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Factsheet "PFAS in PAMCo" Process Automation - Monitoring - Control Fig. 1: True Air Radar Level measurement Fig. 2: Guided Wave Radar Level Measurement Fig. 3: Pressure sensors Electro and Digital Industry Association Fig. 4: Control valves and membrane valve for aseptic (pharma) and hygienic (food) applications Fig. 5: Flow Measurement device Fig. 6: Control valve Fig. 7: Common seal made of Fluoropolymers Fig. 8, Lined control valve Fig. 9, Self operated pressure regulator Fig. 10, Mixing /Flow dividing valve with Electric actuator or electric setpoint for District energy Fig. 11, Photo electric sensors 2 Fig. 12, Electric Accessories Positioner, solenoid, limit switch Fig. 13: Pneumatic accessories: Air volume booster, filter regulator, reversing amplifier Fig. 14: Dust measuring sensors Fig. 15: Diaphragm seal Fig. 16: Gas sample probe Fig. 17: Gas coolers / Peltier & compressor coolers Fig. 18: Filters / Heated & Unheated Fig. 19: Analyzer / Oxygen & multigas analyzers Fig. 20: Sample gas pump 3 Fig. 21: Mobile devices as workers equipments and batteries intended for use in environments as defined in 2014/34/EU (ATEX) Fig. 22: Human Machine Interface intended for use in environments as defined in 2014/34/EU (ATEX) Fig. 23: Field Junction Boxes and Control Cabinets (intended for use in environments as defined in 2014/34/EU (ATEX) Fig. 24. Purge Enclosure (intended for use in environments as defined in 2014/34/EU (ATEX) Fig. 25: Gas Analysis System - with Fluoropolymers filter, tubing, hoses Fig. 26: water sampler Fig. 27: Temperature measurement 4 Fig. 28: Process analytics (pH, chlorine, conductivity, oxygen,...) Fig. 29: process assemblys Fig. 30: analyzer system in environmental monitoring, industrial and municipal wastewater Fig 31: Gas Feed Unit to provide gas from the process to the analyzer Fig. 32: Camera sensor systems with fluoropolymer membranes and fluoropolymer seals Fig. 33: RFID device with fluoropolymer membranes Fig. 34: Fidas24 in EL3000 housing high temperature resistant sealing required, solenoid valves and PCBs included Fig. 35: Limas21 module - different piping versions offered, pressure sensor included Fig. 36: pressure sensor 5 Industry Overview and Products: Process Automation, Monitoring, Control (PAMCo) consists of measurement, monitoring and control systems and associated instrumentation. Function: Process Automation, Monitoring, Control and Drives equipment enables delivery of essential resources such as clean water, waste water other infrastructure (power and energy management, it and telecommunication, transport) safe food and beverage high quality pharmaceuticals, including vaccines and medical devices high quality biological pharmaceuticals reliable energy, metals and metal alloys, pulp and paper, building materials, mobile equipments (vehicles, mobile machines as for Construction, Agriculture, Forestry and Material Handling mobile devices (phone, tablet computers) transportation, recycling materials, and essential goods such as electronic components, chemicals, oil & gas, fertilizer, technical gases (Oxygen, Green Hydrogen ...), clean exhaust and combustion gases (marine sector) defense equipment. Scope: The PAMCo product range consists of a wide variety of devices that measure parameters and control processes. Scope of PAMCo Equipment in particular: Sensors Pressure, Flow, Level, Temperature, Force, Vibration, Inductive, Photoelectric, Capacitive, Magnetic, Valve, Cylinder sensors, Ultrasonic, Density, Viscosity, Gas and liquid process Analysis, Corrosion, Erosion & Heat Trace Monitoring, Flame & Gas Detection, Gas analyzers, Energy Monitoring, Dust, Light Actors Electrical Drives, pneumatic actuators, hydraulic actuators, pumps, self-operated regulators, valves Encoder Transformation of mechanical information into electrical information Monitoring and Control Basic Process control system (BPCS), Distributed Control Systems (DCS), Safety Control system (SCS), Plant Asset Management System (PAMS), Continuous emission monitoring systems (CEMS) Process Infrastructure Interfaces, piping, accessory as solenoid, pneumatic booster, filter-regulator and connecting systems, Electrical Power Distribution The PAMCo units operate as a single unit and failure could be catastrophic. Any failure could create an unstable and unsafe situation that could result in serious harm to people and/or the environment. PAMCo equipment has unlimited configuration flexibility to meet the wide range of processing requirements of the many industries served. 6 Market Information: Process Automation, Monitoring, Control (PAMCo) is a 194B global industry and a 56B European Industry. It consists of measurement, monitoring and control systems and associated instrumentation.i PAMCo market: - Turnover: 194 Billion worldwide / 56 Billion Europe i) - Employees: approx. 500.000 employees - PFAS related: approx. 