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== AKT 5129680 == [ Honeywell meeting follow up ] == Dokument 2 == [ Final Honeywell slides for NO DK EPAs Call on 21 April 2022 FINAL ] == CALL WITH THE NORWEGIAN EPA (21 APRIL 2022) AGENDA I. Introductions II. Context and Objectives III. Key Elements Recap our Calls for Evidence responses (fluorocarbon gases focus) Breakdown products Alternatives IV. Questions and Discussion Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. I INTRODUCTIONS & ABOUT HONEYWELL NASDAQ: HON | ~825 sites | ~103000 employees (>20000 in EU) | Charlotte NC headquarters | Fortune 100 ;;{:IJ: D i "Jinfi%\wz`lfim F II. CONTEXT AND OBJECTIVES What we understand regulators concerns are on PFAS - Persistence, Mobility/Bioaccumulation, Toxicity (humans and environment) Strong willingness to cooperate from the industry side, but there are also some concerns Meeting focus: Revisit main points from our Calls for Evidence submissions Appreciate discussion and clarifications regarding: approach to Fluorocarbon gases in the Restriction Dossier, and opportunities to submit further information to fill data gaps / give more context. Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. IlIlIl. KKEEYY EELLEElM'AEI=NNTITSS - RREECCAAPP CCFFEE SSUUBBMMIISSSSIIOONNSS SUSTAINABLE CHOICE Engineered to deliver unique climate and energy efficiency benefits Enable emissions abatement by reducing indirect emissions Full choice of refrigerants, including fluorocarbon gases, is needed to achieve the EU Net Zero Goals / Energy Efficiency First principle RISK / HAZARD Fluorocarbon gases are use in closed systems, gases are not persistent, not bio accumulative, nor toxic Fluorocarbon gases do not degrade to significant TFA quantities. No evidence that current or future concentrations of TFA from the breakdown harm the environment, marine life or humans. Recent OECD PFAS definition does not inform that substance is harmful or not (nor persistent) L =| MANDATED APPROACH & POSSIBLE CONSEQUENCES Full analysis of fluorocarbon gases and alternatives. Consequences of ban: 1) could jeopardize energy efficiency, Green Deal and "Fit for 55" objectives; 2) obsolescence of existing systems; 3) existing standards constrain systems/performance in the absence of fluorocarbon gases; 4) no more a) highperformance. non-flammable foam blowing agent for insulation = spray b) metered dose inhalers (MDIs); 5) EU competitiveness and SCOPE OF THE RESTRICTION Fluorocarbon gases should be out of scope of the future restriction given unique characteristics and their uses, Fluorocarbon gases are already regulated and phased out under the F-gas Regulation. The current review gives a chance to strengthen this framework Select derogations for certain uses would be impractical and unmonitorable for users, industry and authorities jobs IV. KEY ELEMENTS - BREAKDOWN PRODUCTS 1. TFA extensively studied worldwide, including health and environmental effects of HFCs and HFO-1234yf emissions 2. Approximately 95% of TFA in the environment is naturally occurring. 3. Not all fluorocarbon gases degrade to TFA in meaningful quantities (Yield = HFO-1234yf - 100%, 1234ze and 1233zd - 2%). 4. What really matters is the absolute TFA concentrations in the environment for fluorocarbon gases this is at very low levels. "The current and estimated future concentrations of TFA and its salts resulting from degradation of HCFCs, HFCs, and HFOs do not pose any known significant risk to human or ecosystem health." (UNEP, 2018) OFFER - To introduce you to Honeywell SME expert, and /or independent academics - members of the UNEP panel (including at University of Copenhagen) Environmental Effects Assessment Panel (EEAP) of the United Nations Environment Programme (UNEP) provides comprehensive summary (2021) for Trifluoroacetic acid (TFA) and points out that most PFAS have different properties from TFA. Trifluoroacetic acid continues to be found in the environment, including in remote regions, although not at concentrations likely to have adverse toxicological consequences. Current concentrations of TFA salts and related compounds in soil and surface waters do not present risks of adverse effects in aquatic and terrestrial plants and animals. Humans could be exposed to TFA via drinking water and food but there is no evidence to date of adverse effects on health o TFA salts are of low acute toxicity to mammals under conditions relevant to environmental exposure. Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. V. KEY ELEMENTS - ALTERNATIVES Ammonia, CO2, and hydrocarbons are not viable substitutes because of their hazard and exposure characteristics Ammonia, CO2 and hydrocarbons environmental watch points: Derivatives from fossil fuel processing Lower performance in warm climates Impact on air quality Ammonia, CO2 and hydrocarbons safety concerns : Flammability Toxicity Anesthetic / asphyxiating effects High operating pressure Air pollution Specifically for MAC: CO2 has significantly higher equipment and use / servicing costs A wide ban of fluorocarbon gases would mean that many large vehicles, infrastructure projects and appliances could not be reequipped (lifetime 15-40 years) Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. VI. QUESTIONS AND DISCUSSION 1. What is the planned approach to risk assessment given the diversity and range of substances and applications linked to fluorocarbon gases? 2. What are the proposing countries most important/urgent data gaps - uncertainties for fluorocarbon gases ? 3. Would it be possible for all fluorocarbon gases to be out of scope of the restriction proposal? 4. Assessments of specific fluorocarbon gases vis--vis their degradation product TFA? Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. BBAACCKK UUPP SSLLIIDDEESS !Vie. Illtruesuae MORE ON TFA TFA "CF3C(O)OH" (trifluoroacetic acid and its salts) is a naturally occurring substance which is stable in the environment and resistant to further degradation (breakdown). Present modelling studies suggest that even worstcase HFO-1234yf emission scenarios will increase TFA concentration in oceans and rainwater insignificantly (David et al. 2021) If all cars would use HFO-1234yf and would release it at once this would lead to a 0.04% increase of TFA in oceans. (Honeywell 2020) Projected future increased loads of TFA in the environment because of increased demand for cooling and continued use of HCFCs, HFCs, and replacement products (HFOs) are judged to present de minimis risks for aquatic organisms and humans (Solomon et al. 2016) Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. STUDY REFERENCES TFA 1. Berends AG, Boutonnet JC, Rooij CGD, Thompson RS. 6. Neale RE, Barnes PW, Robson TM, Neale PJ, Bernhard 1999. Toxicity of trifluoroacetate to aquatic organisms. GH, Neale RE, Williamson CE, Zepp RG, Wilson SR, Environmental Toxicology and Chemistry 18:1053-1059. Madronich S, et al. 2021. Environmental effects of 2. Boutonnet JC, Bingham P, Calamari D, Rooij Cd, Franklin stratospheric ozone depletion, UV radiation and J, Kawano T, Libre J-M, McCul-Loch A, Malinverno G, interactions with climate change: UNEP Environmental Odom JM. 1999. Environmental risk assessment of Effects Assessment Panel, Update 2020. Photochemical trifluoroacetic acid. Human and Ecological Risk & Photobiological Sciences 20:1-67. Assessment 5:59-124. 7. Solomon, K. R.; Velders, G. J. M.; Wilson, S. R.; 3. Burkholder, J. B.; Cox, R. A.; Ravishankara, A. R. Madronich, S.; Longstreth, J.; Aucamp, P. J.; Bornman, J. Atmospheric Degradation of Ozone Depleting F. Sources, Fates, Toxicity, and Risks of Trifluoroacetic Substances, Their Substitutes, and Related Species. Acid and Its Salts: Relevance to Substances Regulated Chem. Rev. 2015, 115 (10), 3704-3759. under the Montreal and Kyoto Protocols. J. Toxicol. 4. David, L. M.; Barth, M.; Hglund-Isaksson, L.; Purohit, P.; Environ. Heal. Part B 2016, 19 (7), 289-304. Velders, G. J. M.; Glaser, S.; Ravishankara, A. R. Trifluoroacetic acid deposition from emissions of HFO- 1234yf in India, China, and the Middle East Atmos. Chem. Phys., 2021, 21, 14833-14849. 5. Lindley, A.; McCulloch, A.; Vink, T. Contribution of Hydrofluorocarbons (HFCs) and Hydrofluoro-Olefins (HFOs) Atmospheric Breakdown Products to Acidification ("Acid Rain") in the EU at Present and in the Future. Open J. Air Pollut., 2019, 8, 81-95. Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved. PCTFE - POLYCHLOROTRIFLUOROETHYLENE PCTFE are indispensable in the delivery and preservation of safe pharmaceuticals, which is crucial for society PCTFE and other fluoropolymers are very distinct from other PFAS substances. PCTFE does not pose a risk to human health or the environment at any point during its life cycle (PLC). There are no alternatives for PCTFE based medicines/pharmaceutical packaging - only cold form foil has compatible moisture barrier but it is not transparent and 55% bulkier. If PCTFE materials were to be banned, pharma. producers would be required to find and qualify alternative packaging formats, resulting in additional R&D costs, stability testing, and other regulatory/approval costs for each drug currently packaged in PCTFE. PCTFE uses in medicinal packaging are comprehensively regulated - EMA, marketing authorizations, WHO, FCM, European Pharmacopoeia, EU Pharmaceutical strategy, etc. Honeywell believes that due to unique functionalities and low risk properties of PCTFE, Aclar materials should be derogated from the REACH Annex XV Dossier. Honeywell Confidential - 2022 by Honeywell International Inc. All rights reserved.