Document RpNZ0VjoGYyGqDN2evj3wNGm8

ENV/JM/MONO(2005)1 Unclassified Unclassified AR226-1937 Organisation de Coopration et de Dveloppement Economiques Organisation for Economic Co-operation and Development ENV/JM/MONO(2005)1 13-Jan-2005 E nglish - Or. English ENVIRONMENT DIRECTORATE JOINT M EETIN G OF THE CHEM ICALS COM M ITTEE AND THE W O RK ING PARTY ON CHEM ICALS, PESTICIDES AND BIOTECHNOLOGY RESULTS OF SURVEY ON PRO DUCTIO N AND USE OF PFO S, PFAS AND PFO A, RELATED SUBSTANCES AND PRO DUCTS/ M IXTURES CO NTAINING THESE SUBSTANCES S er oI J T 0 0 1 7 6 8 8 5 H CSTQ3^ Document complet disponible sur OLIS dans son form at d 'origine Complete document available on OLIS in its original form at ENV/JM/MONO(2005) 1 OECD Environment, Health and Safety Publications Series on Risk Management No. 19 RESULTS OF SURVEY ON PRODUCTION AND USE OF PFOS, PFAS AND PFOA, RELATED SUBSTANCES AND PRODUCTS/ MIXTURES CONTAINING THESE SUBSTANCES Environment Directorate ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT Paris 2004 2 ENV/JM/MONO(2005) 1 Other Environment, Health and Safety publications related to Risk Management include: Risk Reduction Monograph No. 1: Lead. Background and National Experience with Reducing Risk (1993) Risk Reduction Monograph No. 2: Methylene Chloride. Background and National Experience with Reducing Risk (1994) Risk Reduction Monograph No. 3: Selected Brominated Flame Retardants. Background and National Experience with Reducing Risk (1994) Risk Reduction Monograph No. 4: Mercury. Background and National Experience with Reducing Risk (1994) Risk Reduction Monograph No. 5: Cadmium. Background and National Experience with Reducing Risk (1994) OECD Proceedings: Sources o f Cadmium in the Environment (1996) OECD Proceedings : Fertilizers as a Source o f Cadmium (1996) Risk Management Series No. 6: Methylene Chloride Information Exchange Programme: Survey Results (1996) Risk Management Series No. 7: Proceedings o f the OECD Workshop on Non-Regulatory Initiatives fo r Chemical Risk Management (1997) Risk Management Series No. 8: Proceedings o f the OECD Workshop on the Effective Recycling o f Nickel-Cadmium Batteries, Lyon, France, 23-25 September 1997 (1999) Risk Management Series No. 9: Proceedings o f the OECD Workshop on the Integration o fSocio Economic Analysis in Chemical Risk Management Decision-making, London, 7-9 January, 1998 (1999) Risk Management Series No. 10: Proceedings o f the OECD Workshop on Sustainable Chemistry, Venice, 15-17 October 1998 (1999) Risk Management Series No. 11: Guidance fo r Conducting Retrospective Studies on Socio-Economic Analysis (1999) Risk Management Series No. 12: Lead Risk Management Activities in OECD Countries from 1993 to 1998 (2000) Risk Management Series No. 13: Frameworkfo r Integrating Socio-Economic Analysis in Chemical Risk Management Decision Making (2000) Risk Management Series No. 14: Technical Guidance Document on the Use o f Socio-Economic Analysis in Chemical Risk Management Decision Making (2002) Risk Management Series No. 15: Needfo r Research and Development Programmes in Sustainable Chemistry (2002) Risk Management Series No. 16: OECD Guidance Document on Risk Communication fo r Chemical Risk Management 3 ENV/JM/MONO(2005) 1 Risk Management Series No. 17: Strategies in the Chemicals Industry and Related Areas; Vienna, Austria, 13-14 November 2003,Part I and Part II: Summary and Conclusions Risk Management Series No.18: Workshop on Exchanging Information Across a Chemical Product Chain, Stockholm, Sweden, 15-16 June 2004 OECD 2005 Applicationsfor permission to reproduce or translate all or part of this material should be made to: Head ofPublications Service, OECD, 2 rue Andr-Pascal, 75775 Paris Cedex 16, France 4 ENV/JM/MONO(2005) 1 About the OECD The Organisation for Economic Co-operation and Development (OECD) is an intergovernmental organisation in which representatives o f 30 industrialised countries in North America, Europe and the Asia and Pacific region, as well as the European Commission, meet to co-ordinate and harmonise policies, discuss issues o f mutual concern, and work together to respond to international problems. Most o f the OECD's work is carried out by more than 200 specialised committees and working groups composed of member country delegates. Observers from several countries with special status at the OECD, and from interested international organisations, attend many o f the OECD's workshops and other meetings. Committees and working groups are served by the OECD Secretariat, located in Paris, France, which is organised into directorates and divisions. The Environment, Health and Safety Division publishes free-of-charge documents in nine different series: Testing and Assessment; Good Laboratory Practice and Compliance Monitoring; Pesticides and Biocides; Risk Management; Harmonisation of Regulatory Oversight in Biotechnology; Safety of Novel Foods and Feeds; Chemical Accidents; Pollutant Release and Transfer Registers; and Emission Scenario Documents. More information about the Environment, Health and Safety Programme and EHS publications is available on the OECD's W orld Wide W eb site (h ttp ://w w w .o e c d .o rg /e h s/). This publication was produced within theframework o f the Inter-Organisation Programmefor the Sound Management of Chemicals (IOMC). The Inter-Organisation Programme for the Sound Management of Chemicals (IOMC) was established in 1995 following recommendations made by the 1992 UN Conference on Environment and Development to strengthen co-operation and increase international co ordination in the field of chemical safety. The participating organisations are FAO, ILO, OECD, UNEP, UNIDO, UNITAR and WHO. The World Bank and UNDP are observers. The purpose of the IOMC is to promote co-ordination of the policies and activities pursued by the Participating Organisations, jointly or separately, to achieve the sound management of chemicals in relation to human health and the environment. 5 ENV/JM/MONO(2005) 1 This publication is available electronically, at no charge. For this and many other Environment, Health and Safety publications, consult the OECD's World Wide Web site (www.oecd.org/ehs/) or contact: OECD Environment Directorate, Environment, Health and Safety Division 2 rue Andr-Pascal 75775 Paris Cedex 16 France Fax: (33-1) 45 24 16 75 E-mail: ehscont@oecd.org 6 ENV/JM/MONO(2005) 1 This document presents the results of the survey of production and use information on Perfluorooctane Sulfonate (PFOS), Perfluoroalkyl Sulfonate (PFAS), Perfluorooctanoic Acid (PFOA), related substances and products/mixtures containing these substances. The document was prepared by Australia on the basis o f the responses received by 10th September 2004. The responses received after this date as well as a compilation o f detailed responses are included in the annex. The Chemicals Committee and the Working Party on Chemicals, Pesticides and Biotechnology at its 37th Joint Meeting endorsed the document and recommended that it be declassified under the authority o f the Secretary General, with the following caveat: The survey on production/importation and use o f Perfluorooctane sulfonate (PFOS), other Perfluoroalkyl sulfonates (PFAS), Perfluorooctanoic acid (PFOA), related substances and products/mixtures containing these substances is an initial step in the collection o f information on these chemicals. The information collated is not exhaustive and all potential exposure sources may not have been captured due to a number o f limitations including those coming from the constraint o f confidential business information and difficulties in capturing "related chemicals " such as polymers and products/mixtures. Furthermore, there was no attempt to reconcile all the data. However, the information will be useful fo r countries wishing to assess and manage the risks arising from these chemicals. An OECD hazard assessment is available fo r PFOS and its salts, not yetfo r PFOA. 7 ENV/JM/MONO(2005) 1 INTRODUCTION This paper is a summary o f responses to a questionnaire sent to OECD member countries requesting information on the production and use o f perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA) and perfluoroalkyl sulphonates (PFAS chemicals) and products/mixtures containing these chemicals. PFOS is a fully fluorinated, eight carbon chain length organic compound. PFOS-related/PFOS based substances may be simple salts o f PFOS, e.g., potassium, lithium, ammonium, diethanolamine, potassium, or polymers that contain PFOS as only a portion of the entire polymer. PFOA is a fully fluorinated eight-carbon chain carboxylic acid (CAS Registry Number 335-67-1). PFOA-related substances may be simple salts of PFOA, e.g., sodium, potassium, silver, or ammonium, or polymers that contain PFOA as only a portion o f the entire polymer. PFOA-related substances may also be construed to include certain fluorinated telomers, which may produce PFOA as a metabolite or degradation product. PFAS is a generic term used to describe any fully fluorinated carbon chain length sulfonate, and includes higher and lower homologues as well as PFOS. PFAS-related substances may be simple salts or polymers that contain the PFAS as only a portion of the entire polymer. BACKGROUND The 34th Joint Meeting (5-8 November, 2002) endorsed a draft assessment o f PFOS and its salts by the United States (US) and the United Kingdom (UK). The Hazard Assessment concludes that PFOS and its salts are persistent, bioaccumulative and toxic to mammalian species. At the 35th Joint Meeting (11-13 June, 2003), Australia confirmed that it would take the lead for PFOS-related activity and draft a questionnaire for circulation to OECD member and non-member countries. A preliminary draft Hazard Assessment of PFOA released by the US EPA in August 2002, found that PFOA and its salts are o f similar concern due to structural analogy with PFOS. Consequently, as a result of the health and environmental concerns for this class o f chemicals, the most recent 36th Joint Meeting (4-6 February, 2004) endorsed the collection of data on PFOA as well as other fully fluorinated carbon chain length sulphonate chemicals (known generically as perfluoroalkyl sulphonates or PFAS), in addition to PFOS. At the 36th Joint Meeting, Canada, Japan, US and Switzerland agreed to comment on the draft questionnaire. The draft circulated questionnaire was revised according to constructive comments received by the OECD Secretariat from these member countries. The questionnaire was also forwarded to OECD non-member countries through the Rotterdam Convention Secretariat. At the time of preparation of this paper, no responses were received from non member countries. 