Document 5Jde6wKx3eDoo7K21VVXr5pD
LIFE SAFETY DISTRIBUTION GmbH
Z.A. La Pice 16 1180 Rolle Switzerland www.honeywell.com
21 September 2023
PFAS REACH Annex XV Restriction Report 1ST Public Consultation (22 March - 25 September 2023)
Request for exclusion or derogation of certain fluorinated materials used in gas detection applications/instruments from the PFAS REACH restriction Proposal.
Table of Contents
1 Executive summary ............................................................................................................................... 2 2 Overview of Gas Detection Instruments ................................................................................................ 4
2.1 Overview of gas sensing techniques ............................................................................................. 5 2.2 Important features of materials used in gas instruments .............................................................. 7 2.3 Gas influx methods for sensors ..................................................................................................... 8 2.4 Mandatory technical specifications .............................................................................................. 10
3 Why fluorinated materials are indispensable for Gas Detection Instruments? ................................... 11 4 Absence of unacceptable and inadequately controlled risk ................................................................ 15
4.1.1 Grouping and risks assessment in the Proposal ................................................................. 15 4.1.2 Other effective RMM in place .............................................................................................. 16 5 Unique characteristics of materials in question and absence of feasible alternatives ........................ 18 6 Socio-economic impact of the proposed REACH restriction ............................................................... 21 7 Conclusion ........................................................................................................................................... 22
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1 Executive summary
Honeywell International Inc. and its affiliated companies (hereinafter - Honeywell)1 are global providers of various electronic and electrical devices (EEE), including instruments for the detection of toxic and flammable gases (Gas Detection Instruments) for downstream sectors that exhibit harsh conditions such as large temperature and humidity variations, high pressure and explosive environments, and exposure to aggressive chemicals, exotic gases, and other contaminants, including, but not limited to, oil and gas (drilling and production), refineries and petrochemicals, steel mills, semiconductors, photovoltaics, water treatment, military, chemical plants, energy generation, and many other industries (Critical Operations). These instruments contain components (for example, membranes, O-rings, seals, valves, films and wires, adaptors, coatings, tubing and pipes, etc.) made of PFAS-related fluoropolymers, (per-)fluoroelastomers and perfluoropolyethers (PTFE, FEP, PFA, PVDF, PVF, PCTFE, PFPE, FKM, FFKM - i.e., Fluorinated Materials) 2 . Unique chemical, electrical, and physical properties of these materials enable essential technical characteristics, compliance with hazardous area approvals, selectivity, measurement precision, response time, reliability, and long service lives for Gas Detection Instruments that are intended to work in Critical Operations.
On 13 January 2023, the competent authorities of five EU/EEA states (Dossier Submitters) submitted to the European Chemical Agency (ECHA) the PFAS REACH Annex XV Restriction Report (Proposal).3 The Proposal covers all PFAS and their uses, including in all gas detector applications.
Honeywell submits that uses of the above Fluorinated Materials in Gas Detection Instruments should be excluded or made subject to the time-unlimited derogation from potential PFAS REACH restrictions due to the following reasons.
Although the aforementioned Fluorinated Materials can be classified as PFAS based on their molecular structure, their mobility and long-range transport potential (LRTP), bioaccumulation, toxicological, and ecotoxicological profiles are essentially different from the majority of PFAS substances. Moreover, polymers such as PTFE, PCTFE, and all other Fluorinated Materials at stake satisfy the OECD criteria for a Polymer of Low Concern (PLC)4, and are deemed to be environmentally and humanly benign. These substances are non-toxic, non-bioavailable, non-water soluble, and non-mobile, indicating that they do not pose any substantial risks to the environment or human health. They do not exhibit any of the intrinsic hazards assessed in section 1.1.4 of the Proposal and are not substances with similar PBT/vPvB concerns. Their grouping with "all other PFAS" for risk assessment purposes is not scientifically and legally justified.5
1
See the list of acronyms and abbreviations (aligned with the Proposal) in Annex I below.
2
The list of PFAS substances contained in components and materials of Gas Detection Instruments is provided
in Annex II below.
3
On 22 March 2023, ECHA published the PFAS REACH Annex XV Restriction Report in the Registry of
restriction intentions until outcome and started the 1st Annex XV report consultation with a final deadline for comments
on 25 September 2023.
4
See detailed analysis in A critical review of the application of polymer of low concern regulatory criteria to
fluoropolymers II: Fluoroplastics and fluoroelastomers, Stephen H. Korzeniowski at al., Integrated Environmental
Assessment and Management -- Volume 19, Number 2--pp. 326-354, 2022.
5
Ibid., page 348-349.
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Respective risks from Fluorinated Materials in Gas Detection Instruments across their entire lifecycles are already adequately controlled by virtue of extensive industry manufacturing standards, responsible manufacturing commitments from industry, negligible leakage during the use phase (as well as during landfill), and detailed disposal requirements under EU WEEE Directive, Waste Framework Directive (WFD) and respective national laws and practices. 6 Incineration of these materials under standard European municipal waste incineration conditions, particularly at temperatures above 850C, has been assessed under the various EU and national waste legislative frameworks above. Additional Risk Management Measures (RMMs) for these devices are practiced today.7
Due to unique physicochemical properties, these materials provide exceptional characteristics for Gas Detection Instruments designed to work in Critical Operations. There are no other known alternative materials allowing for this unique combination of necessary characteristics.
In particular, chemical resistance, inertness, and compatibility of Fluorinated Materials are extremely important for gas-facing surfaces bringing sampled gas to the sensor. To measure sticky gases, e.g., hydrogen chloride, chlorine, chlorine dioxide, hydrogen fluoride, hydrogen bromide, fluorine, boron trifluoride, etc, the material exposed to the environment being monitored should be highly chemically inert. If not, the gas path absorbs a large portion of the gas and would result in the instrument making an inaccurate measurement of the atmosphere or degraded performance over time. This could present a danger to the operators and facility by underreporting the actual gas concentration present. For example, Viton (FKM) O-rings are used for sealing/lubrication for explosion proof enclosure and sensor cartridges in various Gas Detection Instruments. Gas permeable PTFE (Gore) membranes are a key component for most portable and fixed Gas Detection Instruments. In other words, without fluoropolymers, gas detection performance, sensitivity, accuracy, response time, and recovery time will be significantly compromised, thereby putting in danger the safety and health of workers as well as of property/installations and environment in Critical Operations.