75% Requirements Profile (Lifetime: 15+ years Internal development times: 2-5 years PAMCo certification times: 2-4 years Supplier certification times: 2-4 years Customer certification times: 2-4 years Required availability time of spare parts: 10-25 years after product termination Temperature resistance: -196 C up to +260 C Dielectric strength: r < 3 Flame retardancy: UL 94 V0/V1 Standards, certification/approvals, market/customer requirements: - EU / UKCA / Ordinary Location - Ex-approval (with multiple country transcriptions - Europe / America / Asia / Africa / Oceania) - Safety Approvals - Ship approvals - Food contact materials (Europe / USA / China) - Hygienic approvals (Europe / USA) - Radio approvals (Worldwide) The operating profile, to which PAMCo equipment is exposed, is defined by the industries using the technology, such as chemical processing plants, nuclear power plants, semiconductor manufacturing, mining, wastewater management, alternative fuels, oil and gas, rail and other mass transportation, and construction. These applications often involve exposure to multiple extreme environmental conditions simultaneously. PAMCo environmental conditions: - Hazardous environments are prevalent and include fire, explosion, and toxic chemical threats. These environments often require equipment certifications, namely ATEX Directive 2014/34 in Europe. - Broad chemical exposure is common due to the massive number of chemicals processed every day. These chemicals span the entire pH range and are processed at different temperatures and pressures. Example harsh chemicals include sulfuric acid, hydrofluoric acid and chlorine. - Low temperatures near -60C. Beyond this for cryogenic processing, PAMCo equipment can be exposed to temperatures down to -200C. - High temperatures near +200C. - High pressures near 150 bar to accelerate and influence reaction rates and to increase volume-time efficiencies. Pressures up to 1000 bar exist in some chemical processes. Key success factors of PFAS in PAMCo products: - Broad chemical resistance to virtually all chemicals - Low temperature performance down to -200C - High temperature performance up to +260C - Corrosion resistance 7 - Intrinsic flame resistance with a high heat of combustion and limiting O2 Index - Good electrical properties, excellent dielectric properties, high permeability for microwaves - Low friction / Non-adhesive resistance - Purity / inert Identified PFAS Uses In Finished Products / In Processes / In Machinery and Equipment of the Production Processes 1. Non-Contact Radar Level Measurement sensors using microwaves PFAS substance/substance group: PFAS-containing material/component: PTFE Microwave antenna and waveguide PFA Parts in contact with substances to be PVDF Electroniocs Enclosures FFKM/FKM O-Ring sealings Reason for PFAS Use/ Requirements Profile: Very low dielectric constant Temperature resistance at high and low temperature Huge range of chemical resistance Very good water resistance, very low water absorption Longterm radiation resistance Approved flame / burn characteristics High UV radiation resistance Material strength even at very high and low temperatures Explosion proof standards EN60079 for Zone 0/Zone1 separation Less friction, low abrasion and low adhesion 2. Contact Radar Level Measurement sensors using microwaves measured 8 PFAS substance/substance group: PFAS-containing material/component: PTFE Parts in contact with substances to be PFA measured FFKM O-Ring sealings FEPM Reason for PFAS Use/ Requirements Profile: Very low dielectric constant Temperature resistance at high and low temperature Huge range of chemical resistance Very good water resistance, very low water absorption Longterm radiation resistance Approved flame / burn characteristics High UV radiation resistance Material strength even at very high and low temperatures Less friction, low abrasion and low adhesion 3. Pressure measurement sensors PFAS substance/substance group: PFAS-containing material/component: PTFE Seals FKM Pressure compensation membranes Cables Reason for PFAS Use/ Requirements Profile: Huge range of chemical resistance Temperature resistance at high and low temperature Constant dielectric properties 4. Diaphragm Seal By using diaphragm seals, pressure measuring instruments can be adapted to even the most difficult of conditions within process industries. A diaphragm made of the appropriate material separates the medium from the measuring instrument. Diaphragm seal PFAS substance/substance group: PFA, PTFE PFAS-containing material/component: Lining of the diaphragm seal 9 Reason for PFAS Use/ Requirements Profile: Diaphragm seals ensure reliable measurement results, e.g. when critical media are involved (acids, media with high temperatures, etc.) The pressure is transmitted in the diaphragm seal system and thus the medium is separated from the measuring device Industries: Hygienic applications (food, pharmaceuticals, ...) Application according to substances (suitable for viscous substances such as oil, diesel, ...) Effect of PFAS restriction: Certain substances (acids, etc.) /conditions (heat, etc.) attack the material of the measuring device Diaphragm seal systems that are not protected by PTFE can be a source of danger due to destruction by aggressive media For hydrofluoric acid, for example, no other material currently known Adhesions of viscous media can disturb the measurement and thus the entire process 5. Various devices Pressure sensor PFAS substance/substance group: PFAS-containing material/component: FKM, FVMQ Sealings Reason for PFAS Use/ Requirements Profile: Seals are essential for the functioning of the products, as they provide the barrier to the environment FKM and FVMQ are universally applicable for many different substances (Oils, lubricants, fuels, ...) FVMQ has unique low temperature properties Industries: Hydrogen applications Renewable energies (wind turbines) Hydraulics (construction machinery, etc.) Effect with PFAS restriction: No safe processes (Risk of confusion / high effort if there is a seal for each medium) Possible consequences: Leakage ( release of oils or fuels into the environment), damage or failure of entire systems Extremely long development/modification time (searching for new materials, testing, approval) 6. Photoelectric sensors PFAS substance/substance group: PFAS-containing material/component: PTFE Seals Membranes Reason for PFAS Use/ Requirements Profile: chemical resistance (e.g. alcoholic and alkaline cleaning agants, oils and lubricants) 10 7. Flow Measurement devices PFAS substance/substance group: PFAS-containing material/component: PTFE Liners PFA Seals FEP Insulations ETFE Pressure compensating membranes PVDF Signal processing units FKM Cables FFKM Reason for PFAS Use/ Requirements Profile: Temperature resistance at high and low temperature Huge range of chemical resistance Approved flame / burn characteristics Less friction, low abrasion and low adhesion Purity / inert Mechanical strength 8. Temperature measurement (Sensors, transmitters and accessories) 11 PFAS substance/substance group: PFAS-containing material/component: FEP, FP, FT, PFA, PTFE, PVDF, FPM, FKM, Protection fittings, gaskets, o-rings, cables, FPMX, ETFE pipes, heat shrink sleeving Reason for PFAS Use/ Requirements Profile: Combination of properties with respect to high/low temperature, aggressive media/chemicals, abrasion, diffusion, friction, swelling, tensile strength, repelling surface, electrical isolation 9. Process analytics (Sensors, measuring systems, transmitters, accessories and assemblies) Process analytics (pH, chlorine, conductivity, Water & wastewater treatment: disinfection, oxygen..) is absolute necessary for long- Drinking water term monitoring and limit monitoring of processes Cooling water with stable process conditions: Chemical industry Pulp & paper industry Well water Wastewater treatment plant Power plants (e.g. flue gas washers, boiler feed Biotech and pharma industries water) Bioreactors/fermenters: process control in Incineration plants enzyme production Bioreactors/fermenters: control of culture growth Food & Beverage - CIP/SIP applications PFAS substance/substance group: PFAS-containing material/component: PTFE, PVDF, FFKM, FKM, FPM, FEP Plastic parts, gaskets, o-rings, cables for e.g. electrode isolation, process connections, diaphragms, flow-through assemblies Reason for PFAS Use/ Requirements Profile: Combination of properties with respect to high/low temperature, aggressive media/chemicals, abrasion, diffusion, friction, swelling, tensile strength, repelling surface 10. Valves 12 PFAS substance/substance group: PFAS-containing PTFE Seal packing PCTFE Seats ETFE Diaphragm, PVQM FKM, FFKM Reason for PFAS Use/ Requirements Profile: Huge range of chemical resistance Temperature resistance at high and low temperature Long term stability Purity / inert Mechanical strength (Compressive modulus) material/component: 11. Lined Control valve PFAS substance/substance group: PFAS-containing material/component: PTFE, PFA Valve lining (and others as Fig 1) Reason for PFAS Use/ Requirements Profile: Pharmaceutical control valve, Cleaning and inertness Agressive process media (e.g. Chlor) 12. Self operated pressure regulator and component PFAS substance/substance group: PFAS-containing material/component: PTFE, FKM, FFKM, PVQM Sealings (packing. O-Rings) lubricants, diaphragm, bushing Reason for PFAS Use/ Requirements Profile: Chemical resistance, little friction temperature resistance, long life, good sealing, low emissions 13. Mixing or Flow dividing valve with Electric actuator for District energy PFAS substance/substance group: PFAS-containing material/component: PTFE/ PTFE compound Sealing, O-ring, bushing, gearbox Reason for PFAS Use/ Requirements Profile: chemical resistance, little friction temperature resistance, long life, good sealing, low emissions 13 14. Self operated regulator with electric setpoint actuator for District energy PFAS substance/substance group: PFAS-containing material/component: PTFE/ PTFE compound Sealing, O-ring, bushing, gearbox Reason for PFAS Use/ Requirements Profile: Chemical resistance, little friction temperature resistance, long life, good sealing, low emissions 15. Control valves for aseptic (pharma) and hygienic (food) applications PFAS substance/substance group: PFAS-containing material/component: PTFE Diaphragm, bushing,/packing Reason for PFAS Use/ Requirements Profile: Inert to process media , hygienic requirements, cleaning 16. Membrane valve for aseptic and hygienic application PFAS substance/substance group: PFAS-containing material/component: PTFE Diaphragm, bushing,/packing Reason for PFAS Use/ Requirements Profile: Agressive process media (e.g. Chlor) Hygienic requirements, cleaning, Inert to process media 17. Electric Accessories Positioner, solenoid valve, limit switch PFAS substance/substance group: PFAS-containing material/component: PTFE, FKM, FFKM, PVQM Sealings (O-Rings) lubricants, diaphragm, bushing Reason for PFAS Use/ Requirements Profile: Agressive process media (Chlor) Chemical resistance, little friction, temperature resistance, long life, good sealing, low emissions 14 18. Pneumatic accessories: Air volume booster, Reversing amplifier, Filter regulator PFAS substance/substance group: PFAS-containing material/component: PTFE, FKM, FFKM, PVQM