Stockholm Convention Pollutants

030816

UNITED NATIONS

SC

UNEP/POPS/POPRC.12/INF/16

Stockholm Convention on Persistent Organic Pollutants

Distr.: General 2 August 2016

English only

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the annex to the present note contains a table listing the comments and responses relating to the draft guidance.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.


2

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 Comment

Page Para Comments on the second draft Response

Austria 7 2 This statement is better placed in Chapter VII accompanied with a justification for those “critical applications”.

Rejected.

For clarification “where it is not currently possible without the use of PFOS” is added

Austria 15 47 According to http://poppub.bcrc.cn/col/1413428117937/index.html F-53 and F-53B have a long history of usage and have been commercialized before PFOS related substances were used (cf. …”For several years, this compound had remained as the only available mist suppressant in the Chinese electroplating industry, until the emergence of PFOS related substances…”)

May be commercialized is revised to “are commercialized”

Reference http://poppub.bcrc.cn/col/1413428117937/index.html F-53 is included as a footnote.

Austria 16 54 Please provide references for these statements to enhance transparency (as well as in the following paragraphs, if applicable).

Included reference


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:

We were not able to verify the statement in the given reference.

Deleted

“There was no annual consumption in 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 has replaced PFOS by 2015 by 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.

Added as a footnote.

”The semi-conductor industry in Austria has replaced PFOS by 2015 by 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/POPsReviewCommittee/Meetings/POPRC8/POPRC8Followup/SubmissionsPF

1 https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-137-EN-F1-1.PDF.


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Source of Comment


OSdraftguidance/tabid/3233/Default.aspx

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


Austria 23 111 Could you please clarify? The previous sentence states that no alternatives are commercialized for PAG, BARC and TARC.

Included after

“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 Skydrol according to the submission of NO (available at http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC11/POPRC11Followup/PFOSInfoRequest/tabid/4814/Default.aspx

Included

Austria 24 118 Please provide a reference. Please delete the last sentence of para.118 or provide further information.

Added reference


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.


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Source of 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.

Please be aware that e.g. LubeCorp Manufacturing Inc. does not sell approved aviation hydraulic fluids i.e. Lubritherm All-Temp Hydraulic Fluid is not approved for the aviation sector.

Noted.

Please provide reference before any revision can be done.

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 specific exemptions and acceptable purposes listed in the Convention.9

Rejected since this revision does not contribute to clarification of the distinction of metal plating as it is listed in the Convention.

Austria 26 135 Blepp et al. (2015) also points out that purpose and function is important for the distinction of decorative and hard chromium plating because there are transitions between those two processes.

Blepp M. (2015) Berichterstattung an die Europäische Kommission nach Artikel 12 der EU-POP-Verordnung (EU-POP-VO). Umweltbundesamt Projektnummer [55 567]

Included in new para

“There are two main technologies in metal plating namely hard and decorative metal plating. The difference between hard and decorative metal plating is thickness, hardness and deposition of the chrome layer on 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 of the following paras.

Rejected since these have to do with 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.


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Source of Comment


Austria 27 148 Please note that PFOS and PFOA have harmonized 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.

Deleted see above.

Austria 27 149 Are data from regions outside the EU available? Please amend or note the information gap.

Included sentence

“China is the only country documented to still be producing PFOS, though there is no China PFOS emission inventory available11.”

Austria 28 150 Please note that this was due to a criminal mismanagement of several thousand tons of sludge and waste materials. This should be clearly state

Noted but not included since there is a need for further clarification from the Party the general meaning of “criminal mismanagement”

Austria 29 162 Could you explain this term? Deleted sentence

Moreover no antifoam version is available and, therefore, these products can lead to oxyhydrogen explosions in the chrome baths.12

Austria 30 163 Canada is phasing out…

Deletion suggested because this information is already stated in para. 153

Deleted

Austria 30 165 Please rephrase and specify this statement. Please note that PFOS alternatives are in place for metal plating.

In the U.S.?

Revised to since there are alternatives to PFOS for hard and decorative metal plating. Reference inlcuded

“Blepp M. (2015) Berichterstattung an die Europäische Kommission nach Artikel 12 der EU-POP-Verordnung (EU-POP-VO). Umweltbundesamt Projektnummer [55 567]

Austria 30 167 This para. should be moved to para. 163 Accepted

Austria 30 171 Please note that the alternatives may be less persistent.

If alternatives are less bound to sludge than emissions to water may be higher but emissions to soil may be lower. Alternatives may be less persistent, so this statement without any reference needs to be modified. Please rephrase

Please note that this section should focus on human health and environmental effects data. This sentence may be better placed in a summary.

Rejected

Reference included

Danish Ministry of Environment, “Short-chain Polyfluoroalkyl Substances (PFAS).

A literature review of information on human health effects and environmental fate and effect aspects of short-chain PFAS” Environmental project No. 1707, 2015, http://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-15-5.pdf.

Austria 30 172 The frequent present…

Please provide a reference for this statement/para.

Deleted sentence The frequent present…

Austria 30 174 Please spell F-53B uniformly throughout the document.

Please note that the sentence deals with exposure, not effects (as indicated in the heading).

Included.

Deleted since this sentence is already included in appendix 3 concerning health and environmental information for F-53B.

11 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3217613/ 12 Communication with Lanxess.


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Source of Comment


Austria 31 175 Suggestions to combine the paras. dealing with “ the price of the chemicals” para 140 ff

Rejected since this para does not describe the price of chemicals.

Austria 31 185 Medical fabrics are not mentioned in Annex B. Please explain the relevance of this para. for this section

Deleted para 187 and included “Medical fabrics, such as woven or nonwoven surgical drapes and gowns” in para 274 that describes “Uses not exempted: carpets, leather and apparel, textiles and upholstery”

Austria 32 192 Could you please quote a reference for this statement?

Revised sentence from

. Shortly after the manufacturing phase out announcement by 3M of PFOS-based products in 2000, PFOS-based AFFFs were generally become more difficult to purchase no longer available in industrialized countries.”13

“Shortly after the manufacturing phase-out announcement by 3M of PFOS-based products in 2000, PFOS-based AFFFs were generally

Austria 32 193 …is currently under evaluation as a PBT (persistent, bioaccumulative, toxic) substance under REACH in Europe.14

Included

Austria 33 198 EES is not listed in the abbreviation section, please add.

Revised and included as European Economic Area (EEA)

Austria 33 200 “FFFC”,

Please add to the abbreviation section

Included.

“The Fire Fighting Foam Coalition (FFFC) “

Austria 34 201 perfluorohexane ethyl sulfonyl betaine

Could you please add CAS numbers (cf. previous section, alternatives were named with CAS no.).

There is currently no CAS no. available for this substance.

Austria 34 203 as Arctic Re-Healing Foam™ RF

Which alternative substance/class does this product contain?

Please add this information

Included reference

http://www.solbergfoam.com/Foam-Concentrates/ARCTIC-Foam.aspx but no specific substance information provided by Solberg and as mentioned in appendix 4 that this specific substance information is “trade secret”.

Austria 34 204 Suggestion to move this para to costs, para 212. Agreed.

Included as a new para under the head line “Cost effectiveness”.

Austria 35 206 Footnote 124

Could you please amend the paragraph with the requested information from the footnote

The specific identities of replacements or substitutes for PFOS, PFOS-related chemicals and mixtures have been claimed as CBI15 to the extent they have been disclosed to the U.S. government.

“However, chemical structures of major fluorosurfactants used in AFFF

13 UNEP/POPS/COP.7/INF/21. 14 http://echa.europa.eu/addressing-chemicals-of-concern/substances-of-potential-concern/pact/-/substance-rev/8834/term 15 There is no explanation from US to CBI in their contribution. US need to expain CBI.


7

Source of Comment


have been analyzed through an independent scientific study in 201516 Results from this study indicate that these substances and mixtures have included short-chain PFAS and various fluorinated telomers.

Revised footnote 158:

“There are replacements in US but they are not publically disclosed.”

Austria 35 207 Modification to “substances with a high global warming potential” suggested.

Agreed

Austria 35 210 Is there a reason why these fluorosurfactants were not assessed? If yes, please amend.

Deleted

Austria 36 212 Could you please provide a reference that describes the methodology of such a third party assessment?

Included as follows:

“The main contents of compressed air foam fire extinguishing technology in China are Class A foam extinguishing agents. In many countries, manufacturers usually provide Material Safety Data Sheet for commercially available Class A foam fire extinguishing agent products, which includes test data of health and environmental effects. However, a further assessment of health and environmental impacts for Class A foam extinguishing agents is scarcely done.”

Included reference.

UNEP-POPS-POPRC7FU-SUBM-PFOS-OpenApp-China-120302.En This is only described as a statement from China at POPRC7.

Austria 35 212 Could you please provide the information source for these statements?

Included reference:

UNEP-POPS-POPRC7FU-SUBM-PFOS-OpenApp-Norway_1-120131

Austria 36 220 “PFOS derivatives were used in pesticides because they were considered rather inert and non-toxic. “

This statement should be substantiated or deleted.

Included reference:

UNEP/POPS/COP.7/INF/21

Austria 37 226 Several mechanical, cultural, biological and chemical methods have been studied as early as the 50s for controlling leaf-cutting ants.

Deleted since this sentence is repeated in para 227

Austria 37 229 N-Ethyl perfluorooctane sulfonamide (known as sulfluramid or sulfuramid),

Deleted “ or sulfuramid”

Austria 39 238 “of grain”

Seed treatment?

Pesticide treatment of grain.

Austria 39 240 Please note that the content of this para. is already given in para. 225. Suggested deletion?

Deleted with the addition: “According to Brazil…” in para 225

Austria 39 241 Please note that the “release” should be replaced by “primary exposure”.

Included.

16 Will J. Backe, Thomas C. Day, and Jennifer A. Field*, Zwitterionic, Cationic, and Anionic Fluorinated Chemicals in Aqueous Film Forming Foam Formulations and Groundwater from U.S. Military Bases by Nonaqueous Large-Volume Injection HPLC-MS/MS; Environ. Sci. Technol., 2013, 47 (10), pp 5226–5234


8

Source of Comment


Austria 40 Human health

244

This is a very general statement and should be modified to reflect more the specific use/situation or please delete.

Rejected since this introduction reflects that there are threats to human health and environment from certain pesticides.