Due to the high cost and complexity of processing techniques, these materials are employed only in situations where there are no viable alternatives. Currently, there are no other materials that are known or actively in development in the industry that possess the necessary combination of properties, such as high thermal resistance (~200 C), high humidity resistance, high flexibility, high mechanical resistance, high inertness, and chemical resistance, which are specifically required for applications in which toxic and flammable Gas Detection Instruments are used.8 These properties are essential for various components thereof, such as membranes, sealings, O-rings9 as well as their connecting and gas delivery components like tubing, spacers, solenoids, and connectors. Development and commercialisation of alternatives, if it may ever be possible, will require much longer time than envisaged in the Proposal, and substantial resources that could be prohibitive for many manufacturers.
6
Ibid., page 350.
7
See in section 4.1.2 below.
8
See e.g., in section 2.4.10 of Risk management options analysis (RMOA), Fluoropolymer Products Group of
Plastics Europe (FPG), 2021, or at page 347 of the study in footnote 4 above.
9
Ibid. at page 82.
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Moreover, Gas Detection Instruments as well as components and materials thereof are subject to stringent and comprehensive technical regulations under IEC/CENELEC standards, ATEX10 requirements, and other international regulations. Even in the long-term perspective, alternative materials will not be able to comply with the extremely stringent technical specifications required for Critical Operations similar to those in Oil & Gas and Mining sectors. For the latter, the Dossier Submitters already proposed to derogate fluoropolymers uses from the PFAS restriction (see point 6.f of the Proposed restriction - Annex XVII entry PFASs). Relaxing of those specifications is highly risky and dangerous for people, property, and the environment. In the meantime, the combined timeline required for the invention, development, and ATEX (and all other applicable standards) recertification of new material and overall gas detection equipment will require time periods much longer than 13.5 years upon the entry into force of the potential PFAS REACH restriction as envisaged in the Proposal for the Oil and Mining sectors.
As a result, if Fluorinated Materials were banned in Gas Detection Instruments across all applications, industrial production in semiconductors, automotive, petrochemical, and crude oil and natural gas sectors worth over 2 trillion EUR would be severely compromised due to the lack of adequate highly critical safetyrelated gas detection systems.
Therefore, the ban on use of Fluorinated Materials in question in Gas Detection Instruments/applications is disproportionate to alleged risks for health and the environment due to the inaccurately purported PFAS persistency characteristics. Respective REACH restrictions envisaged in the Proposal would endanger lives of people and industrial safety, inevitably resulting in very high costs on the society. These consequences are in direct contradiction with the wider EU industrialisation and competition policies as well as the objectives of the European Green Deal, REPowerEU, European Chips Act, Net Zero Industry Act.11
2 Overview of Gas Detection Instruments
Requirements for toxic, flammable, and oxygen Gas Detection Instruments are similar to the Petroleum and Mining use sector (see section 1.3.2.15 and section E.2.15 of Annex E of the Proposal). Materials used in these applications require high performance and high reliability to provide accurate measurements and to prevent gases emissions/concentrations that could result in harm to people and the environment. The technical properties important for Gas Detection Instruments are durability, high and low temperature resistance (-50C/+75C, over +110C in certain applications), chemical inertness (to enable purity of measured/sampled gases), and chemical resistance, as well as high mechanical strength in harsh conditions observed in Critical Operations. The example of the Petroleum and Mining sector analysed in the Proposal clearly demonstrates that broad derogations of fluoropolymers for similar uses are necessary.
10
Directive 2014/34/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation
of the laws of the Member States relating to equipment and protective systems intended for use in potentially explosive
atmospheres (recast).
11
See e.g., at pages 58, 82 and 85 of Risk management options analysis (RMOA), Fluoropolymer Products
Group of Plastics Europe (FPG), 2021.
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2.1 Overview of gas sensing techniques
Honeywell's fixed and portable industrial Gas Detection Instruments are based on the following gas detection techniques, photochemical techniques, and/or respective electronic gas sensor devices.
Unique properties of Fluorinated Materials used in gas detection sensors/instruments are summarised in Table 1 of section 3 below.
Catalytic combustible gas sensor
A combustible gas is any gas that will burn or ignite. Mixtures of combustible gases with certain volumes of air, when ignited, produce an explosion. A combustible gas sensor monitors the percentage of ambient gas in the air, by allowing the gas to burn in a controlled manner within the sensor, which allows the instrument to monitor the resultant change in resistance. When a particular concentration is reached, the instrument produces an alarm (determined by the user) which may trigger an executive action, such as shutdown of the process, triggering of audible and visual alarms, or evacuation of personnel.
Nearly all modern, low-cost, combustible gas detection sensors are of the electro-catalytic type. They consist of a very small sensing element sometimes called a `bead' or a `Pellistor'. They are made of an electrically heated Platinum wire coil, covered first with a ceramic base such as Alumina and then with a final outer coating of Palladium or Rhodium catalyst dispersed in a substrate of Thoria.
This type of sensor operates on the principle that when a combustible/flammable gas/air mixture passes over the hot catalyst surface, combustion occurs, and the heat increases the temperature of the `bead'. This in turn alters the resistance of the Platinum coil, which can be measured by using the coil as a temperature thermometer in a standard electrical bridge circuit. The resistance change is then directly related to the gas concentration in the surrounding atmosphere and can be displayed on a meter or some similar indicating device.
Sectors/industries of use include refrigeration plants, oil and gas, chemical and petrochemical production, gas storage, hydrogen production and usage, semiconductor manufacturing, solar energy applications, etc.
Deployment of combustible gas sensors may include a PTFE filter in front of the sensor to prevent contaminants and liquids from entering that may inhibit performance of the sensor.
Infrared gas detector
Many toxic and flammable gases have absorption bands in the infrared region of the electromagnetic spectrum of light and the principle of infrared (IR) absorption has been used as a laboratory analytical tool for many years. Since the 1980s, however, electronic and optical advances have made it possible to design equipment of sufficiently low power and smaller size to make this technique available for industrial gas detection products as well.
These instruments can be designed to operate successfully in inert as well as very hazardous atmospheres and under a wide range of ambient temperature, pressure, and humidity conditions. However, this type of sensor cannot detect diatomic gas molecules and is therefore unsuitable for the detection of Hydrogen.
Sectors/industries of use include chemical and petrochemical production, oil and gas, printing, gas storage, brewing, semiconductors, and solar applications.
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Open path flammable infrared gas detector
Traditionally, the conventional method of detecting gas leaks was by point detection, using a number of individual sensors to cover an area or perimeter. More recently, however, instruments have become available that make use of infrared and laser technology in the form of a broad beam (or open path) which can cover a distance of several hundred metres. Early open path designs were typically used to complement point detection; however, the latest generation instruments are now often being used as the primary method of detection. Typical applications where they have had considerable success include FPSO (Floating Production, Storage and Offloading), loading/unloading terminals, pipelines, perimeter monitoring, offshore platforms and LNG (Liquid Natural Gas) storage areas, chemical plants, and many others.
