Document nkQJ7qLwa4QK8erzJQrwQO5R1

GAMBICA Dear ECHA Risk Assessment & Socio-economic committees, GAMBICA is the association for manufacturers of Instrumentation, Control, Automation, and laboratory equipment in the UK. Membership comprises over 200 companies from large multinationals to over half being SME's, exporting around half of products to the EU. Compared to large volume consumer products, our members' products are relatively low volume industrial products sold to other businesses. The GAMBICA Association Ltd Rotherwick house 3 Thomas More street London MN 1YZ T 8080 E (agambica.org.uk W gambica.org.uk GAMBICA members are passionate about protecting people, animals, and the environment from harm. In fact, some members' instruments are used to detect the presence of PFAS and other SVHC's. However, we believe that the restriction should be for PFAS's which are proven to cause harm and applications where harmful PFAS is released into the air, water, soil or directly to humans. Certain compounds with a single isolated -CF2- group are generally understood not to degrade to any of the highly persistent substances that have given rise to the environmental and/or human health i.e., they do not degrade into 'arrowhead substances'. Low volume essential industrial applications of PFAS are subject to special handling at end of life and are not disposed of at municipal consumer waste collection sites. PFAS's are environmentally persistent and resilient so therefore alternatives are likely to have similar properties. Therefore, a comprehensive analysis is required before alternatives are used to avoid 'regrettable substitution'. Below is a non-exhaustive list of PFAS presence in GAMBICA members' products. Detailed derogation requests have been submitted to ECHA for individual applications and industry sectors. Members are largely reliant on components supplied to them and therefore we request at least a 12-year derogation for all industrial instrumentation, control, automation, and laboratory equipment whilst viable alternatives are investigated and validated. PTFE in laboratory filters PTFE coated oxygen permeable membranes. PTFE tape PTFE, FEP tubing FKM, FFKM, PTFE, PCTFE O-rings Er seals PTFE, PFA, FEP, ETFE valve liners for harsh chemical environments PTFE valve packing PCTFE, PTFE, ETFE valve seats In general, substances from the PFAS group are contained in materials such as PTFE, FEP & FKM. These materials are used, for example, for seals in glands and connectors, but also for cable sheaths and for components in the cable (tapes) that are used in particularly challenging environments. Representing UK Instrumentation, Control, Automation and Laboratory manufacturers. The GAMBICA Association Ltd Registered in England & Wales No. 1583204