Austria 40 247 Please add the harmonized classification in the EU for Fipronil, Chlorpyrifos and PFOS (available at: http://echa.europa.eu/information-on-chemicals/cl-inventory-database?p_p_id=dissclinventory_WAR_dissclinventoryportlet&p_p_lifecycle=0&p_p_state=normal&p_p_mode=view&p_p_col_id=column-1&p_p_col_pos=1&p_p_col_count=2

Included reference:

http://echa.europa.eu/information-on-chemicals/cl-inventory-database?p_p_id=dissclinventory_WAR_dissclinventoryportlet&p_p_lifecycle=0&p_p_state=normal&p_p_mode=view&p_p_col_id=column-1&p_p_col_pos=1&p_p_col_count=2

Austria 40 254 This is a very general statement. Suggestions to add specific information (as in previous Chapters) or delete.

Rejected since this introduction reflects that there are threats to human health and environment from certain pesticides

Austria 42 266 Please insert additional information i.e. the importing region

Could you please provide a reference?

Included reference:

UNEP-POPS-POPRC7FU-SUBM-PFOS-OpenApp-US-120210.En and added “to the US according to information submitted in 2010.17 ”

Austria 42 Section K

Suggestions to shorten the following chapters (insertion of references) due to decision SC-7/1.

Noted.

Canada 35 210 Suggest deleting the sentence as it does not add useful information to this section.

Deleted

Brazil 37 227 Leaf-cutting ants have mechanical and chemical defenses that help them to counterbalance the effect of some control measures. Studying the adaptation mechanisms of leaf-cutting ants is recommended to improve effectiveness of strategies for their ecological management. Exocrine glands and symbiotic bacteria are the main sources of antimicrobials in leaf-cutting ants, and are used to counter biological control agents. Studying the adaptation mechanisms of leaf-cutting ants is recommended to improve effectiveness of strategies for their ecological management. However biological control can be effective under some conditions. In laboratory studies, the entomopathogenic Metarrhizium anisopliae can cause the decline and ultimate death of small colonies and recent research indicates that the entomopathogenic fungi Beauveria bassiana and Aspergillus ochraceus both show a high degree of control, causing 50% mortality within 4 to 5 days. Effective natural products include limonoids extracted from the roots of the South Brazilian endemic plant Raulinoa echinata. Further research is required to verify the effectiveness of these interventions under field conditions. Input from Brazil indicated that no effective biological control methods have been identified yet. Several mechanical, cultural, biological and chemical…

Justified by:

This information is not correct because in the original text of scientific articles” D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET

Rejected.

Since further research is required to verify the effectiveness of these interventions under field conditions is still needed which is already indicated in para 227.

17 UNEP-POPS-POPRC7FU-SUBM-PFOS-OpenApp-US-120210.En.


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Source of Comment


APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A:1003830625680” is clear in the abstract, page 51 and page 59 discussion, that the decline in mini-nests was not directly due to the action of the fungus Metarhizium anisopliae [original text, in the abstract, line 14: “However, the decline of these mini-nests after day 26 was not due directly to the pathogenic action of the Metarhizium, nor to the initial ant mortality it had caused”; original text, discussion, line 43:“Secondly, the mini-nest mortality was not due to the Metarhizium infecting and killing every individual in the population. Rather, it was the result of some process set in motion by the early Metarhizium epizootic. The decline of the mini-nests was not explained by the high initial ant mortality either”].

With respect to the scientific article: “Myriam M. R. Ribeiro,1 Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza,1 Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya,2 and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806”, we have several comments to be made:

Firstly the experiments conducted only in the laboratory were made with isolated ant colony, which is not recommended, because the "social control" is nonexistent. This kind of conclusion is completely disconnected from reality. [see text, page 2, item 2. Material and methods, “For each concentration, 50 worker ants received 1 μL of the suspensions on the pronotum. One μL of a 0.05% Tween 80 solution was applied to the control ants. This control group was used in the comparison with the two isolates since the experiments were conducted simultaneously. After receiving the treatments, the insects were held individually in Petri dishes supplied with a honey-water solution (1:1) and sterile distilled water renewed every two days. The mortality of the worker ants was daily monitored”];

Secondly, even in conditions already described, which are experimentally incorrect because the correct would make the use of spores of the fungus colonies of at least two years old, the mortality rate is very low, only 50%.[ in the abstract, “The two species were highly virulent, achieving 50 percent worker mortality within 4-5 days”];

Thirdly, the experimental conditions the mortality should be 100%, and the whole experiment in this way, so far, showed no viability in the field, so the discussion of these fungi for use in biological control has no sense.

With respect to Article:“ Maique W. Biavatti*, I; Rosângela Westerlon I; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical Society Print version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov./Dec. 2005”, in fact this study was not designed to test the efficacy of substances for control of ants. The work has as main


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Source of Comment


objective to present the isolation and identification of limonoids by the technique of x-ray diffraction. A survey of toxic activity on isolated workers (see page 1445, item “Atta sexdens bioassay”: Each treatment consisted of 50 ants distributed in 5 Petri dishes. The leaf-cutting ants were isolated from their nest and fed with an artificial diet. The ants from the treatment received a diet added with epoxy-fraxinellone or limonexic acid, at a concentration of 200 μg. The ants from the control treatment were fed with a diet without this compound is not feasible, because this technique is used for screening when you have dozens, hundreds of substances to be tried. We cannot infer on the efficiency of cutting ant control because after screening several additional experiments are needed to obtain any conclusion about control.

See references BRITTO, J. S.; FORTI, L. C.; OLIVEIRA, M. A.; ZANETTI, R.; WILCKEN, C. F.; ZANUNCIO, J. C.; LOECK, A. E.; CALDATO, N.; NAGAMOTO, N. S.; LEMES, P. G. and CAMARGO, R. S., 2016. Use of alternatives to PFOS, its salts and PFOSF for the control of leaf-cutting ants Atta and Acromyrmex, International Journal of Research in Environmental Studies (2016) 3(2): pp.11-92. p.55, 62.

Brazil 37 232 Suggestion of three paragraphs to be include at the document:

Mechanical control of leaf-cutting ants consist in excavating their nests for queen ant removal. Such a technique is no longer recommended for leaf-cutting colonies that are more than 4 months old, this is when the queen will be lodged at depths exceeding 1 meter, thus rendering the technique unviable due to the great effort required. In practice, mechanical control will be unviable in areas used for commercial plantations, in reforestation projects and grazing systems.

Cultural control has a conventional soil preparation by plowing and harrowing could mean the mortality of newly formed Atta nests, However, with the practice of minimum cultivation adopted in several cultivars and reforestation projects, such control has been abandoned. For adult Atta nests, the result could even be harmful, as soil mechanization could partially upset the anthill causing it to become temporarily inactive and giving the false impression of having been controlled.

Natural biological control, through predators: parasitoids and pathogenic microorganisms (fungi, bacteria and viruses), is of importance in regulating leaf-cutting ants but not to control in commercial plantations. Spiders, acarida, predating ants and beetles should also be mentioned. However, leaf-cutting ants has a complex biology, with a small number of progenies per female, such factors representing hindrances to control which causes low or none efficiency under field conditions

See references: BRITTO, J. S.; FORTI, L. C.; OLIVEIRA, M. A.; ZANETTI, R.; WILCKEN, C. F.; ZANUNCIO, J. C.; LOECK, A. E.; CALDATO, N.; NAGAMOTO, N. S.; LEMES, P. G. and CAMARGO, R. S., 2016. Use of alternatives to PFOS, its salts and PFOSF for the control of leaf-cutting ants Atta and Acromyrmex, International Journal of Research in Environmental Studies (2016)

Included only reference

BRITTO, J. S.; FORTI, L. C.; OLIVEIRA, M. A.; ZANETTI, R.; WILCKEN, C. F.; ZANUNCIO, J. C.; LOECK, A. E.; CALDATO, N.; NAGAMOTO, N. S.; LEMES, P. G. and CAMARGO, R. S., 2016. Use of alternatives to PFOS, its salts and PFOSF for the control of leaf-cutting ants Atta and Acromyrmex, International Journal of Research in Environmental Studies (2016) 3(2): pp.11-92. p.51, 68.


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3(2): pp.11-92. p.51, 68.

Brazil 38 234 However biological control can be effective. The entomopathogenic Metarrhizium anisopliae can cause the decline and ultimate death of small colonies and recent research indicates that the entomopathogenic fungi Beauveria bassiana and Aspergillus ochraceus both show a high degree of control, causing 50% mortality within 4-5 days.

Justified by: The three studies presented by (D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A:1003830625680. ) (Myriam M. R. Ribeiro, Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza, Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya, and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806. Maique W. Biavatti, I; Rosângela WesterlonI; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical SocietyPrint version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov./Dec. 2005, those studies do not conclude the information made in this guide. See paragraph 227, besides it was not referenced that these studies are in laboratory conditions and there is a need to research in field to conclude the effectiveness of these products.


Rejected, see revised para 233

Brazil 38 235 Effective natural products include limonoids extracted from the roots of the South Brazilian endemic plant Raulinoa echinata.

References see above.

Rejected, see revised para 233

Brazil 38 226 Suggestion to change paragraph to :

Fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon, boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective.

Justified by: update from the Report sent by Brazil and presented at COP-7 (UNEP-POPS-COP.7-INF-

Included

“Additionally according to Brazil, fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon, boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective18.”

18 UNEP/POPS/COP.7/INF/11.


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Source of Comment


11.English.pdf) p. 22.

Brazil 38 240 The non-conventional are Entomopathogenic fungi are a) organic bait consisting of rice grains with Beauveria sp. b) Diatomaceous earth mixed with waste water in the principal entry of each anthill c) Vegetal substances with insecticide effect: extract of eucalyptus, castor-oil plant and “Palo Amargo” (“Bitter stick”, Aeschirium crenata Vell. Simaroubaceae) d) Natural enemies: parasitoids known as “Moscas descapitadotas” (“Decapitating flies”, Diptera: Phoridae) (and e) organic baits based on yeast and rice. All these alternatives have been tested in Argentina with promising results

Justified by: These products do not have efficiency and technical feasibility according to references below.

Organic baits based on rice and beer yeast

Contrary to what was asserted here, the rice and beer yeast baits were not the best treatment, as may be ascertained from BORGETTO (2009) 's text. This same author concludes that sufluramida was the most effective treatment. Such results were are confirmed by COLL (2003). He textually concludes “para el control de hormigas cortadoras pertencentes al gênero Acromyrmex, el inseticida (sulfluramida) fue más eficiente” = for controlling the leaf-cutting ants of the Acromyrmex kind, the insecticide (sulfluramida) was more effective. (page 40). As to the rice, CARRERE (2006) concluded that the rice merely prevented the ants' continuing to cut the plants, and had not the effect desired of killing the fungus garden.