Electrochemical (E-Chem) cell sensors
Gas specific electrochemical sensors can be used to detect Oxygen and the majority of common toxic gases, including carbon oxide, hydrogen, chlorine, sulfur dioxide, etc. in a wide variety of safety applications.
Fluorinated Materials are indispensable for the functionality of modern E-chem gas sensors. Please see in detail Honeywell submission specific to this application reference No: 953afdb9-29e0-47d9-bbf149d887020fee.
Photo ionised detection (PID)
This type of detection principle, relying on UV technologies, is often employed in portable gas detection solutions and is designed to deliver highly sensitive monitoring of Volatile Organic Compounds (VOCs) or other gases that need to be detected in very small quantities, such as Chlorinated Hydrocarbons (CHC).
A PID sensor can detect down to parts per billion (ppb), and this is necessary when dealing with VOCs which can be highly toxic for humans/workers in very small quantities.
Chemcassette
Chemcassette is based on the use of an absorbent strip of filter paper acting as a dry reaction substrate. This performs both as a gas-collecting and gas-analysing media and it can be used in a continuously operating mode. The system is based on classic colorimetry techniques and is capable of extremely low detection limits for a specific gas. It can be used very successfully for a wide variety of highly toxic substances, including di-isocyanates, phosgene, chlorine, fluorine, and a number of the hydride gases, mineral acids and amines employed in the manufacture of semiconductors.
Stain intensity is measured with an electro-optical system that reflects light from the surface of the substrate to a photocell located at an angle to the light source. PTFE coating on the optic block of the sensor is required to prevent absorption of the light and chemical resistance of the overall system.
Chemcassette formulations provide a unique detection medium that is not only fast, sensitive, and specific, but it is also the only available system that leaves physical evidence, i.e., the stain on the cassette tape that a gas leak or release has occurred. As sample gas molecules are drawn through the Chemcassette with a vacuum pump, they react with the dry chemical reagents and form a coloured stain specific to that gas only. Detection specificity and sensitivity are achieved through the use of specially formulated chemical reagents, which react only with the sample gas or specific family of gases.
Sectors/industries of use Chemcassette systems inter alia include chemical and petrochemical production, semiconductor manufacturing, and solar energy applications.
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2.2 Important features of materials used in gas instruments
Chemical inertness and resistance
A gas instrument interacts with toxic, flammable gases and oxygen to detect and generate proper alarms for safety. Normally toxic, flammable and oxygen gases are very reactive, corrosive and destructive substances. The materials used in Gas Detection Instruments affect their gas detection performance and instrument integrity.
The mechanism of a sticky gas interaction with a surface depends on the energy and state of the gas molecules and the properties and structure of the surface. The interaction of a sticky gas with a surface can result in different outcomes, such as absorption, adsorption, or reaction. It affects gas accuracy and response time. The gas-facing surface of a Gas Detection Instrument requires chemical inertness to detect sticky gases.
Chemical resistance is related to a Gas Detection Instrument's mechanical integrity. The gas-facing surface is exposed to very aggressive and corrosive materials. It changes and damages surface structure and materials. For example, HF makes Acetal brittle and affects mechanical integrity.
Only the Fluorinated Materials in question (e.g., PTFE, FKM, CTFE, etc.), which have the highest chemical inertness and resistance to the sticky and corrosive substances concerned, can provide the required chemical-resistance. This greatly improves the stability of the Gas Detection Instrument, its precision (calibration), and its longevity.
Gas permeability To achieve the necessary requirements of gas instruments, for example, IP67 rate12, the instrument should block water and dust but allow the gas/air mixture to diffuse into the housing and onto the sensor element. The permeability affects response time significantly.
The speed of response values (e.g., T90) are a crucial characteristic for all gas detection sensors and instruments/systems used for both flammable and toxic gas detection. Faster response time allows for greater precision of measurements in real time and thus more reliability of data and improved operational safety of the overall installation/equipment.13
Fluorinated Materials, such as PTFE, PCTFE, FKM, and others, provide the best available solution to allow the sampled gas to permeate and to be presented inside gas sensors, considerably improving their speed of response values. These materials are also the best ones to prevent contaminants and liquids that may inhibit the sensors' speed of response and general ability to perform its functions.
Smooth surface and stable in extreme temperature A gas instrument has many gas interacting parts. Each part should be sealed and attach/detach over time due to maintenance and operation. Moving parts coated with Fluorinated Materials can glide over each other with much less friction, which leads to reduced abrasion and less wear and tear.
12
See e.g., at page 93 of the Honeywell GasBook.
13
These characteristics are subject to numerous strict technical regulations and standards inter alia referred in
section 4.1.2 below.
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2.3 Gas influx methods for sensors A gas detector consists of gas sensor, signal conditioner, and readout. To detect gas, the gas should meet the gas sensor. There are two ways for the gas to reach to sensors. One is using gas concentration gradient, called "diffusion". The other is using external energy input, for example, a pump, called "extractive".
Diffusion Diffusion is the movement of molecules from an area of high concentration to an area of low concentration. Most portable and fixed Gas Detection Instruments use diffusion as the gas introduction method. Toxic, flammable and oxygen molecules pass through the permeable membrane to reach to a gas sensor. The membrane also blocks the water but passes the gas into instrument. Permeability of PFAS is extremely critical for the speed of response and accuracy of measurements. The same is true for the chemical inertness of the membrane. In particular to detect sticky gases, for example, chlorine, hydrogen chloride, hydrogen fluoride (fluorane), hydrogen bromide, fluorine, the gas permeable membrane should not absorb the gases. If it does, the required amount of gas cannot pass through the membrane and cannot reach the gas sensor. This results in significant and potentially very dangerous underreporting. The picture below is an example of the use of a PFAS membrane (#10).
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Extractive A sample point is located a distance away from the system connected by an FEP tube. The system draws a sample from that location through the tube and into the detector, which passes that sample through internal manifolds and flow control components where the sample passes through a gas sensor. The materials PTFE, PVDF, FEP, PFA, and FKM are critical in this application due to their chemical inertness and non-absorbing characteristics. The sample gas drawn from the target location should be maintained before it reaches the gas sensor to prevent underreporting or slow response. Many exotic gases (Hydrides: AsH3, B2H6, GeH4, H2Se, H2S, PH3, SiH4; Mineral Acids: BF3, HBr, HCl, HF; Amines: NH3, DMA, TDMAT, TMA; Oxidizers: Cl2, F2, NO2) are used in semiconductor, display panel, and solar panel manufacturing processes. Figure 2 below is a flow diagram of a gas detector used in semiconductor manufacturing. To detect these gases in ppb level, all materials leading into a sensor (in this case, the instrument is Chemcassette type optics block) that come into contact with the sample gases must be PTFE, FEP, PVDF, FEP, PFA, or FKM. Several of those Fluorinated Materials are also present in tubing connections and solenoids. Figure 2 - the flow diagram of a gas detector used in semiconductor manufacturing with an optic block
Importantly, in the case of toxic (and some flammable) gas monitoring systems, the atmosphere is often sampled at locations remote from the unit and the gases are drawn by pumps to the sensors through several synthetic material narrow-bore tubes (connectors, see pictures above).