Sealings (O-Rings) lubricants, diaphragm, bushing Reason for PFAS Use/ Requirements Profile: Agressive process media (Chlor) Chemical resistance, little friction, temperature resistance, long life, good sealing, low emissions 19. Continuous emission monitoring systems (CEMS) PFAS substance/substance group: PTFE FKM FFKM PVDF PFA Reason for PFAS Use/ Requirements Profile: High temperature resistance Huge range of chemical resistance Dielectric prperty at elevated temperature PFAS-containing material/component: Gas-conducting hoses Seals, tubes, fittings, hoses Insulations Membranes 15 20. Gas analysis systems PFAS substance/substance group: PFAS-containing material/component: FKM Seals, gaskets, fittings FFKM Filter elements, tubings, hoses FPM Membranes PFA Insulating shells PTFE Valves PVDF Fluorocarbon gas: R134a Reason for PFAS Use/ Requirements Profile: Temperature resistance at high and low temperature Huge range of chemical resistance Approved flame / burn characteristics Purity / inert Mechanical strength Dialectric property at elevated temperature Non-reactive inertness Diffusion resistance 21. Gas sample probe / Heated & unheated probes Gas sample probe The gas composition must remain unchanged. Product is attached to the extraction flange on the process stack. Materials must resist a wide range of environmental conditions from polar frost to maritime salt air or extremely high process temperatures. PFAS substance/substance group: PFAS-containing material/component: Fluoropolymers: PTFE, PVDF, FKM (Viton), FFKM Reason for PFAS Use/ Requirements Profile: Thermal performance at high temperatures Pressure resistance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties Tubing, seals, O-rings, valves, filter housings, mounting flanges, cables & wires, electronic components, and metal coating of housings 16 22. Gas coolers / Peltier & compressor coolers Gas cooler Condensate, usually water or acids, is removed by cooling the sample gas. There are compressors and Peltier coolers, or a combination of both. The sample gas coolers can adapt to the specific process conditions. PFAS substance/substance group: PFAS-containing material/component: Fluoropolymers: PTFE, PVDF, FKM (Viton), Seals, O-rings, insulation lubricants, heat FFKM exchangers, refrigerant, connectors, tubing, Fluorocarbon gas: R134a valves, cables & wires, electronic components, and metal coating of housings Reason for PFAS Use/ Requirements Profile: Non-flammable refrigerant Thermal performance at high temperatures & low tempratures Pressure resistance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties 23. Sample gas pumps / Membranes, bellows & peristaltic pumps Sample gas pump Sample gas pumps increase or decrease the pressure of the gas sample flow to ensure the gas flow through the gas analyzer. Depending on the gas composition and conditions there are various designs: Full PTFE bellows pump, full PTFE diaphragm pump, electrically heated diaphragm pump, corrosion-resistant diaphragm pump. PFAS substance/substance group: PFAS-containing material/component: Fluoropolymers: PTFE, PVDF, FKM (Viton), FFKM Reason for PFAS Use/ Requirements Profile: Thermal performance at high temperatures Pressure resistance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties Seals, O-rings, insulation lubricants, heat exchangers, refrigerant, connectors, tubing, valves, cables & wires, electronic components, and metal coating of housings 17 24. Filters / Heated & unheated Filters retain particles, dust and aerosols throughout the gas sampling and gas flow before the gas analysis. PFAS substance/substance group: PFAS-containing material/component: Fluoropolymers: PTFE, PVDF, FEP, FKM (Viton), FFKM Reason for PFAS Use/ Requirements Profile: Thermal performance at high temperatures Pressure resistance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties Seals, O-rings, filter elements, connectors, filter element holders, filter heads, cables & wires, motor & electronic components, metal coating of housings and lubricants. 25. Analyzer / Oxygen & multigas analyzers The analyzer is the main component of the test gas measurement technology. A' test gas' is a clean and dry gas mixture. The conditioned gas must meet the requirements of the complex' analyzer for a reliable measurement. It is possible to measure: O2 (oxygen), CO (carbon monoxide), CO2 (carbon dioxide), CH4 (methane), NO (nitrogen monoxide), NO2 (nitrogen dioxide), H2 (hydrogen). PFAS substance/substance group: Fluoropolymers: PTFE, PVDF, FKM (Viton), FFKM Reason for PFAS Use/ Requirements Profile: Thermal performance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties PFAS-containing material/component: Tubing, electronic valves, flow meters, connectors, cables & wires, electronic components, metal coating of housings 18 26. Liquid Analyzers Liquid analyzer are regulation-compliant online measurement of different parameter residues in drinking water and wastewater. The liquid analyzer monitors and controls: - Inlets of wastewater treatment plants - Outlets of wastewater treatment plants for documentation purposes - Aeration basins - Water treatment - Cleaning capacity of municipal and industrial wastewater plants It is possible to measure hardness, iron, TOC, COD, ammonium, aluminum, chromate, sodium, silica, orthophosphate, nitrite, total phosphate PFAS substance/substance group: PFAS-containing material/component: Fluoropolymers: PTFE, PVDF, FKM (Viton), FFKM Tubing, electronic valves, flow meters, connectors, cables & wires, electronic components, metal coating of housings Reason for PFAS Use/ Requirements Profile: Thermal performance Corrosion resistance Non-reactive inertness Mechanical strength & flexibility Diffusion resistance Dielectric properties Hygienic design 27. Dust measuring devices PFAS substance/substance group: PTFE FKM FFKM PVDF PFA Reason for PFAS Use/ Requirements Profile: Chemical and temperature resistance Resistance to aggressive components in the PFAS-containing Seals O-rings Parts carrying sample gas material/component: sample gases (e.g. probes, hoses) 28. Encoders PFAS substance/substance group: PTFE Reason for PFAS Use/ Requirements Profile: Chemical resistance High temperature resistance PFAS-containing material/component: Seals Lubricants Gears Circuit boards 19 29. Sensors in harsh environments, like process with high temperatures Paint Draying Welding Process Lacquers process Wastewater Management Mobile Equipment (vehicles) Battery Draying PFAS substance/substance group: PFAS-containing material/component: PTFE Housing PFA Seals (o-ring and other forms) FKM Cable PFBS and its salts Reason for PFAS Use/ Requirements Profile: Temperature resistance at high and low temperature Good compression set in seals at high and low temperature Huge range of chemical resistance Mechanical, chemical resistance for cleaning process Less friction, low abrasion and low adhesion Very low r (dielectric constant) Flame retardant and anti-dripping 30. Mobile Worker Equipment in Process Automation Specifically: Mobile Communication Equipment for data, voice and video, intended for use in environments as defined in 2014/34/EU (ATEX) Affected Industries: Hydrogen, Food and Beverage Pharmaceutical, Chemical, Oil and Gas, Mining. Fire Fighting Operations. Affected Safety: Field Workers, Public Safety Use Case examples: Safety relevant communication, maintenance digital support, field service, manufacturing operations, incident management, public safety relevant communication PFAS substance/substance group: PFAS-containing material/component: PTFE Batteries PFA Sealings FKM Cables PVDF Housing materials PFBS and its salts Membranes covering speakers and microphones Membrane for pressure compensation Displays Reason for PFAS Use/ Requirements Profile: Huge range of chemical resistance (at high and low temperature) since devices might be exposed to aggressive substances during usage Safety relevant properties as required by EU 2014/34/EU and harmonized standards Flame retardant and anti dripping properties of (certified) plastics Rechargeable Batteries: Batteries must be intrinsically safe to meet the requirements defined in the harmonized standards. Non-PFAS rechargeable batteries are not known yet. Displays (TFT/LCD): Non-PFAS based displays are not known yet. 20 31. Human Machine Interfaces in Process Automation (intended for use in environments as defined in 2014/34/EU (ATEX)) Affected Industries: Hydrogen, Food and Beverage, Life Science, Bio-Pharmaceutical, Pharmaceutical, Chemical, Oil and Gas, Mining. Affected Safety: Field Workers, Public Safety Use Case examples: Interaction with local control plant system, safety relevant communication, maintenance, field service, manufacturing operations, incident management, public safety relevant communication PFAS substance/substance group: PFAS-containing material/component: PTFE Display - LCD PFA Keyboard, Mouse FKM Sealings PVDF Cables PFBS and ist salts Housing materials Membrane for pressure compensation and humidity control Reason for PFAS Use/ Requirements Profile: Huge range of chemical resistance (at high and low temperature) since devices might be exposed to aggressive substances during usage Biological inactivity and inertia Safety relevant properties as required by EU 2014/34/EU and harmonized standards Flame retardant and anti dripping properties of (certified) plastics Displays (TFT/LCD): Non-PFAS based displays are not known yet. BIOS CMOS Batteries: Batteries must be intrinsically safe to meet the requirements defined in the harmonized standards. Non-PFAS BIOS CMOS batteries are not known yet Mechanical, chemical biological resistance for cleaning process 32. Field Junction Boxes and Control Cabinets in Process Automation (intended for use in environments as defined in 2014/34/EU (ATEX)) Affected Industries: Hydrogen, Food and Beverage, Life Science, BioPharmaceutical, Pharmaceutical, Chemical, Oil and Gas, Mining. Affected Safety: Field Workers, Public Safety and Explosion Protection Use Case examples: Mounting of electrical equipment in explosion hazardous areas, Power supply control, Plant safety PFAS substance/substance group: PFAS-containing material/component: PTFE Sealings PFA Cables FKM Housing materials PVDF Membrane for pressure compensation and PFBS and ist salts humidity control Reason for PFAS Use/ Requirements Profile: Huge range of chemical resistance (at high (+70C) and low temperature (-40C)) since devices might be exposed to aggressive substances during usage Safety relevant properties as required by EU 2014/34/EU and harmonised standards Flame retardant and anti-dripping properties of (certified) plastics Displays (TFT/LCD): Non-PFAS based displays are not known yet. Mechanical, chemical resistance for cleaning process 21 33. Purge Enclosure in Process Automation (intended