Document nambQqX9wbRXQkXxob1Rp46w

AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Company description Company Name Axon cable SAS Country France Contact person name Agnes Deuwel Role QSE Manager Telephone number 00 33 3 26 8170 00 e-mail address @axon-cable.com Axon Cable is a French owned company having its head office located in Montmirail, Marne. The company has various subsidiaries over the world and exports 70% of its turnover. The company employs 2800 people worldwide, of which 1000 people are located in France. axon' cable& interconnect GLOBAL SIRES, HIGMEERMG 6 MRAUFRCTURIAG FOOTPRIOT RCROSS 3 COfTIDEfTS 4 EUROPE Sales & Design in France, UK, Germany, Spain, Hungary & Latvia Production Development centres in France and UK Volume production in France. Latvia and Hungary R&D in France I RMERICRS Sales, Design, Production in Chicago P:-:ume Production in Mexico & Design in Brazil *il ASIR Sales, Design & Production centres in China and India Sales & Design in Japan Axon' Cable is a world leader in specialist interconnect systems. The company excels in the design and manufacture of wires, cables, terminated harnesses, connectors and integrated systems for high technology applications including aeronautics, military, space, oil and gas exploration, medical electronics, research centres, automotive and consumer electronic 1 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission 2 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission 3 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission 4 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Axon' wires and cables are mainly insulated with Fluoropolymer materials that are purchased to several manufacturers that are part of Fluoropolymer Products Group : Fluoropolymers are high value polymers that play an essential role in many industrial applications. This is due to their unique characteristics, as they are virtually chemically inert, nonwetting, nonstick and highly heat resistant. The fluoropolymer group is composed by extremely stable specialty plastics, elastomers (fluoroelastomers - FKM), and liquid polymers such us PTFE, PVDF and (per)fluoropolyethers1. They are part of a broader family of chemicals known as Per and PolyFluorinated Alkylated Substances (PFAS), based on the OECD classification2, which in its wider definition may include more than 10,000 chemicals. While fluoropolymers show significantly different properties from the health and environmental hazards perspective to other PFAS, a broad restriction proposal from EU authorities that would include 1 FPs (Fluoropolymers/Fluoroplastics) are defined in document "Understanding FluoroTechnology". FPG. Plastics Europe. 2017 2 OECD classification on PFAS : http://www.oecd.org/chemicalsafety/portalperfluorinatedchemicals/aboutpfass/ 5 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission fluoropolymers, without taking into account their specificities, could have a dramatic impact for our company and our customers. Fluoropolymers represent a clearly differentiated group within the vast family of PFAS. Fluoropolymers are durable and stable in the environment, properties which are necessary for their application, but not bioaccumulative or toxic, therefore they do not meet the criteria for restriction. For this reason, we would like highlight, with accurate and verifiable data, the fact that covering fluoropolymers in the broad PFAS restriction would not be an efficient and proportionate regulatory option for these polymers, and that alternative procedures to adequately control the very specific situations that may raise concerns from the use of fluoropolymers are possible. As a key company involved in downstream uses of fluoropolymers, we understand the consequences that a ban on the use of these materials may have. As Manufacturer of Articles, we are committed to responsible product stewardship practices and will continue to work closely with regulatory authorities and our customers around the globe to ensure that our products continue to provide all the benefits and innovations for which they are used with confidence. Throughout our internal processes of regulatory watch and exchanges with our professional organizations and our providers of fluoropolymers, we have actively participated to the Call for Evidence. This document provides our feedback to the public consultation to the PFAS (Per and polyfluoroalkyl substances) REACH restriction proposal. Axon Cable is requesting the Fluoropolymers not to be included in the Restriction proposal. 