Diatom earth

On the Argentine document, the publication date is incorrect; it is not 2012 but rather 2010. First, the research performed in RIOS DE SALUSO (2010): “Manejo de las hormigas cortadoras de hoja em los principales sistemas agropecuários y forestales de la província de Entre Ríos” (Handling of leaf-cutting ants in the main forest, agriculture and cattle-raising systems of the Entre Rios province), points out and concludes that sulfluramidand fipronil, in toxic bait, were the most effective products for controlling Acromyrmex lundi in agricultural systems. It the small discussion of its abstract, it points out that the treatment with diatom earth and fipronil on complete atomization ranked third in effectiveness. We emphasize that there were only four treatments and the witness.

We consider that a product, ranking third for controlling Acromyrmex lundi nests that have only one fungus chamber and are located in the top 30 cm of the ground (GRANGI et al , 2000), is not encouraging. Would it then be encouraging for controlling Atta nests with up to 8,000 chambers

Not revised.

Para 240 are based on comments from Argentina with promising results.

Included reference:



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(MOREIRA et al, 2004a; MOREIRA et al 2004b).

Diatom earth was already tried in Brazil, as candidate for controlling Atta sexdens rubropilosa nests, and the result was the following: "The product based on silica dioxide (Diatom earth), in both dosages tested, has shown inefficient for controlling Atta sexdens rubropilosa settlements, under operating conditions" (VeracelTM - Technical Report).

See references BRITTO, J. S.; FORTI, L. C.; OLIVEIRA, M. A.; ZANETTI, R.; WILCKEN, C. F.; ZANUNCIO, J. C.; LOECK, A. E.; CALDATO, N.; NAGAMOTO, N. S.; LEMES, P. G. and CAMARGO, R. S., 2016. Use of alternatives to PFOS, its salts and PFOSF for the control of leaf-cutting ants Atta and Acromyrmex, International Journal of Research in Environmental Studies (2016) 3(2): pp.11-92. p.48.

Natural enemies: parasites known as phoridae (Diptera, Phoridae)

The work deals with life history (biology) and percentage of parasitism. The work discussion involves potential candidates for a future biological control program. In our opinion, this type of control might not obtain successful control. We must consider that the species studied (4 species) are "candidates for integrating the assemblage of biocontrolagents against Atta vollenweideri”; as written in the article published on the periodical “Journal Economic Entomology 104 (1): 32-40.2011

See references BRITTO, J. S.; FORTI, L. C.; OLIVEIRA, M. A.; ZANETTI, R.; WILCKEN, C. F.; ZANUNCIO, J. C.; LOECK, A. E.; CALDATO, N.; NAGAMOTO, N. S.; LEMES, P. G. and CAMARGO, R. S., 2016. Use of alternatives to PFOS, its salts and PFOSF for the control of leaf-cutting ants Atta and Acromyrmex, International Journal of Research in Environmental Studies (2016) 3(2): pp.11-92. p.68-69.

Entomopathogenic fungi

Until this time, the use of entomopathogenic fungus for controlling leaf-cutting ants has produced no encouraging result, even for the Acromyrmex species having smaller nests. The difficulties in being successful on using entomopathogenic fungi, under field conditions, might be related to the defense strategies of the leaf-cutting ants' settlements, along with its mutualist fungus and the associated microbiota, against parasites and pathogens, of morphological, mechanical and biochemical nature (BOARETTO & FORTI, 1997). According to KERMARREC et al., (1986), the extraordinary resistance of the leaf-cutting ants' mutualist fungi to the epizootic and epiphytic diseases is due to many factors related to the nests' internal hygienic. Attempts for using baits with Beauveria bassiana and Metharrizium anisopliae, under field conditions, with Acromyrmex nests, was not encouraging, since, in this case, the worker ants disinfected, pruned and isolated the fungus culture and, in more severe instances, the ants abandoned the nest.

Certainly, biological control, including with entomopathogenic fungi, is a promising research area, however, it is currently clear the need for basic


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biological knowledge, in order that control strategies for leaf-cutting ants might actually be applied.


Brazil 39 244 Change para to:

Fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon, boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective.

Justified by: update from the Report sent by Brazil and presented at COP-7 (UNEP-POPS-COP.7-INF-11.English.pdf) p. 22.

Included

“According to Brazil, fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon, boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective19.”

See also para 226

Brazil 39 245 Pesticide resistance is a genetically based phenomenon. Resistance can occur when a pest population is exposed to a pesticide and not all insects are killed. Those individuals that survive frequently have done so because they are genetically predisposed to be resistant to the pesticide. The resistance to insecticides does not apply to leaf-cutting ants. In this case, the target of insecticides is the workers who are sterile, thus not allowing the selection of resistant individuals.

Justified by: Follow attached to this document, the report with references.

Included

“The resistance to insecticides does not apply to leaf-cutting ants. In this case, the target of insecticides is the workers who are sterile, thus not allowing the selection of resistant individuals”.

Included reference:

PFOS_Brazil DOCUMENTO REVISÃO DE LITERATURA FINALIZADO INGLES 18 01 2016.pdf

Brazil 89 App. 2 Exclude: Hydramethylnon

Justified by: The active ingredient Hydramethylnon is registered and commercialized in the USA against fire ants (Solenopsis spp.). Also in the USA, it is registered to Atta Texas, for which it has been ineffective. In accordance to the Forest Service Texas, with the bait with the active ingredient hydrametlylnon presents efficiency of only 30% and there is a need of more than one application, especially for large colonies. Another disadvantage is that this insect bait should not be stored for long periods of time, due to its relatively short life time.

Studies were conducted in Brazil to evaluate the potential of such active ingredient in the control of leaf-cutting ants of Atta genus. The results were even more inconsistent, despite the use of high concentrations of this active ingredient in the formulation and higher dosages. Hydramethylnon also has shown not to be efficient to control other ants, just as the leaf-cutting ants’ case. The lack of further research using hydramethylnon in the control of leaf-cutting ants may be to the fact that such active

Rejected

Since it is used as an alternative to sulfluramid effective or not.

Included reference in para 237.

http://landscapeipm.tamu.edu/files/2012/09/AmdroAntBlockLeafcutting_fnl.pdf

19 UNEP/POPS/COP.7/INF/11.


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Source of Comment


ingredient present fast degradation in the presence of light, and this property is considered undesirable for insect baits for leaf-cutting ants used in tropical and subtropical conditions.

Spite of being an insecticide known for more than 30 years, it was neither registered nor has been currently used in Brazil for the control of leaf-cutting ants, certainly because of the proven inefficiency.


Brazil 90,

101

App. 2 Exclude: Non-chemical

Justified by: The three studies presented by (D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A: 1003830625680.) (Myriam M. R. Ribeiro, Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza, Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya, and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806. Maique W. Biavatti, I; Rosângela WesterlonI; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical SocietyPrint version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov./Dec. 2005, those studies do not conclude the information made in this guide. See paragraph 227, besides it was not referenced that these studies are in laboratory conditions and there is a need to research in field to conclude the effectiveness of these products.


Rejected

Since it is used as an alternative to sulfluramid effective or not.

Brazil 102 App. 2 Change: Fenitrothion as insect bait for Thermonebulizable solutions (thermal fogging)

Justified by: to be consistent with the Appendix 2.

Already included in appendix 3.

Brazil 102 App. 2 Change: Deltamethrin as insect bait for Dried Powder Formulations

Justified by: to be consistent with the Appendix 2.

Revised in appendix 3

“Deltamethrin as insect bait exclusively formulated in dried powder formulations”


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Brazil 104 App. 3 Exclude the others pesticides because it does not concern about leaf-cutting ants. Leaving only Fipronil, Deltamethrin and Fenitrothion to be the same as Appendix 2.

Revised to be consistent with appendix 3 and related paras in the main text.

Canada 44 289 Suggest rewording sentence for clarity:

The starting material for the manufacture of polydimethylsiloxanes (PDMS) is dimethyldichlorosilane derived from either the manufacturing of either cyclic or linear siloxanes intermediates.

Revised as suggested

Canada 60 Section 3

As written, this section leads the reader to believe that conclusions have been reached by POPRC for siloxanes when it hasn’t. Caution should be used in referencing Annex D conclusions. Guidance should only refer to substances for which a conclusion has been reached by the Stockholm Convention.

Please refer to statement in paragraphs:

399 a) ii)- vi)

399 b) i)-vi)

399 c) i)-vi)

399 d) i)-vi)

399 e) i)vi)

Rejected since these are conclusions from UNEP/POPS/POPRC.10/INF/7/Rev.1, UNEP/POPS/POPRC.10/INF/8/Rev.1.that are adopted by POPRC.

Canada 93,95 App. 2 Please ensure that siloxanes are not identified as alternatives to PFOS, but rather are used as manufacturing intermediates in the production of PDMS. If the asterisk was intended to convey this message, please provide a definition for the asterisk below the table.

Included asterisk.

Canada 108 App. 3 Please ensure that siloxanes are not identified as alternatives to PFOS, but rather are used as manufacturing intermediates in the production of PDMS.

Included footnote:

“Manufacturing intermediates in the production of PDMS” for clarification

Canada 108 - 109

App. 3 As written, this sentence leads the reader to believe that this conclusion has been reached by POPRC when it hasn’t. Caution should be used in referencing Annex D conclusions. Guidance should only refer to substances for wich a conclusion has been reached by the Stockholm Convention. This is not the case for D4 and D5.

Rejected since these are conclusions from UNEP/POPS/POPRC.10/INF/7/Rev.1, UNEP/POPS/POPRC.10/INF/8/Rev.1.that are adopted by POPRC

Canada 109, 114

App. 3 Consider rephrasing for accuracy and clarity:

The Government of Canada’s screening assessment1 finds that MDM meets the criteria for persistence and bioaccumulation potential as set out in the Persistence and Bioaccumulation Regulations, Empirical and modelled bioconcentration factors in excess of 5000 indicate that MDM also meets the criterion for bioaccumulation potential as set out in the Persistence and Bioaccumulation Regulations

Deleted

Canada 121,122

App. 4 Please ensure that siloxanes are not identified as alternatives to PFOS, but rather are used as manufacturing intermediates in the production of PDMS.

Included footnote:

“Manufacturing intermediates in the production of PDMS” for clarification

Canada 125 App. 5 Please ensure that siloxanes are not identified as alternatives to PFOS, but rather are used as manufacturing intermediates in the production of PDMS.

Included footnote:

“Siloxanes both cyclic and linear are manufacturing intermediates in the production of PDMS”


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Denmark 48 323 The link to the reference is no longer active. Use this: http://mst.dk/75866

Revised as suggested.