for use in environments as defined in 2014/34/EU (ATEX) Affected Industries: Hydrogen, Pharmaceutical, Chemical, Oil and Gas, Mining. Affected Safety: Field Workers, Public Safety and Explosion Protection Use Case examples: Power Applications, Variable Frequency Drives, Gas analyzers, HMIs, plant control, Electrical safety appliances, Motors, Environmental protection PFAS substance/substance group: PFAS-containing material/component: PTFE Sealings PFA Cables FKM Housing Materials PVDF Membrane for pressure compensation and PFBS and ist salts humidity control Reason for PFAS Use/ Requirements Profile: Agressive process media (Chlor) Huge range of chemical resistance (at high (+70C) and low temperature (-40C)) since devices might be exposed to aggressive substances during usage Safety relevant properties as required by EU 2014/34/EU and harmonized standards Flame retardant and anti-dripping properties of (certified) plastics Displays (TFT/LCD): Non-PFAS based displays are not known yet. Mechanical, chemical resistance for cleaning processMechanical, chemical resistance for cleaning process 34. Inductive sensors for welding applications PFAS substance/substance group: PTFE Reason for PFAS Use/ Requirements Profile: chemical resistance high temperature resistance non-stick properties 35. Capacitive sensors for applications within explosive atmospheres PFAS-containing material/component: Coating of housing PFAS substance/substance group: Fluorpolymers Reason for PFAS Use/ Requirements Profile: chemical resistance high temperature resistance reliability PFAS-containing material/component: seals 22 36. 2D- / 3D-Vision sensors / Cameras PFAS substance/substance group: PTFE FKM Reason for PFAS Use/ Requirements Profile: Chemical resistance High temperature resistance Hygienic aspects 37. RFID devices example of Application (milking robot) PFAS-containing material/component: Housing Seals (O-Ring and other forms) Pressure equalization element PFAS substance/substance group: PTFE Reason for PFAS Use/ Requirements Profile: Dirt and water repellent housing ventilation example of Application (factory) PFAS-containing material/component: Pressure equalization element 23 Substitution Non-fluoropolymer alternative materials do not exist today for specific PAMCo applications due to the harsh operating conditions in which the materials are required to operate. While finding suitable alternatives is extremely challenging, evaluating them is straightforward because the material limits of basic properties are often exceeded. In many cases, one just needs to look up materials property data in standard references to determine suitability. In our search for alternatives, other fluoropolymers often show up as the best secondary and tertiary choices. For example, PCTFE is a good back-up material for PTFE and vice versa. Other polymers can demonstrate superior performance in one single property. For example, Polyetheretherkeytone (PEEK) has slightly higher temperature performance than fluoropolymers. However, fluoropolymers are the best choice when both high temperature and chemical resistance are needed simultaneously. Multiple classes of materials were considered as potential alternatives for fluoropolymers with none emerging as a direct replacement. These materials were identified and evaluated using a combination of available data, publications and thorough discussions with material experts and experts consulted from the broader materials industry. Metals Corrosion resistant metals such as stainless steel (SS), titanium, Hastelloy, nickel, copper, and brass were explored as alternatives to fluoropolymer liners and considered unacceptable because of significant incompatibility with some chemicals and lack of purity in certain applications. PTFE is commonly used to coat metals such as 316L SS to protect the surface from corrosion in harsh chemicals. A study by Waseem Akram compared corrosion rates for 316L and PTFE-coated 316L SS in two acidic mediums, hydrochloric acid (HCl) and nitric acid (HNO3). Results are provided in Table below and show a significant corrosion performance increase (less Mils Per Year) by adding the protective layer of PTFE.ii, iii Acids Corrosion Rate: Mils Per Year (MPY) Bare 316L SS 316L w/PTFE Coating HCl 29.6 0.7 HNO3 684.8 4.9 Table: Increase of Corrosion Performance by adding PTFE as a protective layer, study by Waseem Akram Non-PFAS Polymers Engineering plastics such as PEEK and polyphenylene sulphide (PPS) were considered as alternatives for liners, tubing, waveguides and seals but were deemed unsuitable due to their inability to meet all the criteria required for PAMCo equipment. PEEK and PPS can fulfil the high temperature performance requirements. However, their chemical resistance is inferior to fluoropolymers, especially for chemicals such as hydrogen sulfide (sour gas) and strong acids. Also, PEEK's compressive modulus is too high making it unfit for seats in valves and regulators and its moisture uptake prevents its use in certain waveguide applications. Another polymer considered was acetal, which has excellent lubrication properties. However, its chemical resistance and temperature limitations prevent it from being a suitable candidate. Another alternative is polyimides such as VespelTM. They generally have a much higher in compressive strength and therefore do not make good lowpressure seals. They are also incompatible with some