transparency, accountability and supervises the implmentation of the FPG Responsible Manufactunng Programme The exchange forum shall meet formally twice per year with a first meeting by September 2024
To ensure compliance with comptition law, each member of the programme shall remam indpendant in the way in which they implement the voluntary commitment and state-of-theart technologies m their own manufactunng process The information gathered from its members will be aggregated and anonymized in respect of comptition law