Denmark 59 393 The polyfluoroalkyl siloxane was banned in Denmark because of lung damage in experimental mice.20

Deleted

European Union (EU)

17 68 Revise this para as follows.

Sweden reported the estimated use of PFOS in aviation hydraulic fluids as 10 kg/year prior to 2013 as an alternative with another PFAS has been phased in by the supplier. Sweden has an ongoing use of PFOS in hard metal plating. The estimated use was 200 kg/year prior to 2010, approximately 180 kg/year in the period 2011-2013 and from 2014 reduced to 30 kg/year.

Revised

EU 51 Health effects of shorter-chain perfluoroalkyl sulfonates

It would be necessary to balance the assessment on different substitutes. Now, e.g. PFHxS is not assessed against the POP-criteria whereas the siloxanes are. Please, explain the differences for these differences somehow.

Rejected.

PFHxS and other perfluorinated acids are transformation products. Although consideration of transformation products may be relevant for the assessment of some alternatives to

PFOS, their inclusion is outside of the mandate and scope of the current assessment which is intended to be a rapid

screening of alternatives and not an extensive analysis of all possible degradation products of those alternatives.

See reference UNEP/POPS/POPRC.10/INF/7/Rev.1

EU 51 334 “..and PFHxS (C6)”

It would be important in this connection to discuss the persistent and bioaccumulative properties of PFHxS. For PFHxS there are data available on very long elimination half-lives in humans (longer than for, e.g. PFOA, which is considered “bioaccumulative” under REACH).

Rejected.

PFHxS and other perfluorinated acids are transformation products. Although consideration of transformation products may be relevant for the assessment of some alternatives to

PFOS, their inclusion is outside of the mandate and scope of the current assessment which is intended to be a rapid screening of alternatives and not an extensive analysis of all possible degradation products of those alternatives.

See reference UNEP/POPS/POPRC.10/INF/7/Rev.1. However characteristics of e.g. PFHxS is mentioned in appendix 3,

EU 59 388 “Per- and polyfluorinated polyether silanes are used as surface treatments, e.g. for stones or Perfluoroalkyl derivatives of silanes also exist; they include 1H,1H,2H,2H-perfluoroalkyl triethoxysilane, which is effective for glass, stone and surface trea®ent21 and

Deleted as suggested.

20 Nørgaard AW, LarsenST, Hammer M, Poulsen SS, Jensen KA, Nielsen GD, Wolkoff P. 2010. Lung damage in mice after inhalation of nanofilm spray products: the role of perfluorination and free hydroxyl groups. Toxicological Sciences 116 (1): 216–224. 21 ABCR 2006–2007 catalogue: Fluorochemicals. Karlsruhe, Germany.


18

Source of Comment


additionally as antibiofouling agents for ships22. 23. One compound, polyfluorooctyl triethoxysilane (1H,1H,2H,2H-perfluorooctyl triethoxysilane), has been banned in Denmark. The formula is…”

EU 61 397 “The EU ECHA’s PBT Working Group concluded, based on the available information that D4 meets the Annex XIII criteria for both a ‘persistent, bioaccumulative and toxic’ (PBT) and both D4 and D5 as ‘very persistent and very bioaccumulative’ (vPvB) substances in the environment . Although the T criteria in Annex XIII of REACH are not met for D5, there are some uncertainties relating to the limited publically available data on mammalian, avian and fish reproductive effects, and toxicity has been observed in sediment and soil organisms.24”

Please, remove this as point of reference and add reference to RAC opinion and MSC opinion on D4 and D5

RAC opinion: http://echa.europa.eu/documents/10162/18ea3a03-0da4-4a8d-a522-5b467c3a9307

MSC opinion:

http://echa.europa.eu/about-us/who-we-are/member-state-committee/opinions-of-the-msc-adopted-under-specific-echa-s-executive-director-requests


Included references.

EU 63 399 c (iii)

It should be noted that the available information on bioaccumulation (both experimental data and field studies) is currently subject of in-depth assessment by UK. Due to the deficiency of the earlier experimental tests or their reporting study reports have been acquired. For ECHA it is premature to make judgement on bioaccumulation potential based on the presented BCF-values only.

This substance belongs to screening category 3.

Noted but suggested change to category 3 is rejected since assessments constantly may change with time.

EU 73 437

Class 4 table

Dodecamethyl cyclohexasiloxane (D6)*

Belongs rather to class 3

Noted but suggested change to category 3 is rejected since assessments constantly may change with time

EU 73 437

Class 4 table

Hexamethyl disiloxane (MM or HMDS)*

Undergoing Substance Evaluation by the UK.Decision includes information relevant for PBT/vPvB assessment under REACH

Noted and included in appendix 3.

“Hexamethyl disiloxane (MM or HMDS) is undergoing Substance Evaluation by the UK.Decision includes information relevant for PBT/vPvB assessment under REACH”

EU 73 437

Class 4 table

Octamethyl trisiloxane (MDM)*

On the CoRAP for Substance Evaluation (UK) due to PBT/vPvB concerns



EU 73 437

Class 4

Decamethyl tetrasiloxane (MD2M)*

On the CoRAP for Substance Evaluation (UK) due to


On the CoRAP for Substance

22 Posner et.al, “Per- and polyfluorinated substances in the Nordic Countries, Use, occurrence and toxicology”, TemaNord 2013:542, ISBN 978-92-893-2562-2, (2013), http://norden.diva-portal.org/smash/get/diva2:701876/FULLTEXT01.pdf. 23 Posner et.al, “Per- and polyfluorinated substances in the Nordic Countries, Use, occurrence and toxicology”, TemaNord 2013:542, ISBN 978-92-893-2562-2, (2013), http://norden.diva-portal.org/smash/get/diva2:701876/FULLTEXT01.pdf. 24 UNEP/POPS/POPRC.10/INF/8/Rev.1.


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Source of Comment


table PBT/vPvB concerns Evaluation (UK) due to PBT/vPvB concerns

EU 73 437

Class 4 table

Dodecamethyl pentasiloxane (MD3M)*




EU 73 437

Class 4 table

1-Isopropyl-2-phenyl-benzene




EU 73 437

Class 4 table

Diisoproplynaftalene (DIPN)

Undergoing Substance Evaluation (SE) due to PBT/vPvB concerns.


Diisoproplynaftalene (DIPN) is undergoing Substance Evaluation (SE) due to PBT/vPvB concerns.

EU 73 437

Class 4 table

Pesticides (eight substances)

All substances except Fipronil and Hydranethyllnon are approved for biocidal use in EU

Included as new para 254 under chapter “Availability, accessibility and socio economic consideration”

EU 73 437

Class 4 table

“Fenitrothion“

Not approved in the EU: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:141:0076:0077:EN:PDF

Included in appendix 3.

“Fenitrothion is banned in the EU since 200725”

EU 77 Labeling considerations

Labeling and information considerations Included.

EU 77 467 “A number of useful documents that address the question of how to communicate information on chemicals in products and articles to protect human health and the environment have been developed for the Chemicals in Products with activities project led by the United Nations Environment Programme (UNEP). The Chemicals in Products Programme (CiP Programme) is the product of seven years of research and stakeholder consultations and was in September 2015 welcomed by the Strategic Approach to International Chemicals Management (SAICM)Governing body, ICCM4. The finalized Chemicals in Products Programme and the accompanying Programme Guidance can be found on UNEPs web page26

The Chemicals in Products Programme is a voluntary initiative designed to assist all stakeholders throughout the product life cycle who are seeking effective procedures for the exchange of information on chemicals in products. Stakeholders include businesses, governments, intergovernmental agencies, recyclers, waste management actors, non-governmental organizations and consumer groups. The programme document explains the objectives of the Programme’s information exchange system and describes the roles and suggested responsibilities of stakeholders in respect of the exchange of chemicals in products information throughout the product life

Revised as below

“A number of useful documents that address the question of how to communicate information on chemicals in products and articles to protect human health and the environment have been developed for the Chemicals in Products project led by the United Nations Environment Programme (UNEP) in support of the corresponding Strategic Approach to International Chemicals Management (SAICM) Governing body, ICCM4. The finalized Chemicals in Products Programme and the accompanying Programme Guidance can be found on UNEPs web page27”

25 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:141:0076:0077:EN:PDF 26 http://www.unep.org/hazardoussubstances/UNEPsWork/ChemicalsinProductsproject/tabid/56141/ Default.aspx. 27 http://www.unep.org/hazardoussubstances/UNEPsWork/ChemicalsinProductsproject/tabid/56141/ Default.aspx.


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cycle.

The Guidance for stakeholders on exchanging chemicals in products information has been created to support the Chemicals in Products Programme. It is intended to guide those who are designing a chemicals in products information system or those seeking to participate in an existing system. It is also aimed at guiding stakeholders who require assistance in exchanging information on their chemicals in products by describing the steps that are commonly taken in scoping, designing and building information exchange systems on chemicals in products. “

EU 138 App. 8 Sweden: Partially fluorinated alternatives (fluorotelomers) have shown sufficient properties. A survey in 2013 revealed that the industry would benefit from clarified requirements of "closed loop systems" with regards to PFOS need to be clarified - see comment below.

No revision since the current text tells the same story as the suggested revision.

EU 139 App. 8 Suggested text:

“Sweden: Import of PFOS-containing fire-fighting foam ended in 2003. Surveys of the chemical content of selected FFFs on the market and the use in Sweden of fire fighting foams containing PFCs, have been made, (Swedish Chemicals Agency PM 5/15, PM 6/15 and PM 1/16).”

Revised

Ongoing have been made

Indonesia General (1) Necessary to assure that alternatives available on the market are not POPs and are not listed as hazardous chemicals which have been listed in international Conventions.

(2) Necessary to add HS code or CAS no of the alternatives in order for Parties for easily identifying the uses of such alternatives.

(1) That’s why UNEP/POPS/POPRC.10/INF/7/Rev.1 and UNEP/POPS/POPRC.10/INF/8/Rev.1, according to decision POPRC-10/4 where written as an initial source of information to avoid alternatives that may be potential POPs.

(2) Included where available.

Japan 43,45 282,301 Asahi Glass

Correct the company name.

Included

Japan 56 379 Commercial products of polysiloxanes that are alternatives to PFOS for certain coating and water repellent applications. They are primarily used as intermediates in manufacturing high molecular weight silicone polymers,

This is not correct and redundant.

(1) Some silicone polymer products can be the alternatives to PFOS, but not their building blocks (poly siloxanes such as D4 and D5). It is explained in Para 380.

(2) Information of the use as intermediates is already explained in Para 377.