8 ENV/JM/MONO(2005) 1 Survey Responses Responses were received from 10 OECD countries - Australia, Belgium, Finland, Hungary, Italy, Japan, Poland, United Kingdom, Sweden and the United States o f America. The European Chemicals Bureau (ECB) of the European Commission also provided information on these chemicals from their IUCLID database. Data provided in most surveys were limited. In responses from several countries, volume and use data were deemed unsuitable for disclosure due to confidentiality of business information or regulatory restrictions. For several responses, importation could not be distinguished from manufacture. In these cases, data could only be compiled on the total trade of chemicals or products. In other cases, individual PFOS, PFOA or PFAS chemicals or even raw chemicals and products containing these chemicals were not distinguished. One survey response included separate information from one company. Data were provided for year 2003 unless indicated otherwise. PFOS Importation of Individual Chemicals The survey indicates the importation of PFOS and related chemicals by few countries and involving only small amounts of chemicals. A single country indicated importation o f approximately 0.5 tonnes/year of PFOS or related raw chemicals. Another single country indicated the possibility o f importation o f small amounts o f PFOS or related raw chemicals but no data were provided. Manufacture of Individual Chemicals Similar to importation, the survey indicates the manufacture of PFOS and related chemicals by few countries. The total volume is imprecise. Two individual responding countries indicated manufacture of a total of 3 PFOS-related raw chemicals. In the first, the total volume o f manufacture o f 2 chemicals was less than 20 tonnes. The second indicated manufacture o f a single PFOS-related raw chemical at not more than 100 tonnes/year, but the exact volume could not be disclosed. One country indicated that all production o f PFOS ceased in 2002. For Europe, the ECB noted 10 PFOS-related raw chemicals in trade (imported and/or manufactured) since 1996 or 2000 each in volumes less than 1000 tonne/year. Importation/Manufacture of Products/Mixtures Products containing PFOS and related chemicals are still imported and/or manufactured in the OECD. The total volume o f PFOS and related chemicals reported in these products is imprecise but is likely to be at least 30 tonnes/year. In many cases, importation was not distinguished from manufacture and so the information provided could only reflect a total trade in these chemicals. Also, volume data were often missing or imprecise and, in all cases, product names were deemed confidential business information and not disclosed. 9 ENV/JM/MONO(2005) 1 It is important to note that PFOS and related chemicals may not always be listed on MSDS for products/mixtures. Therefore, importers may not be aware of the presence of PFOS and related chemicals within products/mixtures and so these products/mixtures may not always be reported. A total of 4 countries indicated importation and/or manufacture of products/mixtures containing at least 4 different PFOS-related chemicals. One o f these countries indicated a total trade of approximately 10 tonnes/year o f products containing at least 3 PFOS and related chemicals. Unfortunately, in this case, the proportion o f chemicals in the products was not provided and so the volume o f chemicals could not be calculated. Another country recorded approximately 175 kg o f chemical importation. Another recorded a total of approximately 3 tonnes of product-related combined PFOS/PFAS importation. One country indicated a combined volume of trade (importation and/or manufacture) of approximately 20 tonnes/year of PFOS or related chemicals in products. One country included separate data from a single company that indicated trade (importation and/or manufacture) o f products containing a total o f approximately 10 tonnes/year o f chemicals for the year 2002. However, the company indicated that these chemicals were phased out in December, 2002. General Uses of Individual Chemicals or Products/Mixtures Survey responses indicated the use o f PFOS or related raw chemicals in industrial processes only. No domestic uses for the raw chemicals were noted. The processes identified were metal plating and electronic etching operations, semiconductors, metal coatings, in wax or other polishing agents, cleaning agents, in sealants or as a chemical intermediate. Chemicals were present in products in proportions ranging from 0.001% - 50%. For uses in electronic etching or metal plating, PFOS or related chemicals were noted as present at 5% - 25%. For Europe, the IUCLID database contained the following industry sectors associated with PFOS and related chemicals: chemical and polymers industries, metal extraction, refining and processing, paint, lacquers and varnishes industry, paper pulp and board industry, textile industry and other non-specified industries. Uses for PFOS and related chemicals reported for Europe were as fixing agents, flame retardants and fire preventing agents, foaming agents, impregnation agents, solvents, intermediates and other non specified uses. A recent risk reduction strategy report for PFOS published recently in the United Kingdom and posted on the OECD website confirms current uses in the EU in metal plating, fire fighting foams, the photographic industry, in semiconductor photolithography and aviation hydraulic fluids. The report also provides the following specific volume data for the EU: Table 1. Estimated Current Use of PFOS Related Chemicals in the EU Metal Plating 10 tonnes/year Photographic Industry 1 tonne/year Semiconductor Industry 0.5 tonnes/year Aviation Industry (hydraulic fluids) 0.73 tonnes/year Fire Fighting Foams 122 tonnes/year 10 ENV/JM/MONO(2005) 1 Essential Uses The essential uses reported by individual countries for PFOS and related chemicals are as ingredients in fire fighting foams (Class B fires), aircraft hydraulic fluids, chromium plating (mist suppressants), anti-reflective or photoresist agents in semiconductor photolithography and anti-static, surfactant or adhesion control agents in photographic processes. The UK PFOS risk reduction strategy report notes several essential uses in the photographic and photolithographic (semiconductor) industries. New Uses No new uses were reported. Replacement Chemicals and Processes Three countries indicated the use of replacements for PFOS and related chemicals. The first indicated that although specific identities for replacements or substitutes are regarded as confidential business information, other perfluoroalkyl sulfonates and various fluorinated telomers are noted as substitutes for PFOS and related chemicals. One country indicated the use of non-PFOS fluorosurfactants, silicon and hydrocarbon based surfactants and other fluorine free components as substitutes in fire-fighting foams. Company data included in the submission from another country noted the existence o f several commercialised substitutes for fluoropolymers, for agents for the protective treatment o f carpet, textiles and leather and chemical surfactants. One technology utilises perfluorobutane sulfonate as a C4 building block compound providing PFOS substitutes with reported lower toxicity and bioaccumulation potential. The following additional detailed information was available from the UK PFOS risk reduction strategy report. The UK PFOS risk reduction strategy notes that PFOS based substances are no longer used in the manufacture o f fire fighting foams. Telomer and fluorine free alternatives are available. The current use of PFOS is associated with unused foam stocks. A submission from an individual company confirms that the use o f PFOS and related chemicals in fire fighting foams and in industrial moulded goods was phased out in December 2002. In metal plating, alternative processes (eg. use o f Cr (III) in place o f Cr (VI)) are available that restrict the requirement for PFOS. However, previous industry and regulator led initiatives to promote a shift to Cr (III) technology in this industry have apparently had limited effectiveness. In the photographic industry, telomers have replaced PFOS based chemicals in some applications. However, a subset o f critical applications exists for which no alternatives have yet been found. In semiconductor photolithography, PFOS substitutes are available for some applications (details not known) but important applications still exist for which no alternatives are yet established. There are currently no alternatives to the use o f PFOS in aviation hydraulic fluids. Moreover, the development o f new aviation technologies is associated with long review, testing and approval timeframes. 11 ENV/JM/MONO(2005) 1 PFAS Importation of Individual Chemicals The survey noted the importation of PFAS and related chemicals by only one country: a single PFAS and related chemical was imported in volumes less than 1 kg/year. Manufacture of Individual Chemicals Another single country indicated manufacture o f 4 PFAS and related raw chemicals with a total volume o f manufacture o f approximately 7 tonnes/year. For Europe, the ECB noted 6 PFAS and related raw chemicals imported and/or manufactured each in volumes less than 1 000 tonne/year. Importation/Manufacture of Products/Mixtures The survey notes responses from 3 countries indicating importation and/or manufacture of products containing PFAS and related chemicals. The total volume of chemicals in trade (combined importation/manufacture) totalled at least 500 tonnes/year. One country indicated importation only of 3 products with a total product volume of less than 6 tonnes. The number of chemicals and their proportion in the products was not provided and therefore the total volume of chemicals could not be calculated. The second country indicated trade (combined importation/manufacture) o f 3 PFAS and related chemicals in a total product volume o f 38 tonnes/year, representing a total volume o f PFAS and related chemicals o f less than 9.5 kg/year. Company data included in the submission from the third country indicated a total trade (combined importation/manufacture) in PFAS and related chemicals of less than 500 tonnes/year. General Uses of Individual Chemicals or Products/Mixtures Individual country responses indicate uses o f raw PFAS and related chemicals in industrial uses only as reagents in small amounts and in fire resistant aviation hydraulic fluids. No domestic uses were noted. With regards to products/mixtures, the responses from 3 countries indicated both industrial and consumer uses for PFAS or related chemicals in leather, carpet and textile treatments, surfactants, battery components, surface coatings, waxes and other polishing preparations, washing agents and as mist suppressants. PFOA Importation/Manufacture of Individual Chemicals The survey noted importation and/or manufacture of PFOA and related raw chemicals by a total o f 4 countries. The total known trade in PFOA and related chemicals is likely to be between 100 and 200 tonnes/year, but possibly up to 800 tonnes/year. 12 ENV/JM/MONO(2005) 1 The first country indicated manufacture o f 2 chemicals in a combined volume o f less than 37 tonnes/year. The second indicated trade in 2 chemicals in a combined volume o f less than 1 kg. The third noted trade in 4 PFOA and related raw chemicals in a combined volume o f not more than 100 tonnes/year. The exact volume could not be disclosed. The remaining country similarly noted the total import/manufacturing volume o f a single PFOA and related raw chemical as confidential business information but indicated a total national manufacturing capability of less than 660 tonnes/year. For Europe, the ECB noted 2 PFOA and related raw chemicals imported and/or manufactured each in volumes less than 1 000 tonne/year. Importation/Manufacture of Products/Mixtures The survey indicated importation and/or manufacture of products/mixtures containing PFOA and related chemicals by 5 countries. One country declared products containing 6 PFOA-related polymers/telomers with a total product import volume o f 27.5 tonnes/year. The proportion o f chemicals in these products was noted as variable and so the total volume o f chemicals in these products could not be calculated. The other country noted importation of products containing a single PFOA-related chemical. The import volume was not provided. The manufacture of products containing PFOA and related chemicals was noted by only one country. The total manufacture volume for a single chemical was 2.2 tonnes/year. Company data included in the submission from one country indicated a total trade (combined importation/manufacture) in PFOA and related chemicals in that country o f up to 15 tonnes/year. Another country also indicated combined importation/manufacture o f PFOA and related chemicals in products but could not provide volume information. General Uses of Individual Chemicals or Products/Mixtures Responses indicated only industrial use and no domestic use of raw PFOA and related chemicals. Noted uses for these chemicals were as polymer processing aids in photographic film, as reagents, as surfactants and for semiconductors. Products containing PFOA and related chemicals were used only for industrial purposes. No domestic uses were noted. The specific industrial uses were as metal coatings (eg. non-stick cookware), surface coatings, textile treatments, additives for plastic resins and aqueous dispersions and for glass fibre impregnation. References Risk and Policy Analysts Limited (2004) Perfluorooctane Sulphonate. Risk Reduction Strategy and Analysis of Advantages and Drawbacks. Report prepared for Department for Environment, Food and Rural Affairs and the Environment Agency for England and Wales, August 2004. 