On February 7 the European Chemicals Agency (ECHA), the EU agency in charge of regulating chemicals, published a proposal from Denmark, Germany, the Netherlands, Norway and Sweden to restrict per- and polyfluoroalkyl substances (PFAS) – so-called forever chemicals – under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), the EU’s chemicals regulation.
The long-awaited “Universal Restriction Proposal” – officially known as the Annex XV Restriction Report – would restrict the manufacture, use or sale of certain fluorinated refrigerants as substances on their own or in blends according to certain thresholds.
The PFAS definition applied in the proposal for single fluorinated refrigerants would include both HFCs and HFOs, such as HFC-125, HFC-134a, HFC-143a, HFO-1234yf, HFO-1234ze(E), HFO–1336mzz(Z) and HFO-1336mzz(E). The proposal would also apply to trifluoracetic acid (TFA), an atmospheric degradation product of, notably, HFO-1234yf (100% conversion) and HFC-134a (up to 20% conversion).
PFAS pollution is also increasingly in the spotlight due to the Forever Pollution project’s report finding that widespread contamination already affects European soil and ground water.
To gain a greater understanding of the PFAS restriction proposal and the implications of PFAS for the cooling and heating industry, ATMOsphere interviewed Sandrine Benard and Audun Heggelund, Senior Advisors for the Norwegian Environment Agency. Together with their team, they have managed the part of the proposal related to fluorinated gases, such as refrigerants.
ATMOsphere: Sandrine and Audun, many thanks for agreeing to meet us and talk about the Universal Restriction Proposal on PFAS. To kick off this interview, can we please ask you to introduce yourselves to our readers?
Sandrine Benard: Thank you for having us and for the interest in our work. We work together at the Norwegian Environment Agency but in different departments. I work in the Climate Department with regulation of fluorinated gases based on their contribution to global warming, while Audun works with chemicals regulation in the Chemicals and Supervision Department. This combination of knowledge is key to understand the environmental problems caused by the use of fluorinated gases and how to solve them.
Audun Heggelund: The environmental issues with persistent degradation products forming from fluorinated gases were first recognized by our Climate Department some years ago and assessed in a report. However, we soon realized that the European chemicals regulation had the better tools for addressing these challenges.
ATMOsphere: What are the main drivers pushing your agency and the others to take action against PFAS?
A.H.: PFAS are man-made chemicals that don’t belong in the environment. However, over the last decades, the substances have been used in large volumes in many different applications, and today we can find PFAS essentially everywhere on the planet. The main concern with PFAS is their high persistence – that they don’t break down in the environment. The persistence makes them survive over decades and centuries and expose us over generations – and this is also the background for the nickname “forever chemicals.”
ATMOsphere: What are the main concerns related to fluorinated refrigerants that are PFAS?
S.B.: Fluorinated gases defined as PFAS are used in different applications, and when emitted, a small molecular transformation takes place in the atmosphere, and persistent substances like TFA [trifluoroacetic acid] and similar compounds are formed that will stay with us and around us for many, many years. Some of the fluorinated gases that are defined as PFAS have a long lifetime in the atmosphere and contribute first strongly to global warming before they eventually break down to TFA and other PFAS substances.
ATMOsphere: How concerned are you about the creation of growing amounts of TFA in the environment from the atmospheric degradation of f-gases, especially HFO-1234yf?
S.B.: There are many scientific studies of TFA in the environment, which individually represent a worrying trend. The background levels and general exposure to TFA for humans, as well as the environment, are increasing. Taken together, all these studies represent a big concern as they all show the same development. Of particular concern is that substances such as HFO-1234yf, degrading totally into TFA in a few days, may give unexpectedly large increases in TFA locally near the emission source. Hence, densely populated areas that switch to the substance at large scale, e.g., as refrigerant in air-conditioning in cars, may experience surprisingly high levels of TFA in their waterways.
ATMOsphere: What are the main provisions targeting fluorinated refrigerants that are PFAS in the proposal you and your colleagues submitted?
S.B.: Fluorinated refrigerants are treated in the same way as other PFAS in the restriction proposal. To avoid the build-up of the concentrations of these substances and their degradation products (like TFA) in the environment, we aim to reduce uses, and [thus] emissions, to a minimum. For all the applications where we are aware that fluorinated gases are used, we have assessed the availability of non-PFAS alternatives. For the applications where alternatives are not available at commercial scale within the next years to come, we have considered derogations [exemptions]. The few derogations proposed are mainly time-limited, as we expect that non-PFAS alternatives will, over time, be developed and replace PFAS in their applications.
ATMOsphere: What do you expect from the upcoming stakeholder consultation starting end of March?
A.H.: We have already conducted two open consultations on PFAS applications, but in the upcoming formal public consultation, we expect a higher number of companies and stakeholders to come forward with relevant information. Regarding fluorinated gases, we have spoken to different stakeholders within the sector, and we expect inputs from both parties that are still relying on PFAS, as well as players that have already found suitable non-PFAS alternatives for relevant applications. Our task will then be to compare the different inputs and from that basis draw a conclusion on the present and future availability of alternatives for specific applications.
ATMOsphere: What do you expect from the opinion of the scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC)?
A.H.: This is a large restriction dossier covering several sectors, and there are a lot of different issues to discuss in the opinion-making phase. The committees take the comments from the public consultation into account, and this may influence the discussions during the process. We expect not too many questions on the hazard basis, as this is very well known for PFAS today. However, there may be questions raised about specific applications and the need and conditions for derogations.
ATMOsphere: When do you envision the restriction will enter into force?
A.H.: Usually, the opinion-making phase takes one year for restriction proposals. However, in this case the proposal is large and complex, and some additional time may be needed. We hope that the opinion of RAC and SEAC will be finalized and forwarded to the [European] Commission for decision-making during late 2024. After adoption there will be an 18- month transition time until entry into force.