Document 9LrNvqZM0eJpBqwObKO46080q

Per- and polyFluoroAlkyl Substances (PFAS) Why HFO-1234ze shouldn't be subject to restriction All PFASs in scope of this restriction proposal are either persistent themselves or degrade to other persistent PFASs. HFO-1234ze is not classified as PBT and/or vPvB. HFO-1234ze toxicity and environmental impact has been thoroughly assessed, both under REACH and in international forums such as the UN Environmental Program (UNEP) and the Intergovernmental Panel on Climate Change (IPCC) and HFO-1234ze does not decompose into Trifluoroacetic acid (TFA) in a significant fraction, according to several scientific studies (EEAP-2022-Assessment-ReportMay2023.pdf (unep.org)page 25 , Atmospheric chemistry of short-chain haloolefins table 3). All PFASs in scope of this restriction remain in environment for decades to centuries (Forever chemicals) has an atmospheric lifetime of 19 days and a GWP value about 1, according to the IPCC AR6 report The term "PFASs" is a broad, general, non-specific term, which does not inform whether a compound is harmful or not. Moreover the ECHA Read-Across Assessment Framework (RAAF) clearly states that a separate assessment should be conducted for each information requirement intended to be fulfilled by the read-across approach. This is also confirmed by the OECD Expert Group on PFAS (including experts from the dossier submitters) It is clear that including HFO-1234ze in such a general group based on the presence of at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it) does not meet the RAAF criteria. Important points regarding essential uses of HFO-1234ze in XPS Essential Properties deriving from HFO-1234ze use in XPS foams Low thermal conductivity- High thermal insulation performance (max. U value) The use of HFO-1234ze as a blowing agent, which remains for decades in the XPS panel, enables considerably improved declared thermal conductivity values of 23 to 27 mW/m.K, which results into notable energy savings and lower related CO2 emissions of up to 25%. The use of CO2 as a blowing agent together with infrared blockers and small amounts of hydrocarbons only allows a declared thermal conductivity for XPS of minimum 31 - 35 mW/ m.k. Furthermore higher amounts of hydrocarbons as blowing agent, which do not stay more than a decade in the foam, do not allow the XPS to achieve any fire performance classification, even with the addition of flame retardants. This would go against most national safety standards requirements. High Mechanical Properties combined with high Resistance to Humidity of XPS : Unique combination of properties, not provided by alternative insulation foams, is key to retain the thermal performance and provides exceptional durability of the insulation product. Applications where HFO-1234ze in XPS foams is essential Refrigerated trucks Must meet a set of demanding requirements including sustainability standards: - Truck dimensions are regulated under the Weights and Dimensions Directive. A refrigerated truck in order to be in compliance with the predetermined dimensions and weight obligations can only provide restricted space for thermal insulation. - High thermal insulation performance (max. U value) of the refrigerated box is required by the "Agreement on the International Carriage of Perishable Foodstuffs and on the Special Equipment to be Used for such Carriage" (ATP) and confirmed by testing. Furthermore, thermal performance of the truck body must be maintained over its lifetime. The U value requirement only allows to use XPS (with HFO) or PUR (also with HFO or pentane). - The truck floor must be capable of withstanding high mechanical forces from heavy cargo, during service on the road and during loading and unloading; Dynamic flexural fatigue resistance value for XPS on refrigerated trucks floor system, is the highest available in the market thus the very strong differentiation versus any alternative system on floors, and other panels under constant regular cycling loads. The use of any other foam type on the floor would mean more reinforcements (higher weight / more thermal bridges) without guarantee against damages on panels, which will lead to quick absorption of humidity, permanently affecting their insulating and mechanical performance and reducing the overall lifetime of the trailer. The truck would fail the recertification (ATP) after the initial 6 years and the truck must be downgraded or dismantled/wasted. - The truck must also have a low CO2 footprint and a low fuel consumption at fixed outer dimensions and maximized loading volume. HFO-1234ze in XPS foams provide, together with IR blocker, a unique combination of highest thermal insulation performance at low thickness along with the highest possible mechanical strength resisting and fatigue resistance due to driving vibration at low transported weight. Restriction of HFO-1234ze in XPS foams will have a major impact on: - Capability to have a secured food transport: occasional temperature increases on cargo may lead to a hygiene risk. - Loading capacity as higher thickness insulation products would be probably used in order to meet the ATP which will dramatically reduce the loading capacity of the refrigerated truck. - Thermal insultation value and health and safety. An insulation foam blown with high amounts of hydrocarbons (in order to achieve a better U value) which are typically produced from crude oil in refineries, are classified as (extremely) flammable and included in Annex I of the Seveso III Directive (2012/18) on the control of majoraccident hazards involving dangerous substances. The