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United Nations Sc UNITED NATIONS SC UNEP/POPS/POPRC.12/INF/16 Distr.: General 2 August 2016 English only Stockholm Convention on Persistent Organic Pollutants Persistent Organic Pollutants Review Committee Twelfth meeting Rome, 19–23 September 2015 Item 4 (d) of the provisional agenda Technical work: consolidated guidance on alternatives to perfluorooctane sulfonic acid and its related chemicals Comments and responses relating to the draft consolidated guidance on alternatives to perfluorooctane sulfonic acid and its related chemicals Note by the Secretariat As referred to in the note by the Secretariat on guidance on alternatives to perfluorooctane sulfonic acid and its related chemicals (UNEP/POPS/POPRC.12/7), the annex to the present note contains a table listing the comments and responses relating to the draft guidance. The present note, including its annex, has not been formally edited. UNEP/POPS/POPRC.12/1. 030816 UNEP/POPS/POPRC.12/INF/16 Annex Comments and responses relating to the draft consolidated guidance on alternatives to perfluorooctane sulfonic acid and its related chemicals Minor grammatical or spelling changes have been made without acknowledgment. Only substantial comments are listed. Yellow highlight indicates addition of text while green highlight indicates deletion. Source of Page Para Comments on the second draft Response Comment Austria 7 2 This statement is better placed in Chapter VII Rejected. accompanied with a justification for those “critical applications”. For clarification “where it is not currently possible without the use of PFOS” is added Austria 15 47 According to May be commercialized is revised to http://poppub.bcrc.cn/col/1413428117937/index.html “are commercialized” F-53 and F-53B have a long history of usage and have been commercialized before PFOS related Reference substances were used (cf. …”For several years, this http://poppub.bcrc.cn/col/1413428117 compound had remained as the only available mist 937/index.html F-53 is included as a suppressant in the Chinese electroplating industry, footnote. until the emergence of PFOS related substances…”) Austria 16 54 Please provide references for these statements to Included reference enhance transparency (as well as in the following paragraphs, if applicable). UNEP/POPS/POPRC.10/INF/10 Austria 19 87 Please provide a reference for this statement. Included reference UNEP/POPS/POPRC.9/INF/11/Rev.1 Austria 19 87 Footnote 43: Deleted We were not able to verify the statement in the given “There was no annual consumption in reference. the European Union’s photographic industry in 2014since no member states in EU/EEA have declared continuous need for this acceptable purpose, but there are at least four member states in EU/EEA that have no available information whether this acceptable purpose is applied or not in their countries.1” since this cannot be supported by any publicly available reference. Austria 21 100 From Austria the semi-conductor industry in Austria Added as a footnote. has replaced PFOS by 2015 by another PFOS-free photoresistant. However no specific details besides ”The semi-conductor industry in the Web link on the used alternative were provided Austria has replaced PFOS by 2015 by based on the claim of business confidentiality. another PFOS-free photoresistant. However no specific details besides the Web link on the used alternative were provided based on the claim of business confidentiality” Austria 22 103 Please provide a reference for this para. Added reference UNEP-POPS-POPRC8FU-SUBM- PFOS-ESIA-130621.En.pdf http://chm.pops.int/TheConvention/PO PsReviewCommittee/Meetings/POPR C8/POPRC8Followup/SubmissionsPF 1 https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-137-EN-F1-1.PDF. 2 UNEP/POPS/POPRC.12/INF/16 Source of Page Para Comments on the second draft Response Comment OSdraftguidance/tabid/3233/Default.as px Austria 22 107 Please include this updated information. “According to a submission from Japan, alternative methods are expected to be available in 2014.2” This statement originates from UNEP/POPS/POPRC.4/15/Add.6 with no supported updated reference. Austria 23 110 Please provide a reference for this statement. Included reference UNEP/POPS/POPRC.9/INF/11/Rev.1 Austria 23 111 Could you please clarify? The previous sentence Included after states that no alternatives are commercialized for PAG, BARC and TARC. “The previous sentence states that no alternatives are commercialized for PAG, BARC and TARC.” “e.g. Fuji describes photo-resists that are “PFOS & PFAS free.3 The scientific literature indicates that is should be possible to develop a PFOS- free photo-resist system.4 The patent literature also indicates active work in this area. For example, patents describe fluorine-free photoresist compositions as an