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Care in design of such sample systems will include a selection of pumps, filters, and tubes (and components thereof) of a suitable material, which must be not only chemically/temperature/weather, etc. resistant in all senses but also highly inert and compatible (i.e., not react, absorb, etc.) vis--vis the sampled gases.
For sticky gases such as HCl, Cl2, HF, HBr, etc, gas-facing surfaces on the gas path (tube) should be highly chemically inert (see also section 2.3 above). If not, the gas path absorbs a large portion of the gas, thus substantially impacting the accuracy of the measurement. In this regard, fluoropolymers such as PTFE (Teflon) are the only suitable materials for these purposes.
The same is equally true for sealing and lubrication of gas sensors and components of fixed and portable gas detection systems, including Viton (FKM) O-ring (for sealing and lubrication for explosion proof enclosure and sensor cartridge), gas permeable Gore (PTFE) membrane filters (used in most portable and fixed gas detection systems) and many others (see at Table 1 below).
In other words, without the Fluorinated Materials in question, the performance of Gas Detection Instruments (i.e., sensitivity, accuracy, response time, service life, etc.) would be significantly compromised, leading to non-compliance with applicable technical regulations and elevated risks for people, property, and the environment.
2.4 Mandatory technical specifications
The mandatory technical standards used for gas detection systems in the EU and most countries outside of North America are IEC/CENELEC.14 The IEC (International Electrotechnical Commission) has set detailed standards for equipment and classification of areas that are used by countries outside of both Europe and North America. CENELEC (European Committee for Electrotechnical Standardisation) is a rationalising group that uses IEC standards as a base and harmonises them with all ATEX standards and the resulting standards legislated by member countries, which are based upon ATEX.
To ensure the safe operation of electrical equipment in flammable atmospheres, several design standards have now been introduced, largely covered by the EN/IEC 60079 series of standards. These design standards have to be followed by the manufacturer of instruments sold for use in a hazardous area and must be certified as meeting the standard appropriate to its use. Equally, the user is responsible for ensuring that only correctly designed equipment is used in the hazardous area.
The EU Chemical Agents Directive (CAD)15 and Carcinogens, Mutagens or Reprotoxic substances Directive (CMRD)16 regulate inter alia mandatory concentrations (i.e., Occupational Exposure Limit values (OELs)) and monitoring techniques for hazardous toxic gases. Both area surveys (profiling of potential exposures) and personal monitoring (where instruments are worn by a worker and sampling is carried out as near to the breathing zone as possible) are covered by the above stringent requirements. They are set by competent
14
Directive 2014/34/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation
of the laws of the Member States relating to equipment and protective systems intended for use in potentially explosive
atmospheres (recast).
15
Council Directive 98/24/EC of 7 April 1998 on the protection of the health and safety of workers from the risks
related to chemical agents at work (fourteenth individual Directive within the meaning of Article 16(1) of Directive
89/391/EEC).
16
Directive 2004/37/EC of the European Parliament and of the Council of 29 April 2004 on the protection of
workers from the risks related to exposure to carcinogens, mutagens or reprotoxic substances at work (sixth individual
Directive within the meaning of Article 16(1) of Council Directive 89/391/EEC).
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EU national authorities or other relevant national institutions as limits for concentrations of hazardous compounds in workplace air and residential areas. Requirements for detection of toxic gases at workplaces are established in IEC 62990-1 standards.
Moreover, Safety integrity level (SIL) certification based on the EC 61508 standard ensures that the given, e.g., Gas Detection Instrument, provides for the relative level of risk-reduction intended by its safety instrumented function (SIF). In other words, that its measurements satisfy a combination of quantitative and qualitative factors relevant for its reliability of outputs, response time, risks of failure, etc. during its life cycle. For certain industries, this type of certification is mandatory.
3 Why fluorinated materials are indispensable for Gas Detection Instruments?
Gas Detection Instruments are used in critical lifesaving applications and harsh environments. Therefore, all components in the device need to be safe, durable, and non-reactive across a broad range of temperatures, chemical environments, radiation levels, and other environmental exposures that arise in Critical Operations. Fluorinated Materials are the only plastics that can meet all these characteristics.
Given the substantial consequences of any potential failure, it is imperative to approach substitutions of Fluorinated Materials with utmost care. These materials have demonstrated remarkable reliability for more than sixty years. A prevailing apprehension pertains to the possibility that CENELEC/IEC and ATEX might need to be revised to accommodate alternative materials which currently fall short in delivering the necessary level of performance. Afterwards, new materials/instruments/devices for all hazard locations would need to be recertified. This will take significant time, greatly exceeding the 6.5 or 13.5 years envisaged in the Proposal.
Table 1 below summarises PFAS materials (i.e., Fluorinated Materials) and their uses in components of Gas Detection Instruments as well as their respective unique characteristics and benefits.
PFAS Material
Where it is used
Unique properties for this application
PTFE - dispersion
liquid
Gas permeable, hydrophobic channels
for All E-chem gas sensors within hydrophilic catalytic material. Aids
electrodes
bonding to the PTFE electrode support
membrane.
PTFE - tapes
All E-chem gas sensors electrodes, sensor dust caps, manifold fittings
Inert, gas permeable, hydrophobic, electrode support membrane and sensor/fittings seal.
PTFE - surfactants
E-chem manufacturing
electrode
Inert, gas permeable, hydrophobic surfactant to keep precious metal in suspension for electrode manufacturing process.
PTFE - powders
Filtered gas sensors/Toxic Create inert, gas permeable, hydrophobic
gas sensors
channels through active filter material.
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PTFE/PFA/FEP - in Medical & Automotive O2 and Inert, solid state gas diffusion barrier/water
front membranes
Pb sensors
trap
PTFE/PFPE - greases Several E-chem gas sensor Hydrophobic barrier for spigots and threads product ranges
PCTFE - gas barriers O2 pump gas sensors and valve seats
Gas barriers and valve seats for internal gas management
FKM/FFKM - O-rings, gaskets, seals
Internal and external sealing
of
Sensors,
fittings,
connections for fixed and
portable instruments.
Internal sensor sealing. External sealing into instrumentation. Chemical Resistance
PVDF - spacer
Pellistor gas sensors
Inert, high temperature internal spacer.