use of hydrocarbons will not result to the essential thermal insultation value while on the same time challenges regarding health and safety issues in the production process of both the XPS and the truck itself must be overcome. - Driving induced stress. Another foam type will not survive the driving induced stress medium to long term. The resulting loss in both strength and insulation will significantly increase the energy consumption and CO2 emissions of the truck to keep the food safe. The production of these foams entails industrial hygiene requirements (diisocyanates OEL & training) that XPS production do not have. Medical/pharmaceutical packaging Must meet a set of demanding requirements including sustainability standards: - Wide range conservation temperatures of the packaging requires high performance insulation to optimize parcel dimensions - High resistance to humidity of XPS, not provided by alternative insulation foams, is key to retain the thermal performance during the life of the packaging system - High mechanical strength is required for Foldable/flat packable/easy to reassemble packaging systems. - Reuse and Recycle of the packaging is essential for the medical/pharmaceutical industry as it extends the life of the packaging which in any other case will lead to more packaging waste. It is known that each package of XPS foam is being reused for up to 10 years and then it's being recycled easily and economically. XPS foam HFO-1234ze results in products which combine, high thermal insulation performance, high mechanical strength, high resistance to humidity while at the same their low weight uniquely allows a recently implemented worldwide reuse system (Reverse logistics). A restriction on the use of HFO-1234ze foams for this industry will affect : - The ability to secure pharmaceutical transport : occasional temperature increases on cargo may lead to a health risk. - The transportation of the amount of packages per truck as larger size packaging with thicker insulation to retain thermal performance will be used. Therefore more energy will be used, higher emissions of CO2 will be emitted, per transported goods - The end of life management of alternatives o Composite products - needs separation o Thermoset products - no mechanical recycling o Alternative insulation products are more sensitive to humidity which would significantly deteriorate their insulation efficiency medium to long term and potentially result in hygiene or health issues. Insulation of Building for limited thickness application XPS blown with HFO-1234ze is used as a high-performance thermal insulation where space becomes a key driver in respect of the additional energy that can be saved e.g double layer walls. - High-efficiency thermal insulation applications especially where space is constrained. Low thermal conductivity minimizes the board thickness needed to achieve a specific U-value thus allowing the designer greater flexibility while the XPS itself provides the necessary physical integrity, durability and low water absorption that are essential to the upside roof applications - Emissions from thermal insulation in the use phase are very low because of closed cell structures - Thinner external wall construction can result in less material usage which results in savings in embodied carbon. Thinner insulation profiles can create opportunities for more resource-efficient building elements and lower embodied carbon. - Safety requirements. alternative blowing agents offer poorer fire performance when encapsulated in products and limit application of thermally efficient foams. - In renovation & refurbishment projects, the geometry of the building is already defined and available space becomes a key driver in respect of the additional energy that can be saved. Therefore, highly efficient insulation provides greater energy saving prospects. A restriction on the use of HFO-1234ze foams for this industry will have a major impact on : - The increased safety requirements and reduced performance of alternatives compared to HFO-1234ze blowing agent. Would flammable gases be accepted in spite of unsafe conditions when the insulation properties will not achieve those of HFO-1234ze? - High efficiency insulation. Since 80% of the buildings that will be standing in 2050 have already been constructed and are in use, the impact of losing high efficiency insulation will be substantial. - Capital Cost. Increased capital investment costs for alternatives, including that safety equipment for potentially explosive devices (enforced by the EU ATEX regulation332). The previous fluorinated gas prohibition only occurred in 2020 and the foam industry has not yet recovered the investments required by such a recent change. In the proposal several substances are referred as alternatives to HFO for XPS foams:  Hydrocarbons are less thermally performing, will diffuse out quicker from the foams while at the same time they are extremely flammable, therefore they cannot be used due to safety concern. CO2 blown XPS are up to 25% less efficient thermal insulation which is an issue when thickness availability is limited and also in standard building applications because insulation thicknesses are reaching 200 mm and walls, roofs, their fixations have finite dimensions. REFERENCE LIST for the data provided in the sections IPCC AR6 report EEAP-2022-Assessment-Report-May2023.pdf (unep.org) Atmospheric chemistry of short-chain haloolefins Table 3 EFCTC reference incineration reports Co-combustion of BUILDING INSULATION Foams with municipal solid waste. DOI: 10.1080/00102209808952095