Document Yjga7BXnn51z2pRRvp744XQ68

EURATEX submission to ECHA consultation on the U-PFAS restriction Input on PPE Directive Category III (j) cuts by hand-held chainsaws September 2023 In the proposal sent to ECHA, Annex E (page 30) the following reasoning as to why PPE against chainsaws do not get a derogation, was provided: Firstly, to "bullet wounds and knife stabs", there must be a mistake at the report, as hand-held chainsaws are not clearly linked to bullet wounds and knife stabs. Secondly, the first sentence of the rationale (last column) is correct. Indeed, the outer textile layer of a protective garment is not cut-resistant. However, the second sentence is fundamentally incorrect, as the outer (conventional) fabric layers must be made oil repellent. (see the orange layer in the picture bellow). Chainsaws run at speeds of 20 m/s up to 28 m/s (as to EN ISO 11393-2) and the chain is constantly lubricated with machine oil. This means that machine oil in constantly `projected' on the outer (in this case orange) textile fabric (which is indeed on itself not cut resistant). However, under this outer fabric is a protective textile multilayer cut resistant insert, and the protection system is based on pulling out HT (high tenacity) yarns and blocking the sprocket of the chainsaw. This happens in a couple of hundreds of milliseconds. The HT yarns should be `loose' enough to be easily pulled out; however they must be `fixated' enough not to come loose from the outer fabric during use (at the seams) of during washing. This is a delicate balance/compromise. When the outer fabric is only water repellent, and no longer oil repellent, the machine oil will go through the outer fabric and be absorbed by the cut resistant multilayer protective insert. This on itself will change the above-described delicate balance/compromise and cut resistant behaviour. For further information, please see the additional documents added under Annex II folder: 1) publication of the `Beratungsstelle fr Unfallverhtung in der Landweirtschaft (see marked text in green on second page) 2) a presentation by prof. Wolff from the Hochschule fr Forstwirtschaft Rottenburg (see 9th slide) 3) "Factors Influencing the Effective Life of Chainsaw Protective Legwear" (see 1st and 2nd recommendation at the end of the article) Additionally, we would like to draw attention to EN ISO 11393, which is a series of related standards (on leg, body, foot, ... protection). Below extract from EN ISO 11393-2: 2019 is valid for all: Below extract from the standard is in contradiction to what is written in the rationale. However, it is indeed correct that the cut resistance is obtained by a protective (multilayer textile) insert. It is a delicate balance/compromise between fixating the yarns enough not to come loose during wear, washing, ... but not to strong so they can be easily pulled out by the chain moving at the speeds mentioned in 4.7.1 of the standard. The chain in constantly lubricated with machine oil. This means that machine oil in constantly `projected' on the outer (in the above picture orange) textile fabric; This stopping of the chainsaw happens in a couple of hundreds milliseconds. When the outer fabric is only water repellent, and no longer oil repellent, the machine oil will go through the outer fabric and be absorbed by the cut resistant multilayer protective insert. The additional documents added to the Annex II folder also talk about washing the PPE regularly. It's the PPE Manufacturer who signs the DOC (Declaration of Conformity) and takes the responsibility for the CE compliance of this category III PPE; but the manufacturer should also do a risk analysis. The PPE EU Regulation 2016/425 says that in the risk analysis the manufacturer should not only look at the intended use and the foreseeable conditions, but also the reasonably foreseeable conditions of use. In reality these chainsaw protective PPE are not regularly washed, and at least not after each use. Hence the crucial importance of having an oil resistant outer fabric. PPE multilayer protective clothing is relatively thick and heavy to give the cut resistance against chain saws, so there is an inherent discomfort. To stimulate the end-users to wear this PPE, manufacturers must make them as comfortable as possible and maximize breathability and air permeability. Hence, the water- and oil repellency of the outer fabric is obtained by a permeable finish, this means that PU of PES membranes as suggested in the list of PFAS alternatives in E.2.2.2.1 and table E12 of Annex E are excluded. Other state of the art permeable PFAS alternatives do not give oil repellency! The guidelines of PPE EU Regulation 2016/425 says that manufacturers cannot be expected to use solutions which are still at the research stage or technical means that are not generally available on the market.