Revised as suggested

Japan 59 391 Environment Canada concluded that D4 is not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health. meets the legal definition of toxic

It seems that this sentence refers to Screening Assessment by Environment Canada (See below). In that screening document, they conclude that “octamethylcyclotetrasiloxane is not entering the environment in a quantity or concentration or under

Revised as follows:

Environment Canada concluded in 2008 that D4 is not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health but also concluded in a screening assessment report that D4 may be entering the environment in a quantity or


21

Source of Comment


conditions that constitute or may constitute a danger in Canada to human life or health“. This should be quoted from the reference precisely.

Add the reference: http://www.ec.gc.ca/ese-ees/default.asp?lang=En&n=2481B508-1

concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity. Based on the conclusions of the assessment, a Final Order adding D4 is added the List of Toxic Substances in Schedule 1 under the Canadian Environmental Protection Act, 1999(CEPA 1999) was published in Part II of the Canada Gazette on February 16, 201128

Japan 62 399 d, iv

The half-life of D4 in the atmosphere is reported to be from 12.7 to 15.8 days. Therefore D4 is therefore considered likely to fulfill the Annex D 1 (d) (iii) criteria;

Redundant.

This paragraph should be deleted if evidences or references are not added to this document. Also, in para 394, there is a description that some studies conclude that siloxanes are unlikely to meet the POP screening criteria for long range transport.

Rejected since this conclusion is based on a series of modelling data of half-life in air that exceeds 2 days.

Noted but not deleted since this may change over time.

Tanzania General General comments:

PFOS is one of the recently listed POPs, whose life-cycle management is complex due to the wide variety of uses, and the fact that there is need for management of both the chemical and its salts, the articles which contain PFOS and any waste streams.

The CGD is useful in that it includes the aspects of properties, production and use, products in waste streams and recommended management/ destruction options and thereafter analyses the various efforts made in identifying alternatives in the various use areas, which include photo- imaging, semiconductors, Aviation Hydraulic Fluids, Metal Plating, Certain medical devices, Fire Fighting Foams, Insecticides, some color printers and copy machines, chemically driven oil production, carpets, leather and apparel, textiles and upholstery, paper and packaging, coatings and coating additives, rubbers and plastics.

The CGD meets the objectives and is a useful document in that it provides information on health and environmental effects. It also provides information on evaluation and prioritization of the available alternatives by using criteria in Annex D of the Stockholm Convention, to ensure that the alternatives do not exhibit POP - characteristics.

Noting: the hazardous properties of PFOS which led to inclusion in the POPs list, and the complexity of the life-cycle management of PFOS:

The work done by the POPRC, Secretariat and all parties/ sources in providing comprehensive, currently available information on PFOS & salts, and possible alternatives is commended;

2.1 We note that the CGD mainly focuses on PFOS and related chemicals, it also provides information and leads to guidance on products in waste streams

The expressed concerns about incentives towards improved information, labelling and need for more public data and information on alternatives should be further discussed at POPRC12 to strengthen the management capacity of alternatives and phase out of PFOS.

28 https://www.ec.gc.ca/toxiques-toxics/default.asp?lang=En&n=98E80CC6-1&xml=71D7177A-0334-4668-9579-1508F6D55ABD.


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Source of Comment


likely to contain PFOS & related substances, and directs the user to appropriate guidance for BAT/BEP.

Tanzania is yet to conduct a comprehensive PFOS inventory, however the preliminary inventory of 2014- 15 indicates that PFOS may be in the Country mainly in articles and products such as Fire Fighting Foams, Aviation Hydraulic Fluids, synthetic carpets and others. There is therefore, need for diligence in management of the whole life cycle of such goods, including the waste streams.

2.2 We note the provided Guidance, and are committed to managing these substances to minimize risks to health and to the environment.

Finally, all the CGD recommendations are noted and supported

We specifically underline the following:

3.1 The need for incentives towards improved information on safer alternatives, including development of safe, affordable and technically feasible ones;

3.2 Consideration of labeling: whereby in line with the requirement of the SC, parties that shall register for continuing production and use of PFOS, to ensure that such products are identifiable throughout their life- cycles.

Implementation of this requirement shall greatly address the challenge of identification of products containing PFOS, and therefore their management and control especially in developing countries.

We are pleased to inform that Tanzania has already incorporated the principles of GHS in Regulations on Industrial and Consumer Chemicals (2015), and plans to implement GHS for this category of chemicals by 2017.

3.3 Need for more public data and information on alternatives

It is noted with concern, that there is very limited data on alternatives to PFOS, and so we support/ increasing efforts to study and make publicly available the toxicological and environmental effects of possible alternatives, with the private sector bearing key responsibility.

3.4 Need for international cooperation

We support more international cooperation and transparency in the private sector to save resources and speed up the processes of identifying alternatives including conducting Risk Assessments.

The Government is currently enforcing the Industrial & Consumer Chemicals (Management & Control) Act No.3 of 2003 and shall:

(1) Continue to strengthen control and management of Industrial & Consumer Chemicals through registration, inspection and import/export permits, and management chemical wastes, with knowledge and awareness raising efforts

(2) Propose strengthening of current legislation to include chemicals in articles, to facilitate National efforts to meet obligations to the


23

Source of Comment


Stockholm Convention.

United Kingdom of Great Britain and Northern Ireland (UK)

56 Section H

The siloxane monomers mentioned may be present in polymers as impurities, but their emission from the polymers is not quantified. They might reside in the polymer until disposal, or leach/evaporate to a greater or lesser extent, which may depend on the polymer type and specific applications. This does not seem to be discussed anywhere. There is also a possibility that the monomers may be re-formed during use (e.g. silicone oils need to be replaced due to thermal degradation that unzips the polymer). This is not considered in the document.

Noted.

The issue concerning impurities of the manufacturing intermediates VCM is discussed in para 381.

There are references needed to consider re-formed VCM during use from silicon oils that 1) are alternatives to certain uses of PFOS and 2) that clearly demonstrate from a scientific perspective that this really occur, before inclusion in the text.

UK 60 397 The reference to the PBT Expert Group conclusion for D4 and D5 is obsolete. This section should refer to the ECHA Member State Committee Opinion (which dealt with P and B properties) http://echa.europa.eu/documents/10162/13641/art77-3c_msc_opinion_on_d4_and_d5_20150422_en.pdf and the ECHA Risk Assessment Committee opinion (which dealt with toxicity) http://echa.europa.eu/documents/10162/13641/rac_opinion_ec_209-136-7.pdf.

Included in para 398,see comment EU

UK 60-63 The UK is evaluating the environmental properties of both cyclic and linear siloxanes under REACH:

D6 discussion: The UK is performing a PBT assessment for D6. It is currently considered very persistent and bioaccumulative in a REACH context. However, we are aware of a Japanese bioaccumulation study that suggests that it might meet the “very bioaccumulative” criterion (5000 L/kg). The UK requires some additional supplemental information before reaching a conclusion, but it is misleading to say that the BCF is below 2500. The UK is happy to provide more information on this if required.

D4 discussion (see also pararaph 437 on page 70): We agree that D4 has PBT properties. However, the deposition potential in remote environments is not discussed. In our view, the available evidence suggests that although it may be present in the air, it is unlikely to be deposited in significant amounts to surface media, so that wildlife exposure is likely to be very low. In other words, long range transport potential needs to consider deposition.

The linear siloxanes L2 (MM), L3 (MDM), L4 (MD2M) and L5 (MD3M) are on the Community Rolling Action Plan for Substance Evaluation by the UK. We are requesting various tests to clarify their PBT properties, although the data will not be available for a couple of years.

The UK will also be reviewing a couple of branched linear siloxanes in 2017/8.

Noted and included in appendix 3:

“The UK is performing a PBT assessment for D6. It is currently considered very persistent and bioaccumulative in a REACH context”

Since assessments constantly may change with time.

Noted but not included for D4, since assessments constantly may change with time.


Noted but not included since this may change over time.

UK 76 465 The socio-economic and practical consequences of labelling articles and polymers needs to be considered carefully, as well as the legal mechanisms that could be used. Whilst it might be useful for a recycler to know if a material contains a POP, there may be other situations where a POP is present above a de minimis limit but doesn’t volatilise or leach. If , for example, such a product was not intended to be recycled, would it need a label? Also, if you have a complex

Suggest that the issue on labelling is further discussed at POPRC12.


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Source of Comment


article containing a variety of components containing a POP, do they all need to be labelled? What happens if the component is very small?

United States of America (USA)

13 42 “Many of those PFOS-related chemicals are not mentioned in Annex B but are covered by the listing of PFOSF”

Are those substances covered but not listed all produced with PFOSF as a starting or intermediate material? If so, this should be more explicit.

Included

“Since PFOSF is the parent precursor to all PFOS related substances, therefore the present…

USA 17 61 Does these 1730 tons in product include fluorotelomers or unreacted PFOS only?

Included.

“...perfluorooctane sulfonate and derivatives (PFOS) and not only unreacted PFOS29”

USA 35 208 “Dodecafluoro-2-methylpentan-3-one would generally not be considered a viable alternative to PFOS AFFF, since it is used as a fire protection fluid30.”

It’s not clear whether this is to replace PFOS in a small number of fire fighting formulations or whether to replace a small quantity of PFOS within a formulation.

Reason for non viability and/or citation?

According to FFFC “The 3M chemical mentioned in (ii) is an HFC alternative for clean agent systems and is not used in fire fighting foam.” See FFFCPOPscomments1-16 (January 2016).

This is further explained in current para 203.

USA 36 222 Existing stocks of sufluramid-containing pesticide products were allowed to be sold until 2012

Included

“Existing stocks of sufluramid-containing pesticide products were allowed to be sold in US until 2012”

USA 40 247 Is the implication that there is no insect resistance to PFOS?

Correct. This is further explained in para 246

USA 40 257 Please add a reference for this statement. It appears to be a direct quote from the following article:

Steven M. Valles, “Positive-Strand RNA Viruses Infecting the Red Imported Fire Ant, Solenopsis invicta,”Psyche, vol. 2012, Article ID 821591, 14 pages, 2012. doi:10.1155/2012/821591

Included.

USA 43 279 The U.S. revoked approval of three perfluorofinated substances/substace categories for use in Food Contact Materials effective January 4, 2016 to include: Diethanolamine salts of mono- and bis (1 H, 1 H, 2 H, 2 H perfluoroalkyl) phosphates where the alkyl group is even-numbered in the range C8-C18 and the salts have a fluorine content of 52.4 percent to 54.4 percent as determined on a solids basis; Pentanoic acid, 4,4-bis [(gamma-omega-perfluoro-C8-20-alkyl)thio] derivatives, compounds with diethanolamine (CAS Reg. No. 71608-61-2); and 3. Perfluoroalkyl substituted phosphate ester acids, ammonium salts formed by the reaction of 2,2-bis[([gamma], [omega]-perfluoro C4-20 alkylthio) methyl]-1,3-propanediol, polyphosphoric acid and ammonium hydroxide.

https://www.federalregister.gov/articles/2016/01/04/2015-33026/indirect-food-additives-paper-and-paperboard-components

Included in para 305

29 Email communication with Dr. Juergen Helbig European Union OCP & NFP Stockholm Convention. 30 http://multimedia.3m.com/mws/media/124688O/3mtm-novectm-1230-fire-protection-fluid.pdf.


