PFOS) and Related Chemicals Listed Under the Stockholm Convention on Persistent Organic Pollutants

Guidance on best available technology and best Deleted: techniques environmental practices for the use of perfluorooctane sulfonic acid (PFOS) and related chemicals listed under the Stockholm Convention on Persistent Organic Pollutants

Note by the Secretariat: Substantive input and specific comments received from parties and others have been integrated in this draft. General comments requiring additional information which has not been made available to the Secretariat have not yet been addressed. The list of comments and responses is provided in a separate document.

Draft – 5 September 2014 Revised March 2014 Deleted: Formatted: Left Deleted:

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Disclaimer

The views expressed in this publication do not necessarily reflect the views of the Secretariat of the Stockholm Convention (SSC), the United Nations Environment Programme (UNEP), the United Nations Industrial Development Organization (UNIDO), the United Nations Institute for Training and Research (UNITAR), the United Nations (UN) or other contributory organizations. SSC, UNEP, UNIDO, UNITAR or the UN do not accept responsibility for the accuracy or completeness of the contents and shall not be liable for any loss or damage that may be occasioned, directly or indirectly, through the use of, or reliance on, the contents of this publication.

Table of Contents Comment [1]: Please consider updating the Table of Contents according to suggested new structure of the document. An outline for Chapter 3 and 4 can be found after Chapter 2 concludes.

Deleted: Table of Contents 3 ... [1]

Abbreviations and Acronyms Comment [2]: Might need to be updated once all updates in the text are complete ABS acrylonitrile butadiene styrene AFFF aqueous film-forming foam APEO Alkylphenoletoxylates AR-AFF alcohol resistant aqueous film-forming foam ARC anti-reflective coating AR-FFFP alcohol-resistant film-forming fluoroprotein AR-FP alcohol-resistant fluoroprotein Foam BARC bottom anti-reflective coating BAT Best Available Technology Deleted: best BEP Best Environmental Practice Deleted: available Deleted: BOD5 5-Day biochemical oxygen demand techniques BPM barrels per minute Deleted: best BREF BAT Reference Document Deleted: Environmental CCD charge-coupled device (technology for capturing digital images) Deleted: practices CMC critical micelle concentration COD chemical oxygen demand COP Conference of Parties DUV deep ultra violet DWR durable water-repellent ECF electrochemical fluorination EMS environmental management system ETFE Ethylene-tetrafluoroethylene cpolymer Deleted: Tetrafluoroethylene EtFOSA N-Ethyl perflurooctane sulfonamide Deleted: sulfonamide FFFP film-forming fluoroprotein foam FOSA N-Alkylperfluorooctanesulfonamide Deleted: ph FOSE N-Alkylperfluorooctanesulfonamidoethanol Deleted: ph FP fluoroprotein foam IBC intermediate bulk container INPEV National Institute for Processing of Empty Packages LCD liquid crystal display MSDS material safety data sheet PBT Persistent, Bioaccumulative and Toxic Deleted: persistence Deleted: bioaccumulation PFBS perfluorobutane sulfonate Deleted: t PFC perfluorinated compound Deleted: ity PFOS perfluorooctane sulfonic acid Deleted: PFAS PFOSA perfluorooctanesulfonic acid Deleted: perflouroalkyl sulphonate PFOSF perfluorooctanesulphonyl fluoride Deleted: ph PFSA perfluoroalkane sulfonic acid Deleted: ph POPRC Persistent Organic Pollutant Review Committee POPs persistent organic pollutants PPE personal protective equipment

PVD physical vapour deposition R&D research & development SDS Safety Data Sheet STMP surface treatment of metals and plastics TARC top anti-reflective coating THPFOS tetrahydro PFOS TLV threshold limit value UNEP United Nations Environment Programme US EPA United States Environmental Protection Agency VOC volatile organic compounds

1. Introduction

1.1 Purpose Comment [3]: Please consider to include the added sentence as it makes clear that this is The concept of Best Available Technology (BAT) and Best Environmental Practices (BEP) is not not a comprehensive overview of all available alternative techniques. aimed at the prescription of any specific technology or practice. BAT means the most effective Deleted: and advanced technology available in addition to the practical suitability of particular best techniques. Best Environmental Practices (BEP) describe the application of the most appropriate Deleted: available combination of environmental control measures and strategies (Article 5, f (v) of the Stockholm Deleted: techniques Convention). As such this document aims to include best available information on these topics. Deleted: technique However, the content of each chapter might not be comprehensive. The Parties should consider Deleted: technology reaching out to (inter)national industry associations representing the chemical suppliers and the Deleted: techniques different industrial users addressed in this report for further information on (additional) Deleted: environmental alternatives that relate to both BAT and BEP. Deleted: practices Article 3, paragraph 6 of the Stockholm Convention, requests Parties that have a specific exemption and/or acceptable purpose to take measures to ensure that any production or use under such exemption or purpose is carried out in a manner that prevents or minimizes human exposure and releases to the environment (i.e. BEP practices). This guidance document has been developed to guide Parties in adequately addressing the risks of perfluorooctane sulfonic acid (PFOS) and its related substances and to identify suitable alternative candidates. In general, producers and users of chemicals should follow good chemical management practices and implement the Best Environmental Practices (BEP) at their facilities to avoid unnecessary emissions of chemicals to the environment. Comment [4]: http://chm.pops.int/TheConventi A hazard-based assessment of the identified alternatives to PFOS and PFOS-related substances on/POPsReviewCommittee/tabid/3502/Default.asp will be publicly available by the end of October 2014; for a draft version, please see [ ]. It is x strongly recommended that further assessment of such alternatives is carried out within each Formatted: Font:+Theme Body Party’s national framework of authorization. In addition, substances which have been identified Formatted: Font:+Theme Body in that assessment as Class 4, may still exhibit hazardous characteristics. These should be Formatted: Font:+Theme Body assessed by Parties before considering such substances as a suitable alternative. Formatted: Font:+Theme Body Formatted: Font:+Theme Body 1.2 Structure and use of this document Formatted: Font:+Theme Body Chapter 1 outlines the purpose and structure of this document. It also includes a brief Deleted: is description of the characteristics and uses of PFOS and PFOS-related substances, directly Comment [5]: Please consider to structure relevant provisions of the Stockholm Convention (Article 5, Annexes B and C) and a summary of the document in a way that it flows according to „Acceptable Purpose“ and „Specific Exemption“ required measures under these provisions. and the listed industries therein. Please see a suggestion for numbering in Table 1. Chapter 2 provides a brief description of the various processes in which PFOS and PFOS-related substances are used and provides guidance on the consideration of alternatives (BAT) for these Subsequently, please consider inserting two Tables 2 and 3 that summarize the findings processes. whether or not alternatives exist for Acceptable Purpose (Table 2) and Specific Exemption Chapter 3 includes general Best Environmental Practice (BEP) guidance for chemical (Table 3) management, including for PFOS and PFOS-related substances. It would be excellent to have the opportunity to Chapter 4 contains specific BEP guidance for the process categories listed in chapter 2. compare the updated information in this document with the Parties‘ input to the National Reporting System on „progress made to eliminate“ which will be available after August 31, 2014. Deleted: , applicable principles and descriptions of considerations that cut across multiple process categories 7

1.3 Perfluorooctane sulfonic acid, its salts, and perfluorooctane Deleted: Chapter 5 provides general guidance on best environmental practices for the management sulfonyl fluoride of PFOS. 1.3.1 Chemicals listed in Part III of Annex B of the Convention Deleted: incorporated PFOS is a fully fluorinated anionic substance, which is commonly used as a salt or as the acid in Deleted: into some applications or is a degradation product of PFOS-related building blocks of larger Deleted: result in molecules, such as polymers. PFOS and its closely related compounds, which may contain PFOS Comment [6]: Please include the following impurities or substances that can degrade to PFOS, are members of the large family of references: ”Synthesis Paper on Per- and perfluoroalkane sulfonic acids (PFSAs) substances. Polyfluorinated Chemicals (PFCs)”, OECD/UNEP Global PFC Group, June 2013; 1.3.2 Characteristics http://www.oecd.org/env/ehs/risk- management/PFC_FINAL-Web.pdf PFOS is very persistent, has substantial bioaccumulation and biomagnifying properties and is And Buck, R. C.; Franklin, J.; Berger, U.; Conder, J. M.; toxic. Although it does not follow the classic pattern of other POPs by partitioning into fatty Cousins, I. T.; De Voogt, P.; Jensen, A. A.; Kannan, K.; tissues; instead, it binds to proteins in the blood and liver. It has a capacity to undergo long- Mabury, S. A.; van Leeuwen, S. P. J. Perfluoroalkyl and polyfluoroalkyl substances in the environment: range transport. terminology, classification, and origins. Integr Environ Assess Manag 2011, 7, 513–541; Open 1.3.3 Risks Access Publication: http://onlinelibrary.wiley.com/doi/10.1002/ieam.2 At its second meeting, the Persistent Organic Pollutants Review Committee (POPRC) adopted 58/full the “risk profile” on perfluorooctane sulfonate. At its third meeting, the POPRC adopted the “risk management evaluation” on perfluorooctane sulfonate. For more information on the risks Deleted: yl posed by PFOS, these documents can be found in the “New POPs” section at www.pops.int. Deleted: ate 1.3.4 Production and uses Deleted: AS Deleted: and PFOS and PFOS-related substances are listed under Part I of Annex B of the Convention and Part Deleted: s III specifically addresses issues related to these chemicals. Production and use shall be Deleted: eliminated by all Parties except Parties that have notified the secretariat to produce/or use , them according to the possible specific exemptions and acceptable purposes described in Annex Deleted: a B, Part I. PFOS and PFOS-related substances are still produced and used in several countries. Deleted: and also fulfils the toxicity criteria of the Convention The list of uses for acceptable purposes or specific exemptions in the Convention is given in the Deleted: " Table 1 below. All other uses of these compounds are banned under the Convention [see e.g.]. Deleted: " Acceptable Purpose uses and Specific Exemption uses were identified and described in the Deleted: " Guideline on Alternatives to Perfluorooctane Sulfonate and its Derivatives developed under the Deleted: " POPs Review Committee (UNEP/POPS/POPRC.6/13/Add.3, 2010). In its decision SC-5/5, the Deleted: " Conference of the Parties to the Stockholm Convention requested the Persistent Organic Pollutants Review Committee to develop a technical paper on the identification and assessment Deleted: " of alternatives to the use of perfluorooctane sulfonic acid (PFOS) and PFOS-related substances in Deleted: So, open applications. The information provided in the technical paper on the identification and Deleted: is assessment of alternatives to the use of PFOS and PFOS-related substances in open applications Deleted: below is set out in document UNEP/POPS/POPRC.8/INF/17. Please note, the content of each chapter Comment [7]: Guidance for the Inventory of in the two documents referenced above might not be comprehensive. The Parties should Perfluorooctane Sulfonic Acid (PFOS) and Related Chemicals Listed under the Stockholm Convention ... [2] consider reaching out to (inter)national industry associations representing the chemical Deleted: t suppliers and the different industrial users addressed in this report for further information on (additional) alternatives that relate to both BAT and BEP. Deleted: The use categories not listed in the Deleted: are banned uses, Deleted: and

Comment [8]: A newer version exists ... [3]

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Table 1: Acceptable Purpose and Specific Exemptions uses for PFOS, its salts and PFOSF (in the text referred to as “PFOS and PFOS-related substances”) as listed in Annex B of the Stockholm Convention.

1. Acceptable purposes 2. Specific exemptions Formatted: Font:(Default) Calibri, Kern at 16 pt A. Photo-imaging A. Photo masks in the semiconductor Formatted: Font:(Default) Calibri, Bold, B. Photoresist and anti-reflective and liquid crystal display (LCD) Not Italic, Font color: Background 1, Kern Formatted:at 16 pt List Paragraph, None, Space coatings for semiconductors industries Before: 0 pt, Numbered + Level: 1 + C. Etching agent for compound B. Metal plating (hard metal plating) Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment: Left + Aligned at: 0.63 cm + semiconductors and ceramic filters C. Metal plating (decorative plating) Indent at: 1.27 cm, Don't keep with next, D. Aviation hydraulic fluids D. Electric and electronic parts for some Don't keep lines together E. Metal plating (hard metal plating) colour printers and colour copy Formatted: Font:(Default) Calibri, Kern at only in closed-loop systems machines 16 pt Formatted: Font:(Default) Calibri, Bold, F. Certain medical devices (such as E. Insecticides for control of red Not Italic, Font color: Background 1, Kern ethylene tetrafluoroethylene imported fire ants and termites Formatted:at 16 pt Indent: Left: 0.63 cm, No copolymer (ETFE) layers and radio F. Chemically driven oil production bullets or numbering opaque ETFE production, in-vitro G. Carpets Formatted: Font:(Default) Calibri diagnostic medical devices, and CCD H. Leather and apparel Formatted: Indent: Left: 0.63 cm, No bullets or numbering colour filters) I. Textiles and upholstery G. Fire fighting foam K. Paper and packaging H. Insect baits for control of leaf- L. Coatings and coating additives cutting ants from genus Atta spp. and M. Rubber and plastics Formatted: Font:Italic Acromyrmex spp. Deleted: A

Comment [10]: These two paragraphs are not needed. The purpose of this document is to help Parties implement their NIP; contents of the second paragraph are summarized in Table 2 (that has been suggested to be included). Comment [11]: Reference to this document was made earlier in the chapter. Suggest to delete this paragraph. Deleted: Although alternatives to PFOS are available for some applications, as described in the chapter 2, this is not always the case in developing countries, where they still need to be phased in. ... [6] Formatted: No bullets or numbering

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Comment [13]: See above, please update... [13] Process descriptions of current and Best Alternative Comment [14]: Insert reference to most... [15] Technology (BAT) and processes Deleted: and…and in the Technical Paper [ ]... .[14]. Comment [15]: Please provide link to most... [16] This chapter provides brief descriptions of the different processes and – if available - viable Deleted: alternative chemistry to PFOS and PFOS-related substances for each described process. The Formatted Table processes described are for those listed in Table 1. Each chapter aims to identify BAT as ... [17] “Fluorinated Alternatives”, “Non-Fluorinated Alternatives” and “Alternative Technology”. Deleted: Specific Exemption Deleted: Acceptable Alternative Technology ... [18]

For most processes the use of PFOS and PFOS-related substances is no longer needed and Formatted ... [22] alternatives are in use. Please see Table 2 for a summary of key findings for “Acceptable Formatted ... [23] Purpose” applications and please Table 3 for a summary of key findings for “Specific Exemption” Deleted: Photo masks in the semiconductor and ... [24] applications. Please note, more specific chemical information on alternatives to PFOS and PFOS- Formatted related substances can be found in the Guidance on Alternatives to Perfluorooctane Sulphonate ... [25] Formatted ... [26] and its Derivatives (UNEP/POPS/POPRC.6/13/Add.3, 2010), and in the Technical Paper [ ]. A hazard-based assessment of the identified alternatives will be publicly available by the end of Formatted ... [19] October 2014 [please insert web-link here]. It is strongly recommended that further assessment Formatted ... [20] is carried out within each Party’s national framework of authorization. In addition, substances Formatted ... [21] which have been identified in that assessment as not likely to be a POP (Class 4), may still exhibit Deleted: hazardous characteristics that should be assessed by Parties before considering such substances Deleted: Metal plating (hard metal plating) as a suitable alternative. Formatted ... [35]

Formatted ... [36] Please note, this document aims to include best available information on these topics. However, the content of each chapter might not be comprehensive. The Parties should consider Deleted: reaching out to (inter)national industry associations representing the chemical suppliers and the Formatted ... [34] different industrial users addressed in this report for further information on (additional) Formatted ... [37] alternatives that relate to both BAT and BEP. Formatted ... [29] Formatted ... [30] The BAT options listed in the following chapters might not work as “drop-in” replacements and Formatted might therefore require some reformulation work at the user site with assistance from the ... [33] chemical supplier. Formatted ... [40] Formatted ... [32]

Table 2: Summary of key findings for “Acceptable Purpose” applications (*: applies to new uses Formatted ... [27] only; **: identified BAT might yield increased human and environmental exposure). Formatted ... [28]

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Formatted ... [39] Chemical Identity Acceptable Deleted: and Properties of Trade Names Alternative Formatted ... [31] Acceptable and Producers Technology Formatted ... [50] Acceptable Purpose Alternatives Exists [Known/Not Formatted ... [53] [Known/Not Known] Formatted ... [54] [Yes/No] Known] Formatted ... [43] Formatted ... [44] Photo-imaging YES KNOWN NOT KNOWN A Formatted ... [58] NOT KNOWN Photoresist and anti-reflective YES* NOT KNOWN Formatted ... [51] B coatings for semiconductors Formatted ... [55]

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Formatted ... [70] D Aviation hydraulic fluids NO N/A N/A Formatted ... [65] Metal plating (hard metal Formatted ... [61] NOT KNOWN N/A N/A E plating) only in closed-loop Formatted ... [60] systems Formatted ... [62] Certain medical devices (such as YES NOT KNOWN Deleted: ethylene tetrafluoroethylene KNOWN NOT KNOWN NOT KNOWN Formatted ... [63] copolymer (ETFE) layers and NOT KNOWN Formatted ... [64] F radio opaque ETFE production, NOT KNOWN NOT KNOWN NOT KNOWN in-vitro diagnostic medical NOT KNOWN Formatted ... [73] YES NOT KNOWN devices, and CCD colour filters) Formatted ... [74] G Fire fighting foam YES KNOWN KNOWN Formatted ... [76] Insect baits for control of leaf- Formatted ... [77] H cutting ants from genus Atta spp. YES** N/A N/A Deleted: Insecticides for control of red ... [78] and Acromyrmex spp. Deleted: Formatted ... [79] Formatted ... [80]

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Table 3: Summary of key findings for “Specific Exemption” applications (*: alternative(s) might Formatted ... [84] be less effective than incumbent and/or can only be used for certain applications). Formatted ... [85]

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production Formatted: Font:(Default) Calibri, 10 pt, Not Italic, Font color: Auto, English (UK) YES KNOWN KNOWN G Carpets Formatted: Font:(Default) Calibri, 10 pt, Not Italic, Font color: Auto, English (UK) H YES KNOWN KNOWN Leather and apparel Formatted: Font:+Theme Body, 12 pt, Formatted:Bold Centered, Indent: Left: 0 cm I Textiles and upholstery YES KNOWN KNOWN Formatted ... [201] K Paper and packaging YES KNOWN KNOWN Formatted: Centered, None, Space Before: 0 pt, Don't keep with next, Don't Coatings and coating additives L YES KNOWN KNOWN keep lines together Rubber and plastics M YES KNOWN NOT KNOWN Formatted ... [199]

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2.1. Best Available Technology (BAT) for “Acceptable Purpose” Applications

Comment [16]: As defined in Annex B of the 2.1.A. Photo-Imaging Stockholm Convention The text in chapter has been modified by including sections copied from the Guidance Background: document. Slight edits to that text have been made. In the photographic industry PFOS-related substances have been used in manufacturing of Formatted: Font:Bold photographic film, papers and printing plates. These PFOS-based chemicals have been used for Formatted: Font:(Default) Lucida Sans Unicode, Bold the following purposes in mixtures for coatings (RPA association, 2004): Formatted: Font:(Default) Lucida Sans • Surfactants Unicode, Bold • Electrostatic charge control agents Formatted: Heading 3, Left • Friction control agents Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Auto Dirt-repellent agents • Formatted: Font:12 pt • Adhesion control agents Formatted: Font:Bold Formatted: Font:14 pt, Bold Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font:Bold, Font color: Text 2 Substances Comment [17]: Updates include text copied from the Guidance document and the Technical In the past, PFOS-related substances such as tetraethylammonium perfluorooctane sulfonate Paper with some slight edits. and perfluorooctyl sulfonamidopropyl quaternary ammonium iodide have been used in the Formatted: Font:Not Bold range of 0.1–0.8 µg/cm2.