PTFE - spacer
Pellistor gas sensors
Inert, high temperature internal spacer.
PTFE/PFA tubing/connector
- External connections of gas Inert, chemical resistance, high pressure sensors within fixed and rated gas tubing portable test equipment
PTFE - solenoids
External connections of gas sensors within fixed and portable test equipment
Inert, chemical resistance, high pressure rated gas solenoid
PTFE/FKM - seals
External connections of gas sensors within fixed and portable test equipment
Inert, chemical resistance seals
PVDF - Manifolds
PVDF - Valves/Valve Bodies
PVDF - Fittings
PVDF - Mechanical components
Internal manifolds for many gas detectors used in semiconductor manufacturing
Internal/External to gas
detectors
used
in
semiconductor manufacturing
Internal/External fittings to gas
detectors
used
in
semiconductor manufacturing
Internal
Chemcassette
shims for gas detectors used
in
semiconductor
manufacturing, flow housing
for sensor cartridge, Gas inlet
and path in front of sensor
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance, long term mechanical stability
Inert, non-reactive, non-absorbing, chemical resistance
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PVDF - Calibration cap PVDF - Weatherproof PVDF - tubing, adaptor PTFE - Coatings
PTFE - Coatings
PTFE - Coating PTFE - Coating
Front exterior of sensor module for gas calibration
Front exterior of sensor module for sensor protection from harsh environment
Remote gassing kit tube, duct mount kit adaptor
Optic manifolds for gas
detectors
used
in
semiconductor manufacturing
O-rings on moving/sliding components in gas detectors used in semiconductor manufacturing
O-rings on replaceable sensor cartridge assembly in fixed gas detector sensor module
ECC cartridge top cover
Inert, non-reactive, non-absorbing, chemical resistance Inert, non-reactive, non-absorbing, chemical resistance Inert, non-reactive, non-absorbing, chemical resistance Inert, non-reactive, non-absorbing, chemical resistance
Lubricity, chemical resistance, inert, high temperature rating
Lubricity, inert, temperature
Inert, non-reactive, non-absorbing, chemical resistance
PTFE - membranes
Gas Portables inlet for water Inert, non-reactive, non-absorbing, chemical
trap & dust filter & IP6x
resistance
PTFE - Tubing
PTFE - Connector PTFE - Others Mechanical parts
PTFE/FEP/PFA/PVDF - Tubing
PTFE - Membrane (Gore filter)
FEP - Liner
Gas Portables gas path for gas aspiration
Gas Portables gas path for gas aspiration
Gas Portables for sealing & PID sensor
Internal & eternal vacuum
tubing for gas detectors used
in
semiconductor
manufacturing
Gas inlet of sensor cartridge for IP rating
Internal tubing liner for gas
detectors
used
in
semiconductor manufacturing
Inert, non-reactive, non-absorbing, chemical resistance Inert, non-reactive, non-absorbing, chemical resistance Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
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FEP Film
Insulator for optic components in gas detectors used in semiconductor manufacturing
Inert, non-reactive, non-absorbing, chemical resistance
Teflon - Membrane
Particle filter for corrosive Inert, non-reactive, non-absorbing, chemical
gases
resistance
FKM - O-ring,
FKM - Other Mechanical
PTFT/FKM - wire
Fluorocarbon
and
Fluorosilicon
Seals,
gaskets, diaphragms
Flame Plastics
Retardant
FR4 PCBs
Grease and oils
Flexible
electrical
insulators sheets
Gas Portables for sealing Gas Portables for space & sealing Gas Portables for internal connection IM Products
IM and fixed Products
All Products
IM Products
IM Products
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
Inert, non-reactive, non-absorbing, chemical resistance
Fluorocarbon and Fluorosilicon materials are used extensively for their chemical resistance and temperature specifications.
The vast majority of the thermoplastic moulded parts utilized require flame retardants to meet approval agency requirements (UL, CE, CSA, CCC, etc.). PTFE is commonly used as a flame retardant. In addition, we occasionally use PTFE as a filler in some plastics for wear resistance,
The epoxy resins used in FR4 grade laminate materials include PFAS. As a result, 90% of FR4 circuit boards will include some content of PFAS. In addition, PFAS may be used in conformal coatings.
Fluorinated greases and oils may contain a PFPE base oil, PTFE thickener, or PTFE as an additive. PTFE thickeners exhibit excellent performance in vacuum and at high temperatures (space, aerospace, defence, industrial applications).
Flame retardant
Cable/wire insulation
IM and fixed Products
Flame retardants
Pipe sealant
IM Product
PTFE tape or liquid sealant to seal conduit holes/cable fittings
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Resistor films potentiometers
for Transportation
Flame retardant and wear resistance
Unique characteristics of these Fluorinated Materials critical for Gas Detection Instruments applications vis-vis alternatives are explained in section 5 below.
4 Absence of unacceptable and inadequately controlled risk
4.1.1 Grouping and risks assessment in the Proposal
PTFE, PCTFE, FEP, PFA, PVDF, PVF, PFPE, FKM, and FFKM are polymer-type Fluorinated Materials. Although they are not registered under REACH, they satisfy all criteria of the internationally recognised OECD definition for a Polymer of Low Concern (PLC)17. They are scientifically proven to be a low-hazard, non-toxic, non-mobile, and extremely inert materials, without chemical or biological reactivity, and with excellent stability under a range of environmental and normal-use conditions.18
All available scientific data unequivocally demonstrates that the above fluoropolymer materials do not exhibit any of the hazards assessed in Section 1.1.4 of the Proposal and that their physicochemical, toxicological, and ecotoxicological properties are very different from many other PFAS. It is apparent that these Fluorinated Materials do not exhibit PBT/vPvB equivalent concerns, contrary to the erroneous conclusions in section 1.1.6 of the Proposal.
The substances mentioned above exhibit exceptional stability, as they are solid and inert. They are resistant to deterioration caused by various factors such as acids, bases, oxidants, reductants, light-induced processes, microorganisms, and metabolic processes. As a result, they possess high resistance to thermal, chemical, and biological changes. These materials do not typically degrade under normal environmental conditions or during regular use and processing. They are notably durable and persist over time. However, it is important to note that persistence alone does not indicate any current or future risks to human health or the environment. The persistence of these substances is not inherently hazardous, as it does not automatically imply or indicate the potential for adverse effects or toxicity. The regulation of persistence by REACH takes into consideration other properties that provide insight into potential hazards. Fluoropolymers themselves are persistent, but they are not bioaccumulative, not mobile, and not toxic (not PBT/vPvB or PMT/vPvM) and therefore not SVHCs from a regulatory perspective.19
17
Data analysis of the identification of correlations between polymer characteristics and potential for health or
ecotoxicological concern, OECD Environment, Health and Safety Publications, ENV/JM/MONO(2009).