13 ENV/JM/MONO(2005) 1 ANNEX This annex presents the detailed responses to the questionnaire on production and use of Perfluorooctane sulfonate (PFOS), Perfluoroalkyl sulfonate (PFAS), Perfluorooctanoic acid (PFOA), related substances and products/mixtures containing these substances. It also includes responses received after 10th September and before 10th November 2004. The questionnaire was sent by OECD on 1st June 2004 and answers were requested by 30 July; the date for response was extended to 31stAugust 2004. The questionnaire was also sent mid August 2004 by UNEP to all the Designated National Authorities (DNA) for the implementation o f the Rotterdam Convention and to the Focal Points for the Stockholm Convention, with a request for response by 30 October 2004. The OECD Secretariat clarified that this deadline was only for non OECD countries because the questionnaire was sent later by UNEP. The Secretariat received responses from the following countries/organization: Australia Estonia Japan Solomon Islands Belgium France Kiribati Sweden Bulgaria Finland Latvia Switzerland Canada Georgia Lithuania UK Chili Germany New Zealand US Congo Cook Islands Hungary Ireland Norway Poland European Commission Cyprus Italy Slovak Republic Dominican Republic Jamaica Slovenia Only countries with name typed in bold have provided positive responses and/or comments on at least one question. They are mentioned in the following tables when information is available with respect to a particular question. The other countries either provided a negative response to all the questions related to chemicals production and import (Cook Islands, Estonia, Hungary, Georgia, Jamaica, Kiribati, Latvia, Lithuania, Slovak Republic, Solomon Islands) or explained that the chemicals have not been identified or registered (Chili, Congo, Dominican Republic). Several responses were only provided by the DNA for Pesticides, which is not the most relevant for these chemicals. The European Commission provided the OECD with the names of the substances included in the IUCLID database, which in principle covers substances produced or imported with a tonnage over 10 t/year; very general information on use categories and volumes was also given. Producers/Importers agreement is necessary for the Commission to provide more detailed information. A letter cosigned by the European Commission and the OECD was sent end of October to ask these producers/importers to release 14 ENV/JM/MONO(2005) 1 this information. 3M responded on behalf o f two companies that the IUCLID information is no longer upto-date, and it does not take into account the global phase-out o f `perfluorooctanyl' chemistry as announced in May 2000 and accomplished by the end of 2002 except for a small amount of PFOA for internal use; they plan to correct the IUCLID information. The European Commission also pointed out a few substances on the inventory of New Substances (ELINCS) potentially degrading to PFOS in the environment. Further work would be needed to clearly identify which of these substances are o f concern, so they are not listed in this document. To respond to the survey, countries either addressed directly the questions to industry associations, or searched in inventories, product registers, registers o f dangerous (classified) chemicals, literature, or they combined several approaches to find the information. In some countries, it is very difficult to get information if the chemical is not strictly regulated, if the production/import volume is under a particular threshold, or if the number of companies involved in production/import is limited, or without an appropriate customs nomenclature. The Secretariat received several requests for a list of CAS numbers for the substances covered by the questionnaire. Questions were addressed to the Secretariat with respect to confidentiality. Except for 3M in connection with its phase out o f PFOS and PFOS-related substances, the Secretariat did not disclose the name o f companies when they were provided by a country. The responses are mostly useful with respect to the uses o f the chemicals, products and mixtures. W ith respect to production and import, the information is very often more qualitative than quantitative and it is not possible to draw conclusions with certainty. Responses Page Question 1 (PFOS and PFOS-related substances) 4 Question 2 (Products/Mixtures containing PFOS or PFOS-related substances) 12 Question 3 (Uses for PFOS and PFOS-related substances and/or products/mixtures for which no suitable alternatives are available) 18 Question 4 (Other substances and/or products/mixtures used as replacements for PFOS and PFOS-related substances and /or Mixtures) 19 Question 5 (Any new use of PFOS and PFOS-related/PFOS-based substances and products/mixtures containing these substances) 20 Question 6 (Importation/Manufacture of PFAS and PFAS-related substances) 21 Question 7 (Importation/Manufacture o f products/mixtures containing PFAS or PFAS-related Substances) 34 Question 8 (Importation/Manufacture of PFOA and PFOA-related substances) 37 Question 9 (Importation/Manufacture of Products/Mixtures containing PFOA or PFOA-related substances) 41 15 ENV/JM/MONO(2005) 1 Results of Survey on Production and Use of PFOS, PFAS, and PFOA-Related Substances and Products/ Mixtures Containing these Substances Q uestion 1: Im po rtatio n /M an u factu re of PFO S and PFO S-R elated Substances (Table 1):1 M anufacture (yes/no)/ Im port (yes/no) Australia Belgium No/No Y e s 12 PFOS Chemical Name/ CAS No. - No/No3 - M anufacture/Im port Volume range of Chemical (kg) for 2003 calendar year - 5 000 (for year 2000) 471 for the EU4 n/a No use Obviously not in use5 Under exam. Known Uses of the Chemical Photographic6 Semiconductors6 Aviation7 Paper/cardboard transforming Paper/cardboard producers Metal sector. Specify if Industrial and/or Consumer use - Industrial Industrial Industrial Industrial -- 1 P FO S-related chem icals m ay be sim ple salts o f P FO S, e.g., potassium , lithium , am m onium , diethanolam ine, o r polym ers that contain PFO S as only a p o rtion o f the entire polymer. 2 All PFOS, PFAS and PFOA related substances are pooled. 3 Inform ation provided by 3M. See also Q uestion 2 and note to Table 2 for Belgium (3M). 4 No specific figures related to Belgium are available. 5 B ased o n the outcom e o f a query conducted tow ards 13 com panies, fro m w h ich all 5 responders m entioned th at the substances/preparations are n ot used. 6 M ore details on type o f substances, com position o f preparations and use areas are considered as confidential business inform ation (CBI). 7 See however data subm ission by the US where headquarter production site is located and from where distribution occurs to EU and non-EU countries, for more details on type o f substances, com position o f preparations and use areas. At least one distributor in Belgium. 16 Question 1 (continued) Manufacture/ Import PFOS Chemical Name/ CAS No. Bulgaria C a n a d a 10 Cyprus Finland n/a/Yes No/yes No/No N o/N o11 Sulphohalogenated derivatives of hydrocarbons CAS No. 1763-23-1 (Customs code: 2904 9020 0) Other sulphonated, nitrated or nitrosated derivatives of hydrocarbons (Customs code: 2904 9085 0)8 Diethanolamine and its salts CAS No. 70225-14-8 (Customs code: 2922 1200 0) - Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year Production: None. Import: (#)89 (492 for year 2002) Production: None. Import: 17 464 (40 575 for year 2002) Production: (#)9 Import: : 49 786 ( 22 599 for year 2002) 10 - ENV/JM/MONO(2005) 1 Known Uses of the Chemical n/a Specify if Industrial and/or Consumer use n/a n/a n/a n/a n/a 10 10 --- 8 CAS No. might be 29081-56-9. 9 The available data are confidential according to Art. 26 and Art. 27 of Law on Statistics (SG 57/1999, as am ended in SG 42/2001, 45/2002, 74/2002) - National Statistical Institute. 10 D ata regarding specific im ports fo r each CAS No. are n o t publicly available. In total, approxim ately 600 000 kg o f p erfu o rin a te d alkyl substances w ere im ported into Canada during 1997-2000, and o f this total, <250 000 kg were imports o f PFOS and PFOS precursors. PFOS alone accounted for <2% of imported perfuorinated alkyl substances and uses included fire-fighting foams, chemical form ulation and other/unknown. The most significant Canadian imports o f PFOS itself were in the form o f the potassium salt, used for fire-fighting foams. PFOS precursors were used for water, oil, soil and grease repellents for packaging, rugs and carpets, and leather; surfactant-detergent, emulsifier, wetting agent, dispersant; fire-fighting foam, other applications. New data will be collected for PFOS, PFOA, PFAS, telomers, others FO R 2004 and are expected to be available in mid-to late-2005. 11 A ccording to the inform ation F inland has at th eir disposal, there does not exist either m anufacture in Finland or im port to F inland as regards PFO S o r P O FSrelated substances. 17 ENV/JM/MONO(2005) 1 Question 1 (continued) Manufacture/ Import PFOS Chemical Name/ CAS No. G e rm a n y 12 Ireland Italy14 Japan Yes/Yes n/a Yes/- Yes/No Perfluoroctanesulfonylfluoride CAS No. 307-35-7 Tetraethylammoniumperfluoro octanesulfonate CAS No. 56773-42-3 n/a 1-Octanesulfphonyl fluoride, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,6,heptatanedecafluoro CAS No. 307-35-7 1-Octanesulfphonyl acid, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,6,heptatanedecafluoro-potassium salt Heptadecafluorooctane -1 -sulphonic acid CAS No. 1763-23-1 Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year Import: 10 000 - 30 000 Production13: 10 000 ~ 30 000 n/a < 20.000 Known Uses of the Chemical Intermediate for the production of PFOS-related substances. M ist suppressant in electroplating industry, surfactant in photographic processing solutions. Semiconductor Chemical intermediate < 2.000 < 100 00015 Acid mist supressant Semiconductors, etc. Specify if Industrial and/or Consumer use Industrial Industrial Industrial Industrial Industrial Industrial 12Inform ation fro m five com panies are available fo r P F O S/PF A S /P FO A o r related substances/m ixtures. 