Fluorinated Alternatives: • Short-chain fluorotelomer-based products • C3 and C4 (perfluorobutane sulfonate)-based compounds

Non-Fluorinated Alternatives: • Hydrocarbon surfactants • Silicone products1

Alternative Technology: • Digital techniques

With fully capable and acceptable alternative technologies commercially available worldwide and in use, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in photo-imaging. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

1 There are cosiderable datagaps of siloxane compounds used on the market for photographic applications, see reference UNEP/POPS/POPRC.8/INF/17/Rev.1.

Formatted: Font color: Text 2 2.1.B. Photoresist and Anti-Reflective Coatings for Comment [18]: Correct title according to the Semiconductors Convention

Background: Semiconductor manufacturing comprises up to 500 steps, involving four fundamental physical Updates in this entire section include text copied from the Guidance document and the processes: Technical Paper with some slight edits.

• Implant • Deposition • Etch • Photolithography Photolithography is the most important of the four processes. It is essential for the successful implementation of the other three processes and, indeed, the overall production process. It shapes and isolates the junctions and transistors; it defines the metallic interconnects; it delineates the electrical paths that form the transistors; and it joins them together. Photolithography reportedly represents 150 of the total 500 steps. Photolithography is also integral to the miniaturization of semiconductors (RPA association, 2004). PFOS reduces the surface tension and reflection of solutions, properties that are important for Formatted: Body Text, Left, Space After: precise photolithography in the semiconductor industry (photoresists and photo masks (see 0 pt, No bullets or numbering chapter under “Specific Exemption”)). Photoresists are photosensitive polymeric materials used for making circuit patterns. Comment [19]: Text is copied (with minor edits) from Annex F Questionnaire submitted by Japan on Photoresists for fine patterning need to contain a substance called photoacid generator (PAG) Feb. 9, 2007. that include PFOS. PAG generates hydrogen ions by exposure to laser light which causes an http://chm.pops.int/TheConvention/POPsReviewCo mmittee/Meetings/POPRC2/AnnexFinformationYea anisotropic chain reaction that increases focal depth. Therefore, PAGs are essential to fine r2007/tabid/466/Default.aspx patterning. In subsequent steps photoresist agent is rinsed out during the photolithographic process, PFOS does not remain in semiconductors. Since diffused reflection would possibly disorder the shape of a circuit in design, therefore an anti-reflective coating is necessary to avoid disturbance during photolithographic processes. PFOS is used in anti-reflective coating agents to give surface activity and regulate reflective characteristics of the coating between the metal and resist layers. A number of resist suppliers sell top anti-reflective coating (TARC) and bottom anti-reflective coating (BARC), which are used in combination with deep ultra violet (DUV) photoresist. The process involves placing a thin, top coating on the resist to reduce reflective light, in much the same way and for the same purposes that eyeglasses and camera lenses are coated. Since anti-reflective coating agents are rinsed out during the photolithographic process, PFOS does not remain in the semiconductors. Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [20]: Updates include text copied Substances from the Guidance document and the Technical “The industry continues to work towards developing comprehensive PFOS substitutes for Paper with some slight edits. current and future semiconductor manufacturing. From discussions with suppliers we know that the manufacturers who synthesize and supply PFOS to the photolithography chemical suppliers have terminated production of these PFOS materials. The WSC (World Semiconductor Council) manufacturers have agreed not to seek new uses of photolithography chemicals containing PFOS and the suppliers have publically stated that they will not provide PFOS-containing chemicals for any new uses. Additionally, semiconductor companies are replacing remaining use

of PFOS as the feasibility and capability are proven. A few semiconductor companies will be required to continue to use PFOS blends until these feasibility issues are overcome. The amount left in use is highly controlled.” [WSC, 2011 Report]. Comment [21]: http://www.semiconductorcou ncil.org/wsc/uploads/WSC_2011_Joint_Statem ent.pdf The estimated global annual PFOS use (2010 data) for the three remaining applications is as Annex 2 page 16 - 23 follows [WSC, 2011 Report]: Photoresists: 46.4kg Formatted: Indent: Left: 2.54 cm, First BARC: 4.5kg line: 1.27 cm TARC: 893.5kg Formatted: Normal, Indent: Left: 1.27 cm, First line: 1.27 cm, No bullets or numbering Photoresist and anti-reflectant products are solvent-based solutions containing up to 80% Formatted: Normal, No bullets or numbering solvents with the remaining components being acrylic or other polymer resins, PFOS-derived cross-linking agents, stabilizers and/or PFOS-derived surfactants [ ]. Photoresists and anti- Comment [22]: http://msdssearch.dow.com/Pu reflective products that have been formulated without the use of PFOS are commercially blishedLiteratureDOWCOM/dh_090c/0901b803809 0c227.pdf?filepath=productsafety/pdfs/noreg/233- available but it is not known whether or not these products qualify as BAT for the purposes of 00873.pdf&fromPage=GetDoc this report [for example]. http://msdssearch.dow.com/PublishedLiteratureDO WCOM/dh_08fb/0901b803808fb12

Fluorinated Alternatives: Formatted: Font:+Theme Body, 11 pt Fluorinated compounds are in use. However, information on the type and chemical class of Comment [23]: http://msdssearch.dow.com/Pu fluorinated alternatives has not been disclosed. blishedLiteratureDOWCOM/dh_08fb/0901b803808f b120.pdf?filepath=productsafety/pdfs/noreg/233-

Non-Fluorinated Alternatives: No information 00827.pdf&fromPage=GetDoc Formatted: Font:Bold Alternative Technologies: No information Formatted: Font:Bold Formatted: Font:Bold No alternative substances have been commercialized for existing uses in PAG, BARC and TARC. However, production of PFOS and PFOS-related substances seems to have ceased for the applications listed here. With production of PFOS and PFOS-related substances ceased to supply the semiconductor industry worldwide, there is no need to further manufacture PFOS, PFOS-derived, -containing or –releasing chemistry for use in new uses photoresists and anti-reflective coatings for semiconductors. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Formatted: Font color: Text 2 2.1.C. Etching Agent for Compound Semiconductors Comment [24]: Correct title according to the and Ceramic Filters Convention Background Etching Agent for Compound Semiconductors: PFOS has been used as a surfactant in etching processes in the manufacture of compound semiconductors. PFOS was added as part of an etching agent, and rinsed out during the subsequent washing treatment.

Etching Agent for Ceramic Filters: Comment [25]: Text taken (and slightly edited PFOS has been used in the etching process of piezoelectric ceramic filters which are used as a from input provided to the Secretariat by the Chemical Management Policy Division, bandpass filter at intermediate frequency in two-way radios for police radios, FM radios, TV, Manufacturing Industries Bureau at the Ministry of Remote Keyless Entry Systems for Cars, etc. For deciding on the bandwidth of piezoelectric Economy, Trade and Industry of Japan. ceramic filters, the gap dimension of vibrating electrodes on both sides of the ceramic element is the important indicator. The gap dimension must be controlled within several hundred µm. Because of the possibility of bubble creation in such a minute process, 0.033wt% of PFOS were added to the etching liquid as a surface active agent to prevent bubble creation.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [26]: Updates include text copied Substances from the Guidance document and the Technical Etching Agent for Compound Semiconductors: Paper with some slight edits. PFOS was used in this application. Fluorinated Alternatives: According to information provided by the World Semiconductor Council [Insert reference from above, WSC 2011] short-chain perfluoroalkyl sulfonates are fluorinated alternatives that are in Comment [27]: Please insert reference from use today. The use of PFOS has been eliminated for this application. above

Non-Fluorinated Alternatives: No information Formatted: Font:Not Bold Alternative Technology: No information Formatted: Font:Not Bold

With fully capable and acceptable alternative technologies commercially available worldwide and in use, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in etching agents for compound semiconductors. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Etching Agent for Ceramic Filters: PFOS was used in this application in formulations containing 0.033wt%. According to information provided by the Chemical Management Policy Division, Manufacturing Comment [28]: Please include reference from Industries Bureau, Ministry of Economy, Trade and Industry of Japan, the use of PFOS has been above eliminated for this application. However, the type of alternative substances in use has not been disclosed.

Fluorinated Alternatives: No information Non-Fluorinated Alternatives: No information Alternative Technology: No information Formatted: Body Text

With fully capable and acceptable alternative technologies commercially available worldwide and in use, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in etching agents for ceramic filters. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Formatted: Font:(Default) Calibri Formatted: Body Text

Comment [29]: Updates include text copied Aviation Hydraulic Fluids from the Guidance document and the Technical Paper with some slight edits. Background Formatted: Heading 2 Aviation hydraulic fluids based on fire resistant alkyl and/or alkyl phenyl phosphate esters Formatted: Font:12 pt contain additives such as the PFOS-related substance potassium salt of perfluoroethylcyclohexyl Formatted: Footer-pool, Indent: Left: 0 sulfonate (CAS No. 67584-42-3) in concentrations of about 0.1%. This critical additive provides cm, First line: 0 cm, Space After: 0 pt erosion resistance to hydraulic components of the airplane (i.e., valves, actuators, etc.) and therefore helps to avoid damage to mechanical parts and significantly extends their operational life. Phosphate-ester based fluids have been used in civil and military airplanes since the 1970s (United States patent 3679587 dates from 1972). These fluids are used in applications with performance demands that “oil-based” hydraulic fluids cannot match (e.g., fire resistance and very good low temperature properties). The total global market for fluorinated compounds in aircraft hydraulic fluids is estimated to be about 2 tonnes per year. Annual fluorinated compound consumption in the European Union for this use was about 730 kilograms/year in 2009.2 Formatted: Font:Times New Roman, 12 pt, (Asian) Japanese Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Substances Comment [30]: Updates include text copied from the Guidance document and the Technical No alternative substances seem to have been commercialized. Therefore, the PFOS-related Paper with some slight edits. substance potassium salt of perfluoroethylcyclohexyl sulfonate (CAS No. 67584-42-3) represents Formatted: Font color: Auto the Best Available Technology (BAT). Formatted: Font:Not Bold Suppliers to this industry as well as users of chemicals in this industry should follow BEP practices so that emissions to the environment are minimized.

Formatted: Font color: Text 2 Metal Plating (hard metal plating) Only in Closed- Loop Systems

Background The term “hard” refers to the process of electrodepositing a thick layer (0.2mm or more) of certain types of metal directly onto substrates. In terms of hard chrome plating, for example, the deposited chrome layer provides the following desirable properties: • Hardness • Wearability

2 Dorian Carloni “Perfluorooctane Sulfonate (PFOS) ; Production and Use: Past and Current Evidence”, UNIDO (2009) http://www.unido.org/fileadmin/user_media/Services/Environmental_Management/Stockholm_Con vention/POPs/DC_Perfluorooctane%20Sulfonate%20Report.PDF 17

• Corrosion resistance • Lubricity • Low coefficient of friction Examples of hard chrome plated parts are: • Hydraulic cylinders and rods • Railroad wheel bearings and couplers • Molds for the plastic and rubber industry • Tool and die parts The plating process is an electrolytic process that causes mist and bubbles to be ejected from the plating bath containing plating bath solution. This mist is released to the work place environment and will eventually be dispersed into outdoor ambient air unless controlled with add-on air pollution control equipment or chemical fume (mist) suppressants. Chemical fume (mist) suppressants are surfactants that lower the surface tension of the plating solution. While they reduce bubble formation, they also allow for better wetting of the electrolyte at the electrode and allow for better plating bath penetration into patterned articles. The bubbles can cause defects on the plated articles and also cause mist formation. By reducing the surface tension, the created process gas bubbles become smaller and rise more slowly than larger bubbles. Slower bubbles have reduced kinetic energy so that when the bubbles burst at the surface, mist is less likely to be emitted into the air and the droplets fall back onto the plating bath surface. In hard chrome plating and Cr(VI) anodizing tank operations, the plating bath consists of Cr(VI) acid. This acid is a highly oxidative, strong acid that decomposes most types of surfactants. In addition, Cr(VI) is a known human carcinogen and therefore Cr(VI) emissions are regulated to protect workers from occupational exposure and to protect the environment. Emissions to the atmosphere can be reduced by either limiting the amount of Cr(VI) through use of add-on air pollution control devices or utilizing a chemical mist suppressant. Since the plating bath is a highly oxidative environment, PFOS was a suitable surfactant because it is stable under the plating bath conditions. Thus, introduction of PFOS as mist suppressant helped solving occupational safety problems as well as environmental problems relating to Cr(VI) in the hard chrome plating industry. Formatted: Font:(Default) +Theme Body, 11 pt, Font color: Black, (Asian) Chinese Best Available Technology (BAT) for PFOS and PFOS-Related (PRC), (Other) English (US) Substances From the information available it is unclear whether or not PFOS emissions to the environment can occur from the closed-loop process. Furthermore, it is unclear whether or not PFOS is ever exhausted in such application and will need to be replaced. There is not enough information on the current process and on the use of potential alternatives available. The BAT cannot be determined. Formatted: Font:+Theme Body, 11 pt, Not Bold, Font color: Auto Formatted: Normal, Space After: 0 pt

Certain Medical Devices Comment [31]: Updates in this entire section include text copied from the Guidance document and the Technical Paper with some Background slight edits. Formatted: Font:Bold, Font color: Text 2

Video endoscopes contained a charge-coupled device (CCD) colour filter containing 150ng of PFOS. The CCD is part of technology enabling capturing digital images. Another use of PFOS described is as a dispersant of contrast agents that are incorporated into an ethylene- tetrafluoroethylene (ETFE) copolymer layer that is used in radio-opaque catheters.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [32]: Updates include text copied Substances from the Guidance document and the Technical PFOS and PFOS-related substances have been used in critical parts of certain medical devices. Paper with some slight edits. Use in ethylene-tetrafluoroethylene (ETFE) copolymer layers: Formatted: Font:Not Bold Fluorinated Alternatives: § PFBS replaced PFOS as a dispersant of contrast agents in EFTE layers for radio-opaque catheters. Non-Fluorinated Alternatives: No information Alternative Technology: No information Formatted: Font:Not Bold

Use in production of radio-opaque ETFE: Fluorinated Alternatives: No information Formatted: Normal, No bullets or Non-Fluorinated Alternatives: No information Formatted:numbering Font:+Theme Body, 11 pt Alternative Technology: No information Formatted: Font:+Theme Body, 11 pt, Use in certain in-vitro diagnostic devices: English (UK) Fluorinated Alternatives: No information Non-Fluorinated Alternatives: No information Alternative Technology: No information

Use in charge-coupled device (CCD) colour filters: Fluorinated Alternatives: No information Formatted: Normal, No bullets or Non-Fluorinated Alternatives: No information Formatted:numbering Font:+Theme Body, 11 pt Alternative Technology: Formatted: Font:Not Bold § PFOS-free CCD filters are in use

It is unknown whether alternatives to PFOS and PFOS-derived substances for applications such as production of radio-opaque ETFE and use in certain in-vitro diagnostic devices are commercially available. The BAT cannot be determined. With fully capable and acceptable alternative technologies commercially available worldwide and in use for contrast agent dispersants in ETFE layers for radio-opaque catheters and for charge-coupled device (CCD) colour filters, there is no need to use PFOS or PFOS-derived, - containing or –releasing chemistry in certain medical devices. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Fire Fighting Foams

Background Formatted: Font:Bold

Firefighting foams encompass a broad range of products used for the control and Formatted: Font color: Auto extinguishment of Class B combustibles and flammable liquid fuel fires. Class B foam concentrates include those derived from protein bases as well as synthetic or hydrocarbon surfactant based products. Fire fighting foam concentrates are designed primarily for hydrocarbon fuel fire protection and may also include types used for polar solvent or water- miscible fuel fires.