18
Please find detailed assessment of PLC criteria of fluoropolymers in A Critical Review of the Application of
Polymer of Low Concern and Regulatory Criteria to Fluoropolymers, Barbara J Henry et all, Integrated Environmental
Assessment and Management -- Volume 14, Number 3--pp. 316-334, 2018; and more recent and detailed in A critical
review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and
fluoroelastomers, Stephen H. Korzeniowski at al., Integrated Environmental Assessment and Management -- Volume
19, Number 2--pp. 326-354, 2022.
19
Persistent, mobile and toxic substances in the environment: a spotlight on current research and regulatory
activities, Heinz Rdel et al., Environmental Sciences Europe volume 32, Article number: 5 (2020).
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Therefore, grouping of Fluorinated Materials in question with "all other PFAS" for REACH restrictions and/or read-across purposes is not supported by available scientific data and ECHA RAAF requirements. 20 Therefore, "segmentation based on properties should be conducted before performing any grouping-based risk assessment, placing stable, non-hazardous fluoropolymer materials that meet the criteria to be considered PLC in a separate category".21
Furthermore, according to the RAC/SEAC opinions in the Restriction Proposal of microplastics (see the RAC opinion), it is only when a "polymer", as defined in Article 3(5) REACH, has specific intrinsic properties of "microplastics" (i.e., particle size, (bio)degradation, and water solubility thresholds) that these properties may affect its hazard characteristics, resulting in vPvB equivalent concerns. 22 It is evident that the Fluorinated Materials in question used in gas detection instruments do not satisfy the above definition of microplastics. Therefore, the blanket application of conclusions regarding PBT/vPvB and non-threshold properties of microplastics, as proxies to unacceptable risk to all fluoropolymer materials without adequate and comprehensive risk assessments of their respective hazards and exposure, is not justified. 23 The adequate scientific assessment of the above Fluorinated Materials, which is required to demonstrate the level of "unacceptable risk" under Article 68 REACH, is missing in sections 1.1.4., 1.1.5 and 1.1.6 of the Proposal.
4.1.2 Other effective RMM in place
Gas Detection Instruments are subject to various stringent technical regulations during their production, use, and end-of-life (both landfill and incineration) stages.
Manufacturing processes of these devices and Fluorinated Materials in question are regulated by the EU Industrial Emissions Directive (IED) 24 and the recent Responsible Manufacturing Commitment of the industry.25
20
See detailed discussion at pages 348-349 and Conclusions in A critical review of the application of polymer of
low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers, Stephen H. Korzeniowski at
al., Integrated Environmental Assessment and Management -- Volume 19, Number 2--pp. 326-354, 2022.
21
Ibid., at page 349.
22
In this context RAC concluded in section B.1.2.2 of the Opinion on the Restriction Proposal of microplastics
that "although there are uncertainties in the understanding of the hazard and risk of microplastics, there is sufficient
evidence to conclude that that they constitute an intrinsic hazard because of their long-term persistence in the
environment in combination with their particulate form and potential to cause adverse effects".
23
See e.g., on three elements of risk - hazard, exposure, and risk based on the hazard manifesting themselves
in the exposure in the specific case, Fidenato v Comune di Padova, Case C-442/14, Commission v Germany, Case C-
47/90. Etimine SA v Secretary of State for Work and Pensions, C-15/10.
24
Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial
emissions (integrated pollution prevention and control) (Recast).
25
"As such, all FPG Members have committed voluntarily to responsible manufacturing principles in term of
continuously improve and/or develop best available techniques in the manufacturing process, management of
environmental emissions, development of R&D programs for the advancement of technologies allowing for the
replacement of PFAS-based polymerization aids, and/or the increase recyclability and reuse of its products in line with
the objectives of circular economy." PlasticsEurope's Fluoropolymers Product Group (FPG) statement, 2021.
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Design, use, and disposal of industrial Gas Detection Instruments, systems, and materials thereof are also subject to rigorous IEC/CENELEC and ATEX standards.26 Also, the EU Pressure Equipment Directive (PED) applies to the design, manufacture, and conformity assessment of stationary pressure equipment with a maximum allowable pressure greater than 0,5 bar.27
Regulations/standards driving demand for PFAS in Gas Detection Instruments include: EN 62990-1, EN 50379, EN60079, AS/NZS 4641, ANSI/ISA 92.00.01, FDA ISO 80601-55-2, BAR, ISO/PAS 19891:2016, SOLAS guideline XI-11/7, IFC 2018, NBIC 2017, NFPA 55 (2016), Nitrogen Storage Guidelines (2016), BS EN 12021 (2014), Safe Work In Confined Spaces (2014) and HSE Confined Spaces Regulations (1997), EH40 (2011, 2005), Workplace Safety and Health Act (2009), BS 6173 (2009), AS5034 - Installation and use of inert gases for beverage dispensing (2005), Health and Safety at Work etc Act (1974), OSHA permissible exposure limits (1970), SIL 61508. These standards help ensure negligible risks and emissions of the Fluorinated Materials in question during the use stage in gas detection applications.
During the use phase, these materials remain stable and inert. They are also contained in closed and rigorously sealed devices/cells/chambers, excluding any PFAS emissions at the use stage (see sections 2.1 and 2.2 above).
There is also considerable data demonstrating that Fluorinated Materials, e.g., PTFE or PCTFE, do not degrade in the environment or release substances of toxicological or environmental concern during the landfill disposal (i.e., negligibly leachable).28
Moreover, many Gas Detection Instruments are considered as electrical and electronic equipment (EEE) or components thereof. Disposal and waste treatment of EEE at their end-of-life (even as hazardous waste) is subject to the EU WEEE Directive, Waste Framework Directive (WFD) 29 and national waste related legislation of the EU member states. These regulations could be amended at any time to accommodate appropriate handling of PFAS contained waste streams (collection, disposal, reuse, etc.), if warranted. These will be more proportionate and effective risk management options (RMO) than the restriction (i.e., bans) envisaged in the Proposal as far as uses of Fluorinated Materials in Gas Detection Instruments are concerned.
Therefore, risks due to uses of Fluorinated Materials in question in Gas Detection Instruments are already adequately controlled throughout all their lifecycle within the meaning of Articles 68 and 69 REACH, and the proposed REACH restrictions for respective substances are not justified.
26
Directive 2014/34/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation
of the laws of the Member States relating to equipment and protective systems intended for use in potentially explosive
atmospheres (recast).