alternative to PFOS/PFAS use.5, 6, 7” Revised and added: “No alternative substances have been commercialized for existing uses in PAG, BARC and TARC that would allow for the comprehensive substitution of PFOS in these critical applications.8” Austria 23 116 e.g. a perfluoroalkyl sulphonate is currently used by Included Skydrol according to the submission of NO (available at http://chm.pops.int/TheConvention/POPsReviewCom mittee/Meetings/POPRC11/POPRC11Followup/PFO SInfoRequest/tabid/4814/Default.aspx Austria 24 118 Please provide a reference. Please delete the last Added reference sentence of para.118 or provide further information. UNEP/POPS/POPRC.8/INF/17/Rev.1 Deleted below sentence…. “This residual substance is only present at very low levels (a few parts per million) and is only formed in an environment with high pressure and fluorine. The presence of this substance could be considered an “unintentional trace contaminants”. …until confirmed by the Aviation 2 UNEP/POPS/POPRC.4/INF/17/Rev.1. 3 http://www.fujifilmusa.com/products/semiconductor_materials/photoresists/krf/index.html. 4 Ayothi R, Chang SW, Felix N, Cao HB, Deng H, Yueh W, Ober CK (2006) New PFOS free photoresist systems for EUV lithography, Jour Photopolymer Science and Technol 19:515-520. 5 https://www.google.com/patents/US20090181319. 6 https://www.google.com/patents/US8034533. 7 UNEP-POPS-POPRC11FU-SUBM-PFOS-20160108-En.doc 8 UNEP/POPS/COP.7/INF/21. 3 UNEP/POPS/POPRC.12/INF/16 Source of Page Para Comments on the second draft Response Comment Hydrualic Oil suppliers such as Arnica, Tellus, Durad, Fyrquel, Houghto-Safe, Hydraunycoil, Lubritherm Enviro- Safe, Pydraul, Quintolubric, Reofos, Reolube, Valvoline Ultramax, Exxon HyJet, and Skydrol, whether fluorochemicals such as PFOS derivatives are actually used since there is very little information about what they actually contain. It can be further clarified at POPRC12. Austria 24 120 Please update the company information. Noted. Please be aware that e.g. LubeCorp Manufacturing Please provide reference before any Inc. does not sell approved aviation hydraulic fluids revision can be done. i.e. Lubritherm All-Temp Hydraulic Fluid is not approved for the aviation sector. Austria 24 124 Please provide a reference. Added reference: “Blepp M. (2015) Berichterstattung an die Europäische Kommission nach Artikel 12 der EU-POP-Verordnung (EU-POP-VO). Umweltbundesamt Projektnummer [55 567] Austria 25 127 Could you please provide a reference for this finding? Added reference: UNEP-POPS-POPRC8FU-SUBM- PFOS-Boeing_130621.En.doc Austria 26 134 “…including in closed loop systems.” under the Rejected since this revision does not specific exemptions and acceptable purposes listed in contribute to clarification of the the Convention.9 distinction of metal plating as it is listed in the Convention. Austria 26 135 Blepp et al. (2015) also points out that purpose and Included in new para function is important for the distinction of decorative and hard chromium plating because there are “There are two main technologies in transitions between those two processes. metal plating namely hard and decorative metal plating. The Blepp M. (2015) Berichterstattung an die difference between hard and decorative Europäische Kommission nach Artikel 12 der EU- metal plating is thickness, hardness POP-Verordnung (EU-POP-VO). Umweltbundesamt and deposition of the chrome layer on Projektnummer [55 567] the plated object where the hard metal plating is addressed as functional agent e.g. corrosion, abrasion etc and the decorative metal plating main function is primarily a decorative surface finish.” Austria 27 143 Please insert a new heading that reflects the content Rejected since these have to do with of the following paras. price and cost. Austria 28 148 Please provide a reference for these statements. Deleted since this is an old statement based on personal communication from 2009 where a lot has occurred in hazard classification of fluorochemicals since then. …fluorosurfactants are not classified as dangerous, this use in Denmark is not reported to the National Product Registry, and its extent is not known to the authorities.10 9 UNEP/POPS/COP.7/INF/21. 10 Personal communication from Frank Jensen, Danish Environmental Protection Agency, 17 March 2009. 4 UNEP/POPS/POPRC.12/INF/16 Source of Page Para Comments on the second draft Response Comment Austria 27 148 Please note that PFOS and PFOA have harmonized Deleted see above. EU classifications regarding human health and environmental hazards. cf: http://echa.europa.eu/de/information-on- chemicals/cl-inventory-database/-/discli/details/82756 Please specify which fluorosurfactants are meant. Austria 27 149 Are data from regions outside the EU available? Included sentence Please amend or note the
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