6 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission II. Summary of Products and their Applications Product Field of application Short description of the product Wires, Electrical Cables and Aerospace Connectors Wires, Electrical Cables and Medical devices Connectors Wires, Electrical Cables and Connectors Petroleum (oil & gas) & mining Cables for Aircrafts, flight commands for Aircrafts, Satellites, e-VTOL, Drones, communication applications, radars, optronics systems, etc... for civil market or defense market Cables for of Artificial Hearts, robots for surgery, implantable hearing aids, endoscopes, catheter etc... Heating Cables for Oil Pipes and Cables for Prospecting tools and equipments Wires, Electrical Cables and Connectors Electronics and semiconductors electrical wires, cables and manufacture semiconductors, Defense market connectors to expecially for Wires, Electrical Cables and Energy applications, including batteries and hydrogen Nuclear Research and production, Hydrogen Connectors market ( CERN projects ...) Wires, Electrical Cables and Connectors Transportation Miniaturize Automotive Cables, cables to depolluate engine circuit, waves guides Tubes Other... (please describe) fluids transportation (ink, solvent...) According to Table 9 of the Restriction project, our products can be found in the following Use sector / sub uses : Electronics & Semi Conductor - however tubes/cables/harnesses are not listed. Energy Sector (Wires) however tubes/cables and harnesses are not listed. Medical Devices (Tubes and Catheters) - however wires/cables and harnesses are not listed. Transport (automotive, aircraft, rail, marine, and aerospace industries) Petroleum and mining - oil & gas sector Fluoropolymers 7 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission III. Use of Fluoropolymers Volumes We are using Fluoropolymers as raw materials in different forms and in several processes - all are purchased inside Europe Economic Area (EEA). Fluoropolymer PTFE PFA ETFE FEP FKM FMVQ Form Powder, Dispersion Pellets Pellets Pellets, Dispersion Gum, Pasty Mixture Gum, Pasty Mixture Purchase (Tons) 35 3 7 20 2 2 IV. Finished Products - Volumes According Reach Regulation, our product are defined as "an article with no intended release" meaning that under normal and reasonably foreseeable conditions of use, no end user of the product will be exposed to any chemical substance. We have various productions sites in EEA : France, Marne area, Latvia. Our consolidated Turnover is about 200 M, of which 90% are relying on Fluoropolymers. V. Information on Functions and Alternatives 1. Electrical insulation in wires and cables Fluoropolymers are used when a combination of requirements needs to be met and not others materials solutions exists. For example: High volume resistivity (insulation resistance) / miniaturization / mass saving High dielectric strength (breakdown voltage) High frequency and low loss High Temperature use (>150 / 200 / 250C) long term (>20000h) High Flexibility for integration in systems / mass saving / miniaturization Flame Retardant (safety) Outstanding Chemical resistance Arc tracking resistance (for Aerospace applications) 8 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Low Outgassing (for Space applications) UV resistance High Oxygen Index (for cryogenic applications, in Liquid Oxygen environment) This combination of properties is only possible due the chemical structure of fluoropolymers (physicochemical properties). It is therefore not possible to obtain them without the existence of CF bonds. There are several dedicated standards/specifications requiring the use of Fluoropolymers as electrical insulation in the following sectors: Aeronautic : Airframe Hookup Wires : AIRBUS ASN E02 specs; EN2266; EN2267; EN2713; EN2714 ; ABS 1356 ; Power Transmission / High Temperature Wires and Cables : ASNE0438; NSA935131; EN2854; ECS0844; EN4608; EN2346 Defense: Same as Aeronautic + MILSTD83513 + MILSTD32139 Space: All Space cables specifications require the use of Fluoropolymers (without exceptions). ESCC 3901 001 /ESCC 3901 002 / ESCC 3901 012 /ESCC 3901 013 / ESCC 3901 018 /ESCC 3901 019 / ESCC 3901 021 /ESCC 3901 024 /ESCC 3902 002 /ESCC 3902 003 /ESCC 3902 004 /ESCC 3401 029 /ESCC 3401 079 /ESCC 3401 086 / ESCC 3401 089 /ESCC 3401 090 /ESCC 3401 091 /ESCC 3401 092 /ESCC 3401 093 /ESCC 3401 094 /ESCC 3401 095 /ESCC 3402 /ESCC 3408 /ESCC 3409 001 /ESCC 3409 002 /MILC17 /EN 3375 /PAN 6421 /SSQ 21655 /ECS 0700 /ECS 0808 /JN1042 / JN1052 / JN1176 / JN1161 /JN1101 /JN1110 /JN1107 /MIL STD 83513 / SAS AS 22759 /MIL W 16878 / NEMA HP3 /NEMA HP4 / NEMA WC 27500 /MIL DTL 17 /GAMEG 13 /STANAG 4370 / EN 3375 /EN 4604 /ECS 0786 /ISO 19642 It is to be underlined that where "polyimide tapes insulation" is required in Space standards, this means a complex multilayer Polyimide tape with Fluoropolymer layers (usually FEP or PTFE). There is no Polyimide tape used without a Fluoropolymer layer. European Aerospace Companies have all integrated qualified wires and cables using Fluoropolymers insulation layers. In aircrafts, those modern wires and cables insulation systems are often called or known as TKT for "Teflon/Kapton/Teflon". The reason this configuration has been qualified is that it is the only solution that combines high electrical insulation, high electrical breakdown strength, high temperature use (safety), chemical resistance (to all oils, fuels and solvents), arc tracking resistance (safety), high flexibility (integration). No other material solutions and their combinations allow