27
Directive 2014/68/EU of the European Parliament and of the Council of 15 May 2014 on the harmonisation of
the laws of the Member States relating to the making available on the market of pressure equipment (recast).
28
Pages 350 in A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers
II: Fluoroplastics and fluoroelastomers, Stephen H. Korzeniowski at al., Integrated Environmental Assessment and
Management -- Volume 19, Number 2--pp. 326-354, 2022.
29
Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and
repealing certain Directives.
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5 Unique characteristics of materials in question and absence of feasible alternatives
Fluorinated Materials, such as PTFE, FEP, PFA, PVDF, PVF, PCTFE, PFPE, FKM and FFKM, provide unique properties for critical technical features of Gas Detection Instruments. These materials could not be substituted by in-kind alternative substances even within the long perspective as demonstrated below.
As explained above, alternative materials should meet all set of unique characteristics of Fluorinated Materials, including:
- Broad chemical resistance to virtually all chemicals, in particular to harsh chemicals such as sulfuric acid, hydrofluoric acid, and chlorine;
- Inertness in all environments;
- Exposure to low temperatures near -60C and down to -200C for cryogenic processing;
- High temperatures performance up to 260C;
- Corrosion resistance;
- High pressures near 150 bar common for many chemical reactions (up to 1000 bar for some chemical processes);
- Flame resistance with a high heat of combustion and limiting O2 Index;
- Good electrical properties; excellent dielectric properties;
- Low friction / non-adhesive resistance.
Although other materials can demonstrate comparable or even superior performance in single properties, only Fluorinated Materials can reach above characteristics simultaneously (e.g., high temperature performance and chemical resistance on PTFE vs. PEEK).
Importantly, in case of substitution by other materials, new gas detection equipment would need to be recertified under ATEX and all applicable national and international standards (e.g., IEC 62990-1), meaning that hundreds of new gas characterization tests, gas parameters table updates, gas performance tests and certification updates will be required.
- Downsides of alternatives to PTFE and other fluoropolymers
PTFE is a unique inert, gas permeable, hydrophobic, and low flammability material, which is essential for membranes, electrodes, wires, and other components of Gas Detection Instruments. For instance, PTFE allows the support of electrode in E-chem gas sensors, acting as a physical wet barrier for electrolyte containment. Inert and gas permeable, PTFE allows the target gas to diffuse to a three-phase region, where catalyst, gas, and electrolyte can react. The electrode structure of hydrophilic catalytic material and hydrophobic PTFE creating channels within the electrode allow gas to access the wetted catalyst material.
None of other non-PFAS substances (e.g., polymethyl urea (PMU) are able to provide required technical characteristics, specifically in regard to the hydrophobic, inert, and gas permeable properties of PTFE.
PMU based alternatives to PTFE powders have a lower density and decomposition temperature (>200C compared to >345C), which is not suitable for the curing temperature of the electrode process. PMU is a
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polar polymer and a number of reactive groups (including carboxyl, amine, and hydroxyl groups) may cause side reactions with target gases. PTFE, by contrast, is a non-polar polymer and inert.
The same is true for PVA materials used in Gas Detection Instruments. They are not as robust, nor as stable, nor efficient or powerful as PTFE based devices. They are also hydrophilic and soluble in water as well as toxic (solutions containing more than 5% PVA are toxic to fish)30 and they biodegrade slowly.31
PVA
PTFE
PE
PFA
In the meantime, PE, LDPE and HDPE plastics are highly flammable, sensitive to stress cracking, and lack resistance to oxidizing agents and chlorinated hydrocarbons and therefore objectively are not able to serve as a substitute for PTFE in industrial gas detection sensors and systems.
For new material development, producers of industrial gas detectors rely upon their material suppliers. However, in the case of PFAS, to the best of our knowledge, respective suppliers have indicated that replacements will be cost-prohibitive, and time periods much longer than the maximal derogation period of 12-years are envisaged. It is also not certain that those alternatives would enable equivalent technical performance while meeting all relevant regulatory standards, particularly under ATEX for explosive installations. Respective re-certification will also take longer time. Therefore, replacing PTFE in industrial Gas Detection Instruments and components thereof in a specified time frame is not feasible.
PTFE and other fluoroplastics like FEP, PFA, PVDF, PVF, and PCTFE have the ability to endure high temperatures during processing. In this respect, for example, the manufacturing process of gas sensors electrodes involves one, two, or three stages of elevated temperature, depending on the method used. These stages include sintering, bonding, and sealing, and they necessitate temperatures higher than 150C. As a result, certain alternative materials such as polypropylene (melting point: 130-171C) or polyethylene (melting point: 115-135C) cannot be used, and new sensor designs and electrode manufacturing processes would be required.
In this respect, other materials such as acrylic copolymers or polyurethanes (PU) also lack chemical compatibility with strong acids, which makes impossible their use with electrolytes in electrochemical gas sensors. Materials like expanded polypropylene or polyether-ether-ketone (PEEK) have too high surface energy so they cannot be used as gas porous substrates for membranes.
Certain materials, such as polyurethanes (PU) are also susceptible to degradation by repeated exposure to certain toxic acidic-type gases, including hydrogen cyanide, hydrochloric acid, chlorine, sulfur dioxide. Hence, they physically cannot be used in industrial gas sensors (as well as in pumps, dust filters, tubing, spacers, connectors, solenoids, valves, etc.) for detection of toxic gases and thus to substitute fluoropolymers in such applications. The same is true for the engineered plastics PEEK and Polyphenylene
30
Polyvinyl Compounds, Others, Manfred L. Hallensleben, Ullmann's Encyclopedia of Industrial Chemistry, 2000.
31
Biochemistry of microbial polyvinyl alcohol degradation, Applied Microbiology and Biotechnology, Kawai F, Hu
X, 2009.
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Sulfide (PPS), especially where chemicals such as hydrogen sulfide (sour) gas and strong acids are at stake.
Importantly, for detection of sticky gases such as hydrochloric acid, chlorine, hydrogen fluoride, hydrogen bromide, etc, gas-facing surfaces on the sampled gas path of tubes, connectors, and other components should be highly chemically inert. If not, gas path absorbs a large portion of the sampled gas resulting in inaccuracy of the measurement. In this regard, PTFE and other fluoropolymers are the only compatible materials for these purposes.
Fluoropolymers, such as PTFE, FKM, etc. are also indispensable for the insulation of wires and cables used in industrial gas detections systems. It is necessary to protect the systems against environmental threats, harsh operating conditions and to prevent electrical leakage. The use of fluoropolymers in such electric equipment is driven by outstanding electrical properties, such as low dielectric constant, flame, crack, and chemical resistance, thereby contributing to the longevity of the overall system. For example, low dielectric loss tangent and high dielectric strength are important detection instruments used aerospace and petroleum and mining industries. Combined with high chemical and temperature resistance, and low surface friction characteristics of fluoroplastics such cables are easier for passing through tight conduits.