13 T he product is p laced as a 50% aqueous solution (see table 2 o f Q uestion 2 fo r G erm any). 14 Inform ation provided by FED E R C H EM IC A . 15 T he regulation stipulated that it does not release the specific num erical volum e o f im port/m anufacture o f PFO S and its related substances if the total volum es o f them do not exceed 100 000kg per year. 18 Manufacture/ Import New Zealand Norway Poland Sweden N o/n/a16 N o/N o17 No/No No/No Question 1 (continued) PFOS Chemical Name/ CAS No. -/n/a - Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year -/n/a - - ENV/JM/MONO(2005) 1 Known Uses of the Chemical -/n/a - Specify if Industrial and/or Consumer use -/n/a - - 16 Some perfluoroalkyl (PFOS, PFA S, PFO A , related substances and products/m ixtures) are listed as N otified Toxic Substances (N O TS), m eaning that they may be im ported and used. This is not to say that im port and use actually occurs simply that the substances are still "registered". Responses to the questionnaire from two companies show that one company has not manufactured perfluoroalkyls since 2002 according to their phase-out plan announced in July 2000 and has not im ported products containing perfluoroalkyls since the phase-out date, and the other company only im ported a quantity of prim er paints that contained a total o f 4.25grams o f PFOA. M ore available will be available when these chemicals will be transfered to the Hazardous Substances and New Organisms Act framework, w hich is not scheduled until mid-2006. 17 Som e use has b ee n registered, b u t N orw ay does n ot know w hether it is pure PFO S o r in m ixtures. M o st o f the use areas are confidential o r probably not discovered yet. See also Question 2, Note to Table 2 for Norway. 19 ENV/JM/MONO(2005) 1 Manufacture/ Import Switzerland18 No/Yes Question 1 (continued) PFOS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year CAS No. 2795-39-3 n/a CAS No. 29457-72-5 CAS No. 56773-42-3 n/a n/a UK No/Yes Tetraethylammonium salt < 500 of PFOS n/a n/a (470 for the EU) PFOS salt and polymers n/a (750 for the EU) PFOS-related PFOS salt n/a (730 for the EU) 11420 Known Uses of the Chemical Metal surface treatment, metal plating, corrosion inhibitor, wood treatment. Photography agent, laboratory chemicals. Photography/auxiliary/ metal plating agent, adhesives cement, paint, metal surface treatment, car surface agent. Metal (chromium) plating. Photolithography. Photographic anti-static agents. Aviation hydraulic fluids. Fire-fighting foams. Specify if Industrial and/or Consumer use Indust. (1),19 consum.(4). Indust. (2), consum. (1). Indust. (33), consum. (2). Industrial Industrial Industrial Industrial Industrial 18 B ased o n survey o f Swiss P roduct R egister, w hich includes b o th PFO S and P FO S-related substances, an d products/m ixtures containing PFO S o r P FO S-related substances. The data bank can not prove that registered substances or products are still in use. For historical reasons, also generic terms instead of univocal substance names w ith CAS numbers were partially used. Due to this feature of the data bank it also can not be guaranteed that all substances in use are detected in the search. See estimates for actual use and application fields in annexed Table A1. 19 N um ber in brackets indicated num ber o f actual registered products. 20 Substantially greater quantities are stored fo r em ergency use. 20 u s 21, 22 E U 23 Manufacture/ Import No/Yes Yes Question 1 continued) PFOS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year n/a 1 213 955 (for year 2000) n/a 1 071 227 (for year 2000) n/a 572 273 (for year 2000) n/a 92 500 (for year 2000) N-ethylheptadecafluoro-N-(2- < 1 000 000 (since hydroxyethyl)octanesulphonamide 1996) CAS No. 1691-99-2 2-[[(heptadecafluorooctyl) < 1 000 000 (since sulphonyl]methylamino]ethyl 1996) acrylate CAS No. 25268-77-3 ENV/JM/MONO(2005) 1 Known Uses of the Chemical Paper & packaging. Specify if Industrial and/or Consumer use - Textile, leather & carpet treatment. Industrial surfactants, additives, coatings. Fire fighting foams. - -- -- 21 T he U .S. has no inform ation concerning specific im portation o f PFO S o r P FO S-related substances. H ow ever, the U .S. anticipates th at im portation o f lim ited volum es o f such substances is occurring to support the specific uses excluded from the PFAS SNUR, in the industrial use areas o f aviation hydraulic fluids, sem iconductor and electronics manufacture, and imaging. Based on the inform ation provided by these industries during the PFAS SNUR regulatory process, the U.S. believes that all collective manufacture and im port o f these chemicals for all o f these uses com bined would not exceed 8 000 kg/year. 22 T he only public production num bers fo r all PFO S and P FO S-related substances available in the U .S. w ere provided by the 3M Com pany in 2000 in connection w ith its phase-out o f these chem istries (AR226-0600). All PFOS production in the U.S. ceased in 2002. A ccording to 3M, U.S. production o f these chemicals in 2000 was projected at 6 490 000 lbs (2 950 000 kg), and U.S. im portation o f these chem icals in 1999 totaled 239 900 lbs (109 045 kg). The 2000 U.S. production am ount was distributed by use as shown in the table. 23 T he response fo r E U com es fro m E u ro p ean C hem icals Bureau. Inform ation is g iven according to IU C LID data base at EC B , and is the highest volum e o f latest year. See uses found for PFOS and PFOS-related substances in annexed Table A2. 21 ENV/JM/MONO(2005) 1 Question 1 (continued) Manufacture/ Import PFOS Chemical Name/ CAS No. Yes Potassium heptadecafluorooctane1-sulphonate CAS No. 2795-39-3 Potassium N-ethyl-N-[(heptadeca fluorooctyl)sulphonyl]glycinate CAS No. 2991-51-7 Heptadecafluorooctanesulphonyl fluoride CAS No. 307-35-7 Diaquatetrachloro[mu-[N-ethyl-N[(heptadecafluorooctyl)sulphonyl] g ly c in a to - O 1 :O 1 ']]-m u -h y d ro x y b is (2-methylpropanol)dichromium CAS No. 68891-96-3 Tetraethylammonium heptadeca fluorooctanesulphonate24 CAS No. 56773-42-3 [3-[[(heptadecafluorooctyl)sulpho nyl] (3-sulphopropyl)amino]propyl] (2-hydroxyethyl)dimethyl ammonium hydroxide24 CAS No. 68298-11-3 Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year < 1 000 000 (since 1996) < 1 000 000 (since 1996) < 1 000 000 (since 1996) < 1 000 000 (since 1996) < 1 000 000 (since 2000) < 1 000 000 (since 1996) Known Uses of the Chemical - - Specify if Industrial and/or Consumer use - - - - - - 24 N ot in the U S E P A list. 22 Question l(continued). Manufacture/ Import PFOS Chemical Name/ CAS No. Yes N-[3 -(dimethylamino)propyl]hepta D e c a flu o r o o c ta n e s u lp h o n a m id e 24 CAS No. 13417-01-1 Ammonium bis[2-[N-ethyl(heptadeca fluorooctane)sulphonylamino]ethyl] phosphate24 CAS No. 30381-98-7 Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year < 1 000 000 (since 1996) < 1 000 000 (since 1996) ENV/JM/MONO(2005) 1 Known Uses of the Chemical - Specify if Industrial and/or Consumer use - -- 23 ENV/JM/MONO(2005) 1 Question 2: Importation/Manufacture of Products/Mixtures Containing PFOS or PFOS-Related Substances (Table 2). Manufacture (yes/no)/ Import (yes/no) Australia25 No/Yes as impurities Belgium Y e s 27 Y e s /Y e s 28 Product/ mixture name PFOS Chemical Name/ CAS No. Confidential PFOS. Related substances including PFAS (C4-C8) Fire fighting foam concentrate. Miscellaneous fluoropolymers CAS No. 38850-58-7 & CAS No. 2795-39-3 Confidential Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year Confidential. ~ 3 000 as PFAS (including PFOS) < 50 000 < 125 000 Conc. Of Substance in Product/ mixture <0.015% Low 18% < 0.5% Known Uses of the Product/mixture Additive product26 Sealant. Fire fighting form. Molded goods. Specify if Industrial and/or Consumer use, if possible Industrial Industrial Industrial & consumer. Industrial 25 A ustralia notes as PFO S and P FO S-based chem ical ingredients m ay n ot b e m entioned o n M aterial Safety D ata Sheets, im porters m ay n ot know if products/mixtures contain PFOS and may not have identified all the products containing PFOS. 26 A specialized industrial additive product used fo r coating m etal com ponents. T he reported applications do n ot include coating fo r cookw are o r fabric. 27 See Q uestion 1 and the notes to Table 1 fo r Belgium . 28 Inform ation provided by 3M. 3M has not m anufactured the P FO S-related substances in these products after 31 D ecem b er 2002. These substances w ere covered by 3M 's phase-out announcem ent o f 16 M ay 2000 and w ere reflected in 3M 's P hase-out P lan subm itted to U S E P A o n 7 July 2000. 24 ENV/JM/MONO(2005) 1 Bulgaria Canada Cyprus Manufacture /Import n/a N o /Y e s 29 No/Yes Product/ mixture name n/a - ZONYL 9155 carpet protector. ZONYL 8740 protector. Preparations o f fire fighting foams. Question 2(continued) PFOS Chemical Name/ Manufacture/ CAS No. Import Volume range of Chemical (kg) for 2003 calendar year n/a n/a -- Fluoropolymer 430 lt. Fluoropolymer 430 lt. Fluorocarbons 49 30030 Conc. Of Substance in Product/ mixture n/a - 5%31 5 % 31 Known Uses of the Product/mixture n/a - Protection of carpets. Stain and soil repellent. Fire fighting foams. Specify if Industrial and/or Consumer use, if possible n/a - Industrial Industrial Consumer 29 It is expected th at im ports occur. Specific details are n ot publicly available. 30 Final product containing fluorocarbons. 31 In the final m ixture fo r the intended use. 25 ENV/JM/MONO(2005) 1 Manufacture /Import Finland32 No/Yes Germany36 Yes/No Company 1 Company 2 Product/ mixture name Product 1 33 Question 2(continued) PFOS Chemical Name/ Manufacture/ CAS No. Import Volume range of Chemical (kg) for 2003 calendar year CAS No. 70225-14-834 100 Product 233 CAS No. 56773-42-335 1 000 Mist suppressant Fire fighting foam concentrate 37 Tetraethylammonium perfluorooctanesulfonate CAS No. 56773-42-3 CAS No. 38850-58-7 CAS No. 2795-39-3 20 000 ~ 60 000 < 2 000 Conc. Of Substance in Product/ mixture 25% 5 ~ 15% 50% by weight 12% Known Uses of the Product/mixture Electronic etching baths. Metal plating Mist suppressant in electroplating industry. Fire fighting foam. Specify if Industrial and/or Consumer use, if possible Industrial Industrial Industrial Industrial 32 A ccording to the F innish product register there are tw elve products containing P FO S/PFO S related substances currently o n the F innish m arket. T hree o f the products contain more than 1% (max. 25%) substances in question, nine products contain less than 1% and eight o f those nine products contain less than 0.01% PFOS substances. No one o f the products are m anufactured Finland. In practice only two o f the products were imported to Finland during the calendar year 2003. In addition to above mentioned products it has come up that hydraulic fluids containing PFOS substances for aircrafts are m ost likely in use also in Finland. They are imported to Finland and at the moment precise im port volumes are unknown. It has also appeared that fire fighting foams containing PFOS substances have also been in use in Finland and, as a m atter o f fact, they still are to some extent. Finland has not been able to get a clear picture o f the current situation but according to their knowledge fire fighting foams are stored in hundreds o f locations in Finland and quite often part o f the stockpile m ight contain PFOS substances. However, the am ount o f the foam stored is typically quite small. 