Remarks and Clarifications!

Due to some questions from stakeholders, we want to inform you on the following issues:

  • There were requests to have more time for data collection. As a reaction to this we extended the timeline for completing the survey by one month until 15th April 2018.
  • There were contradicting information in the background document whether sulfonated substances are covered by the survey or not.
    The answer to this question is: Yes, these substances are in the scope of this survey! There was a mistake, when we drafted the document. We are apologising for this.
  • Stakeholders asked, if chapter 4 of the survey is related to in principle all fluorinated compounds.
    The answer to this is: No! Only compounds, that can be derived from the short chain substances are of interest (this indeed can include polymers).

Access and registration:

Background

The German Environment Agency (Umweltbundesamt – UBA) is currently investigating specific representatives of poly- and perfluoro alkyl substances (PFASs). In particular the UBA is collecting information on the manufacture and use of such short chain PFASs with the aim to identify areas of use that pose a risk to the environment and/or human health that needs to be addressed by an EU-wide regulatory measure under REACH (a restriction). Furthermore, the data collection covers the availability of alternatives to the use of fluorinated compounds and the socio economic impacts of a potential restriction scenario for the various areas of application.

Short chain PFASs in this regard are substances with chain lengths < 7 perfluorinated C-atoms, more likely the main representatives C4 and C6. These can originate from various chemical groups. Some examples are given below (not conclusive):

  • Per- and Polyfluorinated Carboxylic Acids (PFCAs)
  • Fluorotelomer alcohols (FTOHs)
  • Fluorotelomer iodides (FTIs)
  • Fluorotelomer acrylates (FTAs) and Fluorotelomer methyl acrylates (FMAs)
  • Per- and Polyfluorinated Sulfonic Acids (PFSAs)

Within the scope of the information collection are also polymeric substances that are generated out of these building blocks, such as several fluorotelomers etc.

It should be highlighted that the outcome of such a data collection is to define the scope of the restriction. This also includes:

  • The identification of uses, materials or final products where good control can be assumed. Such applications can be excluded from the scope of the restriction proposal.
  • Furthermore, exemptions can be included in the restriction proposal if these can be justified, e.g. if the lack a of viable alternatives can be demonstrated or a high socio economic importance of the application area.
  • Information on the extend of the use, the content of the substances concerned in products and the socioeconomic impact of a planned “non-use” scenario help to define thresholds of the later restriction.

To be able to draft a suited measure and to be able to consider special requirements for single uses right from the beginning of the restriction process, the UBA is hereby initiating a collection of information in the value chains of these substances.

Therefore the authors of the restriction proposal would welcome any information in this regard that will be provided by stakeholders that can be included into the proposal.

Objective

The objective of this survey is to increase the information basis on

  • manufactured and imported amounts of the respective substance groups
  • manufactured and imported amounts of their potential alternatives
  • the type of uses the substances are applied to as well as
  • the economic effects that are linked to the use of the substances.

Please note that it is highly important to provide information on all the use cases you know of (also if only small tonnages of a substance is applied) to avoid unintended consequences for market actors when a regulatory measure is implemented. This is especially true for uses that might contribute to a high added value of products or have a high socio economic value due to particular application (e.g. health care or pharmaceuticals).

Uses are also of particular relevance if they are linked to long phase-out periods of substances (for example due to long product development cycles, a long service life or safety related approval processes, that require longer transition periods for the phase out of substances).

Participate

To register and to participate in the survey, please use one of the following links that represent your organisation (it is possible to reply to more than one questionnaire if your organisation represents more than one role).

Upon your registration, you will receive your personalized access link for the survey. It is possible to exchange this link with other persons in your organisation so more than one person can add information to the survey. The survey can be accessed an completed until march, 15th, 2018.

How it works

There will be four question groups:

  • Which substances are relevant for your organisation.
  • How are processes performed in your organisation.
  • What might be the economic consequences on your organisation and to what extend do you see a possibility for substitution.
  • How do you in general evaluate a restriction.

You can share this survey with other persons in your organisation, in case you wish other persons in your organisation to provide data as well. In this case, please forward the link to the survey provided in the email you have received upon your registration to the respective persons.

To pause your data input, in order to share it with your colleagues or to continue later, please click on the “Resume later” button on the bottom of the screen.

To submit the survey, you need to click the “Submit” button on the last page. All your data will be editable until you submit the survey.

In case the substance group of PFASs and their precursors may comprise a large number of substances, we prepared an Excel sheet that you can use instead of filling in the information online. This gives you the opportunity to extract data from IT systems in your organisation and simplifies the handling of the data you may provide.

You can download previews of the several surveys on the right side bar of this website. (Note please: This preview is only for your information and is not suited to provide the information.)

Data safety and security

The data will be used by the German Environment Agency and Ökopol GmbH/Swerea IFV to develop a restriction proposal under REACH. The data you are providing is not anonymised when entered into the questionnaire, as we intend to organise a follow up interview process to clarify open issues that might occur upon the processing of the data you have provided. Data that becomes part of publically available documents are only used in anonymised and aggregated ways.

This survey is hosted by Limeservice GmbH Barmbeker Str. 7a, 22303 Hamburg, Germany in accordance with § 9 of the German Federal Data Protection Act.