Aqueous film-forming foam (AFFF) is a generic term for fire fighting and/or vapour suppression products used globally to protect both lives and property. This term also encompasses alcohol Formatted: Font color: Auto resistant aqueous film forming foam (AR-AFFF) concentrates. AFFFs are the premier fire fighting foam in many parts of the world and are unique among other fire fighting foams in that they contain a small percentage of fluorinated surfactant (fluorosurfactant). This key ingredient brings unique performance attributes to the product that enable it to be extremely effective in extinguishing fires, preventing re-ignition, and supressing vapour of Class B flammable liquids. AFFF agents are formulated by combining synthetic hydrocarbon surfactants with perfluorinated Formatted: Font color: Auto surfactants. When mixed with water, the resulting solution achieves extremely low surface tension allowing the solution to produce an aqueous film that spreads across a hydrocarbon fuel surface. AFFF products can be used in fixed and portable systems (e.g. sprinkler systems, handheld fire extinguishers, portable cylinders, fire fighting vehicles (fire trucks), etc.). In most situations, AFFF is purchased as a concentrate, typically referred to as “3%” or “6%” depending on its proportioning ratio to be used with water to generate finished expanded foam. Not every situation will necessarily require the use of fire fighting foams. Selection of the correct product can only be determined by a careful consideration of the specific situation at hand (emergency incident or design of life/property protection system) and review of local building codes and other regulations. It is important to remember that foams have proven to be highly effective for their intended purpose. 2.1.1 Types of foams

Foams have been developed for both Class A (ordinary combustibles such as paper and wood) and Class B (flammable liquids) fires. AFFFs were designed to be especially effective in dealing with Class B incidents. Class B foams have two major categories: synthetic foams and protein-based foams. Synthetic foams AFFFs and alcohol-resistant AFFFs (AR-AFFFs) are synthetic foams based on synthetic hydrocarbon and fluorinated surfactants. AR-AFFFs are designed to be effective in the presence of alcohols and other water miscible compounds. This category also encompasses training Formatted: Font color: Auto foams that are used as AFFF and AR-AFFF substitutes in training and system commissioning tests, Class A foams used primarily as wetting agents for Class A fire protection and wildland forestry protection, and other foam concentrates derived from synthetic and hydrocarbon surfactants such as fluorine-free foams. Protein-based foams

Protein foams contain substances derived from natural, keratinous proteins such as cow hooves and chicken feathers. These protein hydrolysates are used as foaming agents in protein-based foams, and as such, protein-based foams are generally more biodegradable than synthetic foams. Types of protein-based foams include regular protein foam (P), fluoroprotein foam (FP), film-forming fluoroprotein foam (FFFP), alcohol-resistant fluoroprotein foam (AR-FP), and alcohol-resistant film-forming fluoroprotein (AR-FFFP). FP, FFFP, AR-FP, and AR-FFFP foams contain levels of fluorosurfactants that significantly improve fire-fighting performance.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Substances The chemicals used to make the fluorosurfactants that are key ingredients in Class B foams have been manufactured by different processes and have different chemical structures. Prior to 2000, fluorosurfactants used in AFFFs were both PFOS-based and fluorotelomer-based. Although PFOS-based and fluorotelomer-based AFFFs are equally effective, only PFOS-based AFFFs contain PFOS or PFOS precursors. Shortly after the manufacturing phase-out announcement by 3M of PFOS-based products in 2000, PFOS-based AFFFs were generally no longer available within developed countries. The primary supply of AFFF then became fluorotelomer-based. Over the last several years, manufacturers of fluorotelomer-based AFFF have been replacing long-chain (C8 and higher) fluorosurfactants with shorter-chain (C6) fluorosurfactants. Formatted: Font:Calibri, 11 pt, (Asian) Chinese (PRC), (Other) English (UK) The choice of foam to be used in any specific situation needs to be carefully made, taking into consideration multiple factors. It is critically important that the tremendous effectiveness of AFFF products in protecting life and property be considered in making use and system design decisions. Fire protection experts clearly need to have a lead role in making these decisions. When evaluating foam for use in preventing or fighting a fire, several factors could be considered: • Is any type of foam actually needed? For example, in a Class A incident, it may not be necessary to use any foam to control the situation. • If use of a foam is deemed appropriate and/or necessary, does it need to be a Class B foam? For example, while Class B foams may be quite effective on Class A fires, other techniques may be equally effective and more appropriate. • Consideration should be given to using alternative fluids that do not contain fluorinated substances for training and the testing of foam proportioning equipment.

Synthetic and Protein-based Class B Foams: Fluorinated Alternatives: Formatted: Indent: First line: 1.27 cm Foam manufacturers are currently transitioning to the use of short-chain, fluorotelomer-based surfactants as the key ingredient to produce synthetic Class B foams. Listed below in alphabetical order are the main suppliers of fluorinated surfactants to the fire fighting foam industry with their brand names: Short-chain fluorinated telomer-based surfactants: Chemguard Formatted: Indent: First line: 1.27 cm DuPont (Capstone®) Dynax

Non-fluorinated Alternatives: Formatted: Indent: First line: 1.27 cm Non-fluorinated alternatives exist and are in use but often cannot achieve the stringent performance requirements.

Alternative Technology: Formatted: Indent: First line: 1.27 cm No information

With fully capable and acceptable alternative technologies commercially available and in use worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in fire fighting foams. Spent Fire Fighting Foam solution has been identified as a point source of fluorinated surfactants emissions to the environment. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Insect Baits for Control of Leaf-Cutting Ants from genus Atta spp. And Acromyrmex spp. Background: Formatted: Font:Bold N-Ethyl perfluorooctane sulfonamide (EtFOSA; CAS No. 4151-50-2), also called sulfluramid, or Formatted: Font color: Auto sulfuramid, is both a surfactant and a pesticide used in Brazil for control of leaf-cutting ants from the species Atta spp. and Acromyrmex spp. Sulfluramid was introduced in Brazil in 1992, after verification of its efficiency with many leaf-cutting ant species, replacing the active ingredient dodecachlor. In addition, the following active ingredients are registered and in use in Brazil for the control of leaf-cutting ants: fenitrothion (in the form of thermo-nebulization) and deltamethrin (in powder form). Sulfluramid is the active ingredient in the manufacturing of ant baits in ready-to-use formulations (3g/kg) for the control of leaf-cutting ants such as the genus Atta (saúvas) and Acromyrmex (quenquéns), which are the insects that cause the most damage to agriculture. The active ingredient is effective after ingestion and presents a so called retarded action. Granulated baits represent the most widely used method for leaf-cutting ants control, consisting of a mixture of an attractive substrate (vehicle) (usually dehydrated citric pulp from the orange juice industry and vegetable oil) and an active ingredient (insecticide), presented in the form of pellets. This method seems to be low-cost that delivers high efficiency with reduced acute health hazards to humans and the environment during application, and it is specific to the pest target. Its localized application does not require application equipment. Baits are “ready to use” to be directly applied from their packaging close to active nest entrance holes or anthill trails and carried into the colony by the ants themselves.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [33]: Updates include text copied Substances from the Guidance document and the Technical Paper with some slight edits.

Currently, the active ingredients registered in Brazil for producing bait to control leaf-cutting ants are sulfluramid (in the form of granulated baits at concentrations of 0.3wt%), fenitrothion Formatted: Font:Not Bold (to be applied via thermo-nebulization) in a mineral oil or diesel oil vehicle and deltamethrin (to Formatted: Font:Not Bold be applied in powder form) which kills on contact. Thermo-nebulization has the potential for Formatted: Font:Not Bold worker exposure and the powder form seems to be only effective in small nests. Formatted: Font:Not Bold According to the Brazilian Annex F information, sulfluramid cannot currently be efficiently Comment [34]: Please insert reference replaced in Brazil by any other registered products commercialized for the same purpose. From the information available it is unclear which application technique and mode of action of the insecticide represents the most effective and advanced technology available. Alternative products and technologies exist and are in use. Updated information will be available after 31 October 2014 as requested in the “Call for Formatted: Normal_number, Justified information and follow-up to the sixth meeting of the Conference of the Parties to the Stockholm Convention; Number 5B”. Comment [35]: Please insert reference Suppliers to this industry as well as users of chemicals in this industry should follow BEP practices so that emissions to the environment are minimized.

Formatted: Font color: Text 2 Best Available Technology (BAT) for “Specific Exemption” Applications

Photo Masks in the Semiconductor and Liquid Crystal Comment [36]: Correct title according to the Display (LCD) Industries Convention

Background Photomasks are an essential part of the photolithography process of semiconductor and LCD production. The production process for photomasks consist of the following steps: • Deposit a chromium layer on a glass substrate by sputtering (photomask blank) Formatted: Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: 1.27 cm • Coat photoresist onto the chromium layer • Draw wiring pattern on the photoresist • Develop the photoresist • Remove un-covered chromium layer with etchant • Remove hardened photoresist with rinsing fluid • Dry the photomask In this wet process, PFOS was used as a surfactant in the etching solution to enhance the surface wettability by reducing the surface tension. This enables producing the required fine patterning defect-free.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [37]: Updates include text copied Substances from Japan’s Annex F submission in 2007. PFOS was used as a surfactant in the etching solution. Formatted: Normal, Space After: 0 pt Formatted: Font:Not Bold In most recent data (from 2007) Japan [Annex F reporting] reported estimated global use of PFOS for this application was approximately 100kg. Formatted: Font color: Auto Formatted: Font:Not Bold, Font color: Auto Fluorinated Alternatives: No information Formatted: Font:Bold, English (UK) Formatted: Normal, Space After: 0 pt Non-Fluorinated Alternatives: No information Formatted: Font:Bold, English (UK) Alternative Technologies: A dry process exists and is practiced for some specific cases for photo Formatted: Font:+Theme Body, 11 pt, masks for the semiconductor industry. Not Bold Formatted: Font color: Auto With the exception for some specific uses, no alternative substances seem to have been Formatted: Normal, Space After: 0 pt commercialized. Therefore, PFOS represents the Best Available Technology (BAT) as a Formatted: Font:12 pt, Not Bold surfactant in etching solutions for photo masks. Comment [38]: Updates include text copied from the Guidance document and the Technical Suppliers to this industry as well as users of chemicals in this industry should follow BEP Paper with some slight edits. practices so that emissions to the environment are minimized. Another resource used was: „PFOS Chromium Electroplater Study“ U.S. Environmental Protection Agency – Region 5, Sept. 2009 (http://www.epa.gov/oppt/pfoa/pubs/pfoschrome platerstudypdf_final.pdf) and from Ref. 63 Guidance Document Metal Plating (hard metal plating) Formatted: Font color: Text 2 24

Background For “Background” on “Metal Plating”, please see Chapter “Metal Plating (hard metal plating) Only in Closed-Loop Systems”. Other uses of PFOS are the alkaline zinc and zinc alloy plating, the electroless nickel dispersion coating and strong acid electrolytes with insoluble anodes, such as precious metal electrolytes (e.g. gold, palladium and rhodium). In China the following two products are being offered as potential alternatives to PFOS: • FC-53 (potassium 1,1,2,2-tetrafluoro-2-(perfluorohexyloxo)ethane sulfonate) • FC-53B (Potassium 2-(6-chloro-1,1,2,2,3,3,4,4,5,5,6,6-dodecafluorohexyloxy)-1,1,2,2- tetraflouroethane sulfonate) These products belong to the class of perfluorohexane sulfonyl fluorides (PFHxSF) and are related to PFHxS substances. PFHxS and related substances are considered by OECD as long- Comment [39]: Please include reference from chain perfluorinated chemicals (LCPFCs) which are not feasible as alternatives to PFOS due to above their similar environmental hazards. Furthermore, PFHxS is regulated in the USA as part of a Comment [40]: Please consider including: ”PFHxS has an elimination half-life in monkeys SNUR that was published in 2002. No third party assessment of the health and environmental of 141 days for males and 87 days for females impact for perfluorohexane sulfonyl fluoride (PFHxSF) and its derivatives exists. Furthermore and a geometric mean human blood elimination half-life of 8.5 years (3100 days). See: S. A. FC53B can only be dissolved in boiling water which makes handling much more difficult. Gannon et al. ”Adsorption, distribution, Therefore, FC-53 and FC-53B should not be considered as viable alternatives to PFOS. metabolism, and excretion of ([1-14C]-PFHx) in rats and mice”, Toxicology 2011. 283: p.55-62”

Comment [41]: Need to include Federal Register Notice reference Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font:+Theme Body, 11 pt Substances Formatted: Font color: Text 2 It is important to note that the use of mist suppressants enables to meet occupational health Comment [42]: Updates include text copied regulations and therefore each alternative needs to be assessed in those terms as well. from the Guidance document and the Technical Paper with some slight edits. PFOS is used as a mist suppressant in hard metal plating.

Fluorinated Alternatives: • PFBS Formatted: Font:(Default) +Theme Body, 11 pt • 6:2 Fluorotelomer sulfonate (6:2 FTS; CAS No. 27619-97-2) Formatted: List Paragraph, Bulleted + Although fluorinated alternatives exist according to the Guidance on alternatives to Level: 1 + Aligned at: 0.63 cm + Indent at: perfluorooctane sulfonate and its derivatives [referenced earlier], currently, no other surfactant Formatted: 1.27 cm Font:(Default) +Theme Body, can match the low surface tension of PFOS. Therefore, the quantity required for substitution of 11 pt PFOS by polyfluorinated surfactants increases considerably about three to ten times [Reference Comment [43]: Please include reference 2 in Guidance Document]. Furthermore, the alternatives may be less stable and therefore may Comment [44]: Please include reference have to be replenished more frequently. Non-Fluorinated Alternatives: • Alkylsulfonate (trade name: TIB Suract CR-H (TIB Chemicals AG)) Formatted: Font:(Default) +Theme Body, 11 pt Non-fluorinated surfactants are degraded in the chromium electrolyte or etching bath and must Formatted: List Paragraph, Bulleted + be constantly dosed. Those products are not considered equally effective. In addition, such Level: 1 + Aligned at: 0.63 cm + Indent at: products can reduce Cr-VI to Cr-III in the chromium electrolyte which can lead to serious faults 1.27 cm in the chromium coating. Alternative Technology:

• PTFE coated balls on top of bath Formatted: Font:(Default) +Theme Body, 11 pt • Mesh or blankets (Composite Mesh Pads) placed on top of bath Formatted: List Paragraph, Bulleted + • Add-on air pollution control devices (Packed Bed Scrubbers) Level: 1 + Aligned at: 0.63 cm + Indent at: • Closed-Loop System (see above) 1.27 cm

With fully capable and acceptable alternative technologies commercially available worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in non-closed loop hard metal plating processes. The metal plating industry has been identified as a point source of fluorinated surfactants emissions to the environment [2009 US EPA Region 5 Report]. Comment [45]: http://www.epa.gov/region5/w ater/npdestek/pdfs/pfoschromeplaterstudypdf_fi It is important for suppliers and users in this industry to implement and adhere to Best nal.pdf Environmental Practices to reduce emissions to the environment.

Formatted: Font color: Text 2 Metal Plating (decorative plating)

Background Formatted: Font:Bold The term “decorative” refers to a different process than described above, whereby only a thin layer (0.05 to 0.5µm) of metal is deposited onto substrates. In terms of decorative chrome plating, for example, the deposited chrome layer provides the following desirable properties: • Appearance (aesthetically pleasing) • Non-tarnishing Examples of decorative chrome plated parts are: • Car and truck pumpers • Motorcycle parts • Kitchen appliances • Smart phones and tablets For further background, please see the previous chapter on hard metal plating (closed loop systems).

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [46]: Updates include text copied Substances from the Guidance document and the Technical PFOS is used in this application. Paper with some slight edits. Formatted: Font:Not Bold Fluorinated Alternatives: • PFBS • 6:2 Fluorotelomer sulfonate (6:2 FTS; CAS No. 27619-97-2) Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: Non-Fluorinated Alternatives: Formatted: 1.27 cm Font:Not Bold • Alkylsulfonate (trade name: TIB Suract CR-H (TIB Chemicals AG)) Formatted: Font:(Default) +Theme Body, 11 pt Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: 1.27 cm 26

Non-fluorinated surfactants are degraded in the chromium electrolyte or etching bath and must Formatted: Left, Space After: 0 pt, Don't adjust space between Latin and Asian be constantly dosed. Those products are not considered equally effective. text, Don't adjust space between Asian Alternative Technology: text and numbers Parts of the decorative chrome plating industry has adopted trivalent chromium or Cr(III) Formatted: Font:Not Bold, English (US) plating. Cr(III) is intrinsically less toxic than Cr(VI). However, the German industry group FKG “Fachverband Galvanisierte Kunststoffe” has recently published findings of a comparison field Comment [47]: www.zvo.org/aktuelles/detaila nsicht/artkel/fgk-zeigt-den –stand-der chrom-vi- trial with 3000 samples. There Cr-III derived samples were less colour stable, more soil sensitive alternativen (May 2014) and displayed higher corrosion rates. FKG concluded that the BAT for decorative chrome plating for the automotive industry is based on Cr-VI plating. Formatted: Font:+Theme Body, 11 pt With a fully capable and acceptable alternative technology commercially available worldwide and in use, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in decorative metal plating processes. The metal plating industry has been identified as a point source of fluorinated surfactants emissions to the environment [US EPA Region 5 Report; see previous chapter]. It is important for suppliers and users in this industry to implement and adhere to Best Environmental Practices to reduce emissions to the environment.