33 A ccording to the F innish legislation, Finland is not allow ed to give inform ation requested fo r nam ed products. 34 1-O ctanesulphonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-heptadecafluoro-, com pd. w ith 2,2'-im inobis[ethanol] (1:1). 35E thanam inium , N ,N ',N ''-triethyl-, salt w ith 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-heptadecafluoro-1-octanesulphonic acid (1:1). 36 See Q uestion 1 and the notes to Table 1 fo r Germany. 37 3M has not m anufactured the PFO S related substances in these product after D ecem ber 31, 2002. T hese substances w ere covered by 3 M 's phase out announcem ent o f M ay 16, 2000 and w ere reflected in 3 M 's Phase out P lan subm itted to the U nited States E nvironm ental P ro tectio n A gency o n July 7, 2000. No Fire Fighting Foam Concentrate has been im ported in 2004 YTD. 26 ENV/JM/MONO(2005) 1 Italy Japan New Zealand39 Manufacture /Import Company 5 No/No Y e s 38 No/n/a Product/ mixture name AZ Aquatar -III 45 - Question 2(continued) PFOS Chemical Name/ Manufacture/ CAS No. Import Volume range of Chemical (kg) for 2003 calendar year Heptadecafluorooctane- ca 100 1-sulphonic acid CAS No. 1763-23-1 -- -- Conc. of Substance in Product/ mixture Known Uses of the Product/mixture 2.6% - Antireflective coating in photolithography. - Specify if Industrial and/or Consumer use, if possible Industrial - 38 A lthough potassium , lithium , am m onium , diethanolam ine, o r polym ers m ay b e subject to this questionnaire, Jap an does not take into account in its answ er since it is difficult to figure out a precise picture o f PFO S-related substances, and Japan does not have enough result o f hazard assessments o f each PFOSrelated substance. T herefore, Japan is not able to provide the detail o f T able 2. 39 See Q uestion 1 and the notes to Table 1 fo r N ew Zealand. 27 ENV/JM/MONO(2005) 1 Manufacture /Import N o rw a y 40 No/Yes Poland No/No Product/ mixture name Confidential Confidential Confidential Confidential - Question 2(continued) PFOS Chemical Name/ Manufacture/ CAS No. Import Volume range of Chemical (kg) for 2003 calendar year 1-Octanesulphonic acid, >> 10 1,1,2,2,3,3,4,4,5,5,6,6,7, 7,8,8,8-heptadeca fluoro , potassium salt CAS No. 2795-39-3 Glycine, N-ethyl-N- >> 10 [(heptadeca fluorooctyl) sulphonyl]-, potassium salt CAS No. 2991-51-7 1-Octanesulphonic acid, >> 10 1,1,2,2,3,3,4,4,5,5,6,6, 7,7,,8,8-heptadeca fluoro-, ammonium salt CAS No. 56773-42-3 E th a n am in iu m ,N ,N ',N '' >> 10 -triethyl-, salt with 1,1, 2,2,3,3,4,4,5,5,6,6,7,7,8, 8,8-heptadecafluoro -1- octanesulphonic acid (1:1) CAS No. 56773-42-3 -- Conc. of Substance in Product/ mixture Unknown Unknown Unknown Unknown - Known Uses of the Product/mixture Confidential Confidential Confidential Confidential - Specify if Industrial and/or Consumer use, if possible - 40 Som e use has b ee n registered, b u t N orw ay does n ot know w hether it is pure PFO S o r in m ixtures. M o st o f the use areas are confidential o r probably not discovered yet 28 Manufacture /Import Product/ mixture name Slovenia No/Yes Raid formiche Sweden41 Yes/Yes ChrombadNetzmittel FT 248 * * * Switzerland Uk 43 u s 44 Y e s /Y e s 42 - No/Yes * * * * * * - Question 2 (continued) PFOS Chemical Manufacture/ Name/ Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Litium perfluoro- 692,08 octane sulfonate CAS No. 29457-72-5 Perfluorooctane 25 sulfonate Conc. of Substance in Product/ mixture <0.1% 5% ENV/JM/MONO(2005) 1 Known Uses of the Product/mixture Specify if Industrial and/or Consumer use, if possible Biocid Consumer Wetting agent Industrial CAS No. 68608-14-0 CAS No. 56773-42-3 CAS No. 2991-51-7 CAS No. 2991-51-7 CAS No. 2795-39-3 CAS No. 2795-39-3 CAS No. 383-07-3 CAS No. 383-07-3 CAS No. 70225-14-8 Import* Manufact. /import 36 300 Import/ manufact. 622 000 Manufacture /import* Manufacture* Import* Manufacture* Manufacture* Import* * 0.001 ~ 50 0.002 ~ 0.24 * * Galvanotechnical agents; raw materials. Wax & other polishing preparations cleaning agents. * ** ** ** ** ** Industrial Industrial Industrial/ consumer Industrial Industrial Industrial Consumer Consumer Industrial - -- - - - -- - - 41 " *" data could not be disclosed due to secrecy reasons: < 3 com panies have reported the m arketing o f the p roduct containing the substance. 42 See inform ation included in Q uestion 1 and the notes to T able 1 fo r Switzerland. 43 U K is not b e e n able to distinguish b etw een the im ports o f substances an d preparations. See Table 1. 29 ENV/JM/MONO(2005) 1 Question 3: The Uses for PFOS and PFOS-Related Substances and/or Products/Mixtures for which No Suitable Alternatives Are Available. Country Comment Australia Essential uses reported to date in Australia include use o f PFOS as an ingredient in certain aqueous film forming foam (AFFF) and alcohol type fire fighting foams. AFFF and ATC fire fighting foam is used to extinguish Class B fires. No other essential uses of PFOS and its derivatives are reported in Australia. Belgium Photographic industry, electronics industry (semi-conductors), aviation hydraulic fluids. Belgium45 3M is not aware o f alternatives for products used in aviation hydraulic fluid and in certain photographic and electronics applications. Canada Not determined. Finland Although the use o f products containing PFOS/PFOS-related substances is quite limited in Finland, the known uses are mainly connected to metal plating and photolithography processes in semiconductor industry as well as hydraulic fluids for aircrafts and it is obvious that the same difficulties to find substitutes for these purposes that came up in UK study apply also to the Finnish situation. New Information provided by a company: products used in aviation hydraulic fluid and in certain photographic and electronic Zealand applications. Norway The main uses for PFOS and PFOS related substances in Norway are not completely investigated. Therefore they cannot answer this question. Switzerland See in annexed Table A1 well as Tables 1 and 2. UK Uses are; 1) chromium plating (mist suppressants), 2) semiconductors (photolithography), 3) aviation hydraulic fluids, and 4) photographic anti-static agents. UK has evaluated all uses o f PFOS related substances and is confident that alternatives either exist or can be developed except for aviation hydraulic fluids. US In a Final Rule published 9 December 2002 (67 FR 72854), the U.S. excluded from regulation PFOS-related substances used (1) as an anti-erosion additive in fire-resistant phosphate ester aviation hydraulic fuels; (2) as a component of a photoresist substance, or as a component of an anti-reflective coating, used in a photomicrolithography process to produce semiconductors or similar components of electronic or other miniaturized devices; (3) in coatings for surface tension, static discharge, and adhesion control for analog and digital imaging films, papers, and printing plates, or as a surfactant in mixtures used to process imaging films; or (4) as an intermediate only to produce other chemical substances to be used solely for the three foregoing uses. Each of these excluded uses involves applications in which no suitable alternatives for PFOS and PFOS-related substances are available. EU See annexed Table A2, the uses found for PFOS and PFOS-related substances. 44 T he U .S. has no inform ation concerning specific products/m ixtures containing PFO S o r P F O S -related substances b ein g im ported into the U.S. H ow ever, the U.S. anticipates that im portation o f lim ited volum es o f such products/m ixtures is occurring to support the specific industrial uses excluded from the PFAS SNUR, in the areas o f aviation hydraulic fluids, sem iconductor and electronics manufacture, and imaging. 45 Inform ation provided by 3M. 30 ENV/JM/MONO(2005) 1 Question 4. Other Substances and/or Products/Mixtures Used as Replacements for PFOS and PFOS-Related Substances and/or Mixtures Country Comment Australia Relates to confidential information which precludes disclosure. Belgium Confidentiality problem for information provided by chemicals producers/processors. B e lg iu m 46 Canada Cyprus New Zealand Norway Switzerland UK US Over the past few years, 3M developed new technologies that can be used to produce products as substitutes for some of the phased-out PFOS-related products. For example, at this time 3M has commercialized substitutes for protective treatment of carpet, textiles & leather, fluoropolymers and for chemical surfactants. One o f the technologies utilizes a C4 building block compound. 3M has developed a substantial database of information on perfluorobutane sulfonate (PFBS). The results o f physical, chemical and environmental fate testing, ecological toxicity studies and mammalian toxicity studies on PFBS indicate that the compound has very low toxicity and a very low potential to bioaccumulate. The bioconcentration factor o f PFBS is less than one (<1). All o f the study results have been shared with the US EPA and the new substances are being commercialized in the US under a testing consent agreement with US EPA. The substances are also commercialized in Europe. This is currently being established. Alternatives may include perfluorobutane sulfonate substances as well as hydrocarbon-based surfactants and silicone-based surfactants. It is expected other fluorosurfactants are being used. No substances and/or products/mixtures are known to be used as replacements for PFOS and PFOS-related substances. A company is developing new technologies as substitutes for some phased-out PFOS-related products. One o f these technologies utilizes a C4 building block compound, perfluorobutane sulfonate, which has very low toxicity and potential to accumulate. This has not been investigated yet. Norway knows that PFAS have replaced PFOS-related substances in fire fighting foams. The survey in Switzerland was not able to deliver detailed information about replacements for PFOS and PFOS-related substances. According to industry, 3M replaces C-8 chemistry with C-4 chemistry. Replacements have been developed for PFOS related substances used in fire-fighting foams. These include non-PFOS fluorosurfactants, silicone and hydrocarbon based surfactants, and fluorine free fire-fighting foams. The specific identities of replacements or substitutes for PFOS and PFOS-related substances and mixtures have been claimed as Confidential Business Information (CBI) to the extent they have been disclosed to the U.S. government. Generally speaking, however, these substances and mixtures have included other perfluoroalkyl sulfonates (PFAS) and various fluorinated telomers. 