Document a1nQpMyoOv7myyNyOyg3ypO2b
RED FLAG
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GUJARAT RUOROCHEMICALS
Ad-Hoc open BCR Meeting PFAS Restriction
28 March 2023
Fluoropolymers are safe: different from other PFAS
Fluoropolymers are not harmful and pose no significant risk to human health or the environment
Distinct subset of PFAS, with unique toxicological properties:
Not soluble in water
Fulfil the criteria established by the Organization for Economic Cooperation and Development (OECD) to be regarded as Polymers of Low Concern
Fluoropolymers are safe: manufacturing & EOL
During manufacturing: Today, majority of FPLs can be manufactured without the use of PFAS of concern through use of non-fluorinated polymerization aids. Advanced abatement technologies significantly reduce emissions during manufacturing.
At end of life: Incineration: thermally decomposed in incineration facilities. [RIVM, GORE, GFL] no significant PFAS generation at temperatures > 850C (Municipal WI) Mineralisation at temperatures > 1100C (Industrial WI) Landfills: FPL waste is inert, non-toxic and not mobile. No threat to human health or environment [GORE]
Fluoropolymers are indispensable
FPLs are an integral building block of the modern world with unique properties that are essential for a wide range of societally beneficial applications:
Renewable energy Electric vehicles Semiconductors Chemical process Industry Transport Food and water treatment Pharmaceutical and medical devices
Fluoropolymers are mostly used to keep us safe at the
performance we need
Fluoropolymers are essential for the success of the energy transition and
on-shoring of key technologies
Fluoropolymers are very stable - key to circularity
To meet climate targets, the EU needs to move away from the linear economy
CIRCULAR ECONOMY DEFINITION (WBCSD)
The circular economy is an economic model that is regenerative by design. The goal is to retain the value of the circulating resources, products, parts and materials by creating a system with innovative business models that allow for renewability, long life, optimal (re)use, refurbishment, remanufacturing, recycling and biodegradation.
Ellen MacArthur Foundation circular economy principles: Design out waste and pollution Keep products and materials in use Regenerate natural
Concluding...
Fluoropolymers: Are safe and very different from small molecule PFAS Do not pose an unacceptable risk to humans nor the environment over their life Are paramount to functioning of modern society across the globe Key to reaching climate goals Should be exempted from REACH regulation
Thank you