Formatted: Font:Calibri, 11 pt, Not Bold Electric and Electronic Parts for Some Colour Printers and Colour Copy Machines

Comment [48]: Copied from „Technical Background Paper“ An information gap exists and an assessment on Best Available Technology could not be Formatted: Font:Bold, Font color: Text 2 performed due to a lack of information where exactly PFOS and/or PFOS-related substances are or have been used in the application different from the listed “Acceptable Purpose” and “Specific Exemption” applications described in this document. Formatted: Normal, Space After: 0 pt Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Substances Formatted: Normal, Space After: 0 pt

Fluorinated Alternatives: No information Formatted: Font:Bold, English (UK) Non-Fluorinated Alternatives: No information Formatted: Font:Bold, English (UK) Alternative Technology: No information Formatted: Font:Bold, English (UK) Formatted: Font:+Theme Body, 11 pt, Not Bold Insecticides for Control of Red Imported Fire Ants and Formatted: Font:12 pt, Not Bold Termites

Background Formatted: Font:Bold, Font color: Text 2 N-Ethyl perfluorooctane sulfonamide (EtFOSA; sulfuramid; CAS No. 4151-50-2), also called sulfluramid, is both a surfactant and a pesticide that was used against termites, cockroaches, and ants. 27

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [49]: Updates include text copied Substances from the Guidance document and the Technical EtFOSA is no longer used to manufacture ant bait or insecticides against beetles and ants in the Paper with some slight edits. United States. The U.S. Environmental Protection Agency cancelled the registration of sulfluramid in May 2008.3 In the European Union, PFOS-related substances are not used in the manufacture of pesticides.4 Ant baits containing S-methoprene and pyriproxifen are registered in New Zealand for the control of exotic ants by aerial and ground applications.5 Alternative Chemistry: The reported alternatives to sulfluramid are: • Chlorpirifos • Cypermethrin • mixture of chlorpirifos and cypermethrin • fipronil • imidacloprid • abamectin • deltamethrin • fenitrothion • mixture of fenitrothion and deltamethrin. Please note, some of the alternative chemistries have been part of the “Assessment of Alternatives to endosulfan” [include reference here]. Please consider conclusions from this Comment [50]: http://chm.pops.int/TheConve ntion/POPsReviewCommittee/Meetings/POPR document in your selection of suitable alternatives. C8/MeetingDocuments/tabid/2801/Default.aspx

Alternative Technology: Comment [51]: Insert references provided by Several options have been evaluated for effectiveness: Brazil (Alternatives Assessment 2nd draft comments) • organic bait consisting of rice grains with Beauveria sp. (De Soll et al., 2010) • Diatomaceous earth mixed with waste water in the principal entry of each anthill (Ríos de Saluso,2010) • Vegetal substances with insecticide effect: extract of eucalyptus, castor-oil plant (Pelicano et al., 2002) • “Palo Amargo” (“Bitter stick”, Aeschirium crenata Vell. Simaroubaceae) (Rodfígue et al., 2006) • Natural enemies: parasitoids known as “Moscas descapitadotas” (“Decapitating flies”, Diptera: Phoridae) (Guilllade y Folgarait, 2010) • organic baits based on yeast and rice (Borgetto, 2009)

With fully capable and acceptable alternative technologies commercially available and in use worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in insecticides for control of red imported fire ants and termites. Suppliers to this industry as well as users of insecticides in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

3 www.epa.gov/fedrgstr/EPA-PEST/2008/May/Day-16/p10919.htm. 4 http://archive.defra.gov.uk/environment/quality/chemicals/documents/pfos-riskstrategy.pdf 5 Environmental Risk Management Authority of New Zealand (ERMA NZ) (2007), Decision, 2007-11-11. 28

Chemically Driven Oil Production Formatted: Font color: Text 2 Formatted: Font color: Text 2 Background Formatted: Font color: Text 2 It is reported that PFOS is used in some parts of the world as surfactants in oil well stimulation Formatted: Font color: Text 2 to recover oil trapped in small pores between rock particles. Oil well stimulation includes, in general, a variety of operations performed on a well to improve its productivity. The main two types of operations are matrix acidization and hydraulic fracturing.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Comment [52]: Updates include text copied Substances from the Guidance document and the Technical Fluorinated Alternatives: Paper with some slight edits. Obtaining detailed information on this use proved to be challenging. Alternatives to PFOS identified in two previous reports are: § PFBS § short-chain fluorotelomer-based fluorosurfactants or polymers § other perfluoroalkyl-substituted amines, acids, amino acids, and thioether acids Non-Fluorinated Alternatives: In most parts of the world where oil exploration and production are taking place, oil service companies engaged in provision of well stimulation services predominantly use formulation of alcohols, alkyl phenols, ethers, aromatic hydrocarbons, inorganic salts, methylated alcohols, for oil well stimulation. Oil well stimulation services also involve corrosion control, water blocks/blockage control, iron control, clay control, paraffin wax and asphaltene removal and prevention of fluid loss and diverting. Formatted: Font:Not Bold Alternative Technology: No information Formatted: Font:Not Bold

With fully capable and acceptable alternative technologies commercially available worldwide and in use, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in the chemically driven oil production industry. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Comment [53]: This section is now separate Carpets from „Textiles“ and content has been added. References for the content have been added as Background well. Fluorinated polymers may be applied during manufacturing of residential and commercial carpets made from both synthetic and natural fibres (e.g. wool) to provide stain and soil protection. There are three scenarios for the chemical application: a) application at a carpet or rug mill during the manufacturing process; b) application to carpet after the manufacturing

process at a separate finishing facility; c) re-application by professionals or end consumers in the post manufacturing stage (e.g., in offices or residences).[Reference]. Comment [54]: “Long-Chain Perfluorinated Chemicals (LCPFCs) Used in Carpets”; Contract EP- W-08-010; Prepared for: Economic and Policy Analysis Branch; Economics, Exposure and Technology Division; Office of Pollution, Prevention Best Available Technology (BAT) for PFOS and PFOS-Related and Toxics; U.S. Environmental Protection Agency; Substances July 2012. Electronic form available at: http://www.fluoridealert.org/wp- Fluorinated finishes are the only technology known to deliver durable stain and soil repellency. content/uploads/pfcs.carpet.report.epa_.2012.pdf Historically, fluorinated polymers based on perfluorooctane sulfonyl (PFOS-related) Formatted: Font color: Text 2 electrochemical fluorination chemistry have been used. PFOS-related substances were used to Comment [55]: Text has been copied from the previous original chapter as it described treat carpets but PFOS as such was present at up to 2wt% in articles. In addition, fluorotelomer- „chemicals for carpet treatment“. Text has based polymers have also been used. As stated earlier, major manufacturers in conjunction been slightly edited to address „Carpet“ only. with global regulators have agreed to discontinue the manufacture of “long-chain” fluorinated products and move to “short-chain” fluorinated products. Such “short-chain” polymeric alternatives have entered the commercial space over the last years and have undergone much higher regulatory rigor than their “long-chain” predecessors, for example in Canada, in Europe and in the USA [for example, see ]. Comment [56]: http://epa.gov/oppt/pfoa/pubs/ altnewchems.html Fluorinated Alternatives: New short-chain-based polymeric products have been approved for manufacture, sale and use, and have been demonstrated to deliver the desired performance in textiles applications. Examples of well-known trademarked fluorinated durable water repellents are: Comment [57]: Taken form the Guidance document – same below. One should consider 1. PFBS-based products Scotchgard™ from 3M citing the same references here as well. The references would need to be copied from the 2. Short-chain fluorotelomer-based polymeric products Guidance. a. Capstone® from DuPont Formatted b. products from Daikin and others Formatted: Font:Calibri, 11 pt Non-Fluorinated Alternative hydrophobic finishes for carpet (Water Repellency) For these applications several alternatives exist: 1. Wax-based repellents consisting of paraffin-metal salt formulations 2. Hydrophobic modified polyurethanes (hydrophobic modified hyperbranched polyurethanes called dendrimers) 3. Polysiloxane-based products 4. Resin-based repellents consisting of fatty modified melamine resins These non-fluorinated alternative technologies do not provide durable oily stain and soil repellency. If oily stain and soil repellency is required, fluorinated polymers are the state of the art. Alternative Technology for stain protected residential carpet: Inherently stain-resistant (but not soil resistant) polyester carpet fibers are offered as alternative technology to soil- and stain-protected for residential use.

With fully capable and acceptable alternative technologies commercially available and in use worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry for

treating carpets. Suppliers to this industry as well as users of chemicals in this industry should follow BAT and BEP practices so that emissions to the environment are minimized.

Comment [58]: Text was added because the Leather and Apparel application can be different from Textiles and Carpet as are the products used. Background

Fluorinated polymers may be applied during the leather making process in the tannery, in the finishing step as a surface treatment or at home by the end consumer to provide water, stain and soil protection to leather substrates such as shoes, apparel and upholstery. In the past, aqueous dispersions of anionic PFOS-related polymers have been utilized in tanneries and in consumer products such as shoe care products. Solvent-borne PFOS-related polymers have been used in the finishing process of leather as well as in consumer shoe care aerosol sprays use under the Scotchgard® brand name. This type of chemistry has been replaced by either PFBS- based polymers or by short-chain fluorotelomer-based polymers.

Best Available Technology (BAT) for PFOS and PFOS-Related Formatted: Font color: Text 2 Substances Fluorinated polymers are the only technology known to deliver durable water, stain and soil repellency for leather. Historically, fluorinated polymers based on perfluorooctane sulfonyl (PFOS-related) electrochemical fluorination chemistry have been used. In addition, fluorotelomer-based polymers have also been used. As stated earlier, major manufacturers in conjunction with global regulators have agreed to discontinue the manufacture of “long-chain” fluorinated products and move to “short-chain” fluorinated products. Such “short-chain” polymeric alternatives have entered the commercial space over the last years and have undergone much higher regulatory rigor than their “long-chain” predecessors, for example in Canada, in Europe and in the USA [for example, see reference in previous chapter].

Fluorinated Alternatives: New short-chain-based fluorinated polymeric products have been approved for manufacture, sale and use, and have been demonstrated to deliver the desired performance in leather applications. Examples of such products are: • PFBS-based products: Scotchgard™ from 3M market by TFL • Short-chain fluorotelomer-based polymeric products o Nuva from Clariant Formatted: English (US) o Products from Daikin and others Formatted Formatted: Font:Calibri, 11 pt Non-Fluorinated Alternatives: Waterproofing agents (Water Repellency): These offerings exist but these do not provide oil, soil and stain protection. Some examples are: 1. Wax-based repellents consisting of paraffin-metal salt formulations

2. Hydrophobic modified polyurethanes (hydrophobic modified hyperbranched Formatted: Font:(Default) Lucida Sans polyurethanes called dendrimers) Unicode, 14 pt, Font color: Auto, English (US) Comment [59]: Contents are used in 3. Polysiloxane-based products paragraphs above. 4. Resin-based repellents consisting of fatty modified melamine resins Comment [60]: Content has been summarized in the parapgraph above. Comment [61]: This section has been combined with the introductory section of this Alternative Technology: No information chapter. With fully capable and acceptable alternative technologies commercially available and in use Deleted: Coated and impregnated items ... [229] worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry for Formatted: Font:Calibri, 11 pt treating leather. Suppliers to this industry as well as users of chemicals in this industry should Moved (insertion) [1] follow BAT and BEP practices so that emissions to the environment are minimized. Moved up [1]: Although fluorosurfactants are typically added early in the coating formulation process, they can be added at any time. All surfactants are delivered at high concentrations and usually beyond the critical micelle concentration (cmc). Since the utility of all surfactants at wetting, flow and levelling applications is at the molecular level, rather than as aggregates, time is required to disperse. Fluorosurfactants require more time than hydrocarbon surfactants to disperse from a ... [230] Formatted: Font:14 pt Textiles and Upholstery Formatted: Underline Formatted: Font:Bold Background Formatted: Font:Calibri, 11 pt Side-chain fluorinated polymers [include reference] are used by the textile industry for the Formatted: English (US) treatment of all-weather clothing, umbrellas, bags, sails, tents, parasols, sunshades, upholstery, Formatted: Normal, Left, Space After: 0 pt footwear, rugs, mats, and the like to repel water, oil and dirt (stains) without imparing the Comment [62]: Leather and Paper are... [232] breathability (air and water vapour permeability) of the fabric. Formatted ... [231] The earliest applications used fluorosurfactants. These were quickly replaced, however, with Formatted: No bullets or numbering high molecular weight fluorinated polymers, most commonly either PFOS-related or fluorinated Formatted ... [233] poly(meth)acrylates based on fluorotelomer chemistry, also denoted as side-chain fluorinated Formatted ... [234] polymers. The side-chain fluorinated polymers are typically aqueous polymer dispersions that Formatted: Font:Bold are diluted and then applied to the textile and then dried on at a textile mill or industrial Deleted: , contract finisher. The polymers are designed to strongly adsorb and, in some cases, chemically Deleted: paper and leather bond to any kind of textile fiberThe polymers are designed to perform after multiple Comment [63]: Please include the following ... [236] cleanings/washings and last the lifetime of the treated article. Deleted: Fluorosurfactants Formatted ... [235] Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt

Deleted: and polymers have been used to treat ... [237] Deleted: Deleted: , Deleted: leather or paper, Deleted: the

Deleted: textile, leather or paper. For textiles ... [238] 32

Comment [64]: This chapter will be considered later on in the BEP Section Deleted: Finishing processes With respect to water pollution, it has to be taken Best Available Technology (BAT) for PFOS and PFOS-Related into account that polysiloxanes, melamine and fluorocarbon resins are all characterized by poor Substances biodegradability and bioeliminability (IPPC, 2003). Fluorinated finishes are the only technology known to deliver durable and effective oil and Formatted: Font:Calibri, 11 pt water repellence and release properties. Historically, fluorinated polymers based on Formatted: Justified, Indent: Left: 1.27 cm perfluorooctane sulfonyl (PFOS-related) electrochemical fluorination chemistry have been used. Comment [65]: Polymers usually do not bioaccumulate. The polymers are stabke and PFOS-related substances were used to treat textiles but PFOS as such was present at up to 2wt% do not biodegrade easily. in articles. In addition, fluorotelomer-based polymers have also been used. Major Deleted: With respect to water pollution, it has to manufacturers, in conjunction with global regulators, have agreed to discontinue the into account that polysiloxanes, melamine and manufacture of “long-chain” fluorinated polymeric products and move to “short-chain” fluorocarbon resins are all characterized by poor biodegradability and bioeliminability (IPPC, 2003). fluorinated polymeric products. Such “short-chain” polymeric alternatives have entered the Formatted: Font:Bold, Not Italic commercial space over the last years and have undergone much higher regulatory rigor than Deleted: Textiles, paper and leather their “long-chain” predecessors, for example in Canada, in Europe and in the USA [for example, chemistry ... [239] see reference in previous chapter]. Deleted: based Deleted: Fluorinated Alternatives: Deleted: Deleted: As stated earlier, New short-chain-based polymeric products,have been approved for manufacture, sale and use, Deleted: m and have been demonstrated to deliver the desired performance in textiles applications. Deleted: . Examples of well-known trademarked fluorinated durable water repellents are: Deleted: currently defined as BAT to achieve the 1. PFBS-based products: Scotchgard™ from 3M needed performance effects, 2. Short-chain fluorotelomer-based polymeric products Deleted: , leather and paper a. Products from Archroma (formerly Clariant) Formatted ... [240]

b. Products from Asahi Glass Formatted ... [241] c. Products from Daikin Formatted: Font:Calibri, 11 pt d. Capstone® from DuPont Formatted: Font:Calibri, 11 pt

e. Products from Rudolf Chemie and others Formatted ... [242] 3. Fluorinated oxetane-based products: Omnova Formatted: Font:Calibri, 11 pt Formatted ... [243] Non-Fluorinated Alternatives: Formatted: Font:Calibri, 11 pt Water Repellency: Deleted: hydrophobic finishes for textiles Non-fluorinated alternatives can provide durable water repellence (DWR; aka hydrophobic Moved (insertion) [9] properties) but not oil repellence or oil and soil release. If oil, stain, blood or soil repellence is Deleted: technologies required, fluorinated polymers are the state of the art. For most of the applications, such as Deleted: such as hydrocarbon waxes and silicones outdoor clothing, tents, awnings etc., the durable water-repellent effect (DWR) of the fabric Deleted: . might be the main property requested by the users. For these applications several alternatives Deleted: is exist: Deleted: , there are 1. Wax-based repellents consisting of paraffin-metal salt formulations Deleted: Deleted: existing 2. • Hydrophobic modified polyurethanes (hydrophobic modified hyperbranched Deleted: to fluorocarbons that are not based on ... [244] polyurethanes called dendrimers; Bionic Finish Eco® from Rudolf Chemie) Deleted: •

