EFCTC contribution to the ECHA Public Consultation on the proposed restriction of PFASs in fire-fighting foams
EFCTC has prepared a submission to the ECHA Public Consultation on the REACH restriction proposal of PFAS in fire-fighting foams to bring to the attention of the members of the ECHA RAC and SEAC that F-gases are not contained in fire-fighting foams. Some F-gases are used in very specific and limited cases for clean fire-extinguishing and suppression techniques, which are not in scope of this restriction proposal. These techniques do not leave any oily residues, particulates, or water damage and rapidly extinguish fires with an excellent weight to effectiveness ratio, which makes them ideal for fire-fighting in critical high value applications such as data centres and museums.
EFCTC identified three main issues discussed in the report and annexes and has provided further information.
- TFA yields from the degradation of most HFOs, and HCFOs. The EFCTC analysis Published evidence supports very low yields of TFA from most HFOs and HCFOs - Fluorocarbons concluded that 10% TFA yield, in the documentation, is a considerable overestimate for HFO-1234ze, HFO-1336mzz and HCFO-1233zd. EFCTC believes that its analysis would contribute to an improved understanding of degradation.
- The possible formation of CHF3 (fluoroform, HFC-23) from some HFOs. The documentation gives undue emphasis to the atmospheric degradation of HFO's as an unrecognized and secondary source of fluoroform (CHF3, HFC-23). This has been disproved by a 2022 paper, which observed no formation of CHF3 (HFC-23) under any of the experimental conditions.
- Global warming potential of degradation products from HFOs and HCFOs. EFCTC provided authoritative data sources for the HFOs and HCFOs, demonstrating that formation in the atmosphere of degradation intermediates or final products with high GWP is not significant.
EFCTC has expressed its availability to answer any follow-up questions in the context of the inclusion of F-gases in this REACH restriction process.
More information about the EFCTC submission will be included in the next issue of the Newsletter – SUSCRIBE
For any questions, please contact the EFCTC Secretariat at firstname.lastname@example.org