Document qm0x67a54wgv22mjbwERaex8j

REACH PFOA Restriction Enforcement Development of EU standardised analytical methods Background and Purpose o REACH PFOA Restriction sets forth two different concentration limits: 25 ppb for PFOA and its salts and 1 000 ppb for one or a combination of PFOA-related substances, in other substances, mixtures or articles o Recital 12 states that "The deferral period for the restriction should allow the further development of suitable analytical methods that can be applied to all matrices. " o The FluoroCouncil would like to highlight the complexity of developing reproducible, cost-efficient analytical methods for all matrices in scope and against the given thresholds o The FluoroCouncil would like to underline the importance of timely adoption of analytical methods to enable effective enforcement o The FluoroCouncil is willing to take part in the process to share its knowledge and experience 2 Introduction to FluoroCouncil and FluoroTechnology 3 About the FluoroCouncil Represents leading manufacturers of FluoroTechnology products Member companies: - Archroma Management LLC - Arkema France - Asahi Glass Co., Ltd. - Daikin Industries, Ltd. - Solvay Specialty Polymers - The Chemours Company LLC - Dynax (associate member) - W.L. Gore and Associates (provisional member) 4 FluoroTechnology Fluorotelomer-based products - Fluoropolymers Fluorotelomer-based products: polymers and surfactants "Short" fluorinated chains that may be attached to organic polymer backbones Modify material properties: surface modification & protection, water & oil repellency; soil resistance, wetting and spreading Applications: Textiles, Carpets, Paper, Stone & Tile, AFFF, Surfactants Fluoropolymers (Fluoroplastics & fluoroelastomers) High molecular weight polymers PTFE, Melt Copolymers, Thermoset Elastomers Fluorinated "backbone" Material properties: chemical resistance, thermal stability, resilience (elastomers) Applications: Breathable membranes, Aerospace Materials, Hydraulic tubing, Chemical Processing , Semiconductor Manufacture, Transportation 5 FluoroCouncil's views on analytical methods to enforce the REACH PFOA Restriction 6 What is needed? o European Standard in order to demonstrate if the limit values set in the REACH PFOA Restriction are met or not, for : 1. Fluorotelomers (fluorinated polymers and surfactants) 2. Fluoropolymers and fluoroelastomers (not covered as such by the Restriction) o Initial screening methods, easier to implement and less costly for enforcers Target analytes Sampling preparation FLUOROTELOMERS: FLUORINATED POLYMERS AND SURFACTANTS FLUOROPOLYMERS AND FLUOROELASTOMERS PFOA, 8:2 FTOH, monomer (fluorinated polymers), 8:2 FTS (AFFF) PFOA Matrix dependent: textile, firefighting foams etc. May differ between different forms of fluoropolymers and fluoroelastomers and matrix 7 FluoroCouncil's recommendations Analytical standards methods should take most account of the following two aspects: Practicability While sample preparation is matrix dependent, the analytical methods should be broadly available and applicable to the largest possible scope of products Economic feasibility The analyticals methods should not result in too high costs for industry and enforcers 8 Fluoropolymers/Fluoroelastomers Examples of analytical methods Analyte Matrix Type of fluorochemistry LOQ or LOD Instrumentation method Cost estimate PFOA Articles made of fluropolymers Fluoropolymers PFOA Aqueous polymeric dispersion Fluoropolymers ppb levels LC-MS/MS 500-1700 depending on matrix /sample preparation PFOA Articles made of fluoroelastomers Fluoroelastomers 9 Fluorotelomers Examples of analytical methods Analyte Matrix PFOA 8:2 FTOH Performance Textiles Performance Textiles Type of fluorochemistry Fluorotelomers LOQ or LOD Method Cost estimate ppb levels LC-MS/MS GC-MS/MS 500 (+ sample preparation cost) PFOA / 8:2 FTS Fire Fighting Foams Surfactants 10 Initial screening methods Analyte Matrix Type of fluorochemistry 8:2 FTOH vs. 6:2 FTOH Articles treated Fluoro- with fluorotelomers telomers PFOA Any matrix containing fluoroproducts (articles, resins, dispersions and other substances or mixtures) All fluoroproducts LOD or LOQ Instrumentation method GC/MS Cost estimate 250 ppm levels LC-MS/MS 250-450 (+ sample preparation cost) 11 Standard development process o PFOS precedent with CEN/TS 15968: o To our knowledge, technical specifications not yet converted to a European standard mainly related to reproducibility issues o Highlights complexity of the issue and extension to PFOA and PFOArelated substances. o Next steps in development of analytical methods and possibilities for the FluoroCouncil to take part in the process? o How could the Commission / ECHA Enforcement Forum support enforcement of the Restriction by competent national authorities? 12 Thank you 13