media such as water and steam. Non-PFFAS Elastomers Traditional elastomers such as Ethylene Propylene Diene Monomer (EPDM), Hydrogenated Nitrile Butadiene (H-NBR), and Silicone have been considered as alternatives for seals, but were deemed unsuitable due to their inferior chemical resistance, temperature limitations, and mechanical properties. Most elastomers cannot operate above 150C. Silicone has higher temperature resistance but is inferior in mechanical performance and is also not recommended in high friction and high wear applications. The use of materials that are not suitable for the operating conditions is not recommended and would, at a minimum, require an unrealistic number of maintenance cycles. In addition, worker and environmental safety could be compromised due to increased probability of failure and possible release of hazardous materials. All potential alternatives, metals, non-PFAS polymers, and non-PFAS elastomers, are high performance materials that are likely to be persistent similar to fluoropolymers, resulting in the substitution of a persistent material for an inferior performing one, leading to increased maintenance cycles and generation of higher amounts of environmental waste. 24 Safe Use: Prevention and Reduction of Emissions and Exposure Precise PAMCo fluoropolymer emissions are more difficult to assess because they take place at the end of a 15+ year life. Both the benefits and impacts must be considered. On the positive side, fluoropolymer valve packing prevents emissions to the environment due to increased seal efficiency over competing materials. On the negative side, negligible and non-toxic emissions may be released over the entire life cycle of the fluoropolymer product. Despite the relatively small emissions in the PAMCo sector, there are further mitigating factors that tend to reduce the concern about emissions even more. The useful lives of PAMCo equipment and components are very long, often greater than 15 years. This is in contrast to single use and/or limited lifetime consumer products that reach their end-of-life stage more quickly. Moreover, due to the closed-loop and sealed structure of PAMCo equipment, the risk of environmental or human exposure is very limited during the use phase. Even equipment operators are unlikely to come in contact with the fluoropolymers in the system, as the fluoropolymers are utilized in discrete, solid plastic parts that are embedded or lined inside the components of the final end-products. Concerns related to PFAS emissions during the manufacturing of fluoropolymers are expected to be addressed and should be manageable in a reasonable and defined timeframe, per feedback received in a recent inquiry. Implementation of various abatement technologies/emission control methods to reduce the environmental footprint are necessary and we intend to continue maintaining a responsible supply chain. Another option for estimating PAMCo emissions is to leverage the similarities to the Petroleum and Mining use sector and assign values that are on the same order of magnitude. Socio-economic Impact Consequences of the Proposed Restriction Failure to grant a long-term derogation for PAMCo as a use sector in the PFAS restriction dossier and the implementation of a blanket PFAS ban on the sector will have significant socio-economic implications on the European economy. Industrial automation alone represents around 3-5% of major infrastructure capital. In addition to this impact, it should be noted that the number of essential products and services coming from these installations is orders of magnitude higher. If the REACH PFAS restriction proposal is adopted in its current form, PAMCo equipment will be eliminated for all use sectors except for the 14 defined in the restriction proposal, resulting in devastating cuts and a direct reduction of the European economy based on the elimination of most of the chemical processing industry alone. Furthermore, the potential elimination of PAMCo and fluoropolymers, could cause the EU to fall behind other countries in terms of technological competitiveness, particularly in chemical processing. Possible consequences include a reduction in manufacturing operations, leading to increased imports of everything from food to pharmaceuticals. The materials used in PAMCo equipment are also used in the production of water and carbon sequestration equipment. all of which are critical to long-term sustainability success. Moreover, materials constraints will continue to limit the scope of technology-related activities, including those that are critical to Europe's future, namely alternative energy, transport and battery manufacturing. Materials are critical enablers of these technologies, and only a derogation for fluoropolymers will allow Europe to maintain a level playing field and increase the likelihood of a successful outcome. Number of Companies Affected by a PFAS Ban All companies who manufacture PAMCo equipment will be affected by the restriction. We estimate this number to be around 2,000 for Europe. Additionally, 100,000+ global customers will be affected given the large installed base and not viable replacement options. Required Transition Period and/or Derogations Fluoropolymers are clearly distinct from other chemicals in this very broad group of PFAS. There is strong evidence that these materials do not give rise to situations of concern for human health or the