fulfilling aerospace standards requirements. In term of development history perspective, TKT solutions and the use of Fluoropolymers became a standard and mandatory because all previous solutions like full polyimides (Kapton) insulations systems have led to accident/airplanes failures due to arc 9 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission tracking / hydrolysis susceptibility. Others nonfluoropolymers substitution to fluoropolymers do not comply the aerospace specifications requirements. For example PAEK (PEEK, PEKK, PEKEKK, PEK,...), Polyimides, LCP, EPDM, Silicones, Polysulfones (PAES: PES, PPS, PSU, PPSU). All those and others high performances high temperature resistant insulation materials have been tested by Wire and Cable manufacturers but none are able to replace the fluoropolymer layer used in harsh environment as aerospace insulated wire and cables because they fail to comply to final combination of requirements (especially Arc Tracking..). 2. Dielectric Layer in high performance communication cables and connectors Fluoropolymers are used to reach Low Dielectric constant ( 2) and low dieletric loss up to 250C due to their apolar symetric structure (CF bonds around the carbon backbone structure for PTFE ; it is not possible to synthetize polymers with similar full long chain stable apolar symetric chemical structure with others atoms only with Hydrogen (polyethylene, polypropylene) and Fluorine (perfluoropolymers: PTFE, PFA, FEP). It is not possible to achieve similar performances with all others existing materials due to physical reasons. There are several dedicated standards/specifications requiring the use of Fluoropolymers as Dielectric Layer in cables and connectors in the following sectors: Aeronautic : Coaxial Cables: ASNE0293; ASNE0291; NSA935348; ECS0757; ASNE0406; ASNE0691; ASNE0692; ASNE0752; NSA935344; ASNE0690; ASNE0634 Defence: Same as Aeronautic Space : ESA ESCC3902 : All qualified data cables use fluoropolymers (without exceptions) ESCC 3901 001 /ESCC 3901 002 / ESCC 3901 012 /ESCC 3901 013 / ESCC 3901 018 /ESCC 3901 019 / ESCC 3901 021 /ESCC 3901 024 /ESCC 3902 002 /ESCC 3902 003 /ESCC 3902 004 /ESCC 3401 029 /ESCC 3401 079 /ESCC 3401 086 / ESCC 3401 089 /ESCC 3401 090 /ESCC 3401 091 /ESCC 3401 092 /ESCC 3401 093 /ESCC 3401 094 /ESCC 3401 095 /ESCC 3402 /ESCC 3408 /ESCC 3409 001 /ESCC 3409 002 /MILC17 /EN 3375 /PAN 6421 /SSQ 21655 /ECS 0700 /ECS 0808 /JN1042 / JN1052 / JN1176 / JN1161 /JN1101 /JN1110 /JN1107 /MIL STD 83513 / SAS AS 22759 /MIL W 16878 / NEMA HP3 /NEMA HP4 / NEMA WC 27500 /MIL DTL 17 /GAMEG 13 /STANAG 4370 / EN 3375 /EN 4604 /ECS 0786 /ISO 19642 If we look at other materials, they have limited performances. For example, Polyethylenes, Polypropylene and other polyolfinesbased materials : Applications limited to temperatures below 80100C (due to low CH bond temperature stability) with similar performances to Fluropolymers due to their apolar structure (CH symetric structure around the Carbon backbone) 10 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission All others materials (polyimides, PEEK, etc...) present by definition chemical structure that are more polars than polyolefines and perfluoropolymers (PTFE, FEP, PTFE). Therefore, the results will be getting final communication/data cables and interconnects products with higher dielectric loss (due to molecular polarity which disturbs the signals), and that are heavier and bigger (higher dielectric constant means thicker dielectric layer to obtain the same final electrical impedance). 3. Research Innovation and Development Axon' has a wide expertise for more than 30 years in Research and Development with more than 300 Engineers. One of their mission is to realize active survey and literature review on High Performances materials. The other mission of Research and Development is to evaluate materials properties in order to develop products (prototypes) with performances depending on markets, products, customer requirements and standards. Our knowledge is that our internal development cycle is of more than three years to identify and qualify a new material as an alternative. This time is not taking into account the time needed for the mandated bodies to certify the alternatives, whether at our customers according to their standards, or at national or international standardization organisations such as European Standards (EN), European Space Agency (ESCC), National Electrical Manufacturers Associations (NEMA), United States Military Standards (MILSTD) or International Standard Organisation (ISO). HalogenFree solutions could be alternative to Fluoropolymers, however they cannot be used when a combination of several parameters and performances are required in the same product: High Temperature (>150C) + Flexibility (Elastic Modulus <1000MPa) + High Ductility (Elongation at break >100%) + High Volume Resistivity (>1E+16 ohm.cm) + Low dielectric constant ( < 2,2) + Flame retardancy + Chemical Resistance. These nonexhaustive requirements are mandatory for Aerospace Wire and Cables in order to ensure safety, performances, miniaturization, mass saving. No other existing materials are able to fulfil them. In the table below, we have summarized for each potential raw material alternative, what are the limitations justifying why the material cannot be used as material alternative. Our conclusion is that the potential alternatives to Fluoropolymers are not alternative, as their performances and technical characteristics are not at the level of Fluoropolymers. 