3. Silicone repellents Formatted ... [245] Deleted: • 33

4. Resin-based repellents consisting of fatty modified melamine resins Moved up [9]: Non-fluorinated alternative Alternative technology: No information technologies such as hydrocarbon waxes and silicones can provide durable water repellence With fully capable and acceptable alternative technologies commercially available and in use (DWR; aka hydrophobic properties) but not oil repellence or oil and soil release. If oil, blood or soil worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in repellence is required, fluorinated polymers are the treating textiles. Suppliers to this industry as well as users of chemicals in this industry should state of the art. follow BAT and BEP practices so that emissions to the environment are minimized. Deleted: • …esin-based repellents consisting ... [246] Deleted: Deleted: -…releasing chemistry in treating ... [247] Deleted: Since these alternatives have their own Paper and Packaging special profiles, the textile industry needs to be very selective about BAT and BEP depending on for which purpose which kind of chemistry is used. Background Comment [66]: This section is now separate from „Textiles“ and content has been added. Fluorinated compounds are used to render paper, cardboard and molded pulp articles grease- References for the content have been added as and waterproof and are thus applied only in a small part of the overall paper market well. (approximately 8%), targeted towards specialty papers for which grease protection is necessary. Comment [67]: Replaced by paragraph above. Some examples are: Deleted: Carpets ... [248] Food contact applications such as plates (molded pulp), food containers, (microwave) popcorn Formatted: Font:(Default) Lucida Sans bags, pizza boxes, fast food wraps and pet food packaging. Please note, specific regulations exist Unicode, 14 pt, Bold, Font color: Custom in many countries that regulate and approve products for use in food contact applications. Color(RGB(79,129,189)), English (UK), Kern at 16 pt Formatted: Normal, No bullets or numbering Non-food contact applications such as folding cartons, containers, carbonless copy forms and Comment [68]: Updates include text copied... [249] paint masking papers. Fluorinated surfactants have been evaluated for paper uses since the Formatted: Font:14 pt, Bold early 1960s . Perfluorooctyl sulfoamido ethanol-based phosphates were the first substances Deleted: packaging used to provide grease repellence to food contact papers. Fluorotelomer thiol-based Formatted: Font:14 pt, Bold phosphates and polymers followed. Those were then followed by polyfluoroalkyl phosphonic Formatted: Font:14 pt, Bold acids (PAPs) in food contact paper products. Since paper fibers and phosphate-based fluorinated Formatted: Font:Bold, Font color: Text 2 surfactants are both anionic, cationic bridge molecules need to be used in order to ensure the Deleted: and …cardboard and molded pulp ... [250] electrostatic adsorption of the surfactant onto the paper fiber. Formatted: Font:+Theme Body

In terms of oil and water repellency, it is well recognized in the paper industry that phosphate- Formatted ... [251] based fluorinated surfactants provide good oil repellency but have limited water repellency. Formatted: Font:+Theme Body, 11 pt

Acrylate polymers with fluorinated side chains derived from sulfoamido alcohols and Deleted: ... [252] fluorotelomer alcohols have been the most widely used polymers because they deliver oil, Formatted ... [253] grease, and water repellence. Most recently, perfluoropolyether-based phosphates and polymers have become widely used treatments for food contact paper and paper packaging [6 – Comment [69]: Please include reference reference from Technical Paper]. Deleted: Formatted: Font:+Theme Body Best Available Technology (BAT) for PFOS and PFOS-Related Deleted:

Substances Formatted ... [254] In the past, paper protection by PFOS derivatives has been achieved by using one of the Formatted: Font:Bold, Font color: Text 2 following: Comment [70]: Updates include text copied... [255] Formatted ... [256] Mono-, di- or triphosphate esters of N-ethyl perfluorooctane sulfonamidoethanol (EtFOSE) Formatted ... [257]

N-Methyl perfluorooctane sulfonamidoethanol acrylate polymers. Formatted ... [258]

Formatted ... [259]

Formatted ... [260] 34

Major manufacturers, in conjunction with global regulators, have agreed to discontinue the manufacture of “long-chain” fluorinated polymeric products and move to “short-chain” fluorinated polymeric products. Such “short-chain” polymeric alternatives have entered the commercial space over the last years and have undergone much higher regulatory rigor than their “long-chain” predecessors, for example in Canada, in Europe and in the USA [for example, see reference in previous chapter].

Deleted: As stated in section 2.1.2, there is no Fluorinated Alternatives: need to use PFOS-derived, -containing or -releasing chemistry in treating paper. There are fully capable The paper industry is using 1.0-1.5wt% (based on dry weight of fibres) short-chain fluorinated and acceptable alternative technologies polymers to produce waterproof and greaseproof paper, cardboard and molded pulp articles. commercially available worldwide. Following are the main suppliers of fluorinated polymers in the paper industry, with their brand Formatted: Font:+Theme Body, Bold names (in alphabetical order): Formatted: Font:Not Bold Formatted: No bullets or numbering • Short-chain fluorinated telomer-based polymers: Formatted: Font:Not Bold o Archroma Paper (Formerly Clariant Paper) Cartafluor® Formatted: Font:+Theme Body, 11 pt, Not Bold o Asahi Asahigard® Formatted: Font:+Theme Body, 11 pt, Not Bold o Ashland ImPress® Formatted: Font:+Theme Body, 11 pt, o Daikin Unidyne® Not Bold Formatted: Bulleted + Level: 1 + Aligned o DuPont Capstone® at: 0.63 cm + Indent at: 1.27 cm o Rudolf Chemie Ruco-guard® Formatted: English (UK) Formatted: Font:+Theme Body, 11 pt • Fluoro-polyethers: Formatted: Bulleted + Level: 2 + Aligned o Solvay Solvera® at: 1.9 cm + Indent at: 2.54 cm Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt Non-Fluorinated Alternatives: Formatted: Font:+Theme Body, 11 pt Non-fluorinated alternatives cannot achieve the stringent performance requirements for oil and Formatted: Font:+Theme Body, 11 pt grease resistance but can achieve excellent water repellency. Formatted: Font color: Auto

Alternative Technology: Formatted: Font:+Theme Body, 11 pt At least one manufacturer has developed a non-chemical alternative for this use. The Norwegian Formatted: Font:+Theme Body, 11 pt paper producer Nordic Paper is using mechanical processes to produce, without using any Formatted: Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: 1.27 cm persistent chemical, extra-dense paper that inhibits leakage of grease through the paper. [2 – Formatted: Font:+Theme Body, 11 pt reference from Technical Paper] Formatted: Bulleted + Level: 2 + Aligned at: 1.9 cm + Indent at: 2.54 cm With fully capable and acceptable alternative technologies commercially available and in use Formatted: Font:+Theme Body, 11 pt worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in Formatted: Font:Bold treating paper, cardboard and molded pulp. Suppliers to this industry as well as users of Formatted: Normal, Don't adjust space chemicals in this industry should follow BAT and BEP practices so that emissions to the between Latin and Asian text, Don't adjust space between Asian text and numbers environment are minimized. Formatted: Font:Bold Comment [71]: Please include reference

Coatings and Coating Additives Comment [72]: Section has been edited with original content and content from Guidance document and Technical Paper and has been Background shortened. Coatings: Formatted: Font color: Text 2 Formatted: Font color: Auto In the past, PFOS-related fluorinated polymers containing up to 4% of fluorinated residuals were sold as coating materials for e.g. printed circuit boards and hard disk drive components. Such coatings provide protection against corrosion, contamination and grime as well as repellency properties leading to an improved manufacturing efficiency. Coating Additives: Fluorinated surfactants provide exceptional wetting, leveling and flow control for water-based, solvent-based and high-solids organic polymer coating systems when added in amounts of just 100–500ppm. These properties result in: • improved anti-crater and improved surface appearance • better flow and levelling • reduced foaming • decreased block • extended open-time • increased bond strength • oil repellency • dirt pick-up resistance Typical industries utilizing fluorinated surfactants to achieve these properties include: • industrial and institutional floor polishes • architectural paints and coatings • varnishes • printing inks • adhesives Formatted: Indent: Left: 1.27 cm, No For detailed discussions of the important properties of and technology behind commercial bullets or numbering fluorosurfactants, see Kissa 1994; Taylor 1999; Buck et al. 2011. Comment [73]: Please include these One of the largest consumers of PFOS and PFOS-related fluorosurfactants, was floor polish for references industrial and institutional flooring. The floor polish must wet a floor that can be made of low surface energy material or that may be contaminated with a low surface tension (hydrophobic) material. Proper surface wetting requires a surfactant that will ensure the coating has a sufficiently low surface tension to function. In addition, high gloss is very desirable with floor polish. Fluorosurfactants are excellent at mitigating surface tension gradients that can cause coating defects and reduce gloss. Floor polishes form a somewhat unique subset of coatings in that they are applied and removed as required for another floor care application and then disposed directly into wastewater. Disposing of removed floor polish into wastewater poses environmental concerns as the techniques and chemistry involved in most municipal wastewater treatment facilities cannot process all components properly. This is true particularly for fluorosurfactants. What remains of the fluorosurfactant after treatment depends on the nature of the fluorosurfactant; however, degradation is often of the oxidative type and perfluorocarboxylic acids can be produced and passed to the local aquifer.

Ultimately, the use and choice of a particular fluorosurfactant will depend on whether the Formatted: Font:+Theme Body, 11 pt material provides the necessary performance or benefits that cannot be attained with other surfactants. In the past PFOS has been used in the described applications. The conversion from PFOS to short-chain fluorosurfactants has been considered successful to date (OECD, 2010). Comment [74]: Please include this referecne Formatted: Font:+Theme Body, 11 pt

Best Available Technology (BAT) for PFOS and PFOS-Related Substances Major manufacturers, in conjunction with global regulators, have agreed to discontinue the manufacture of “long-chain” fluorinated polymeric products and move to “short-chain” fluorinated polymeric products. Such “short-chain” polymeric alternatives have entered the commercial space over the last years and have undergone much higher regulatory rigor than their “long-chain” predecessors, for example in Canada, in Europe and in the USA [for example, see reference in previous chapter]. Use rates of fluorosurfactants tend to follow surface tension reduction and efficiency trends. The shorter perfluoroalkyl chain fluorosurfactants, the higher addition levels they require. The fluorosurfactant level required to achieve adequate wetting, flow and levelling will depend strongly on the coating formulation as well. For aqueous-based coatings, the fluorosurfactant use levels required are, generally, near the cmc and range from approximately 50 ppm to 500 ppm, based on the weight of the coating. Solvent-borne coatings, however, require much higher addition levels and can range from 500 ppm to 5000 ppm, based on the weight of the coating.

For Coatings: Fluorinated Alternatives: • Perfluorobutance sulfonate (PFBS)-based polymers (e.g. Novec® products from 3M) Non-Fluorinated Alternatives: No information Alternative Technology: No information

For Coating Additives: Fluorinated Alternatives: Comment [75]: Taken from the Guidance Document and the Technical Paper 1. Short chain fluorotelomer-based surfactants6 (e.g., Capstone® products from DuPont); 2. Perfluorobutane sulfonate (PFBS)-based compounds (e.g., Novec® products from 3M) 3. Fluorinated polyethers (e.g., PolyFox® products from Omnova) Non-Fluorinated Alternatives:

6 Perfluorocarboxylic Acid Content in 116 Articles of Commerce, US EPA (2009) http://www.oecd.org/env/48125746.pdf. 37

1. Sulfosuccinates, for example the sodium salt of di-(2-ethylhexyl) sulfosuccinate Deleted: dissolved in ethanol and water, which is used as an alternative in wood primers Comment [76]: Updates include text copied and printing inks from the Guidance document and the Technical Paper with some slight edits. 2. Silicone polymers, such as polyether-modified polydimethyl siloxane, mixed Comment [77]: This information is not with di-(2-ethylhexyl) sulfosuccinate in ethanol and water (WorléeAdd®) relevant for this document and should be removed. 3. Propylated naphthalenes and propylated biphenyls, which can be used as water Comment [78]: This information is not repelling agents for applications such as rust protection systems, marine paints, relevant for this document and should be resins, printing inks and coatings in electrical applications removed. Comment [79]: The same information is used 4. Fatty alcohol polyglycol ether telomers, sometimes together with a in the beginning of this paragraph and should sulfosuccinate therefore be deleted here. Comment [80]: Since no alternatives to Alternative Technology: No information control leaf-cutting ants seem to exist, this information is not relevant to this report and With fully capable and acceptable alternative technologies commercially available and in use should be removed. worldwide, there is no need to use PFOS, PFOS-derived, -containing or –releasing fluorinated Deleted: Insecticides surfactants as coating additives or for coatings. Suppliers to this industry as well as users of Aviation hydraulic fluids Decorative and hard metal plating chemicals in this industry should follow BAT and BEP practices so that emissions to the processes environment are minimized. Rubber and plastic products PFOS can be used as a surfactant in etching processes in the manufacture of compound semiconductors and ceramic filters. PFOS is then Rubber and Plastics added as part of an etching agent, and rinsed out during the subsequent washing treatment. Background PFOS is used as a component of a photoresist substance (see figure 2-4), including a photo acid PFOS and/or PFOS-related substances have been used as mold release agents in rubber and generator or surfactant; or of an anti-reflective plastics moulding applications. coating, used in a photomicrolithography process to produce semiconductors or similar components of Best Available Technology (BAT) for PFOS and PFOS-Related electronic or other miniaturized devices (see figure ... [261] Formatted: Font:14 pt

Substances Moved (insertion) [2] Fluorinated Alternatives: Moved down [3]: N-Ethyl perfluorooctane Perfluorobutane sulphonate (PFBS) derivatives or various C4-perfluorocompounds sulfonamide (EtFOSA; sulfluramid; CAS No. 4151... [262]-50- Formatted: Font:14 pt, Bold Non-Fluorinated Alternatives: No information Moved (insertion) [3] Alternative Technology: No information Moved up [2]: Sulfluramid is the only active ingredient with all the properties necessary for ... [263] With fully capable and acceptable alternative technologies commercially available worldwide, Comment [81]: Updates include text copied and in use there is no need to use PFOS, PFOS-derived, -containing or –releasing chemistry in from the Guidance document and the Technical... [265] the rubber and plastics industry. Suppliers to this industry as well as users of chemicals in this Deleted: Aviation hydraulic fluids ... [264] industry should follow BAT and BEP practices so that emissions to the environment are Formatted: Font:14 pt minimized. Formatted: Font:14 pt Deleted: Decorative and hard metal processes ... [266]

Deleted: Rubber and plastic products ... [267] Formatted: Font:(Default) Times New Roman, 14 pt, Bold, Font color: Text 2, Formatted:English (US) Font:Calibri, 11 pt Formatted: Font:14 pt Formatted: Font:(Default) Lucida Sans Unicode Formatted: Font:Calibri, 11 pt 38

Moved (insertion) [4]

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Formatted ... [270]

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Moved up [4]: PFOS can be used as a surfactant ... [274]

Deleted: The other processes involved are ... [275]

PFOS use in Electronics Industry (in Japan)

fix-unit PFOS surface treatment anti-reflective dispersion • coating • adhesive surface treatment solder paint • photoresist desmear metal other use • etching plating

semiconductor parts, modules photo masks PWB HDD Effect for other industries •

Deleted: Deleted: Figure 2-2: PFOS use in electronic...s [276] Deleted: Semiconductor industry ... [277]

Moved up [5]: Semiconductor manufacturing PFOS Usage in Semiconductor Manufacturing... [278] Wafer Wax Slurry Wafer Repeat Surfactant 20-40 times Diffusion/CVD Mask Diffusion/CVD Cr Eｔchant Resist Resist Patterning ARC Surfactant Developer Glass plate Polyimideolyimide....etcetc Probe Card Plating chemicals Assembly for Probe Card

Lead Frame Test Mask Synthetic resin Eｔchant Product Products Deleted:

Formatted ... [279]

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Moved up [6]: PFOS reduces the surface tension ... [281]

Formatted ... [282] Deleted: <#> 39 Formatted: Font color:PAG Red, English (P (UK)hoto-Acid Generator)

Wave length of Laser light for exposure device is very short. Then light can not attain to the bottom of resist. PAG can resolve this problem

exposure 1. Low surface tension 2. Low reflection 3. High acid durability acid（Ｈ＋） 4. Thermal stability 5. High UV durability Generation of acid 6. Dispersible 酸発⽣剤に光が当ると酸（Ｈ＋）を放出する

exposure露光

発⽣した酸（Ｈ＋）はポリマーのアルカリ不溶性保護基と反応してアルカリ可容基に変化させる。このAcid reacts with resist 反応は酸触媒反応で連続して反応を繰り返す。 No substitution of PFOS

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Formatted: Font:(Default) Lucida Sans Chapter 3: Best Environmental Practices (BEP) for Unicode, 14 pt, Bold, Font color: Text 2 Chemicals Management

Formatted: No Spacing1, Justified, General Guidance on Best Environmental Practices Indent: First line: 0.63 cm, Space After: 6 pt (BEP) Formatted: Indent: Left: 0.63 cm General BEP Measures applicable to handling all chemicals BEP Measures for manufacturing of PFOS containing PFOS-related substances containing products Specific BEP measures when using PFOS and PFOS- Related Substances BEP Measures for manufacturing of Alternatives to Formatted: Font:(Default) Lucida Sans PFOS and PFOS-related Substances Unicode, 14 pt, Bold, Font color: Text 2 Specific BEP Measures when using Alternatives to Formatted: Font:(Default) Lucida Sans PFOS and PFOS-related Substances Unicode, 14 pt, Bold, Font color: Text 2

Chapter 4: Formatted: Font:(Default) Lucida Sans Specific BEP Measures for Acceptable Purposes Unicode, 14 pt, Bold, Font color: Text 2 Processes Formatted: List Paragraph, Numbered + A. BEP for Photo-Imaging Level: 1 + Numbering Style: A, B, C, ... + Start at: 1 + Alignment: Left + Aligned at: B. BEP for Photoresist and anti-reflective coatings 1.27 cm + Indent at: 1.9 cm Formatted: Font:(Default) Lucida Sans for semiconductors Unicode, 14 pt, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans C.BEP for etching agent for compound Unicode, 14 pt, Bold, Font color: Text 2 semiconductors and ceramic filters Formatted: Font:(Default) Lucida Sans D. BEP for Aviation hydraulic fluids Unicode, 14 pt, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans E. BEP for metal plating (hard metal plating) only Unicode, 14 pt, Bold, Font color: Text 2 in closed-loop systems Formatted: Font:(Default) Lucida Sans F. BEP for certain medical devices (such as Unicode, 14 pt, Bold, Font color: Text 2 ethylene tetraethylene copolymer (ETFE) layers

and radio opaque ETFE production, in vitro- diagnostic medical devices, and CCD colour filters) Formatted: Font:(Default) Lucida Sans G. BEP for Fire Fighting Foam Unicode, 14 pt, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans H.BEP for insect baits for control of leaf-cutting Unicode, 14 pt, Bold, Font color: Text 2 ants from Atta spp. and Acromyrmex spp.