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Source of Comment


USA 53 348 polyfluorodialkyl ether sulfonates are outside the domain of applicability of EPI Suite models for the purposes of estimating persistence and bioaccumulation.

Included

“Polyfluorodialkyl ether sulfonates are outside the domain of applicability of EPI Suite models for the purposes of estimating persistence and bioaccumulation.” in para 376

USA 60 399 For reasons elaborated on in comments to paragraph 434, please avoid definitively statements indicating that a substance fulfils or meets Annex D criteria. If the Annex D metric for alternatives is retained, which we would strongly prefer it not be, please replace definitive statements that something fulfils or meets annex D criteria with a statement that it likely to fulfil or likely to meet those criteria.

Noted:

”Considered or likely to fulfil” is applied and cited conclusions from UNEP/POPS/POPRC.10/INF/8/Rev.1 that is adopted by POPRC.

USA 70 434 Despite the history of use of Annex D crtiteria as a metric for alternatives, the USG still thinks that while some kind of safety screening categorization is needed for an alternatives analysis, and while it would be preferable to avoid substituting one POPS-listed chemical with a future POPS-listed chemical, measuring potential substitutes by the criteria of Annex D has at least two major drawbacks: 1) It risks the appearance of a determination of POPS status without a formal political nomination. At a minimum the POPRC should avoid saying that a substance meets Annex D criteria. 2) Use of annex D qualifying criteria may set too high a threshold for risk of potential substitutes such that much safer substitutes are not sufficiently differentiated from only moderately safer substitutes.

Noted:

The screening assessments in para 434 and 437 origin from UNEP/POPS/POPRC.10/INF/7/Rev.1 and UNEP/POPS/POPRC.10/INF/8/Rev.1, according to decision POPRC-10/4 where the Committee decided to submit the summary where Parties may use this report when choosing alternatives to PFOS, its salts and PFOSF as an initial source of information. The results of assessment in UNEP/POPS/POPRC.10/INF/7/Rev.1 and UNEP/POPS/POPRC.10/INF/8/Rev.1 are based on an analysis on a screening level as to whether or not the identified alternatives to PFOS meets the numerical thresholds in Annex D, but does not analyze monitoring data or other evidence as provided for in Annex D. It should be noted that the assessment is not equivalent to the work undertaken by the Committee in examining proposals submitted by Parties for listing of chemicals under the Convention in accordance with paragraph 3 of Article 8 of the Convention.

USA 70 434,437 Met likely to meet

The alternatives guidance should not be used as a substitute for formal submission and determination that a substance meets Annex D criteria through the nomination process. If the Annex D criteria are maintained as the metric in fututre drafts of this alternatives guidance, any statement which identifies a chemical as meeting Annex D criteria should be omitted. Use of the word “likely“mirrors the “not likely“language used for “Class 4“.

Noted:

”Considered or likely to fulfil” is applied and cited conclusions from UNEP/POPS/POPRC.10/INF/8/Rev.1 that is adopted by POPRC.

USA 103 App. 3 “FTS can be expected in the aqueous environment. In the environment a degrade to the stable perfluorohexane acid (PFHxA) is found.”

The meaning here could be more clear. Would the following wording accomplish the authors‘ intent:

6:2 FTS has been shown to degrade to the stable

Revised:

6:2 FTS can be expected in the aqueous environment. In the environment a degrade to the stable perfluorohexane acid (PFHxA) is found. 6:2 FTS has been shown to degrade to the stable perfluorohexane


26

Source of Comment


perfluorohexane acid (PFHxA) in the environment. acid (PFHxA) in the environment.

USA 141 App.10, Other sources

OECD. [supply date] Perfluorooctane sulfonate (PFOS) and related chemical products. www.oecd.org/document/58/0,,en_2649_34375_2384378_1_1_1_1,00

Date needed. Also, URL appears invalid or broken.

Revised

New link included in appendix 10

http://www.oecd.org/env/ehs/risk-management/perfluorooctanesulfonatepfosandrelatedchemicalproducts.htm

Leaf-Cutting Ant Baits Industries Association (ABRAISCA)

35 217 We suggest that the Secretariat check this information with Vietnam, once there is no occurrence of leaf-cutting ant in that country

Vietnam did request registration , see

http://chm.pops.int/Implementation/Exemptionsandacceptablepurposes/RegistersofAcceptablePurposes/AcceptablePurposesPFOSandPFOSF/tabid/794/Default.aspx and listed in appendix 1.

The occurrence of leaf-cutting ants Atta and Acromyrmex is written in para 217.

ABRAISCA 36 219 This information does not concern about leaf-cutting ants. The concentration used of 0.01 – 0,1% refeers to others used such as fire ants, cockroaches, termites, white ants, etc. The concentration informed it is not to leaf-cutting ant. We suggest that this paragraph should be in the Item H.

Rejected

According to a submission from Brazil to POPRC in 2007 , Brazil mentioned that the concentration was 3 g/kg (0,3%) and that it is very reduced. So there is a need for new references to revise this para.

ABRAISCA 36 220 We would like to insist in transfer this information to Item H (Insecticides for control of red imported fire ants and termites). This is not about leaf-cutting ants.

Revised

Marked green is moved to new para 251.

Fluorosurfactants may also be used as “inert” surfactants (enhancers used in pesticide formulations but not constituting active ingredients) in pesticide products. The two PFOS-related substances potassium N-ethyl-N-[(heptadecafluorooctyl) sulfonyl] glycinate (CAS No: 2991-51-7) and 3-[[(heptadecafluorooctyl)sulfonyl]amino]-N,N,N-trimethyl 1-propanaminium iodide (CAS No: 1652-63-7) have been approved in pesticide formulations in the United States in the past.31 However, 3-[[(heptadecafluorooctyl)sulfonyl]amino]-N,N,N-trimethyl 1-propanaminium iodide (CAS No: 1652-63-7) is currently only approved for non-food use and potassium N-ethyl-N-[(heptadecafluorooctyl) sulfonyl] glycinate (CAS No: 2991-51-7) is no longer permitted.32, 33 Both chemicals have other uses, for example as cleaning agents. PFOS derivatives were used in pesticides because they were considered rather inert and non-toxic34.

31 www.fluoridealert.org/pesticides/pfos.pfoas-page.htm. 32 http://iaspub.epa.gov/apex/pesticides. 33 Federal Register: June 24, 1998 (Volume 63, Number 121), Notices, Page 34384-34390. 34 UNEP/POPS/COP.7/INF/21


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Source of Comment


ABRAISCA 36 221 We understand that this information is important, but it should be allocated in the Item H, not here that deals exclusively with leaf-cutting ants, noting that sulfluramid was never registered for control of leaf-cutting ants in the USA even with occurrence of this pest. In USA the pesticide register that were cancelled were for cockroach, fire-ants, termites. And in Europe there is no occurrence of leaf-cutting ant.

Revised as below.

Marked green moved to new para 247

PFOS is no longer used to manufacture ant bait or insecticides against beetles and ants in the European Union, and the United States Environmental Protection Agency cancelled the manufacturing use-registration of sulfluramid in May 2008 and all product registrations by 2012.35 Existing stocks of sufluramid-containing pesticide products were allowed to be sold in US until 2012. According to information submitted to the secretariat of the Stockholm Convention, sulfluramid had been used for pest control (to control cockroaches, white ants and fire ants) in China.

Sulfluramid is used in Brazil in more than 95% of baits for the control of leaf-cutting ants, although the amount of PFOS used was not reported. Since 10% of sulfluramid is degraded to PFOS, its use represents a direct release of PFOS to the environment.36,

37

ABRAISCA 36 221 “Since 10% of sulfluramid is degraded to PFOS, its use represents a direct release of PFOS to the environment.

There is no study published or that made this evaluation concerning about degradation of sulfluramid in PFOS with insect baits containing sulfluramid. Declare that the use of insect bait represents a direct release of PFOS in the environment lacks scientific evidence, this document is a technical paper and should support in scientific references and can not contain affirmative sentences without such certification. The few sulfluramid degradation studies are technical material with pH conditions that do not normally occur in nature and never made with the insect bait insecticides containing sulfluramid. We understand that there are studies showing the degradation of sulfluramide as technical product in PFOS, but say that sulfluramid as insect bait for leaf-cutting ant degrades into PFOS lacks scientific research.

Please, see the references:

The study of degradation (Long Term Aerobic Soil Metabolism of 14C - Sulfluramid) which was presented by the industry comes to degradation of 10% of sulfluramid in PFOS, but this study was done with the technical product (active ingredient) in soil with pH = 6.3, this usually does not occur in Brazil´s soils and the study was not done with insect bait.

There is an understanding through the specialists that sulfluramid as ant bait, may not degrade in PFOS by being tightly bound to the organic matter presented at

Rejected

Included reference.

Löfstedt et al,” Is Ongoing Sulfluramid Use in South America a Significant Source of Perfluorooctanesulfonate (PFOS)? Production Inventories, Environmental Fate, and Local Occurrence” Environ. Sci. Technol., 2016, 50 (2), pp 653–659

DOI: 10.1021/acs.est.5b04544

http://pubs.acs.org/doi/abs/10.1021/acs.est.5b04544?journalCode=esthag

35 www.epa.gov/fedrgstr/EPA-PEST/2008/May/Day-16/p10919.htm.

36 UNEP/POPS/POPRC.3/20/Add.5. 37 http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+7100


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Source of Comment


insect bait formulation and/or organic matter in the Brazilian’s soil, or by the action of microorganisms in the soil, that may be the possibility of biodegradation of PFOS.

This doubt exists and needs scientific confirmation, this concern is presented at the National Implementation Plan - NIP from Brazil, that contains the realization of a project coordinated by the Ministry of Environment to assess the environmental impact of applying these insect baits in open application and the use of ant bait with sulfluramid can lead to degradation the active ingredient in PFOS. As expected result intended to identify whether the ant bait used with sulfluramid might or not might degrade into PFOS and identifying the release and concentration of PFOS during the process on the application of granular ant baits.

