Document baKDaEG6vXZExMaXqYBooVb23

EURATEX submission to ECHA consultation on the U-PFAS restriction Input on PPE Directive Category III (l) bullet wounds or knife stabs September 2023 Relating to restriction proposal's Annex E, table E. 131 and the conclusion that `no PFAS required'. The rationale is correct that only water repellent treatments of the para-aramid are necessary, and this for 2 reasons: -moisture present in between the multilayer para-aramid textile layers can act as a lubricant for an impacting heated bullet -para-aramids have very high mechanical (tensile) strength but are susceptible to hydrolysis (depolymerization) which causes a drastically drop in tensile strength, hence the protection level There is a list of PFAS alternatives in E.2.2.2.1 and table E12 of Annex E. The composition of ballistic and/or stab resistant vests can be very complex. To date it has not been proven that these PFAS alternatives on itself cannot have a lubricating effect on penetrating heated bullets or knifes. As per PPE Regulation EU 2016/425, the manufacturer of (soft) `body armour' vests must sign a DOC (Declaration of Conformity) by which they take full responsibility that the produced and delivered PPE meets the identified requirements and is identical to the Module B certified product and technical file. Typically for body armour, (public) procurers and end users ask for 10 - 15 years of warranty! Another end use of para-aramids is in Firefighting PPE, where a mixture of 60% Para-aramid (for it high mechanical strength) and 40% PBI (for it is high LOI = Limited Oxigen Index; but lower mechanical strength). The study of Saiful Hoque et al (Univ. Of Alberta) has identified that PBI has a sulphur residue which in combination with moisture creates an acid, which attacks the para-aramid (hydrolysis) lowering it mechanical strength (even more important/critical for ballistic applications). To date it has not been proven that these PFAS alternatives cannot cause hydrolysis of para-aramids over time (taking into account 10 - 15 years of warranty). 1 U-PFAS restriction proposal, Annex E - https://echa.europa.eu/documents/10162/57812f19-8c98-ee67-b70f6e8a51fe77e5, page 30 The sensitivity of this potential issue is illustrated by below case with another fibre PBO of Zylon. https://archives.fbi.gov/archives/washingtondc/press-releases/2011/wfo012511.htm For combined protection against bullets and knifes, a certain stiffness is incorporated into the multilayer protective pack; but at the same time it's important the layers can `glide' freely over one another for the knife resistance. Cases are known where these layers start to stick to one another after 5, 6, 7 years... To date it has not been proven that these PFAS alternatives don't have a worse effect on this. 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. LSU EURATEX ==h= TIZTI=TT Te cutpean appaReL Z1IZ1 IZ AND TEXTILE CONFEDERATION Preliminary Remark 3 "stateof the art" `The notion of "state of the art" is not defined as such in the PPE Regulation. However. it is clear fiom Preliminary Remark 3 that the notion of the "state of the art" includes both technical and economic aspects. In order to correspond to the "stateofthe art", the technical solutions adopted to fulfil the EHSRs must employ the most effective technical means that are available at the time for a cost which is reasonable taking account of the seriousness of the `hantheriskreductionisrequired toaddress. It may not always be possible to satisfy certain EHSR fully. given the current "stateof the art". In such cases. the PPE manufacturer must strive to fulfl the objectives set out in the EHSR (0 the greatest extent possible Manufacturersof PPE cannotbeexpected to use solutionsthatare sill atheresearchstageor technical means that are not generally available on the market. On the other hand. they must take account of technical progress and adopt the most effective technical solutions that are appropriate to the PPE concerned when they become available for a reasonable cost. "The "state of the art" is thus a dynamic concept: the "state of the art" evolves when more effective technical means become available or when their relative cost diminishes. Thus a technical solution that is considered to satisfy the EHSRs of the Regulation at a given time may be considered inadequate at a later time. if the state of the art has evolved. Usually. `hannonised European standards are taken as a reference to define the "stateofthe art" at a done moment. A PPE manufacturer can only take account of the "state of the art" at the time the PPE is THE VOICE OF THE EUROPEAN TEXTILE AND APPAREL INDUSTRY Rue Bellord 40 Box 2| B-1040 Brussels +322285 4081 [wwweoratexu