Formatted: Indent: Left: 0.63 cm Specific BEP Measures for Specific Exemptions Formatted: List Paragraph, Numbered + A. BEP for photo masks in the semiconductor and Level: 1 + Numbering Style: A, B, C, ... + Start at: 1 + Alignment: Left + Aligned at: liquid crystal display (LCD) industries 1.27 cm + Indent at: 1.9 cm Formatted: Font:(Default) Lucida Sans B. BEP for metal plating (hard metal plating) Unicode, 14 pt, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans C.BEP for metal plating (decorative plating) Unicode, 14 pt, Bold, Font color: Text 2 D. BEP for electric and electronic parts for some Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2 colour printers and colour copy machines Formatted: Font:(Default) Lucida Sans E. BEP for insecticides for control of red imported Unicode, 14 pt, Bold, Font color: Text 2 fire ants and termites Formatted: Font:(Default) Lucida Sans F. BEP for chemically driven oil production Unicode, 14 pt, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans G.BEP for carpets Unicode, 14 pt, Bold, Font color: Text 2 H. BEP for leather and apparel Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2 I. BEP for textiles and upholstery Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2 J. BEP for paper and packaging Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2 K. BEP for coatings and coating additives Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2 L. BEP for rubber and plastics Formatted: Font:(Default) Lucida Sans Unicode, 14 pt, Bold, Font color: Text 2

Formatted: Font:+Theme Body, English (UK) Comment [82]: This and the following chapter Chapter 3: have been reformated to allow for a better flow of infomation and to adhere to a similar Best Environmental Practices (BEP) for Chemicals structure as used in Chapter 2. The content of these chapters has been consolidated from the original text and has Management been expanded in places Formatted: Font:(Default) Lucida Sans Unicode General Guidance on Best Environmental Practices (BEP) Formatted: Font:(Default) Lucida Sans Unicode The following subchapters contain specific areas in relation to the environmental management Formatted: Font:(Default) Lucida Sans systems (EMS) that could improve environmental performance of an installation including the Unicode, 14 pt, Bold, Font color: Text 2 increased awareness of the workers/employees handling chemicals. Formatted: Indent: Left: 1.27 cm BEP describes the application of the most appropriate combination of environmental control Formatted: List Paragraph, Bulleted + measures and strategies, which includes a behaviour that relates to the continuous Level: 2 + Aligned at: 1.9 cm + Indent at: improvement of environmental performance. BEP provides the framework for ensuring the Formatted:2.54 cm Indent: Left: 0.63 cm identification, adoption and adherence to management options that remain important and can Formatted: List Paragraph, Bulleted + play a role in improving environmental performance of the installation. In general, good Level: 2 + Aligned at: 1.9 cm + Indent at: housekeeping/management techniques/tools often prevent emissions. Formatted:2.54 cm Font:(Default) Calibri, 11 pt The main ecological advantages achieved through the use of BEP management methods include: Formatted: Font:(Default) Calibri, 11 pt savings in consumption of: Formatted: Font:(Default) Calibri, 11 pt o chemicals/auxiliaries Formatted: Normal, Justified o fresh water Comment [83]: Please include this reference o energy Formatted: Font:(Default) Calibri, 11 pt minimizing the amount of: Comment [84]: http://www.ifc.org/wps/wcm/c o solid waste onnect/Topics_Ext_Content/IFC_External_Corporat o ecological loads in wastewater e_Site/IFC+Sustainability/Sustainability+Framework /Environmental,+Health,+and+Safety+Guidelines/ o off-gas emissions (might not relate to all processes) Another advantage is an improved workplace situation. Well-trained employees are a Comment [85]: “Draft revised general technical prerequisite for implementing BEP system measures. Limiting factors for improving existing guidelines for the environmentally sound management of wastes consisting of, containing or equipment also need to be taken into consideration with the application of BEP, e.g. new contaminated with persistent organic pollutants” at equipment has to be rebuilt/modified or installed (automated dosing systems, etc.). These http://www.basel.int/Implementation/TechnicalMa applicability factors can be limited due to the fact that the measures may be too cost-intensive tters/DevelopmentofTechnicalGuidelines/POPs/tabi d/2381/Default.aspx or due to technological/logistics or a space problem (Schönberger et al., 2005). For references on general examples of Good International Industry Practice (GIIP), including environmental, Please ensure to link to the most recent revised health, and safety guidelines, please see International Finance Corporation’s website [ ] that also document. contains a list of specific industry sector guidelines. Comment [86]: “Draft revised technical guidelines for the environmentally sound General technical guidelines for the environmentally sound management of wastes have been management of wastes consisting of, containing or developed under the Basel Convention. For a general technical guideline, please see [ ] and for contaminated with perfluorooctane sulfonic acid, its a detailed guidance on the environmentally sound management of PFOS-containing waste salts and perfluorooctanesulfonyl fluoride” at http://www.basel.int/Implementation/TechnicalMa please see [ ]. tters/DevelopmentofTechnicalGuidelines/POPs/tabi d/2381/Default.aspx ... [288] Environmental Management Systems (EMS) Formatted: Font color: Custom Color(RGB(0,112,192)) A number of environmental management techniques are determined as BEP. The scope and Formatted: Indent: Left: 1.27 cm nature of an EMS will generally be related to the nature, scale and complexity of the installation, Formatted: Font:12 pt, Bold, Font color: and the range of environmental impacts it may have. For example, ISO 14001 sets out criteria Custom Color(RGB(0,112,192)) for an EMS [ ]. Comment [87]: http://www.iso.org/iso/home/s tandards/management-standards/iso14000.htm... [289] 42

BEP is to implement and adhere to an EMS that incorporates the following features, as appropriate, for individual circumstances: • Definition of an environmental policy for installation by top management (its commitment is regarded as a precondition for a successful application of other features of the EMS). • Planning and establishing of the necessary procedures. • Implementation of the procedures, paying particular attention to: • Structure and responsibility • Training, awareness and competence • Communication • Employee involvement • Documentation • Efficient process control • Maintenance programme • Emergency preparedness and response • Safeguarding compliance with environmental legislation • Checking of performance and taking of corrective action, paying particular attention to: • Monitoring and measurement • Corrective and preventive action • Maintenance of records • Perform independent (where feasible) internal auditing to determine whether or not the EMS conforms to planned arrangements and has been properly implemented and maintained Formatted: Font:+Theme Body Formatted: Font:+Theme Body, 11 pt Additional Considerations Formatted: Font color: Custom Color(RGB(0,112,192)) Three additional features are considered as supporting measures; their absence, however, is Formatted: Indent: Left: 1.27 cm generally not inconsistent with BEP: Formatted: Font:12 pt, Bold, Font color: Custom Color(RGB(0,112,192)) • Examination and validation of the management system and audit procedure by an accredited certification body or an external EMS verifier • Preparation and publication (and possibly external validation) of a regular environmental statement describing all the significant environmental aspects of the installation, allowing for year-by-year comparison against environmental objectives and targets as well as with sector benchmarks as appropriate • Implementation and adherence to an internationally accepted EMS This last voluntary step could give higher credibility to the EMS, particularly internationally accepted and transparent standards, such as ISO9001 and ISO14001. Non-standardized systems can in principle be equally effective provided that they are properly designed and implemented. Formatted: Indent: Left: 1.27 cm Specific Education and Training of Employees Formatted: Font color: Custom Color(RGB(0,112,192)) The following training and education opportunities could be beneficial for raising awareness at Formatted: Font:12 pt, Bold, Font color: work for sound chemical management in general: Custom Color(RGB(0,112,192)) • Process- and machinery-specific training to increase the level of environmental awareness • Appropriate education of workers concerning handling of chemicals and auxiliaries, especially in case of hazardous substances

• Maintenance of technical equipment (machines in production as well as abatement and recovery devices); machinery checking (e.g. pumps, valves, level switches); general maintenance by specialized companies at regular intervals; and checking of the burner air inlet at regular intervals • Leak control of chemicals when stored and during processing • Filter maintenance (periodically cleaning and controlling) • Calibration of equipment for chemicals measuring and dispensing devices

Industrial Considerations Formatted: Font color: Custom Color(RGB(0,112,192)) It is also important for industry to consider the following potential features of the EMS: Formatted: Font:12 pt, Bold, Font color: • At the plant design stage, give consideration to the environmental impact of the Custom Color(RGB(0,112,192)) eventual decommissioning of the unit Formatted: Indent: Left: 1.27 cm • Give consideration to the development of cleaner technologies • Where practicable, conduct sector benchmarking on a regular basis, including energy efficiency and energy conservation activities, choice of input materials, emissions to air, discharges to water, consumption of water and generation of waste • Ensure the provision of full details of the activities carried out on-site: • Descriptions of the waste treatment methods and procedures in the place of installation • Diagrams of the main plant items that have some environmental relevance, together with process flow diagrams (schematics) • Details on the control system philosophy and how the control system incorporates the environmental monitoring information • Details on how protection is provided during abnormal operating conditions such as momentary stoppages, start-ups, and shutdowns • Instruction manual • Operational diary • Annual survey of the activities carried out and the waste treated, which contains a quarterly balance sheet of the waste and residue streams, including the auxiliary materials used for each site • Have good housekeeping procedures in place, which will also cover the maintenance procedure, and an adequate training programme, covering the preventive actions that workers need to take on health and safety issues and environmental risks • Have a close relationship with the waste producer/holder so that the customers' sites implement measures to produce the required quality of waste necessary for the waste treatment process to be carried out • Have sufficient staff available on duty with the requisite qualifications at all times. All personnel should undergo specific job training and further education

Formatted: Font:14 pt, Bold Formatted: Font:(Default) Lucida Sans General BEP Measures applicable to handling all chemicals Unicode, Bold, Font color: Text 2 This section describes principles, measures and safety precautions that apply to all types of Formatted: Normal, Justified, Space chemicals and industries handling them. Guidelines that apply to specific process categories are After: 6 pt described in the following chapters. Formatted: Font:Calibri, 11 pt Formatted: Font:(Default) Calibri, 11 pt, (Asian) Chinese (PRC), (Other) German

Chemical Knowledge, Storage, Handling, Dosing, Dispensing and Transport Formatted: Font:12 pt, Font color: Custom Color(RGB(0,112,192)) In storing, handling, dosing, dispensing, and transporting of any chemical, caution should be Formatted: Font color: Custom used. Color(RGB(0,112,192)) • Before ordering/receiving any chemical review the Safety Data Sheet (SDS). If possible, Formatted: Indent: Left: 1.27 cm avoid CMR (Carcinogenic, Mutagenic, Reproductive Toxin) and PBT (Persistent, Formatted: Font:Bold, Font color: Custom Bioaccumulative and Toxic) substances, and substances that can degrade to CMR or PBT Color(RGB(0,112,192)) substances (see SDS Section 2, 11, and 12) Formatted: Font color: Custom Color(RGB(0,112,192)) • In case a complete SDS is not available from one supplier, order the product from an Formatted: Font:Bold, Font color: Custom alternative supplier that provides a complete SDS Color(RGB(0,112,192)) • Gather information from your supplier on amounts of residual raw materials, by- Formatted: Font color: Custom products and potential degradation products in the product you intend to order Color(RGB(0,112,192)) • Reject leaking or dented containers upon receiving Formatted: Font:+Theme Body, Bold, Font color: Custom • Proper storage according to the instruction of the most up to date material safety data Color(RGB(0,112,192)) sheet (SDS), preferably in Global Harmonization Standard (GHS) format Formatted: Font color: Custom Color(RGB(0,112,192))

• Before handling any chemical, review the SDS carefully Formatted: Font:+Theme Body, Bold, • Proper labelling of containers and equipment; storage in special compartments, Font color: Custom containers or locations for toxic and explosive chemicals to avoid leakage and spill Formatted:Color(RGB(0,112,192)) Font color: Custom • Dosing and dispensing without spilling in automated dosing systems Color(RGB(0,112,192)) Formatted: Font:+Theme Body, Bold, Minimization/Optimization of the Chemicals Used Font color: Custom Formatted:Color(RGB(0,112,192)) Font:12 pt, Bold, Font color: • Minimize the use of all chemicals and auxiliary materials Custom Color(RGB(0,112,192)) • Measure, mix and dose chemicals carefully to avoid losses Formatted: Indent: Left: 0.63 cm, First • Minimize residual, left-over chemicals, by calculating exactly how much is needed for line: 0.63 cm the process step Formatted: Font color: Custom Color(RGB(0,112,192)) • Substitution of overflow rinsing or minimization of water consumption in overflow Formatted: Font:12 pt, Bold, Font color: rinsing by means of optimized process control Custom Color(RGB(0,112,192)) • Reuse of rinsing baths, including final rinsing baths Formatted: Font color: Custom • Reversing of current flows in continuous washing Color(RGB(0,112,192)) • Cleaning and recycling of process water – where possible Formatted: Font:12 pt, Bold, Font color: • Use of low emission preparation agents through the total supply chain where possible Custom Color(RGB(0,112,192)) • Use of low emission options Formatted ... [290] Formatted ... [291] Equipment Formatted ... [292] Formatted ... [293] • Use equipment, pipes, valves, etc. that are suited to handle the material (e.g., corrosion resistance) top ensure a long equipment life and to avoid equipment breakdown and Formatted: Font:12 pt leaks Formatted: Font:12 pt • To prevent releases to the environment via air, install dust collectors, scrubbers or Formatted: Font:12 pt similar devices Formatted ... [294] • Collect all waste and leftover chemicals from all processes and dispose of them in Formatted ... [295] accordance to guidance provided in the product SDS and in compliance with local rules Formatted ... [296] and regulations. In general, the drain is not an appropriate outlet for waste. Formatted: Font:11 pt

Formatted ... [297] Leak and Spill Procedure Formatted: Font:12 pt

• Follow instructions according to information provided on the SDS Formatted ... [298]

• Make such a procedure part of the operator training to enhance preparedness Formatted ... [299] Formatted: Font:11 pt 45

Emissions Reductions and Waste Management Formatted: Font color: Custom Color(RGB(0,112,192)) The following measures could be considered for water management, off-gas and solid waste Formatted: Font:Bold, Font color: Custom management: Color(RGB(0,112,192)) • Follow all procedures as outlined above Formatted: Indent: Left: 0.63 cm, First line: 0.63 cm • Adhere to waste disposal methods given in the SDS Formatted: Font:12 pt, Font color: • For guidance on sound management of waste, please follow guidance provided by the Custom Color(RGB(0,112,192)) Basel Convention [see above]. Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 BEP Measures for Manufacturing of PFOS Containing or PFOS- Formatted: Font:(Default) Lucida Sans Related Substances Containing Products Unicode, Bold, Font color: Text 2 • In case such products still need to be manufactured, the manufacturer should employ Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 technology to minimize worker exposure and to minimize emissions to the environment Formatted: Font:(Default) Lucida Sans which includes water, air and soil Unicode, Bold, Font color: Text 2 • Information provided in the previous chapters is applicable and should be utilized Formatted: Font:(Default) Lucida Sans • Technology should be deployed to minimize unreacted raw material and byproduct Unicode, Bold, Font color: Text 2 content in the products sold Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 • Information on unreacted raw material and byproduct content in products sold should Formatted: List Paragraph, Bulleted + be made public to all customers and interested parties Level: 1 + Aligned at: 0.63 cm + Indent at: Formatted: 1.27 cm Font:12 pt Removal of PFOS and PFOS-related substances from Waste Water Formatted: Font:11 pt By Adsorption Formatted: Font:12 pt Formatted: Font:12 pt By selecting suitable activated carbon and optimized flow rates, up to 99% of PFOS can be Formatted: Indent: Left: 0.63 cm removed from wastewater by adsorption onto activated carbon (Fath, 2008). Formatted: Font:Bold, Font color: Custom When using special basic ion exchange resins, a reduction of more than 99% of the initial PFOS Color(RGB(0,112,192)), English (UK) concentration can be achieved (Zentralverband Oberflächentechnik, 2011). Either weak base or Formatted: Normal, Indent: Left: 0.63 cm, First line: 0.63 cm strong base anion exchangers are able to reduce the PFOS concentration to <10µg/l (Neumann, Formatted: Font:12 pt, Italic, Font color: 2011). Custom Color(RGB(0,112,192)) The recommendations of the Stockholm Convention’s COP-5 must be taken into account when Formatted: Font:Bold using any adsorption method that requires a final destruction of the adsorbent that contains Formatted: Indent: Left: 1.27 cm, PFOS or PFOS-related substances at the end-of-life so as not to deposit such wastes improperly. Hanging: 0.38 cm The destruction could be done in a BAT hazardous waste incineration plant at temperatures of Formatted: Font:+Theme Body, 11 pt, Bold, Not Italic at least 1100°C and with a residence time of 2 seconds. Please consult Basel Convention Guidance [ ] for further details. Comment [88]: Please include this reference Comment [89]: Please include this reference Comment [90]: Please include this reference Comment [91]: Please provide a link to the recommendation Specific BEP Measures when Using PFOS and PFOS-Related Comment [92]: “Draft revised technical Substances guidelines for the environmentally sound management of wastes consisting of, containing or • When using PFOS or a PFOS-related substance, select a product that has a verified contaminated with perfluorooctane sulfonic acid, its lowest possible amount of unreacted raw materials, by-products and potential salts and perfluorooctanesulfonyl fluoride” at degradation products present http://www.basel.int/Implementation/TechnicalMa... [300] Formatted ... [301]