However, the environment monitoring project of granular ant bait with Sulfluramid conducted in a forest area with Eucalyptus showed that the analysis of residues of all matrixes: water, soils, fish and wild rats (blood and fats) did not present any level of residues of sulfluramid or DESFA( perfluoroctane sulfonamide). The results found, aside the lack of any mortality of fish and animals in the site, revealed that there was no negative effect to the local fauna caused by the use, in commercial dosage, of the ant baits(Environmental Risk Assessment Of Sulfluramid-Based Ant Killer Baits At Forest Areas”.- UNEP-POPS-POPRC-SUB-F08-LEAF7.English.pdf).

Additionally, analyses of pesticides in water, soil and sediments in the areas of the Micro-basin Project of Aracruz Celulose, conducted from 1993 until the present days, have not revealed the presence of Sulfluramid residues in any of the samples collected.(UNEP-POPS-POPRC- SUB- F08- LEAF9.English.pdf)

A Sulfluramid residue study in grass and soil, conducted in a pasture area with ant bait, did not show any level of residue in the samples of grass and soil analyzed.("Agronomic Efficiency of the MIREX-S MAX product in the control of Atta capiguara Gonçalves, 1944(Hymenoptera:Formicidae) and analysis of Sulfluramid residues in grass and soil" by Ramos, Vania M; Forti, Luiz C.;Andrade, Ana Paula P.- UNEP-POPS-POPRC-SUB-F08-LEAF10.English.pdf).

ABRAISCA 36 224 Idem para 220. We would like to insist in transfer this information to Item H (Insecticides for control of red imported fire ants and termites). This is not about leaf-cutting ants.

Revised and moved to new para 248

In the EU, PFOS-related substances are not used in the manufacture of pesticides.38 Ant baits containing S-methoprene and pyriproxifen are registered in New Zealand for the control of exotic ants by aerial and ground applications.39

ABRAISCA 36 226 “Fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon,

Included and revised, see comment from Brazil

38 http://archive.defra.gov.uk/environment/quality/chemicals/documents/pfos-riskstrategy.pdf. 39 Environmental Risk Management Authority of New Zealand (ERMA NZ) (2007), Decision, 2007-11-11.


29

Source of Comment


boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective.“

Update from the Report sent by Brazil and presented at COP-7 (UNEP-POPS-COP.7-INF-11.English.pdf) p. 22.

ABRAISCA 37 227 “However biological control can be effective under some conditions. In laboratory studies, the entomopathogenic Metarrhizium anisopliae can cause the decline and ultimate death of small colonies and recent research indicates that the entomopathogenic fungi Beauveria bassiana and Aspergillus ochraceus both show a high degree of control, causing 50% mortality within 4 to 5 days. Effective natural products include limonoids extracted from the roots of the South Brazilian endemic plant Raulinoa echinata. Further research is required to verify the effectiveness of these interventions under field conditions. I”

The three studies presented do not conclude the information made in this guide.

Please see the references UNEP-POPS-POPRC.8FU-SUBM-PFOS-BRAZIL-130529.En

This information is not correct because in the original text of scientific articles” D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A:1003830625680” is clear in the abstract, page 51 and page 59 discussion, that the decline in mini-nests was not directly due to the action of the fungus Metarhizium anisopliae [original text, in the abstract, line 14: “However, the decline of these mini-nests after day 26 was not due directly to the pathogenic action of the Metarhizium, nor to the initial ant mortality it had caused”; original text, discussion, line 43:“Secondly, the mini-nest mortality was not due to the Metarhizium infecting and killing every individual in the population. Rather, it was the result of some process set in motion by the early Metarhizium epizootic. The decline of the mini-nests was not explained by the high initial ant mortality either”].

With respect to the scientific article: “Myriam M. R. Ribeiro,1 Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza,1 Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya,2 and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806”, we have several comments to be made:

Firstly the experiments conducted only in the laboratory were made with isolated ant colony, which is not recommended, because the "social control" is nonexistent. This kind of conclusion is completely disconnected from reality. [see text, page 2, item 2. Material and methods, “For each concentration, 50 worker ants received 1 μL of the suspensions on the

Rejected since further research is required to verify the effectiveness of these interventions under field conditions is still needed which is already indicated in para 231.


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Source of Comment


pronotum. One μL of a 0.05% Tween 80 solution was applied to the control ants. This control group was used in the comparison with the two isolates since the experiments were conducted simultaneously. After receiving the treatments, the insects were held individually in Petri dishes supplied with a honey-water solution (1:1) and sterile distilled water renewed every two days. The mortality of the worker ants was daily monitored”];

Secondly, even in conditions already described, which are experimentally incorrect because the correct would make the use of spores of the fungus colonies of at least two years old, the mortality rate is very low, only 50%.[ in the abstract, “The two species were highly virulent, achieving 50 percent worker mortality within 4-5 days”];

Thirdly, these experimental conditions the mortality should be 100%, and thewhole experiment in this way, so far, showed no viability in the field, so the discussion of these fungi for use in biological control has no sense.

With respect to Article :“ Maique W. Biavatti*, I; Rosângela WesterlonI; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical Society Print version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov. /Dec. 2005”, in fact this study was not designed to test the efficacy of substances for control of ants. The work has as main objective to present the isolation and identification of limonoids by the technique of x-ray diffraction. A survey of toxic activity on isolated workers (see page 1445, item “Atta sexdens bioassay”: Each treatment consisted of 50 ants distributed in 5 Petri dishes. The leaf-cutting ants were isolated from their nest and fed with an artificial diet. The ants from the treatment received a diet added with epoxy-fraxinellone or limonexic acid, at a concentration of 200 μg. The ants from the control treatment were fed with a diet without this compound is not feasible, because this technique is used for screening when you have dozens, hundreds of substances to be tried. We cannot infer on the efficiency of cutting ant control because after screening several additional experiments are needed to obtain any conclusion about control.

ABRAISCA 37 230 We suggest that the text be in line with Appendix 2, separating leaf-cutting ants to the other uses (Insecticides for control of red imported fire ants and termites). The current text suggests that are numbers of alternatives, without separating those are alternatives for each pest leading to wrong conclusions.

Revised as below since this is in line with para 226.

There are a number of chemical alternatives to N-Ethyl perfluorooctane sulfonamide (known as sulfluramid), with a multitude of uses40 and/or tested as alternatives to sulfluramid.

Chlorpirifos, Cypermethrin, mixture of Chlorpirifos and Cypermethrin, Fipronil, Imidacloprid,41 Abamectin, Deltamethrin, Fenitrothion, mixture of Fenitrothion and Deltamethrin.

40 Contribution from Argentina and China. 41 Contribution from China.


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Source of Comment


Chlorpirifos used to be considered as an alternative, but due to the severe toxicological and environmental characteristics of this pesticide it can no longer be considered as an alternative for effective control of Atta spp. and Acromyrmex spp.42

ABRAISCA 38 229 - 231

We suggest to include this three paragraphs to a better understand in what situations that cultural, mechanical and biological methods can be used.

Not included since this is already shortly reflected in para 231 and 232.

ABRAISCA 38 234 - 235

“However biological control can be effective. The entomopathogenic Metarrhizium anisopliae can cause the decline and ultimate death of small colonies and recent research indicates that the entomopathogenic fungi Beauveria bassiana and Aspergillus ochraceus both show a high degree of control, causing 50% mortality within 4-5 days.

Effective natural products include limonoids extracted from the roots of the South Brazilian endemic plant Raulinoa echinata.”

The three studies presented by (D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A:1003830625680. ) (Myriam M. R. Ribeiro, Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza, Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya, and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806. Maique W. Biavatti, I; Rosângela WesterlonI; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical SocietyPrint version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov./Dec. 2005, those studies do not conclude the information made in this guide. See paragraph 227, besides it was not referenced that these studies are in laboratory conditions and there is a need to research in field to conclude the effectiveness of these products.

Please see the references UNEP-POPS-POPRC.8FU-SUBM-PFOS-BRAZIL-130529.En

Rejected

Since further research is required to verify the effectiveness of these interventions under field conditions is still needed which is already indicated in para 231.

ABRAISCA 39 237 We suggest that the text be in line with Appendix 2, separating leaf-cutting ants to the other uses (Insecticides for control of red imported fire ants and termites). The current text suggests that are numbers of alternatives, without separating those are alternatives for each pest leading to wrong conclusions.

Revised as below to be consistent with appendix 2.

The reported alternatives to sulfluramid as pesticides for leaf cutting ants are: chlorpirifos, cypermethrin, mixture of chlorpirifos and cypermethrin, fipronil, imidacloprid, abamectin, deltamethrin, fenitrothion mixture of fenitrothion deltamethrin and hydramethylnon

42 UNEP/POPS/POPRC.10/INF/7/Rev.1.


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fenoxycarb, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron and prodrone.

ABRAISCA 39 240 The non-conventional are Entomopathogenic fungi are a) organic bait consisting of rice grains with Beauveria sp. b) Diatomaceous earth mixed with waste water in the principal entry of each anthill c) Vegetal substances with insecticide effect: extract of eucalyptus, castor-oil plant and “Palo Amargo” (“Bitter stick”, Aeschirium crenata Vell. Simaroubaceae) d) Natural enemies: parasitoids known as “Moscas descapitadotas” (“Decapitating flies”, Diptera: Phoridae) (and e) organic baits based on yeast and rice. All these alternatives have been tested in Argentina with promising results.

These products do not have efficiency and technical feasibility according to references below.

Please see UNEP-POPS-POPRC11-FU-SUBM-PFOS-BRAZIL-3-20160108.En

Organic baits based on rice and beer yeast

Contrary to what was asserted here, the rice and beer yeast baits were not the best treatment, as may be ascertained from BORGETTO (2009) 's text. This same author concludes that sufluramida was the most effective treatment. Such results were confirmed by COLL (2003). He textually concludes “para el control de hormigas cortadoras pertencentes al gênero Acromyrmex, el inseticida (sulfluramida) fue más eficiente” = for controlling the leaf-cutting ants of the Acromyrmex kind, the insecticide (sulfluramida) was more effective. (page 40). As to the rice, CARRERE (2006) concluded that the rice merely prevented the ants' continuing to cut the plants, and had not the effect desired of killing the fungus garden.

Diatom earth

On the Argentine document, the publication date is incorrect; it is not 2012 but rather 2010. First, the research performed in RIOS DE SALUSO (2010): “Manejo de las hormigas cortadoras de hoja em los principales sistemas agropecuários y forestales de la província de Entre Ríos” (Handling of leaf-cutting ants in the main forest, agriculture and cattle-raising systems of the Entre Rios province), points out and concludes that sulfluramidand fipronil, in toxic bait, were the most effective products for controlling Acromyrmex lundi in agricultural systems. It the small discussion of its abstract, it points out that the treatment with diatom earth and fipronil on complete atomization ranked third in effectiveness. We emphasize that there were only four treatments and the witness.

