Document RpjJz99mxkNXo6eGZq1qvV7aV

From: Sent: To: Cc: Subject: (SPF Sant Publique - FOD Volksgezondheid) (SPF Sant Publique - FOD Volksgezondheid) < mardi, 28 novembre 2023 15:56 envcoord.health.fgov.be (SPF Sant Publique - FOD Volksgezondheid); RE: Feedback on deadline for PFOA POP entry . @health.fgov.be> Dear CCIM PFAS WG colleagues, Recently we received similar concerns from our Swedish colleagues on this PFOA entry for firefighting foam stocks (see blue text below). We suspect that there are similar concern regarding these uses for Belgium, it would thus be very valuable if you could indicate to us whether you are experiencing similar problems or are looking into this. Many thanks in advance for your feedback! Kind regards, We would like to share some experience from our side as well, Sweden has rather similar experience as FI that stakeholders will have problems meeting the 2025 target and we are also uncertain whether the requirements have reached all related stakeholders. Regarding stockpiles of AFFF: For years, Swedish authorities have propagated to stop using AFFF:s and PFAS-containing ones in particular. AFFF use has decreased substantially, and many Civil Protection services has stopped using foam completely, and today, only a few percent of fires are extinguished using foam. The Swedish Contingencies Agency has since 2022 a government assignment to administer the collection and destruction of PFAS-containing AFFF:s in stock at the Civil Protection services. Funding for PFAS-containing AFFFdestruction comes from the Swedish EPA budget post - prevention of contaminated land. Half-time description of the project at the Swedish EPA website (in Swedish). Today's figure: about 320 tons AFFF is destroyed and of civil protection services joined. The situation in the private sector is unclear, but most likely amounts of AFFF are at least in the same order of magnitude as in the Civil Protection services. In March this year The Contingencies Agency published a guidance on the environmental effects of contaminated fire water of which PFAS constitutes a part of the problem. The Swedish EPA will, before the end of the year, publish guidance for enforcement of fire extinguishing actors (both commercial and public ones). Regarding contaminated equipment: The Contingencies Agency has launched several pilot studies addressing efficiency of different techniques to clean and relining equipment (foremost tanks and piping of firefighting trucks), and some Civil Protection services has done monitoring pre and post cleaning of equipment.. In most cases recontamination occurred after a period of time concentrations increased continuously to reach tens of thousands ng PFAS11 per litre after two months. 1 . Tel: @health.fgov.be Galileelaan, 5/2 1210 Brussel www.health.belgium.be From: (SPF Sant Publique - FOD Volksgezondheid) Sent: mercredi, 22 novembre 2023 10:55 To: envcoord.health.fgov.be Cc: (SPF Sant Publique - FOD Volksgezondheid) < . Subject: RE: Feedback on deadline for PFOA POP entry @health.fgov.be> Dear CCIM PFAS WG colleagues, As follow-up on this concern regarding the PFOA POP entry you can find a response from colleagues of FI on this question: Thank you for raising this important issue. We have been working on this matter domestically as well, although our scale is much smaller than in Germany. We have not (yet) received any information from stakeholders that they would not be able to meet the 2025 target. We are, however, somewhat uncertain whether the requirements have actually reached all related stakeholders and whether all AFFF holders are actually aware of the problem, continue working to reach out to all. We can't really see how the deadlines set by Stockholm Convention could be extended, though.. The companies would always have chance to replace C8 foams with C6, which would be a little easier than to go straight to F3s, although it would make a little sense economically (or likely environmentally either). Related to this we would like to hear your experiences and perhaps discuss common approaches on how to deal with the potential PFOA/precursor residues in the systems and alternative foams. We are still in the process of gathering experiences in cleaning up the systems from PFOA/PFHxS/precursor residues and we are requested to provide guidance values for specifying what could be considered "clean". An additional challenge is the rebound rebound of PFAS from the system surfaces back into the foam solution (that could be fluorine free to begin with). We have little information on if, or when, or to what extent the residues would contaminate the fluorine-free contents at levels where they would have to be considered C8 foams again. Finally I would like to advertise that our project under the Arctic Council on AFFF transition guidance has been completed recently: https://arctic-council.org/about/working-groups/acap/home/projects/afff-aqueous-film-forming-foam-andother-pfas-containing-foam-phase-out-in-the-arctic/ The background documents and transition manuals are freely available on the site if you find them helpful. You can disregard the disclaimer: the deliverable have been approved on the working group level by all 8 Arctic countries. It will likely take some time before they can be adopted on the ministerial level for reasons you all know. We will continue working on pilot projects in 2024 and gather further experiences on the transition. 2 . Tel: @health.fgov.be Galileelaan, 5/2 1210 Brussel www.health.belgium.be From: (SPF Sant Publique - FOD Volksgezondheid) Sent: mardi, 14 novembre 2023 10:58 To: envcoord.health.fgov.be Cc: (SPF Sant Publique - FOD Volksgezondheid) < . Subject: Feedback on deadline for PFOA POP entry @health.fgov.be> Dear CCIM PFAS WG colleagues, We have received information from the German Competent Authority for POP regarding the concerns on the deadlines of certain PFOA uses that will no longer be derogated after July 2025. More specifically it is asked whether other countries are experiencing similar challenges with stockpiles of certain uses, which could make it challenging to reach the July 2025 deadline. The following uses of PFOA are concerned for the 2025 deadline: photolithography or etch processes in semiconductor manufacturing, photographic coatings applied to films, invasive and implantable medical devices fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems Could you inform us on whether you have similar concerns or have received these concerns from stakeholders? FYI below you can find the exact question from Germany: In the course of our reporting activities on stockpiles, we identified the following issue with fire-fighting foams containing PFOA. The enforcement authorities informed us that many companies will not be able to meet the deadline of July 4, 2025 due to different reasons: some companies were not aware of the deadline; some underestimated the effort involved; some did not follow the regulations as a whole; in some cases, there is probably also a lack of financial resources. This is in line with the feedback from a consultant to the fire departments with whom we are in contact. According to his estimate, around 2000 systems in Germany will be affected and would be non-compliant from July 5, 2025. What is the experience with this issue in your country? How do we want to proceed? Is a request for an extension of the deadline, also for the Stockholm Convention, an option? Kind regards, 3 . @health.fgov.be Galileelaan, 5/2 1210 Brussel www.health.belgium.be 4