Formatted ... [302] 46

• Apply all BEP principles from above and adhere to BEP principles for your particular process outlined in Chapter 4 • Follow instructions given on the most recent SDS, preferably the SDS should adhere to Formatted: Font:11 pt GHS format and be provided in a local language version Formatted: Font:Bold, Italic • Have dedicated equipment in your facility that only runs processes with PFOS and/or PFOS-related substances • When a business operator handling PFOS (excluding a transport operator to whom Formatted: Space After: 6 pt transport is entrusted) transports it, it is recommended that measures be taken to prevent a container that stores PFOS from overturning. The container must be able to withstand the physical impact in case of an accident Formatted: Font:11 pt Formatted: No bullets or numbering Indication of storage location Formatted: Font:+Theme Body, Bold When storing and handling PFOS and PFOS-related substances, indicate that such substance(s) is Formatted: Indent: Left: 0.63 cm, No being stored in the defined location. bullets or numbering Refill Formatted: Font:+Theme Body, Bold Formatted: No bullets or numbering When refilling the PFOS- or PFOS-related product containing agent: • Handle the product indoors • Minimize number refills necessary • Avoid spills and overflows, use secondary containers to catch any spilled material • Prevent the product from remaining in equipment and take measures to recover it as much Formatted: Justified, Space After: 6 pt, Outline numbered + Level: 1 + Numbering as possible Style: Bullet + Aligned at: 0 cm + Tab after: 0.63 cm + Indent at: 0.63 cm Formatted: Font:Calibri, 11 pt

Formatted: Font:(Default) Lucida Sans BEP Measures for Manufacturing of Alternatives to PFOS and Unicode, Bold, Font color: Text 2 PFOS-Related Substances Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 • The manufacturer should employ technology to minimize exposure to workers and Formatted: Font:(Default) Lucida Sans minimize emissions to the environment which includes water, air and soil Unicode, Bold, Font color: Text 2 • The content of all previous chapters on BEP apply and should be utilized Formatted: Font:12 pt • Technology should be deployed to minimize unreacted raw material and byproduct content in the products sold • Information on unreacted raw material and byproduct content in products sold should be made public to all customers and interested parties Formatted: Font:+Theme Body Formatted: List Paragraph

Formatted: Font:(Default) Lucida Sans Specific BEP measures when using Alternatives to PFOS and Unicode, Bold, Font color: Text 2 PFOS-related Substances Formatted: Font:(Default) Lucida Sans Unicode, Bold, Font color: Text 2 • Avoid any material that may contain PFOS and/or PFOS-related substances as by- products or that can potentially degrade to form them Formatted: Font:12 pt • Avoid any material that may contain long-chain fluorinated materials [for a definition, please see the following OECD website: ], including as by-products or that can Comment [93]: http://www.oecd.org/ehs/pfc/ potentially degrade to form them

• Avoid – if possible – alternative products that contain an unknown amount or high levels of unreacted raw materials and by-products Formatted: Font:12 pt • Apply all BEP principles from above and adhere to BEP principles for your particular process outlined in Chapter 4 • Follow instructions given on the most recent SDS, preferably the SDS should adhere to GHS format and be provided in a local language version Formatted: Indent: Left: 1.27 cm, No bullets or numbering

Chapter 4: Formatted: Font:(Default) Lucida Sans Specific BEP Measures for Acceptable Purposes Unicode, 14 pt, Bold, Font color: Text 2 Processes It is important to be aware that good chemical management procedures are excellent tools to utilize to limit chemicals from entering the environment. Moreover, adhering to these procedures becomes more important when the potential exists to release harmful chemicals to the environment and/or to release chemicals that could transform in the environment to become harmful to the environment and/or to release chemicals that will be persistent in the environment. The previous chapters focussed on general aspect applicable broadly. The following chapters will address BEP measures specific to “Acceptable Purpose” and “Specific Exemption” applications (see Chapter 2) and apply whether PFOS and PFOS-related or their Formatted: Font:Bold, Font color: Text 2 alternatives are in use. Formatted: Left, Indent: Left: 1.27 cm, Space After: 0 pt Formatted: List Paragraph, Left, Space BEP for Photo-Imaging After: 0 pt • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:+Theme Body, 11 pt Formatted: Normal, No bullets or No further specific information on BEP related topics on the photo-imaging processes discussed Formatted:numbering Font:+Theme Body, 11 pt in this report could be found. Formatted: Font:+Theme Body, 11 pt Formatted: Indent: Left: 0 cm Formatted: Font:Bold, Font color: Text 2 BEP for Photoresist and Anti-Reflective Coatings for Semiconductors Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • For general environmental, health, and safety guidelines for semiconductors & other Formatted: Font:Bold, Font color: Text 2 electronics manufacturing, see for example, [ ] Formatted: Font:Bold, Font color: Text 2 • Produce, distribute, store and consume the products in closed systems to prevent Formatted: Font:+Theme Body, 11 pt workplace exposure Formatted: Bulleted + Level: 1 + Aligned • Use product only in explosion-proof equipment at: 0 cm + Indent at: 0.63 cm • Ground and bond all containers and handling equipment Formatted: Font:+Theme Body, 11 pt • Adhere to a rigorous quality control strategy, special tools and handling procedures, and Formatted: Font:+Theme Body, 11 pt low tolerance for contamination Comment [94]: http://www.ifc.org/wps/wcm/c • Liquid and solid wastes from the manufacturing processes are collected and ultimately onnect/bc321500488558d4817cd36a6515bb18/Fin al%2B- incinerated %2BSemiconductors%2Band%2BOther%2BElectroni • Solvents used in these processes will evaporate during the production process. The c%2BMnfg.pdf?MOD=AJPERES&id=1323152500561 vapors should be collected in local exhaust systems and vented to air pollution control equipment before their release to the environment Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt 48

• Wear respiratory protection during spill clean-up, remove all ignition sources • In case of a small spill, absorb with inert material such as sand or soil. Collect that material and dispose of it appropriately as chemical waste • Large spills can be prevented by only using the material in small containers (1 gallon or less). In the event of a spill, the product should be captured, collected, and reprocessed or disposed of according to applicable governmental requirements • The majority of the photoresists and anti-reflectant products are applied to silicon Formatted: Normal Indent wafers. Approximately 97% of the applied product will be spinning off the wafer and Comment [95]: Please insert reference should be captured as waste for off-site incineration. The product remaining on the Formatted: Font:(Default) +Theme Body, wafer undergoes heat treatment (baking step) and converts to a film (solvents are 11 pt evaporated). The dry film may consist of non-volatile acrylic polymers, cross-linkers, Comment [96]: http://msdssearch.dow.com/Pu surfactant, stabilizers and other additives. Ca. 50% of the dried film may dissolve during blishedLiteratureDOWCOM/dh_090c/0901b803809 0c227.pdf?filepath=productsafety/pdfs/noreg/233- the development step. The dissolved ingredients should be later neutralized in 00873.pdf&fromPage=GetDoc and wastewater-treatment processes, any fluorinated material remaining in the aqueous http://msdssearch.dow.com/PublishedLiteratureDO phase should be removed before being discharged to the aquatic environment. WCOM/dh_08fb/0901b803808fb120.pdf?filepath= productsafety/pdfs/noreg/233- • The industry has implemented process tools to reuse and recycle as well as to incinerate 00827.pdf&fromPage=GetDoc spent liquid along other measures and reports global emissions of PFOS to waste water to be approximately 6kg/year [WSC, 2011 Report]. In that report, no information on Formatted: Normal, Indent: Left: 1.27 emission quantities of the alternative products was provided cm, No bullets or numbering • For further information, see for example: [ ] Formatted: Font:+Theme Body, 11 pt Formatted: Font:+Theme Body, 11 pt No further specific information on BEP related topics on the processes discussed in this report Formatted: Normal, No bullets or numbering could be found. Formatted: Font:Bold, Font color: Text 2 Formatted: Normal, Indent: Left: 1.27 cm Formatted: Font:Bold, Font color: Text 2 BEP for Etching Agent for Compound Semiconductors and Ceramic Filters Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • For general environmental, health, and safety guidelines for semiconductors & other Formatted: Font:Bold, Font color: Text 2 electronics manufacturing, see [ ] Formatted: Font:Bold, Font color: Text 2 • Used etching liquid should be collected for recovery and reuse and/or be sent for Formatted: Font:Bold, Font color: Text 2 suitable waste treatment Comment [97]: http://www.ifc.org/wps/wcm/c onnect/bc321500488558d4817cd36a6515bb18/Fin al%2B- No further specific information on BEP related topics on the processes discussed in this report %2BSemiconductors%2Band%2BOther%2BElectroni could be found. c%2BMnfg.pdf?MOD=AJPERES&id=1323152500561

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BEP for Aviation Hydraulic Fluids Formatted: Indent: Left: 1.27 cm, No • The content of all previous general chapters on BEP apply and should be utilized bullets or numbering • Aviation hydraulic fluids should be disposed of by approved disposal methods in Formatted: Indent: Left: 0 cm accordance with national, federal, state and local guidelines. Presently, the most Formatted: Font:Bold, Font color: Text 2 universally accepted disposal method is incineration in an approved facility. Formatted: Font:Bold, Font color: Text 2 • Partial reclamation of phosphate ester base stock of spent aviation hydraulic fluids is Formatted: Font:11 pt being practiced. There is no approved reclamation system or known practical Formatted: Font:+Theme Body, 11 pt technology to completely reclaim spent aviation hydraulic fluids for return to aircraft Formatted: Font:11 pt hydraulic system usage. Formatted: Indent: Left: 1.27 cm, No bullets or numbering 49

No further specific information on BEP related topics on the processes discussed in this report Formatted: Indent: Left: 0 cm could be found. Formatted: Font:11 pt

BEP for Metal Plating (hard metal plating) Only in Closed-Loop Systems Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • Utilize suitable combinations of techniques such as cascade rinsing, ion exchange and Formatted: Font:Bold, Font color: Text 2 evaporation Formatted: Font:Bold, Font color: Text 2 • When hot electrolytes with high evaporation rates are used, closing of the material loop Formatted: Font:Bold, Font color: Text 2 can sometimes already be achieved by simple methods such as using a single static rinse Formatted: Font:Bold, Font color: Text 2 in combination with seven rinsing steps in a pumped, very slowly flowing rinsing Formatted: Font:Bold, Font color: Text 2 cascade. But in most cases, an evaporator is required to regain the electrolyte from the Formatted: Font color: Auto rinse water Formatted: Justified, Space After: 6 pt • Use evaporation for drag-out recovery. An example of this technology, which has been used commercially in decorative plating processes for 20 years (Hauser, 2011), is given Comment [98]: Please include reference in Figure 4-2 Formatted: Font:Calibri, 11 pt

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Figure 4-2: Closed loop in decorative chromium plating (Hauser, 2011) Formatted: Font:Calibri, 11 pt, Font color: Black • Regional weather patterns may affect applicability of evaporation. Cation exchange Formatted: List Paragraph, Bulleted + resins with high resistance to strong oxidants are used to selectively remove unwanted Level: 1 + Aligned at: 0.63 cm + Indent at: metal ions Formatted: 1.27 cm Font:Calibri, 11 pt, Font color: Black Formatted: Font:Times New Roman, 12 pt, Font color: Auto 50

• Closing the loop for process chemicals does not mean being free of wastewater. In fact Formatted: Font:Calibri, 11 pt, Font color: Black no loop can be held completely closed all the time. Losses of 10–20% of the applied PFOS amount into the wastewater cannot be avoided. Formatted: Font:Times New Roman, 12 pt, Font color: Auto • Sources for PFOS can be regeneration of ion exchangers, air scrubber effluents, floor Formatted: Font:Calibri, 11 pt, Font color: water of the plating plant and carry-over effects. Black Formatted: Indent: Left: 0 cm Figure 4-3 shows a flow diagram of an almost closed system with optimized PFOS adsorption. The system is used in plastic plating processes. The use of evaporators is a costly investment but might be amortized over a few years.

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Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: Formatted: 1.27 cm Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Figure 4-3: Process and systems engineering for chromium plating on ABS plastics (Schwarz, 2011) Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt • With this combination of recycling of rinse water, ion exchangers, evaporators, air Formatted: Font:Calibri, 11 pt scrubber, and finally a two-step adsorption unit, a return or elimination of PFOS by > Formatted: Font:Calibri, 11 pt 99% can be permanently achieved. The separation of PFOS using activated carbon or ion Formatted: Font:Calibri, 11 pt exchangers is realized at a central point in the conventional process of chromium (VI) Formatted: Font:Calibri, 11 pt reduction (Schwarz, 2011). Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:Calibri, 11 pt could be found. Comment [99]: Please include reference Formatted: Font:Calibri, 11 pt Formatted: Font:Calibri, 11 pt Formatted: Font:11 pt Formatted: Indent: Left: 0 cm 51

BEP for Certain Medical Devices (such as ethylene tetraethylene copolymer (ETFE) Formatted: Font:Bold, Font color: Text 2 layers and radio opaque ETFE production, in vitro-diagnostic medical devices, and Formatted: Font:Bold, Font color: Text 2 CCD colour filters) Formatted: Indent: Left: 0.63 cm • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:+Theme Body, 11 pt could be found. Formatted: Normal, No bullets or Formatted:numbering Indent: Left: 0 cm Formatted: Font:11 pt BEP for Fire Fighting Foam Formatted: Font:Bold, Font color: Text 2

• The content of all previous general chapters apply and should be utilized Formatted: Font:11 pt • For a brief overview on BEP in this industry, please see [Industrial Fire Journal, Spring 2014, Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0 cm + Indent at: p. 24 and 25] 0.63 cm Formatted: Font:+Theme Body, 11 pt Comment [100]: Please include this AFFF products are extremely effective in protecting lives and property, and this guidance is not reference intended to discourage the use of AFFF for fire protection services. There are numerous Formatted: Font:+Theme Body, 11 pt available techniques and environmental practices, however, that can be employed to minimize Formatted: Indent: Left: 0 cm the possibility of unintended or unnecessary releases and mitigate impacts in the event that an incident occurs. Finally, residual materials could be appropriately managed. 4.1.1 Inventory management Inventory identification A list of fire protection systems and associated types and amounts of AFFF used in each system or piece of equipment may be developed and maintained. Such a list could be helpful in identifying PFOS-based foams should it become necessary to remove them from service or inventory. When product identification is uncertain, the services of an analytical laboratory may be helpful. Product information sheets (i.e. MSDS) should be available at a facility where AFFF is in use. This information could be vital in the event of an incident. Containers or storage vessels could be clearly marked and the contents and type of foam listed. Inventory review It is important to periodically review the inventory of fixed and portable systems that contain AFFF in order to determine the ongoing need for use of these products in each specific location. Over time, use and fire protection classification of areas can change significantly. As appropriate, fire protection personnel would be involved in these determinations. AFFF that is no longer needed at any given facility or location could be removed and appropriately disposed of. As part of this review, the age of products in the inventory could be considered along with the possibility of replacement by newer products. 4.1.2 Training with foams Training of emergency response personnel is a critical step to ensure that timely and appropriate actions can be taken in the event of an emergency. Relative to practice exercises on extinguishing fires, practice foams that do not contain fluorosurfactants can be readily available and used in appropriate circumstances.