environment, while recognising that industry continues to make significant progress in reducing the use of PFAS 25 polymerisation aids and in implementing appropriate abatement techniques to adequately control the emissions of potentially harmful fluorinated by-products. Fluoropolymers provide many beneficial properties simultaneously (combined in single products), allowing the continued development of applications that are critical to society, not only in terms of technological progress, but especially in terms of public safety and the development of green energy alternatives. In conclusion, we recommend the inclusion of PAMCo as a new use sector in the restriction dossier and the exclusion of fluoropolymers from the scope of the restriction. Alternatively, we request a derogation of at least 12 years (plus transition period) for fluoropolymers for use in PAMCo equipment as part of the upcoming REACH PFAS restriction. In addition, a review option is needed to extend the derogation if no suitable alternatives are found. This position is in line with the industry's efforts to maintain environmental sustainability and human health and to reduce the use and the emissions of hazardous substances wherever possible. We therefore request a two-fold derogation, as follows: 1. Incorporation of PAMCo equipment as a missing use, 2. Spare parts and refurbished products must in principle be exempted from the restriction. The repair-as- produced principle must be applied to the placing on the market of spare parts, wear parts and used parts. Especially in process industry 30 years use time is typical and therefore spare parts in approved/certified equipment must be available. 3. Fluoropolymers should be considered as "Polymers of Low Concern" (PLC) and therefore be excluded from the restriction scope or should have a 12-year derogation (plus transition period) for use in PAMCo equipment with review option for extension if no suitable substitutes are found Our sector offers: PAMCo equipment can be disassembled and separated at the end-of-life for processing or re-use in a circularity methodology. The fate of fluoropolymers at the end-of-life in this business sector is controllable and can be any one or more of the following: Recovery and Recycling Fluoropolymers can be chemically returned back to their building blocks for reconstruction without damage to their properties. Melt-processable fluoropolymers, which excludes PTFE, can be recycled through traditional mechanical methodologies. The challenge for non-melt processable fluoropolymers like PTFE is identifying ways to return materials to a facility that can perform chemical recycling. This is a difficult problem, but not insurmountable. Incineration There are available studies that strongly suggest that PTFE, the most stable fluoropolymer, undergoes complete thermal decomposition at a temperature of about 800C and is safe for incineration at municipal incineration facilities5. Therefore, it is assumed that most other fluoropolymers also thermally decompose within similar parameters and are also safe for incineration at most typical municipality incineration facilities. Landfills Fluoropolymers are inherently safe, non-mobile, non-bio accumulative and non-toxic. Waste is chemically inert and therefore, fluoropolymers disposed in landfills do not pose any substantive threat to human health and the environment. 26 Contact Felix Seibl Managing Director Measurement and Process Automation Section Automation Department Phone: +4969 6302 451 Mobile: +49162 2664 931 E-Mail: zvei.org Kirsten Metz Senior Manager Environmental and Chemicals Polic Sustainability & Environment Division Tel.: +4969 6302 212 Mobile: +49162 2664 952 E-Mail: zvei.org ZVEI e. V. Electro and Digital Industry Association Lyoner Strafle 9 60528 Frankfurt am Main Germany Lobbying Register ID.: R002101 'v EU Transparency Register ID: 94770746469-09 www.zvei.org Date: September 21, 2023 Coe ri ht Pictures ABB EMERSON Endress+Hauser www.endress.com Buhler Technologies GmbH KROHNE VEGA Grieshaber KG ifm electronic gmbh SICK AG WIKA Alexander Wiegand SE & Co. KG SAMSON AKTIENGESELLSCHAFT M&C Techgroup Germany GmbH Pepperl+Fuchs SE Fig. II Examples of uses No [n] Fig. 31, 34, 35 // No. [20] Fig. 1, 5, 6, 7 // No. [1], [7], [10], Fig. 1, 2, 3, 5, 18, 21, 23, 25, 26, 27, 28, 29, 30 // No. [1], [2], [3], [7], [8], [8], [20], [26] Fig. 16, 17, 18, 20, 25 // No. [20], [21], [22], [23] [24] Fig. 1, 3, 5, 27, 28 // No. [1], [3], [7], [8], [9: Fig. 1, 2, // No. [1], [2] Fig. 2, 32, 33 // No. [2], [3], [6], [34], [35], [36], [37] Fig. 3, 5, 11, 14 // No. [3], [6], [7], [19], [20], [27], [28] Fig. 3, 15, 36 // No. [3], [4], [5] Fig. 4, 6, 8, 9, 10, 12, 13 // No. [10], [11], [12], [13], [14], [15], [16], [17], [18] Fig. 16, 17, 18, 19, 20 // No. [20], [21], [22], [23], [24], [25] Fig. 21, 22, 23, 24 // No. [29], [30], [31], [32], [33] References www.precedenceresearch.com, Report Code: 2170; Category: Semiconductor and Electronic; Published 2022 ii Emerson's Request for the Creation of a New Industrial Automation Monitoring and Control Use Sector and a 12-Year Derogation for Fluoropolymers in that Sector iii Akram, W., Farhan Rafique, A., Maqsood, N., Khan, A., Badshah, S., & Khan, R. U. (2020). Characterization of PTFE film on 316L stainless steel deposited through spin coating and its anticorrosion performance in multi acidic mediums. Materials, 13(2), 388 (Link) 27