Alternatives such as PEEK do not satisfy all application requirements (e.g., when PEEK is pressurized with steam, the water will penetrate into the waveguide and affect the reliability of the measurement and even block the signal of the measurement).
For many of the substances concerned, there are no alternative theoretical material chemistries which could be used as a basis for invention, and the development of a whole new area of chemistry and/or technology will be required. There are also concerns that substitution of certain specific materials would be as large as designing new gas sensors and industrial detection systems and would require an uncertain period of time, as highlighted above.
- Alternatives to (per-)fluoroelastomers (FKM/FFKM) as gaskets, O-rings, and sealants
FKM and FFKM materials are used to seal components inside gas sensors and detection systems and/or its external components, i.e., between tubes, pumps, dust filters, solenoids, connectors, etc. They have excellent sealing properties in extreme conditions.
Their unique properties include high oxidation resistance. This makes (per-)fluoroelastomers the only suitable materials for oxygen and hydrogen equipment and oxidising environments. In addition, it is not feasible to use alternative materials to measure reactive or acidic gases, such as ozone, nitrogen dioxide, chlorine, sulphur dioxide, and hydrogen sulphide. Only highly chemically inert seals and other components from FKM/FFKM may be used. No satisfactory alternatives for those applications have been found so far.
- Alternatives to perfluoropolyether (PFPE) and PTFE greases
Industrial gas sensors and detection systems rely on PFPE and PTFE materials, including powders, due to their remarkable resistance to highly acidic conditions (e.g., electrolytes or hydrogen fluoride (HF) chemical production) and fluctuations in temperature. Specifically, PTFE/PFPE greases exhibit consistent viscosity across a wide temperature range spanning from -40C to +60C. No viable alternatives currently exist that can provide a grease formulation with a low dependence on viscosity-temperature relationship.
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- Other materials
All potential alternatives, metals, non-PFAS polymers (PEEK, PPS, etc.), and non-PFAS elastomers (e.g., Ethylene Propylene Diene Monomer (EPDM), Hydrogenated Nitrile Butadiene (H-NBR), and Silicone) are not suitable for many critical gas detection applications due to either weaker chemical resistance, temperature limitations, and/or mechanical properties. Moreover, these are high performance materials that are likely persistent or very persistent substances similar to fluoropolymers, resulting in substitution of one persistent material with an inferior performing one, leading to increased failure risks, maintenance cycles and generation of higher amounts of environmental waste. These materials could be considered as "regrettable substitutions" as far as Gas Detection Instruments are concerned.
6 Socio-economic impact of the proposed REACH restriction
Industrial gas detectors provide continuous monitoring for toxic (including, HCl, HF, PH3, BCl, H2Cl2Si, AsH3, CO, O3, C4F6, GeH4, SiH4) and flammable gases (e.g., C3H8O, CH4, H2) and alert users of the potential presence of these gases to mitigate the risk of employee exposure and potential loss of life or property. It is equally important to have accurate gas monitoring systems to avoid false shutdowns of whole industrial installations due to inaccurate detection that can result in lost revenues up to 500 000 Euro per hour of stoppage.32
Fluoropolymers, such as PTFE, (per-)fluoroelastomers, and perfluoropolyethers, provide crucial characteristics for key components of Gas Detection Instruments/systems (gas sensors, tubes, connectors, duct filters, valves, seals, etc.). These chemicals possess high temperature, compression, chemical, and mechanical resistance, making them ideal for gas detection applications. Respective characteristics directly influence selectivity, precision, reliability, and longevity of these instruments in Critical Operations.
Without the above Fluorinated Materials, Gas Detection Instruments would likely experience much higher rates of failure, component failures, errors in measurements, and false or absent alarms, leading to premature obsolescence of other devices/machinery and substantial industrial safety and health incidents. Currently, there are no known technically, or economically, feasible alternatives to most of these substances in Gas Detection Instruments for mineral acids and oxidizer gases used in semiconductor manufacturing, oil and gas, confined space application, water treatment, chemical production and many other sectors. Moreover, there is great uncertainty about successful development of alternatives within the time frames envisaged in the Proposal for most derogations.
In case the proposed PFAS restriction would be adopted, the worldwide industrial sectors that rely on gas detection as a whole would experience tremendous economic and social shock. This would consequently cause a huge socio-economic impact to many industries and societies because gas detection is used in essential utilities (power generation, water treatment, security and defence, etc.), all major production facilities (semiconductors, chemicals, oils and gas, etc.), fixed and portable gas detection (life safety in petrochemical plants, steel mills, etc.) and in many other economy sectors. As noted above, if Fluorinated
32
In particular, toxic gas detection is crucial for the semiconductor manufacturing industry, which uses complex
high-purity chemicals and where disruptions in the production processes are extremely costly. These disruptions might
also have negative cascading impact on several other industries (medical devices, transportation, defence, etc.)
essential for the economy and society.
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Materials were banned in Gas Detection Instruments, industrial production in semiconductors, automotive, petrochemical, and crude oil sectors worth over 2 trillion EUR would be compromised due to the lack of adequate safety-related gas detection systems. These consequences are certainly in conflict with the wider EU industrialisation and competition policies as well as objectives of the European Green Deal, REPowerEU, European Chips Act, Net Zero Industry Act, and other emerging laws around sustainability, workplace safety, and industrial process controls. Although it is practically impossible to estimate exact volumes and emissions of Fluorinated Materials used in Gas Detection Instruments in the EU, it is evident that the proposed ban on all PFAS in industrial Gas Detection Instruments applications would result in too high costs on the society and is disproportionate to the alleged risks for health and the environment due to the lack of persistency of the PFAS materials in question.
7 Conclusion Considering the above, PFAS materials are critical to the quality and fundamental functionality of Gas Detection Instruments and systems. Submitted information provide the necessary evidence to support either the complete exclusion of the Fluorinated Materials in question from the Proposal or to justify respective time-unlimited derogations because there are no available suitable alternatives. In this respect, the complete ban envisaged in the Proposal on all uses in the EU of Gas Detection Instruments with Fluorinated Materials/components as spare parts for the existing equipment and installed systems would have tremendous consequences and costs for society. Honeywell requests that PTFE, PCTFE, EFTFE, FEP, PFA, PVDF, PVF, FKM and FFKM based fluorinated materials used in all Gas Detection Instrument applications should be either excluded from the scope of the Proposal or made subject to a time-unlimited derogation.
______
Annex I - List of acronyms and abbreviations Annex II - Lists of fluorinated substances and components of Gas Detection Instruments
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