46 Inform ation provided by 3M. 31 ENV/JM/MONO(2005) 1 Question 5: Any New Uses of PFOS and PFOS-related/PFOS-Based Substances and Products/Mixtures Containing These Substances Country Comment Australia Nil other than as an impurity in a specialised industrial additive (See Table 2). Belgium - B e lg iu m 47 Canada Cyprus Finland Norway Switzerland UK US None Canada is unaware o f any new uses. None There should not be any new uses of PFOS/PFOS-related substances in Finland to report. Norway has no knowledge on about any new uses of PFOS. Refer Tables 1 & 2. None UK is aware of. None 47 Inform ation provided by 3M. 32 ENV/JM/MONO(2005) 1 Q uestion 6: Im p o rtatio n /M an u factu re of PFA S and PFA S-R elated Substances (Table 3):48 M anufacture (yes/no)/ Im port (yes/no) PFAS Chemical Name/ CAS No. Australia49 Belgium Bulgaria No/No Y e s 50 Y e s /Y e s 51 Yes/Yes - Other sulphonamides CAS No. 4151-50-2 (Customs code: 2935 0090 9) Canada Finland N o /-53 No/no - M anufacture/Im port Volume range of Chemical (kg) for 2003 calendar year - Known Uses of the Chemical - Specify if Industrial and/or C onsum er use - Production: (#)52 Import: 48 923 (55 699 for year 2002) n/a n/a n/a n/a - -- 48 P FA S-related chem icals m ay be sim ple salts o r polym ers th a t contain the PFA S as only a p o rtion o f the entire polym er. F o r the purpose o f this table, this group includes PFAS and PFAS-related substances other than PFOS and PFOS-related substances. 49 A ustralia notes as PFA S and P FA S-based chem ical ingredients m ay n ot b e m entioned o n M aterial Safety D ata Sheets, som e im porters m ay n ot know if products/mixtures contain PFAS. 50 See Q uestion 1 and the notes to Table 1 fo r Belgium . 51 Inform ation provided by a com pany. See also Q u estio n 7, w here a jo in t answ er is g iven fo r b o th substances and products/m ixtures (or preparations). 52 T he available data are confidential according to Art. 26 and Art. 27 o f L aw o n Statistics (SG 57/1999, as am ended in SG 42/2001, 45/2002, 74/2002) - N ational Statistical Institute. 53 Im port: not determ ined. 33 ENV/JM/MONO(2005) 1 Question 6 (continued) Manufacture/ Import PFAS Chemical Name/ CAS No. G e rm a n y 54 Yes/No Company 1 Perfluorbutanesulfonylfluoride CAS No. 375-72-4 Hungary Potassiumperfluorbutanesulfonate CAS No. 29420-49-3 Company 3 No/No Bis-[2-(N.methylperfluorbutanesulfonamido)ethoxy]phosphoric acid ester CAS No. 120945-47-3 C4 PFAS-related substance CAS No: confidential. - Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year Known Uses of the Chemical Specify if Industrial and/or Consumer use 30 000 ~ 50 000 30 000 ~ 50 000 20 000 ~ 50 000 Intermediate for the production of PFAS related substances, fluorinating agent. Flame retardant, intermediate for the production of catalysts. Defoamer in electroplating industry. Industrial Industrial55 Industrial < 500 - Manufacturing intermediate. - Industrial - 54 See Q uestion 1 and the notes to Table 1 fo r Germany. 55 P arts o f the resulting products m ay be p laced o n the consum er marked. 34 Question 6 (continued) Italy Japan New Zealand56 Manufacture/ Import PFAS Chemical Name/ CAS No. Yes/- No/No No/n/a 1 Exanesulfonyl fluoride, 1,1,2,2,3, 3,4,4,5,5,6,6,6 tridecafluoroCAS No. 423-50-7 1 Exane sulfonic Acid, 1,1,2,2,3, 3,4,4,5,5,6,6,6 tridecafluoropotassium aalt CAS No. 3871-99-6 Cicloexane sulfonic acid, Decafluoro, (Pentafluoroethyl)potassium salt CAS No. 67584-42-3 1 Exane sulfonic acid amide, 1,1,2,2, 3,3,4,4,5,5,6,6,6 tridecafluoroCAS No. 41999-13-1 - Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year < 4.000 < 1.500 <1.200 600 - ENV/JM/MONO(2005) 1 Known Uses of the Chemical Unknown Specify if Industrial and/or Consumer use Industrial Unknown Industrial Fire resistant, hydraulic fluid. Industrial/ aircraft Unknown Industrial -- 56 See Q uestion 1 and the notes to Table 1 fo r N ew Zealand. 35 ENV/JM/MONO(2005) 1 Manufacture/ Import Norway N o /Y e s 57 Question 6 icontinued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Propenoic aicd, 2-3,3,4,4,5,5,6,6,7,7, 8,8,9, 9,10,10,11,11,12,12,12- Unknown Heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8, 9,9,10,10,10-heptadecafluorodecyl 2-propenoate, hexadecyl 2propenoate, N(hydroxymethyl)- 2-propenamide, octadecyl 2-pro CAS No. 115592-83-1 Propanaminium, 3(((heptadeca fluorooctyl)sulfonyl)amino)-N,N,N, trimethyl-, iodide, 1CAS No. 1652-63-7 Oktansulfonamide 1, N-etyl-1,1,2,2, 3,3,4,4,5,5,6,6,7,7,8,8,8-heptadeca fluoro-N-(2-hydroksyetyl)CAS No. 1691-99-2 Nonanesulfonic acid, 1,1,2,2,3,3,4,4, 5,5,6,6,7,7,8,8,9,9,Nonadedecafluoro-, ammonium salt (C9-H-F19-O3-S.H3-N) CAS 17202-41-4 Kaliumperfluoroktansulfonat CAS No. 2795-39-3 Unknown Unknown Unknown Unknown Known Uses of the Chemical - Specify if Industrial and/or Consumer use - 57 N orw ay does not have inform ation o n w hether the im port is as pure PFA S o r mixtures. 36 Manufacture/ Import Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year No/Yes Poly(oksi-1, 2-etandiyl), alfa-(2-(etyl (heptadekafluoroktyl)sulfonyl) amino)etyl)-omega-hydroksiCAS No. 29117-08-6 Butansulfonsyre, 1,1,2,2,3,3,4,4, -nonafluoro-1-, kalium salt CAS No. 29420-49-3 Glycine, N-ethyl-N-((heptadecafluro octyl)sulfonyl)-, potassium salt CAS No. 2991-51-7 Phosphinicobis(oxy-2,1 -ethanediyl) bis(N-ethyl-1,1,2,2, 3,3,4,4,5,5,6,6, 7,7,8,8,8-heptadecafluoro-1 -octan sulphonamide, ammonium salt, N ,N 'CAS No. 30381-98-7 Carboxymethyldimethyl -3-[[(3,3, 4,4,5,5,6,6,7,7,8,8,9,9,tridecafluorooctyl)sulphonyl]amino] propylammonium hydroxide CAS No. 34455-29-3 Propanaminium,3 -(((heptadeca fulorooctyl)sulfonyl)amino)-N,N,Ntrimetyl- 1,chloride (C14H16F17N2O2S.Cl) CAS No. 38006-74-5 Unknown Unknown Unknown Unknown Unknown Unknown ENV/JM/MONO(2005) 1 Known Uses of the Chemical Specify if Industrial and/or Consumer use 37 ENV/JM/MONO(2005) 1 Manufacture/ Import No/Yes Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Ammonium pentadecafluoro Unknown octanoate CAS No. 3825-26-1 Pentansulfonsyre, 1,1,2,2,3,3,4,4,5, Unknown 5,5-undekafluoro-1-, kalium salt CAS No. 3872-25-1 Butandioic acid, sulfo, (3,3,4,4,5,5, Unknown 6,6,7,7,8,8,8, tridecafluorooctyl) estersodium salt CAS No. 54950-05-9 Poly(oksi-1,2-etandiyl), alfa-(2-(etyl Unknown ((tridekafluorheksyl)sulfonyl)amino) etyl)-omega-hydorksi- CAS No. 56372-23-7 Ethanaminium,N,N,N-triethyl-, salt Unknown with 14,2,2,3,3,4,4,5,5,6,6,7,7,8,8, - heptadecafluoro-1-octanesulfonic acid (1:1) CAS No. 56773-42-3 Heptansulfonsyre-1,1,2,2,3,3,4,4, Unknown 5,5,6,6,7,7,7- pentadekafluoro-1-, kalium salt CAS No. 60270-55-5 Poly(difluromethylene), alpha.- Unknown fluro.-omega.-(2-(2-methyl-1-oxo- 2-propenyl)oxy)ethyl)- CAS No. 65530-66-7 Known Uses of the Chemical Confidential Confidential Confidential Confidential Specify if Industrial and/or Consumer use - 38 Manufacture/ Import No/Yes Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Poly(difluoromethylene)alpha(2-((2- Unknown carboxyethyl)thio)ethyl)-w-fluoro-, lithium salt CAS No. 65530-69-0 Poly(difluoromethylene), alfa, alfa- Unknown (phosphinicobis(oxy-2,1 - ethanediyl))bis(omega-fluoro-, ammonium salt CAS No. 65530-70-3 Poly(difluoromethylene), alfa- Unknown fluoro-omega-(2-(phosphonoxy) ethyl)-, monoammonium salt CAS No. 65530-71-4 Poly(difluoromethylene), alfa- Unknown fluoro-omega-(2-(phosphonoxy) ethyl)-, diammonium salt CAS No. 65530-72-5 Poly(oxy-1, 2-ethanediyl), alpha, Unknown hydro-, omega, -hydroxy-, ether with alpha, fluoro-, omega,-(2- (hydroxyethyl)poly(difluoromethy lene) (1:1) CAS No. 65545-80-4 Poly(difluoromethylene), alpha- Unknown fluoror-omega-(2-((1-0x0-2- propenyl)oxy)ethyl) CAS No. 65605-70-1 ENV/JM/MONO(2005) 1 Known Uses of the Chemical Confidential Specify if Industrial and/or Consumer use Confidential - Confidential Confidential Confidential - Confidential 39 ENV/JM/MONO(2005) 1 Manufacture/ Import No/Yes Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Cyclohexanesulfonic acid, Unknown decafluoro(pentafluoroethyl)-, potassium salt CAS No. 67584-42-3 Glycin, N-ethyl-N-((nonafluoro Unknown butyl)sulfonyl), kalium salt CAS No. 67584-51-4 Glycin, N-ethyl-N-((undekafluoro Unknown pentyl)sulfonyl), kalium salt CAS No. 67584-52-5 Glycin, N-ethyl-N-((tridekafluoro Unknown heksyl)sulfonyl), kalium salt CAS No. 67584-53-6 Glycin, N-ethyl-N-((pentadeka Unknown fluoroheptyl)sulfonyl), kalium salt CAS No. 67584-62-7 Decanesulfonic acid, 1,1,2,2,3,3,4,4, Unknown 5,5,6,6,7,7,8,8,9,9,10,10,10-heneico- safluoro-, ammonium salt (C10-H-F21-O3-S.H3-N), 1- CAS No. 67906-42-7 Octansulfonamide, N-ethyl-1,1,2,2, Unknown 3,3,4,4,5,5,6,6,7,7,8,8-heptadeca fluoro-N-(2-(phosphonooxy)ethyl)- 1, diammonium salt CAS No. 67969-69-1 Known Uses of the Chemical Confidential Confidential Confidential Confidential Confidential Confidential Confidential Specify if Industrial and/or Consumer use 40 Manufacture/ Import No/Yes Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Propensyre, 2-(butyl((heptadeca Unknown fluorooktyl)sulfonyl)amino)etyl ester, telomer med 2-(butyl(penta decafluoroheptyl)-sulfonyl)amino) etyl, 2-propeonat, metyl oksiran polymer med oksiran di-2-propeo nat, metyl oksiran polymer med oksiran mono-2-propeonat og 1-O CAS No. 68298-62-4 Poly(oksi-1,2-etandiyl), alfa-(2-etyl Unknown ((nonafluorbutyl)sulfonyl)amino) etyl)-om ega-hydroksi -((C2H4O)nC8 H10F9NO3S) CAS No. 68298-79-3 Poly(oky- 1,2-etandiyl), alfa-(2-etyl Unknown ((undekafluoropentyl)sulfonyl) amino) ethyl)-omega-hydroxy- ((C2H4O)nC9 H10F11NO3S) CAS No. 68298-80-6 Poly(oksi-1,2-etandiyl), alfa-(2-etyl Unknown ((pentadecafluorheptyl)sulfonyl) amino)etyl)-omega-hydroksi- CAS No. 68298-81-7 ENV/JM/MONO(2005) 1 Known Uses of the Chemical Confidential Specify if Industrial and/or Consumer use Confidential Confidential Confidential 41 ENV/JM/MONO(2005) 1 Manufacture/ Import No/Yes Poland Sweden No/Yes No/No Question 6 (continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year Krom, diaquatetraklor( .mu.-(N-etyl - Unknown N-((peptadekafluorooktyl)sulfonyl) glycinato-01:01'))-.mu.-hydroksybis (2-metylpropanol)di- CAS No. 68891-96-3 Poly(oxy-1,2-etandiyl), a-(2-etyl Unknown ((heptadekafluorooktyl)sulfonyl) amino)etyl)-w-metoksy- CAS No. 68958-61-2 Heptadekafluorooctane sulphonic Unknown acid, compound with 2,2'- iminodiethanol (1:1) CAS No. 70225-14-8 Propanaminium, 2-hydroxy, N,N,N- Unknown trimethyl-, 3-(gamma-omega- perfluoro-C6-20-alkyl)thio)derives, chlorides, 1- CAS No. 70983-60-7 1,1,2,2,3,3,4,4,4-nonafluorobutane- 0.025 1-sulphonyl fluoride CAS No. 375-72-4 -- Known Uses of the Chemical Confidential Confidential Confidential Confidential Reagent - Specify if Industrial and/or Consumer use - 42 Manufacture/ Import Switzerland58 No59/Yes Question 6^(continued) PFAS Chemical Name/ Manufacture/Import CAS No. Volume range of Chemical (kg) for 2003 calendar year CAS No. 70225-18-8 n/a CAS No. 2991-51-7 n/a CAS No. 1652-63-7 CAS No. 38006-74-5 CAS No. 65530-69-0 CAS No. 65530-83-8 CAS No. 17741-60-5 CAS No. 27905-45-9 CAS 65605-70-1 n/a n/a n/a n/a n/a n/a n/a ENV/JM/MONO(2005) 1 Known Uses of the Chemical Solvent, emulsifier, diluting agent, paint stripper, surfactant, Cr metal plating/ galvanic agent. Paint, emulsifier, stone floor polishing/car polish/water repellence/ cleaning/ disinfection agents, biostatica, shoe & leather protection agent, adhesives, cement, paint. Paint. Cleaning agents. Paints, metal treatment agents, surfactant, shoe & leather protection/floor polishing agent. Dito. W ater repellence agent. W ater repellence agent. W ater repellence agent. Specify if Industrial and/or Consumer use Indust. (8).60 Consum.(64), indust. (138). Indust. (2). Consum. (2). Consum.(2), indust. (12). Consum.(2), indust. (9). Consum. (1). Consum. (1). Consum. (1). 