4.1.3 Prevention of unintended releases It is important that unintended or unnecessary releases to the environment be minimized as much as possible. Towards this end, this section includes a list of actions that can be applied to help prevent an unintended release at a facility and/or mitigate the impacts of such a release to the environment. Secondary containment • Review adequacy and integrity of secondary containment systems that may be utilized in the event of a potential release. • Upgrade these systems, as necessary, based on the assessment performed. Testing of fire protection systems • Review procedures to test fire protection systems and modify as needed to ensure containment or capture of any AFFF-containing solution. • Avoid releases to sewers or soils during testing activities. • Consider the use of surrogate fluids when testing the proportioning accuracy of hardware in fire protection systems. This can be an effective method to reduce releases to sewers and may also reduce the cost of testing. Evaluation of sprinkler systems • Survey sprinkler systems to identify the potential for accidental discharge. Consider areas where sprinkler heads could be physically damaged (e.g. vehicular traffic). Evaluate the potential for ambient air temperature or system pressure excursions to trigger a discharge. • Evaluate options and make changes as deemed necessary. Preventative maintenance • Regularly perform preventative maintenance on sprinkler systems, including backflow prevention valves. Emergency procedures • Establish/modify site-specific emergency procedures to incorporate the options proposed in this guidance (see also section 4.3.4). Training • Conduct training, especially for plant maintenance and emergency response personnel, on this guidance (see also section 4.3.4). Container integrity • Regular inspection of containers and vessels (tanks) used to store AFFF concentrate. Integrity of related secondary containment areas could also be included in this procedure. • Record inspection results. 4.1.4 Response to a release Response actions The following guiding principles could be used for responses to an AFFF release: 53

• Minimize intentional release of material or rinse water onto soil. • Avoid discharge of released material or rinse water into a sanitary or storm sewer. • Minimize the volume of impacted materials to the greatest extent possible. • Sites should develop a mitigation plan and evaluate their storm water/accidental release plans. These principles could also be incorporated into a facility’s emergency response plans and procedures. Again, execution of this guidance should not compromise protection of life or property in the event of an emergency. The initial response to a release can be critical in terms of minimizing possible impacts. Possible immediate actions that could be taken following a release to prevent/mitigate the migration of the release into the environment include: • Use close containment or isolation valves • Use secondary containment • Place released material into secure containers as soon as possible (if plausible) • Build a dam to contain/control run-off • Block a trench • Install a sewer plug • Divert released material into a containment pond • Pump released material into a septic system pumper truck or vacuum truck • Use a defoamer to reduce foam volumes • Place impacted soils on plastic and cover to prevent run-on and run-off • Add adsorbent The above list is only intended to suggest possible actions that could be taken and is not necessarily exhaustive. It would be beneficial that each facility has a site-specific response plan that appropriately considers and incorporates relevant actions and procedures, some of which may be listed above. Documenting a release It is also important to quantify and document any release that occurs including estimations of the amount of AFFF released, the nature of the release (i.e. concentrate or dilute), and the amount of materials impacted (i.e. soil, water, etc.). Two ways to quantify a release from fire protection systems are to: • Calculate the amount based on how long the fire suppression system operated • Measure the amount of AFFF concentrate remaining in the system following the incident and compare it to the inventory before the release Release notification Prompt and appropriate notification concerning a release is another critical element. Notification requirements and procedures would vary depending on where the AFFF release occurred, the nature of the release and governmental reporting requirements (considerations could include potential impacts to drinking water supplies, release to a sensitive environmental area, magnitude of the release, involvement of outside parties, etc.). Site-specific notification requirements and procedures could be clearly outlined in facility emergency response plans and be reviewed as part of routine training.

4.1.5 Management of residual (waste) materials

Specific actions relative to the management of waste are determined on a case-by-case basis. Guidance on environmentally sound management of wastes consisting of, containing or contaminated with PFOS is available under the Basel Convention. BAT in dealing with PFOS-based AFFF concentrate and concentrated rinse water is high temperature incineration at a facility designed to handle halogenated waste streams. Small volumes of solid materials (soils, absorbent materials, etc.) that contain higher levels of PFOS- based AFFF can be handled in a similar fashion. According to experiments on destruction of wastes containing conducted by the Ministry of Environment, Japan, destruction could be done in an incinerator which consists of a primary furnace (a rotary kiln) at temperature of 1,110° C and secondary furnace at temperatures of 900° C, with the combined gas retention time of approximately 8 seconds (Ministry of Environment of Japan, 2013). Comment [101]: Please include this reference When PFOS-based AFFF exists in a dilute solution (e.g. collection of water resulting from an accidental triggering of a sprinkler system), treatment using granular activated carbon may be an option. Carbon vendors can be contacted for assistance if the treatment is to occur on site. In situations where dilute PFOS-based AFFF has been applied on top of fuel to prevent or extinguish a fire, the analysis of potential residual management options can become quite complex. Treatment using granular activated carbon may be a viable option although pre- treatment steps may be required to extend the life of the carbon in removing perfluorochemicals. Use of reverse osmosis coupled to electrocoagulation-filtration has also recently been reported as a possible means to treat fire fighting water (Baudequin et. al., 2011). Comment [102]: Please include this reference There is ongoing research to develop innovative treatment technologies to remove PFCs from wastewater streams (see Herrera, 2008; Senevirathna, 2010).

No further specific information on BEP related topics on the processes discussed in this report could be found. Formatted: Indent: Left: 0 cm

BEP for Insect Baits for Control of Leaf-Cutting Ants from Genus Atta spp. and Formatted: Font:Bold, Font color: Text 2 Acromyrmex spp. Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters apply and should be utlized Formatted: Font:Bold, Font color: Text 2 • The production of sulfluramid is often carried out in a closed system, with no releases Formatted: Font:Bold, Font color: Text 2 (discharges, losses, or emissions). The best available process results in a product with purity Formatted: Font:Bold, Font color: Text 2 of at least 98%. Formatted: Font:Bold, Font color: Text 2 • Place granular pellets in proper location. Do not overdose Formatted: Font:Bold, Font color: Text 2 • Dispose of left over granular pellets according to information provided by the manufacturer Formatted: Font:Bold, Font color: Text 2 Formatted: Font:11 pt No further specific information on BEP related topics on the processes discussed in this report Formatted: List Paragraph, Bulleted + could be found. Level: 1 + Aligned at: 0 cm + Indent at: 0.63 cm Formatted: Font:+Theme Body, 11 pt Formatted: Font:11 pt Formatted: Font:(Default) Lucida Sans Specific BEP Measures for Specific Exemptions Unicode, 14 pt, Bold, Font color: Text 2

BEP for Photo Masks in the Semiconductor and Liquid Crystal Display (LCD) Formatted: Font:Bold, Font color: Text 2 Industries Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • For general environmental, health, and safety guidelines for semiconductors & other Formatted: Font:Bold, Font color: Text 2 electronics manufacturing, see [ ] Formatted: Font:Bold, Font color: Text 2 • Liquid waste from the etching process contains chromium-VI and PFOS. Both these Formatted: Font:Bold, Font color: Text 2 substances should be removed from waste water before it is released to the Formatted: Font:+Theme Body, 11 pt environment. Comment [103]: http://www.ifc.org/wps/wcm/ • The solid, PFOS containing waste should be disposed of according to guidance provided connect/bc321500488558d4817cd36a6515bb18/Fi nal%2B- by the Basel Convention [insert link]. %2BSemiconductors%2Band%2BOther%2BElectroni c%2BMnfg.pdf?MOD=AJPERES&id=1323152500561

No further specific information on BEP related topics on the processes discussed in this report Comment [104]: Please include reference could be found. from earlier Formatted: Font:+Theme Body, 11 pt Formatted: Indent: Left: 0 cm BEP for Metal Plating (hard metal plating) Formatted: Indent: Left: 0 cm For general information on Best Environmental Practices in the Surface Treatment of Metals and Formatted: Font:Bold, Font color: Text 2 Plastics industry, please see a document published by the European Commission’s Integrated Formatted: Font:Bold, Font color: Text 2 Pollution Prevention and Control Group [ ]. Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Normal, Justified, Space After: 6 pt, Tabs: 1.27 cm, Left • Consider operating closed-loop systems (see Chapter 4E) Comment [105]: http://eippcb.jrc.ec.europa.eu • There might be additional BEP measures to consider related to Chromium-VI which are /reference important but outside the scope of this document Formatted: Font:(Default) Calibri, Bold, • Controlling the electroplating process can lead to reducing PFOS emissions by 50% (IPPC, English (UK) 2006). To better control the process: Formatted: Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: 1.27 cm o Measure surface tension of the electrolyte Comment [106]: Please include reference o Measure ampere hour rate Formatted o Determine a certain defined surface throughput o Measure foam stability Formatted: List Paragraph, Space After: 6 pt, Bulleted + Level: 2 + Aligned at: 1.9 • In addition, maximize water-reduced rinsing, extensive material recycling and low carry- cm + Indent at: 2.54 cm over losses by transportation, as well as the reduction of material losses due to process- Formatted: Font:(Default) Calibri, Bold integrated measures (IPPC, 2006). Formatted: List Paragraph, Justified, When the chrome plating solution is spent, the bath is exhausted and the plating Space After: 6 pt, Bulleted + Level: 1 + • Aligned at: 0.63 cm + Indent at: 1.27 cm solution liquid must be disposed of. The spent solution needs to be treated at a Formatted: Font:(Default) Calibri, Bold chemical waste water treatment plant, where the chromium is precipitated as Formatted: Font:(Default) +Theme Body, chromium (III) hydroxide. The resulting dewatered sludge needs to be disposed of at 11 pt, English (UK) 7 specially prepared landfills, engineered to prevent leakage, where the sludge is stored. Formatted: Bulleted + Level: 1 + Aligned The practice to use this sludge as a fertilizer for agricultural soil can result in broad scale at: 0.63 cm + Indent at: 1.27 cm Formatted: Font:(Default) +Theme Body, 11 pt, Not Bold Formatted: Font:(Default) +Theme Body, 11 pt, English (UK) Formatted: Font:+Theme Body, 11 pt 7 IPPC BREF BAT for the Surface Treatment of Metals and Plastics European Commission, 2006. 56

contamination of agricultural fields and provides a major emission source to food and water and should no longer be practiced.8 Formatted: Font:(Default) +Theme Body, 11 pt, English (US)

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BEP for Metal Plating (decorative plating) Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • Consider operating closed-loop systems (see Chapter 4E) Formatted: Font:Bold, Font color: Text 2 Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0 cm + Indent at: 0.63 cm No further specific information on BEP related topics on the alternative process discussed in this Formatted: Indent: Left: 0 cm report could be found. Formatted: Font:11 pt

Formatted: Font:Bold, Font color: Text 2 BEP for Electric and Electronic Parts for Some Colour Printers and Colour Copy Formatted: Font:Bold, Font color: Text 2 Machines Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:Bold, Font color: Text 2 could be found. Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 BEP for Insecticides for Control of Red Imported Fire Ants and Termites Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:11 pt, Bold, Font color: Text 2

Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:Bold, Font color: Text 2 could be found. Formatted: Font:Bold, Font color: Text 2

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Formatted: Font:Bold, Font color: Text 2 BEP for Chemically Driven Oil Production Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • In addition, consider the following steps: Formatted: Font:Bold, Font color: Text 2 • Step 1: All arrangements put in place to avoid/prevent occupational health and safety Formatted: Font:Bold, Font color: Text 2 hazards including ensuring the availability and use of personal protective equipment (PPE), review of checklist for spillage prevention and control and selection/use of Formatted: Font:Bold, Font color: Text 2 relevant and applicable equipment and machinery. Formatted: Font:Bold, Font color: Text 2 • Step 2: All relevant equipment items including those for stimulation, coil tubing and Formatted: Font:Bold, Font color: Text 2 nitrogen storage and circulation unit mobilized on site. Formatted: Font:Bold, Font color: Text 2 Formatted: Justified, Space After: 6 pt, Bulleted + Level: 1 + Aligned at: 0 cm + Indent at: 0.63 cm 8 Krofges P, Skutlarek D, Farber H, Baitinger C, Godeke I, Weber R., PFOS/PFOA Formatted: List Paragraph, Bulleted + Contaminated Megasites In Germany Polluting The Drinking Water Supply Of Millions Level: 1 + Aligned at: 0 cm + Indent at: Of People Organohalogen Compounds Vol. 69 (2007). Formatted:0.63 cm Font color: Black 57

• Step 3: Stimulation equipment is connected to the wellhead and pressure testing is carried out at pressures of up to 4,500 psi for 15 minutes to ensure that system is leakproof. The system is bled off to zero. • Step 4: The injectivity test is carried out by opening the lower master valve on well, 3% NH4Cl is injected and the flow rates recorded against corresponding pressures. This is to ensure that the formation is open enough to accept the acid treated fluid. If injectivity is less than 0.5 barrels per minute (bpm) at less than fracture pressure, further assessment of the well will need to be made. • Step 5: Mix the acid treatment as stipulated in the recipes once injectivity of well is established • Step 6: Acidize the formation intervals as follows: • Pump acid preflush (fresh water, corrosion inhibitor, hydrochloric acid, iron sequestering agent, surfactant, mutual solvent and phosphonic complex) • Follow with main treatment flush (fresh water, corrosion inhibitor, surfactant, clay stabilizing agent, iron sequestering agent, phosphonic acid, ammonium fluoride and hydrochloric acid) • Pump after-flush (fresh water, ammonium chloride, mutual solvent, surfactant, fine stabilizer and clay control) • Pump displacement fluid (3% ammonium chloride of tube volume amount) to top of perforation • Step 7: Open the upper master valve gradually and produce immediately the spent acid from the formation and neutralize with soda ash in the flow back tank. If the well does not flow naturally, run in the coil tubing to carry out gas lift with nitrogen gas. Formatted: Font:Times New Roman, 12 pt • Step 8: The spent liquid in the flow back tank should be treated to remove surfactants Formatted: Font:Not Bold and other additives before releasing it to the environment. Remaining solids from the spent liquid treatment should be incinerated.

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Comment [107]: This chapter could be expanded with text from the Australian Carpet Institute referenced here. BEP for Carpets Is this something to consider for the BAT/BEP • The content of all previous general chapters on BEP apply and should be utilized Expert Group to take on? • For a brief general overview over practices for environmental management, the Carpet Formatted: Font:Bold, Font color: Text 2 Institute of Australia has published a good summary document [ ] Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Comment [108]: http://www.carpetinstitute.co could be found. m.au/downloads/CodeofPracticeforEnvironmental ManagementVersion1.1.pdf

Formatted: Font:+Theme Body, 11 pt BEP for Leather and Apparel Formatted: Indent: Left: 0 cm Finishing Process Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 58

• For a reference document on Best Environmental Practices for the tanning of hides and Comment [109]: http://eippcb.jrc.ec.europa.eu /reference skins, please see a document published by the European Commission’s Joint Research Centre [ ]. Formatted: Font:+Theme Body, 11 pt • The products are typically aqueous dispersions of fluorinated polymers that are being Formatted: Font:+Theme Body, 11 pt, applied during the fat liquoring process in the tannery (but there might be other points English (US) of applications during the wet processing) or aqueous- or solvent-based formulations of Formatted: Indent: Left: 0.63 cm fluorinated polymers being applied in an industrial spray coating process. Formatted: List Paragraph, Bulleted + Level: 1 + Aligned at: 0.63 cm + Indent at: No further specific information on BEP related topics on the processes discussed in this report Formatted: 1.27 cm Font:+Theme Body, 11 pt could be found. Formatted: Font:+Theme Body, 11 pt, English (UK) Consumer Use Formatted: Indent: Left: 0.63 cm • The content of all previous general chapters on BEP apply and should be utilized Formatted: Indent: Left: 0 cm • Formulations used by consumers are either leather care products in forms of creams, Formatted: Font:11 pt lotions or spray. Often spray applications are via aerosol spray (e.g., offered under the Comment [110]: FluoroCouncil provided a copy of a guidance document. Consider Scotchgard® brand and other companies’ brands). inserting its content for this chapter. Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:Bold, Font color: Text 2 could be found. Formatted: Font:Bold, Font color: Text 2 Formatted: Font:+Theme Body, Bold, Font color: Text 2 BEP for Textiles and Upholstery Formatted: List Paragraph, Bulleted + • The content of all previous general chapters on BEP apply and should be utilized Level: 1 + Aligned at: 0.63 cm + Indent at: 1.27 cm Formatted: Font:+Theme Body, 11 pt No further specific information on BEP related topics on the processes discussed in this report Formatted: List Paragraph, Indent: Left: 0 cm could be found. Formatted: List Paragraph, Indent: Left: 0 cm Formatted: Font:+Theme Body BEP for Paper and Packaging Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 • For a reference document on Best Environmental Practices for the production of pulp, Formatted: Font:Bold, Font color: Text 2 paper and board, please see a document published by the European Commission’s Joint Comment [111]: http://eippcb.jrc.ec.europa.eu Research Centre [ ] /reference

No further specific information on BEP related topics on the processes discussed in this report Formatted ... [303] could be found. Formatted: Indent: Left: 0 cm Formatted: Font:11 pt Formatted: Font:Bold, Font color: Text 2 BEP for Coatings and Coating Additives Formatted: Font:Bold, Font color: Text 2 • The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 No further specific information on BEP related topics on the processes discussed in this report Formatted: Font:+Theme Body, 11 pt could be found. Formatted: Indent: Left: 0.63 cm Formatted: Indent: Left: 0 cm Formatted: Font:Bold, Font color: Text 2 BEP for Rubber and Plastics Formatted: Font:Bold, Font color: Text 2 Formatted: Font:Bold, Font color: Text 2 59

• The content of all previous general chapters on BEP apply and should be utilized Formatted: Font:+Theme Body, 11 pt

No further specific information on BEP related topics on the processes discussed in this report could be found.

Formatted: Font:+Theme Body Formatted: List Paragraph, Outline numbered + Level: 7 + Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment: Left + Aligned at: 13.45 cm + Tab after: 14.09 cm + Indent at: 14.09 cm

Deleted: <#>BAT/BEP principles for chemicals management of PFOS Page Break ... [304] Formatted: Font:Calibri, 11 pt, Font color: Black Formatted: Font:Calibri, 11 pt, Bold Deleted: Page Break ... [305]

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