11 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Potential alternative to Fluoropolymers (FEP/PFA/ETFE, PTFE) Polyethylene (PE) Polypropylene (PP) and others Polyolefinbased materials Products product examined or groups Wire and Cables PVC Wire and Cables Glass / Ceramics / Mica Wire and Cables Polysulfones (PSU, PPSU, PPS, and Polyetherketones (PEEK, PEKK, PEKEKK,PEK) Wire and Cables Polyimides Wire and Cables Technical feasibility (performance, technical characteristics, etc.) Economic feasibility (cheaper, more expensive, reason) Limited temperature use (<100C) Poor Flexibility (Elastic Modulus >1000MPa) Not Flame retardant for dielectric applications Limited temperature use (<100C) Low volume resistivity <10E+14 ohm.cm High (poor) Dielectric constant (>4) Very stiff (Elastic Modulus >5000MPa) Low volume resistivity <10E+13 ohm.cm Low Breakdown Voltage Poor Ductility ( Elongation at break <10%) Susceptible to Humidity / water Limited temperature use (<180C) Very stiff (Elastic Modulus >3000MPa) Too High dielectric constant ( > 3) Amorphous polymers susceptible to stress cracking Very stiff (Elastic Modulus >3000MPa) High (poor) dielectric constant ( > 3) Susceptible to Arc tracking Susceptible to hydrolysis This is not an alternative product This is not an alternative product This is not an alternative product This is not an alternative product This is not an alternative product 12 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Potential alternative to Fluoropolymers (FKM/FVMQ) EPDM rubber Nitrile rubber (NBR) Hydrogenated (HNBR) Acrylic rubber Ethyleneacrylic (AEM) rubber Silicone Products product examined or groups sealing elements, cable insulation, shock absorbers, O rings sealing elements, cable insulation, shock absorbers, O rings sealing elements, cable insulation, shock absorbers, O rings sealing elements, cable insulation, shock absorbers, O rings sealing elements, cable insulation, shock absorbers, O rings Technical feasibility (performance, technical characteristics, etc.) Economic feasibility (cheaper, more expensive, reason) EPDM rubber is much less efficient in terms of temperature resistance. much less efficient in terms of oil resistance much less resistant to abrasion NBR is much less efficient in terms of temperature resistance, bad in Ozone resistance and bad exterior aging, poor in water vapour resistance. Acrylic rubber is less good in high temperature, less good in flexibility, low tensile strength, less good in resistance hydrocabure.... AEM rubber is less good in oil resistance, not good in case of temperature. silicone has Poor mechanical Properties (abrasion, cut through and tear resistance) Limited use at >180C (some can withstand 260C but few hours only) Poor dielectric properties Outgassing issues cheaper but it is not an alternative as its efficiency is poor. cheaper but it is not an alternative as its efficiency is poor. cheaper but it is not an alternative as its efficiency is poor cheaper but it is not an alternative as its efficiency is poor cheaper but it is not an alternative as its efficiency is poor. 13 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission VI. Impact Assessment Should Fluoropolymers be banned in Europe, the consequences for our activities are estimated as follows. the shutdown of all our factories Our Headquarters, which is also the main factory producing wires and cables, is located in France. Its shutdown will generate the shutdown of all its subsidiaries including those outside Europe, that means laying off : o 2000 people in Europe o 2800 people in total worldwide the difficulties and/or shutdown of our providers which are in majority in Europe the difficulties or even the shutdown of many companies located around our plants (for memory 1 industrial job creates 3 indirect service jobs). 70% of our Export Turnover is located in Europe. The majority of our customers are located in Europe. We expect many of them will no longer have any activity (e.g. aerospace, medical equipment, ....) in Europe, either in production or in sales. 