58 B ased o n survey o f Swiss P roduct R egister, w hich includes b o th PFA S an d P FA S-related substances, and products/m ixtures containing PFA S o r P FA S-related substances. The data ban k ca n n ot prove th at registered substances o r products are still in use. See Q uestion 1, note to T able 1 fo r Sw itzerland and annexed Table A1. 59 T his is not p roved in detail. 60 N um ber in brackets indicated num ber o f actual registered products. 43 ENV/JM/MONO(2005) 1 Question 6 (continued) Manufacture/ PFAS Chemical Name/ Manufacture/Import Known Uses of the Import CAS No. Volume range of Chemical Chemical (kg) for 2003 calendar year No/Yes CAS No. 65545-80-4 n/a Paints, auxiliary agents, surfactant, cleaning/car polish/water repellence/ floor surface treatment/ photographical agents. CAS No. 68586-14-1 n/a (3M-products, according to 3M not any more in use) CAS No. 34395-24-9 n/a Natural stone sealing agent (register date: Feb. 2004) CAS No. 53515-73-4 n/a W ater repellence agent (register date: Feb. 2004) US Yes/Yes61 n/a n/a n/a EU Yes (2-hydroxyethyl)dimethyl [3-[(3- < 1 000 000 (since sulphopropyl)[(tridecafluorohexyl) 1996) sulphonyl]amino]propyl] ammonium hydroxide CAS No. 38850-58-7 Perfluorohexanesulphonyl fluoride < 1 000 000 (since - CAS No. 423-50-7 1996) Potassium 1,1,2,2,3,3,4,4,4- < 1 000 000 (since - nonafluorobutane-1-sulphonate62 2000) CAS No. 29420-49-3 Specify if Industrial and/or Consumer use Consum.(4), indust. (13). - Consum./ indust. (1). Consum./ indust. (1). n/a - - 61 N on-P FO S -related PFA S and P FA S-related substances o f v ary in g carbon ch ain lengths are b o th m anufactured in and im ported into the U.S. A t this tim e, however, the U.S. has no inform ation that it is able to share concerning the specific identities or production/im portation volum es of these substances. Many chemical identities and production volumes are reported as confidential business information. Additionally, these substances may be manufactured or imported in volumes below regulatory reporting thresholds. 62 N ot in the U S E P A list. 44 Manufacture/ Import PFAS Chemical Name/ CAS No. Question 6 Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year n/a 1,1,2,2,3,3,4,4,4-nonafluorobutane-1- < 1 000 000 (since sulphonyl fluoride62 2000) CAS No. 375-72-4 3-[[3 -(dimethylamino)propyl] < 1 000 000 (since [(tridecafluorohexyl)sulphonyl] 1994) amino]propanesulphonic acid62 CAS No. 38850-60-1 Trifluoromethanesulphonic acid62 < 1 000 000 (since CAS No. 1493-13-6 1991) ENV/JM/MONO(2005) 1 Known Uses of the Chemical - Specify if Industrial and/or Consumer use - -- -- 45 ENV/JM/MONO(2005) 1 Question 7: Importation/Manufacture of Products/Mixtures Containing PFAS or PFAS-Related Substances (Table 4) Manufacture (yes/no)/ Import (yes/no) Product/ mixture name PFAS Chemical Name/ CAS No. A u s tra lia 63 Belgium Bulgaria Canada Cyprus67 Finland Italy No/Yes Y e s 64 Y e s /Y e s 65 n/a N o /-66 No/Yes No/No No/No 3 products containing PFASrelated chemicals & polymers n/a - n/a - Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year < 6 000 (as PFAS) Conc. of Substance in Product/ mixture Confidential Known Uses of the Product/mixture Mist suppressant, carpet treatment, surface coatings. Specify if Industrial and/or Consumer use, if possible Industrial & consumer n/a n/a --- n/a n/a --- 63 P olym ers containing P FA S-based chem icals. 64 See Q uestion 1 and the notes to T able 1 fo r Belgium . 65 Inform ation provided by a com pany. This com pany currently m anufactures/im ports several products containing PFA S related substances w h ich are sold as leather, carpet & textile im pregnation agents, surfactants, battery components, miscellaneous fluoropolymers and intermediates. These products contain either C1 or C4 PFA S-related substances and some o f those are (high m olecular weight) polym ers o f w hich the PFAS related substance is only 1 out o f several other monomers and reactants. For all currently com mercially available PFAS-related substances containing products the am ount o f m anufactured/im ported PFA S-related substances by this com pany is < 500 000 kg. 66 Im port: not determ ined. 67 See Q uestion 2 and the notes to Table 2 fo r Cyprus. 46 Question 7 (continued) ENV/JM/MONO(2005) 1 Japan New Zealand68 N o rw a y 69 Poland Slovenia Sweden70 Switzerland Manufacture Product/ /Import mixture name No/No No/n/a No/Yes No/No No/Yes - Fumetrol Yes/Yes Y e s /Y e s 71 * * * - PFAS Chemical Name/ CAS No. - TetraethylammoniumheptadekaFluorooctane Sulphonate CAS No. 56773-42-3 CAS No. 67584-42-3 CAS No. 67906-42-7 & CAS No. 67584-83-6 Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year - 800 Import* Import/ manufact. 38 000 (total) Conc. of Substance in Product/ mixture - 10% * 0.0005 ~ 0.025 Known Uses of the Product/mixture - Wetting agent * Wax & other polishing preparations washing agents. Specify if Industrial and/or Consumer use, if possible - Metal finishing Industrial Industrial/ consumer 68 See Q uestion 1 and the notes to Table 1 fo r N ew Zealand. 69 N orw ay does not have inform ation o n w hether the im port is as pure PFA S o r in m ixtures. See Q uestion 6. 70 " *" data could not be disclosed due to secrecy reasons: < 3 com panies have reported the m arketing o f the p roduct containing the substance. 71 B ased o n survey o f Swiss P roduct R egister, w hich includes b o th PFA S an d P FA S-related substances, and products/m ixtures containing PFA S o r P FA S-related substances. The data bank can not prove that registered substances or products are still in use. . For historical reasons, also generic term s instead of univocal substance names w ith CAS numbers were partially used. Due to this feature of the data bank it also can not be guaranteed that all substances in use are detected in the search See Table 3 and annexed Table A1. 47 ENV/JM/MONO(2005) 1 Manufacture Product/ /Import mixture name US Y e s /Y e s 72 n/a Question 7 (continued) PFAS Chemical Name/ CAS No. n/a Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year n/a Conc. of Substance in Product/ mixture n/a Known Uses of the Product/mixture n/a Specify if Industrial and/or Consumer use, if possible n/a 72 P roducts/m ixtures containing non-PF O S -related PFA S and P FA S-related substances o f v ary in g carbon chain lengths are b o th m anufactured in and im ported into the U .S. At this tim e, however, the U .S. has no inform ation that it is able to share concerning the specific identities or production/im portation volumes o f these products/mixtures. Many chemical identities and production volumes are reported as confidential business information. Additionally, these substances may be m anufactured or imported in volum es below regulatory reporting thresholds. 48 ENV/JM/MONO(2005) 1 Question 8: Importation/manufacture of PFOA and PFOA-related substances (Table 5):73 Manufacture (yes/no)/ Import (yes/no) PFOA Chemical Name/ CAS No. Australia B e lg iu m 74 Bulgaria Canada Cyprus Finland France76 No/No Yes n/a/Yes N o /Y e s 75 No/No No/No Yes - Palmitic acid, stearic acid, their salts and esters CAS No. 307-24-4 CAS No. 375-58-9 CAS No. 375-95-1 (Customs code: 2915 9080 0) Carboxylic acids, C7-C13, perfluoro, ammonium salts CAS No. 72968-38-8 Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year - Production: None Import: 212 458 (232 504 for year 2002) Known Uses of the Chemical - Specify if Industrial and/or Consumer use - n/a n/a Confidential - Surfactant in the polymerisation process of polyvinylidene fluoride Industrial 73 P FO A -related chem icals m ay be sim ple salts o f PFO A , e.g , sodium , potassium , silver, am m onium , o r polym ers that contain P F O A as only a portion o f the entire polymer. 74 See Q uestion 1 and the notes to Table 1 fo r Belgium . 75 Specific details are currently not publicly available. 76 T he response is fro m C hem ical Industry A ssociation. 49 ENV/JM/MONO(2005) 1 Manufacture/ Import Germany No/Yes Company 3 Italy Yes/- Japan Yes/Yes Question 8 (continued) PFOA Chemical Name/ CAS No. Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year CAS No. 3825-26-1 Octanoic acid pentadecafluoroCAS No. 335-61-1 Octanoic acid pentadecafluoro ammonium salt CAS No. 3825-26-1 Pentadecafluorooctanoic acid CAS No. 335-67-1 Ammonium perfluorooctanate CAS No. 3825-26-1 Lithium heptadecafluorooctane sulphonate CAS No. 29457-72-5 Potassium heptadecafluorooctane-1sulphonate CAS No. 2795-39-3 For 2003/2004 Use: < 50 000 Import: < 10 000 Future replenishment: < 5 000 < 1.000 < 36.000 < 100 0007/ < 100 000 < 100 000 < 100 000 Known Uses of the Chemical Essential emulsifier for polymerisation of fluoropolymers. Polymer processing aids, photographic film. Polymer processing aids, photographic film. Semiconductors, etc. Polymer production, etc. Surfactant, etc. Surfactant, etc. Specify if Industrial and/or Consumer use Industrial Industrial Industrial Industrial Industrial Industrial Industrial The regulation stipulates that it does not release the specific numerical volum e o f import/manufacture o f PFOA and its related substances if the total volum es o f them do not exceed 100 000 kg/year. 50 Question 8 (continued) ENV/JM/MONO(2005) 1 Manufacture/ Import PFOA Chemical Name/ CAS No. New Zealand78 Poland No/n/a No/Yes Sweden Switzerland79 No/No No/Yes UK Yes81 H e p ta d e c a flu o r o - 1-iodooctane CAS No. 507-63-1 Tetraethylammonium heptadeca fluorooctanesulphonate CAS No. 56773-42-3 CAS No. 3825-26-1 CAS No. 335-67-1 n/a Manufacture/Import Volume range of Chemical (kg) for 2003 calendar year Known Uses of the Chemical 0.0501 Reagent 0.100 Reagent (0.005 for year 2002) -n/a Paints, auxiliary. Textile cleaning/general n/a chemical/flux agent. n/a n/a Specify if Industrial and/or Consumer use - Industrial (3)80 Industrial (3) n/a 78 See Q uestion 1 and the notes to Table 1 fo r N ew zealand. 79 B ased o n survey o f Swiss P roduct R egister, w hich includes b o th P FO A and P FO A -related substances, an d products/m ixtures containing P F O A o r P FO A -related substances. The data bank can not prove that registered substances or products are still in use. . For historical reasons, also generic term s instead of univocal substance names w ith CAS numbers were partially used. Due to this feature of the data bank it also can not be guaranteed that all substances in use are detected in the search 80 N um ber in brackets indicated num ber o f actual registered products. 81 D etailed inform ation is not available. 