30% of our Export Turnover is located outside Europe. We expect nonEEA competitors will gain our market share as they will be still using Fluoropolymers outside EEA. No possibility to reenter the market as no Fluoropolymerfree does not exist. End Users in EEA will be finally affected as they may not have access anymore to o Specific and Innovative health care o electric vehicle because of the reduced performance of the batteries o large number of electrical and electronics equipment due to the lack of semiconductors o constant and stable energy due to the stop of nuclear programs due to the lack of suitable components o products related to the manufacture of hydrogen o air travelling Europe sovereignty will be affected in terms of security and safety (Weakened defence and poor communications systems). We equip Electronics Products for Defence and Space, that are critical for European public safety 14 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission Indeed our product performs a critical function / meets a critical need in EEA in the following aspects : Environment: climate change mitigation/adaptation, circular economy, water sustainability, prevention of pollution or biodiversity. o We work since many years on the miniaturisation and the efficiency of our products. This is generating less consumptions of resources (at our factory, on our products). Our products last longer, which means less waste for our customers. o we equip nuclear plant o we work on hydrogen subjects Human Health : protection of public health o we equip medical devices o some of our products are resisting very extreme temperature, like in Fires, that helps to protect human health during crisis This would not be possible without the high performances of Fluoropolymers. VII. Measures of Protection for the Environment The policy of our company is to prevent pollution and to meet all regulatory and legal requirements. We perform regular monitoring onsite to control emissions to the environment during the manufacturing of our products. Since our activities are controlled by the government (Installations Classes pour l'Environnement ICPE according the French Environmental Law) we are subjected to : Yearly analysis of our rejects in the air (according to French Arrt dated 02/02/1998) 15 AXON'CABLE (+ADDIX SAS) Yearly analysis of our rejects in rain water : 30th May 2023 First Submission The water tank of an extruder machine is in closed circuit. There is no discharge of Industrial water to the municipality. We are subjected to the new regulation in France on the prevention of losses of industrial plastic pellets into the environment. As production site storing, transforming and transporting plastic pellets between different production sites, we are currently reviewing and improving our internal dispositions that are subjected to external audits made by independent certified organisms. Tracking and reporting of our wastes in the TRACK DECHETS database of the French Ministry of Ecological Transition Registering our products whenever applicable into the European SCIP Database 16 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission We are ISO 14001 approved for nearly 20 years. According our environmental managing system, we are periodically collecting, analysing and determining adequate action plans for any our activities that may have an impact for the environment. We are also ISO 9001 and AS9100 for more than 30 years. According our system for the management of the quality for all markets (ISO9001) and specific markets (AS9100, ISO13485, IATF16949) scraps and nonconformities are subjected to constant monitoring and improvement. Our processes are implementing both Preventive and Corrective dispositions according ISO 9001/EN9100/ISO14001 certifications: Prevention: monitoring input and output, risk analysis, control means and action plan to reduce any identified significate impact for the environment. Correction: containment and reaction plan against each event of emergency, Lessons Learned. 17 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission According our environmental risk analysis, the waste that might be generated by our processes using Fluoropolymers is treated according the applicable European regulations. Our scraps are of different types depending on the process and the materials. PTFE powder residues: powder residues in the form of PTFE cones are collected as chemical waste and revalued . Empty cans and barrels of Fluoropolymers: they are collected as chemical wastes and re valued. Semifinished or finished products scraps : they are sold to companies which valorize them. They are burnt to generate energy (R1) Soiled rags : they monitoring input and output, risk analysis, control means and action plan to reduce any identified significative impact for the environment. Liquid waste (water + ink) they are collected and revalued by certified organism (ORTEC) to generate energy (R1). Type of waste PTFE residues (cones) Liquid Waste (water+ink) Soiled rags Scraps of semi finished / finished products Disposition Energy Recovery Energy Recovery Recycled Recycled 2021 (T) 4 8 2 Confidential information 2022 (T) 5,8 12,6 2 Confidential information We have agreement with our different providers of collection & elimination of waste that Recycling or ReValorisation (like energy recovery) are the only way to dispose of our waste. Each waste is characterized through chemical analysis to identify its nature and the best way to manage it, in compliance with all applicable regulations, and our request to revalue or recycle each waste. This operation is done by our providers who are all certified manage waste. As our products are not directly put on the market, but are integrated in the systems of our customers, we do not have to date information on how our customer are managing end of life of their systems, that include our products. However, our products can be repaired or upgraded according the customer request and the technical possibilities of rework. 18 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission VIII. Measures of Protection for the Health & Safety Fluoropolymers are used in several processes such as 1. PTFE Extrusion: the material mixture (PTFE + Mineral Essence + Pigment") is prepared in a dedicated room. This mixture is pneumatically preformed to form a block of material which is introduced into a cylinder to be cold extruded around a metal conductor. The wire passes through an oven allowing evaporation of gasoline, then undergoes heat treatment. The yarn is then taken back to test benches to eliminate defects and package the product. A storage room is dedicated to the storage of essences and powders, on retention tanks. 2. FEP/PFA Extrusion : the material mixture (virgin material + pigment) is prepared in a dedicated room. This mixture is driven by a set screw inside a metal cylinder heated to a temperature regulated and adapted. The temperature causes the mixture to melt. The product thus achieved thanks to the action of a die forms a tube that is driven onto a conductor, creating insulation. Depending on the case, controlled cooling is carried out by water (city or softened) or by air (compressed). The product is then taken back to test benches to eliminate defects and package the product. A storage room is dedicated to the storage of pellets and pigments, on retention tanks. 3. Taping : The tape is mechanically wrapped around a metallic core and then is subjected to heat treatment. 4. Lacquering a liquid (PTFE or FEP coloured lacquer) is deposited on an insulated conductor or cable and then heattreated Safety instructions are in place wherever applicable (on the machines and/or in the workshop). MSDS are available in our ERP systems, in each workshop. Our ERP systems generates Simplified MSDS showing each risk and cautious measures, pictograms and associated PPC/PPE as protection. OELV are controlled whenever applicable. PPP / PPE are defined according the risk evaluation at the job station DUERP : o Ventilation, extractor hoods, laboratory fume hoods o Masks, Gloves, Protective Blouses Risk evaluation at the job station (DUERP) is mandatory by law in France. At minimum, the evaluation must take place on a yearly basis, and at each significant event (accident at work, safety and/or environmental incident, .). Risk evaluation is involving a multi discipline team 19 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission (operators, managers, safety/environment leader, employee representative bodies such as CSE, and occupational medicine). The risk evaluation and its action plan is evaluated on yearly basis by independent certified organisms such as AFNOR. Our company is one of the first to have been certified ISO 45001 in March 2018 by AFNOR. Before that, we were OHSAS accredited, which makes a total of nearly 20 years of commitment. According our Health & Safety management system, we are periodically collecting, analysing and determining adequate action plans for any our activities that may have an impact for the Health and Safety of our collaborators. Our processes are implementing both Preventive and Corrective dispositions according ISO 9001/EN9100/ISO45001 certifications: Prevention: monitoring input and output, risk analysis, control means and action plan to suppress hazards and reduce the risk of significate impact for the Health & Safety. Correction: containment and reaction plan against each emergency situation, Lessons Learned. 20 AXON'CABLE (+ADDIX SAS) 30th May 2023 First Submission IX. Conclusion Axon'Cable advocates for a balanced environment, based on scientific facts. As such, Axon'Cable shares the opinion of a large number of scientists, namely, that fluoropolymers must be distinguished from other PFAS. This is particularly true because fluoropolymers have very different toxicological profiles from other PFAS substances. According to OECD criteria, they are considered "Polymers of low concern (PLC)", "Fluoropolymers are nontoxic, not bioavailable, nonwater soluble and nonmobile molecules and are deemed as such to have no significant environmental and human health impacts". They are used in a large number of applications, some of which bring considerable benefits to society, up to meeting the ambitions of the European Union in terms of climate, energy, health and Industry. Currently, there is no alternative material that can replace fluoropolymers. And there is nothing to suggest that it could be otherwise in the short, medium or long term. Therefore, Axon Cable is requesting the Fluoropolymers not to be included in the Restriction proposal. 21