51 ENV/JM/MONO(2005) 1 Question 8 (continued) Manufacture/ PFOA Chemical Name/ Manufacture/Import Known Uses of the Import CAS No. Volume range of Chemical Chemical (kg) for 2003 calendar year US Y e s /-82 Octanoic acid, pentadecafluoro-, Confidential; Total Manufacture of ammonium salt (also Ammonium U.S. manufacturing fluoropolymer dry resins perfluorooctanoate, or APFO) capacity less than and aqueous dispersions CAS No. 3825-26-1 660,000 lbs (300,000 kg; data source, AR226-1094) EU Yes Pentadecafluorooctanoic acid < 1 000 000 (since CAS No. 335-67-1 1994) Ammonium pentadecafluoro octanoate < 1 000 000 (since CAS No. 3825-26-1 1996) - Specify if Industrial and/or Consumer use Industrial. End use products made from fluoropolymers have both industrial and commercial uses - 82 C ertain fluorinated telom er chem icals m anufactured in and im ported into the U.S. m ay also b e P FO A -related substances. L im ited d ata indicate th at the 8-2 telom er alcohol (CAS. No. 673-39-7, 1-Decanol,3,3,4,4,5,5,6,6,7,7,8,8,10,10,10-heptadecafluoro) metabolises and degrades to PFOA. Additional research is underway to determine w hether other telom er chemicals can degrade similarly to PFOA. Specific telom er chemical identities and the production and im portation volum es associated w ith those chem ical identities are claim ed as confidential business inform ation (CBI) in the U.S. and cannot be reported here. Non-CBI prelim inary aggregate data reported to the U.S. on N ovem ber 25, 2002 by the Telom er Research Program (AR2261141) identified global T elom er A [ F(C F 2CF2)nI, w here n = 2-8] equivalents p roduced in 2000-2002 at approxim ately 5 to 6.5 m illion kg/year, w ith 40% o f that product distribution in the U.S. The follow ing chart presents the carbon chain length distribution o f that total production. % of Telom er Production Polym er N on-Poly me r Il C4 4% 99% 1% I 06 16% 45% 55% II 08 46% 85% 15% I O > 1O I 33% 88% 12% Total 1 oo% 80% 20% | 52 ENV/JM/MONO(2005) 1 Question 9: Importation/Manufacture of Products/Mixtures Containing PFOA or PFOA-Related Substances (Table 6) Australia Belgium Bulgaria Canada Cyprus85 Finland Manufacture (yes/no)/ Import (yes/no) No/Yes Y e s 83 Y e s /Y e s 84 n/a No/n/a No/Yes No/No Product/ mixture name PFOA Chemical Name/ CAS No. 6 PFOArelated polymers/ telemer containing Confidential n/a CAS No. 3825-26-1 n/a -- Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year 27 500 as PFOA related monomer Conc. of Substance in Product/ mixture Variable < 50 000 n/a 0.1% & 30% n/a -- Known Uses of the Product/mixture Surface coatings, textile treatment Intermediate. n/a - Specify if Industrial and/or Consumer use, if possible Industrial Industrial n/a - 83 See Q uestion 1 and the notes to Table 1 fo r Belgium . 84 Inform ation provided by a com pany. 85 See Q uestion 2 and the notes to Table 2 fo r Cyprus. 53 ENV/JM/MONO(2005) 1 Question 9 (continued) Manufacture/ Import Product/ mixture name PFOS Chemical Name/ CAS No. France Y es86 Polyvinylidene fluoride Surflon-111 S.WB CAS No. 72968-38 3 N o /Y e s 87* Aqueous dispersions of PTFE (polytetra fluoroethylne) & PFA Ammonium salt of PFOA CAS No. 3825-26-1 Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year Confidential 88 Conc. of Substance in Product/ mixture < 2ppm89 < 0.1% (PTFE) < 0.1% (PFA) Known Uses of the Product/mixture Chemical indust.: tubes & fittings, Semiconductors: buildings, cables, isolation. Coating products (frypan, sauce pan, ...) as non stick coating. Non-stick coating in many electrical appliances (barbecue, sandwich makers, fryers, ...) Specify if Industrial and/or Consumer use, if possible Industrial Indust.90, 91 86 Inform ation provided by the C hem ical Industry A ssociation. 87 Inform ation provided by a sm all household appliances m anufacturer. 88 Aqueous dispersion o f PTFE (60% PTFE - 40% water), aqueous dispersion o f PFA (50% PFA - 50% water). 89 200 pp m o f total surfactant w hich is approxim ately less th a n 2 p p m o f P F O A in the polym eric matrix. 90 P F O A is not present in any o f their finished goods. The non-stick coating o f articles used by consum ers does not co n tain PFO A , as P F O A is totally burned during industrial therm al transform ation at 400 - 420C. It has been proved by three independent analyses, available on request. 91 A t the end o f 2000 asked their suppliers o f aqueous dispersions o f P T F E to study new dispersions o f P T F E and P FA w ith reduce concentration o f PFO A . They have approved, at the end o f 2003, only one type o f dispersion o f PTFE w ith a low concentration o f PFOA (between 30 - 100ppm = 0.003 - 0.01%), this new dispersion o f PTFE is used. Four others are in test and two dispersions could be approved at the end o f 2004. Unless the drastic reduction o f concentration o f PFOA in the preparations, it appears that they cannot manufacture non-stick coating without a small am ount o f PFOA. 54 Question 9 (continued) Manufacture/ Import Product/ mixture name PFOS Chemical Name/ CAS No. Germany Italy Yes/No Company 3 Company 4 Yes/No Aqueous fluoropolymer dispersions. 92 Algoflon (PTFE) dispersions CAS No. 3825-26-1 Perfluoroalkyl surfactant Ammonium perfluoro octanoate CAS No. 3825-26-1 Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year Confidential 30 000 2 700 000 Japan New Zealand96 Yes95 No/Yes97 - - - ENV/JM/MONO(2005) 1 Conc. of Substance in Product/ mixture Known Uses of the Product/mixture Specify if Industrial and/or Consumer use, if possible 0.5%93 Coatings94 Industrial 0.004% 0.07 0.08% - Corrosion protection. Metal coating, glass fiber impregnation additives of plastic resins. - Strictly industrial Industrial - 92 T rade nam e k ept confidential. 93 T he com pany has developed and is currently im plem enting technologies to rem ove the am m onium salt o f P FO A fro m aqueous dispersion products o f fluoropolym ers to a content less than 100 ppm. The com pany is com m itted to transfer all products to that standard by 2005. The A PFO rem oved from 94D uring these dispersions is recovered and recycled. processing, coating products are therm ally treated(sintered) to develop the final coating properties, consequently, the PFOA is rem oved and destroyed. 95 A lthough potassium , lithium , am m onium , diethanolam ine, o r polym ers m ay be subject to this questionnaire, Japan does not take them into account in its answ er since it is difficult to figure out a precise picture o f PFOA-related substances, and Japan does not have enough result o f hazard assessments o f each P FO A -related substance. T herefore, Japan is n ot able to provide the detail o f T able 6. 96 See Q uestion 1 and the notes to Table 1 fo r N ew Zealand. 97 A com pany im ported a quantity o f prim er paints that contained a total 4.25 gram s o f P FO A in total in 2003. 55 ENV/JM/MONO(2005) 1 Question 9 (continued) Manufacture/ Product/ Import mixture name Poland Slovenia S w e d en 98 S w itze rlan d 99 UK N o/N o N o/Y es N o/yes Y es/Y es Y e s 100 H ostaflon TF 5039 D icrylan 7581 * n/a PFOS Chemical Name/ CAS No. A m m onium pentadecafluorooktanoat CAS No. 3825-26-1 A m m onium pentadecafluorooktanoat CAS No. 3825-26-1 CAS No. 3825-26-1 n/a Manufacture/ Import Volume range of Chemical (kg) for 2003 calendar year 880 13kg in 2003 (129kg in 2002) Im port* n/a Conc. of Substance in Product/ mixture < 0 .2 % < 0 .5 % * n/a Known Uses of the Product/mixture Surface antistick. Thin layer leather * n/a Specify if Industrial and/or Consumer use, if possible Industrial Industrial Industrial n/a 98 " *" data could not be disclosed due to secrecy reasons: < 3 com panies have reported the m arketing o f the p roduct containing the substance. 99 B ased o n survey o f Swiss P roduct R egister, w hich includes b o th P FO A and P FO A -related substances, an d products/m ixtures containing P F O A o r P FO A -related substances. The data bank can not prove that registered substances or products are still in use. . For historical reasons, also generic term s instead of univocal substance names w ith CAS numbers were partially used. Due to this feature of the data bank it also can not be guaranteed that all substances in use are detected in the search See Q uestion 8 and notes to Table 5 for Switzerland.. 100 D etailed inform ation is not available. 56 ENV/JM/MONO(2005) 1 Question 9 (continued) Manufacture/ Product/ PFOA Chemical Manufacture/ Conc. of Known Uses of Specify if Import mixture Name/ Import Substance the Industrial name CAS No. Volume in Product/mixture and/or range Product/ Consumer of Chemical mixture use, if (kg) for 2003 possible calendar year US Yes/Yes101 Fluoropolymer Octanoic acid, n/a < 1% by Metal coating, Industrial use aqueous pentadecafluoro-, weight fiberglass cloth in dispersions ammonium salt (Data and coating manufacturing (also Ammonium source: formulations. both industrial perfluorooctanoate, AR226- and consumer or APFO) 1063) end products CAS No. 3825-26-1 (i.e., non-stick cookware, construction fabrics, etc.) 101 C ertain fluorinated telom er chem ical-containing products/m ixtures m anufactured in an d im ported into the U .S. m ay b e P FO A -related substances. L im ited data indicate that the 8-2 telom er alcohol metabolises and degrades to PFOA. Additional research is underway to determine w hether other telom er chemicals can degrade similarly to PFOA. Specific telom er chemical identities and the production and im portation volumes associated w ith those chemical identities are claim ed as confidential business inform ation (CBI) in the U.S. and cannot be reported here. 57 ENV/JM/MONO(2005) 1 Annex Table A1. Estimate for "Actual" Use and Application Fields of PFOS after the Retreat of 3M Products in Switzerland A ccording to (RPA & BRE, 2000)102 Actual use Photographic industry Photolithography & semiconductors Hydraulic fluids Metal coating Total use Storage of fire fighting foams Kg/year 19 9 14 190 230 2 300 Share (%) 8 4 6 82 102 Up to know there are no studies about substance flows or actual measurements o f concentrations in products available for Switzerland. The investigations carried out so far for Switzerland do not allow to answer the questions regarding use figures as detailed as inquired in Table 1 to 4 of this questionnaire. Consequently the estimates for Switzerland are based on data out of an international literature review. Literature that was used to estimate application fields and use figures for Switzerland is as following: > RPA& BRE (2004), Perfluorooctane sulphonate risk reduction strategy and analysis o f advantages and drawbacks, final report prepared by Risk & policy analysis limited and BRE Environm ent for Department for Environment, Food and rural affairs and the environm ent agency for England and Wales, August 2004. > H ekster F. M., Voogt, P. de, Pijnenburg, A.M .C.M ., Laane, R.W .P.M . (2002), Perfluoroalkylated substances - Aquatic environm ental assessment, Report RIZK / 2002.043, 1 July 2002. > H avelund, S. (2001), K o rtlsg n in g a f perfluorooktanylsulfonat og lignende forbindelser i forbrugerprodukter - fase 2, M iloproject No. 691, 2002, M iljostyrelsen, Miljoministeriet. The results are presented in the Table A1. There are indications that PFOS/PFAS are still in use also in applications not pointed out as application fields after 3 M retreat by RPA&BRE (2004). 58 Table A2. EU Uses Found for PFOS and PFOS-Related Substances. Industrial category_______________________________ _____ Chemical industry: used in synthesis____________ _____ Metal extraction, refining and processing o f metals _____ Paints, lacquers and varnishes industry__________ _____ Paper, pulp and board industry__________________ _____ Polymers industry_____________________________ _____ Textile processing industry_____________________ Other Type______________________________________ _____ Non dispersive use_______________________ _____ Used in closed system____________________ _____ Use resulting in inclusion into or onto matrix _____ Wide dispersive use______________________ Use category______________________________ _____ Fixing agents__________________________ _____ Flame retardants and fire preventing agents _____ Foaming agents________________________ _____ Impregnation agents____________________ _____ Intermediates__________________________ _____ Solvents______________________________ Other 59 ENV/JM/MONO(2005) 1