We consider that a product, ranking third for controlling Acromyrmex lundi nests that have only one fungus chamber and are located in the top 30 cm of the ground (GRANGI et al , 2000), is not encouraging. Would it then be encouraging for controlling Atta nests with up to 8,000 chambers (MOREIRA et al, 2004a; MOREIRA et al 2004b).

Diatom earth was already tried in Brazil, as candidate for controlling Atta sexdens rubropilosa nests, and the result was the following: "The product based on silica dioxide (Diatom earth), in both dosages tested,

Not revised.

Para 240 are based on comments from Argentina with promising results.

Included reference:



33

Source of Comment


has shown inefficient for controlling Atta sexdens rubropilosa settlements, under operating conditions" (VeracelTM - Technical Report).

Natural enemies: parasites known as phoridae (Diptera, Phoridae)

The work deals with life history (biology) and percentage of parasitism. The work discussion involves potential candidates for a future biological control program. In our opinion, this type of control might not obtain successful control. We must consider that the species studied (4 species) are "candidates for integrating the assemblage of biocontrolagents against Atta vollenweideri”; as written in the article published on the periodical “Journal Economic Entomology 104 (1): 32-40.2011

Entomopathogenic fungi

Until this time, the use of entomopathogenic fungus for controlling leaf-cutting ants has produced no encouraging result, even for the Acromyrmex species having smaller nests. The difficulties in being successful on using entomopathogenic fungi, under field conditions, might be related to the defense strategies of the leaf-cutting ants' settlements, along with its mutualist fungus and the associated microbiota, against parasites and pathogens, of morphological, mechanical and biochemical nature (BOARETTO & FORTI, 1997). According to KERMARREC et al., (1986), the extraordinary resistance of the leaf-cutting ants' mutualist fungi to the epizootic and epiphytic diseases is due to many factors related to the nests' internal hygienic. Attempts for using baits with Beauveria bassiana and Metharrizium anisopliae, under field conditions, with Acromyrmex nests, was not encouraging, since, in this case, the worker ants disinfected, pruned and isolated the fungus culture and, in more severe instances, the ants abandoned the nest.

Certainly, biological control, including with entomopathogenic fungi, is a promising research area, however, it is currently clear the need for basic biological knowledge, in order that control strategies for leaf-cutting ants might actually be applied.

ABRAISCA 39 243 “PFOS-related chemicals are no longer used as insect baits or insecticides for the control of red imported fire ants and termites in USA. The specific identities of replacements or substitutes for PFOS, PFOS-related chemicals and mixtures have been claimed as confidential business information (CBI) to the extent they have been disclosed to the U.S. government. Generally speaking, however, these substances and mixtures have included short-chain PFAS and various fluorinated telomers.”

We would like to insist in transfer this information to Item H (Insecticides for control of red imported fire ants and termites). This is not about leaf-cutting ants.

Revised and moved to new para 253.

ABRAISCA 40 244 “Fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin and methoprene had been tested for leaf-cutting ants, but in Brazil they have experienced that these pesticides were not effective Fenoxycarb, pyriproxyfen, diflubenzuron, teflubenzuron, silaneafone, thidiazuron, tefluron, prodrone, abamectin, methoprene, Hydramethylnon,

Revised, see comment Brazil.


34

Source of Comment


boric acid, some insecticides from the group of neonicotinoids, pyrethroids, Spinosyns, etc., had been tested for leaf-cutting ants, but they were not effective..”

Update from the Report sent by Brazil and presented at COP-7 (UNEP-POPS-COP.7-INF-11.English.pdf) p. 22.

ABRAISCA 40 246 “Pesticide resistance is a genetically based phenomenon. Resistance can occur when a pest population is exposed to a pesticide and not all insects are killed. Those individuals that survive frequently have done so because they are genetically predisposed to be resistant to the pesticide. The resistance to insecticides does not apply to leaf-cutting ants. In the case, the target of insecticides is the workers who are sterile, thus not allowing the selection of resistant individuals.”

Included

“The resistance to insecticides does not apply to leaf-cutting ants. In this case, the target of insecticides is the workers who are sterile, thus not allowing the selection of resistant individuals”.

Included reference:

PFOS_Brazil DOCUMENTO REVISÃO DE LITERATURA FINALIZADO INGLES 18 01 2016.pdf

ABRAISCA 40 249 Which alternatives? There are no references. Included (old para 249/ new para 244)

Chlorpirifos, cypermethrin, fipronil, abamectin, deltamethrin and fenitrothion43

Included reference


ABRAISCA 40 250 Currently, the active ingredients registered in Brazil for ant baits are sulfluramid, fipronil and chlorpyrifos. Chorpyrifos as insect baits is no longer used in Brazil for control leaf cutting ants.

Included

ABRAISCA 90 Appendix 2

“Hydramethylnon”

The active ingredient Hydramethylnon is registered and commercialized in the USA against fire ants (Solenopsis spp.). Also in the USA, it is registered to Atta Texas, for which it has been ineffective. In accordance to the Forest Service Texas, with the bait with the active ingredient hydrametlylnon presents efficiency of only 30% and there is a need of more than one application, especially for large colonies. Another disadvantage is that this insect bait should not be stored for long periods of time, due to its relatively short life time.

Studies were conducted in Brazil to evaluate the potential of such active ingredient in the control of leaf-cutting ants of Atta genus. The results were even more inconsistent, despite the use of high concentrations of this active ingredient in the formulation and higher dosages. Hydramethylnon also has shown not to be efficient to control other ants, just as the leaf-cutting ants case. The lack of further research using hydramethylnon in the control of leaf-cutting ants may be to the fact that such active ingredient present fast degradation in the presence of light, and this property is considered undesirable for insect baits for leaf-cutting ants used in tropical and subtropical conditions.

Spite of being an insecticide known for more than 30 years, it was neither registered nor has been currently

Rejected

Since it is used as an alternative to sulfluramid effective or not



43 UNEP/POPS/POPRC.8/INF/18.


35

Source of Comment


used in Brazil for the control of leaf-cutting ants, certainly because of the proven inefficiency.

The three studies presented by (D.B. Jaccoud, W.O.H. Hughes and C.W. Jackson, The epizootiology of a Metarhizium infection in mini-nests of the leaf-cutting ant Atta sexdens rubropilosa, 1999, ENTOMOLOGIA EXPERIMENTALIS ET APPLICATA, Volume 93, Number 1, 51-61, DOI: 10.1023/A:1003830625680. ) (Myriam M. R. Ribeiro, Karina D. Amaral, Vanessa E. Seide, Bressane M. R. Souza, Terezinha M. C. Della Lucia, Maria Catarina M. Kasuya, and Danival J. de Souza, Diversity of Fungi Associated with Atta bisphaerica (Hymenoptera: Formicidae): The Activity of Aspergillus ochraceus and Beauveria bassiana, Psyche Volume 2012, 2012, Article ID 389806, 6 pages, doi:10.1155/2012/389806. Maique W. Biavatti, I; Rosângela WesterlonI; Paulo C. Vieira; M. Fátima G. F. da Silva; João B. Fernandes; M. Fernanda G. V. Peñaflor; Odair C. Bueno; Javier Ellena, Leaf-cutting ants toxicity of limonexic acid and degraded limonoids from Raulinoa echinata. X-ray structure of epoxy-fraxinellone, Journal of the Brazilian Chemical SocietyPrint version ISSN 0103-5053. Chem. Soc. vol.16 no.6b São Paulo Nov./Dec. 2005, those studies do not conclude the information made in this guide. See paragraph 227, besides it was not referenced that these studies are in laboratory conditions and there is a need to research in field to conclude the effectiveness of these products.


”Fenitrothion”

Thermonebulizable solutions (thermal fogging). Insect bait

Included


”Deltamethrin”

Dried powder formulation. Insect bait

Included, see comment Brazil.


“Hydramethylnon”

Insect bait for control of leaf-cutting ants from Atta spp. and Acromyrmex spp.

Rejected

Since it is used as an alternative to sulfluramid effective or not




Revise into below:

Fipronil are considered more acutely toxic to humans and the environment than sulfluramid. deltamethrin, fenitrothion, fipronil, were not likely considered to fulfil the criteria on persistence and bioaccumulation in Annex D of the Stockholm Convention.44

To be consistency with the appendix 2 and only those products are for leaf-cutting ant.

Revised, see comment Brazil.

BAT/BEP Experts

1 Disclaimer

The Disclaimer is not appropriate since it contains a value judgement (data gaps remain). The UN has standard formulations for disclaimers. The process needs to be described here; conclusions or description of present status of PFOS alternatives are part of the main text of the document.

Revised.

44 Decision POPRC-8/6: Assessment of alternatives to endosulfan.


36

Source of Comment


BAT/BEP Experts

7 2 Note to Secretariat:

Can you please check if all BAT/BEP Expert Group related decisions and actions are correctly covered?

Please also see note close to the end of this document where all references are tabulated.

The Secretariat checked.

BAT/BEP Experts

10 Objectives

This document summarizes information. However, it often fails to question the validity of it and sometimes omits to clearly highlight “current state“ of the particular use and “state of the art“ of alternatives. Having such clarity will greatly enhance the usefuls of this document to Parties.

Clearly stating for each chapter whether or not feasible alternatives exists will greatly enhance clarity of this document

The document summarizes available information on alternatives to PFOS.

BAT/BEP Experts

11 39 Please state what is the result and not what USEPA did

Reference to the work of USEPA added.

BAT/BEP Experts

13 II.Characteristics of PFOS and its related chemicals

This chapter should not repeat other documents and rather focus on PFOS and what is necessary to determine if an alternative (i) existis, (ii) which chemical.

The document summarizes available information on alternatives to PFOS based on publically available sources.

BAT/BEP Experts

13 43 This paragraph is not needed Rejected

These are additional important sources of information on risk management that is useful for PFOS and alternatives.

BAT/BEP Experts

13 44, table 2

Table 2 seems to be very subjective. We suggest to refer to the Global Monitoring Plan guidance document [1] with reference to the following compounds FOSA (note: no P in the abbreviation), N-methyl- and N-ethyle -FOSA and –FOSE.

Revised to FOSA

Rejected for inclusion of the reference the Global Monitoring Plan guidance document since is no relevance to the context of table 2.

Table 2 are examples of other PFOS related substances that are not exampled in the Convention.

BAT/BEP Experts

14 45 it shall be noted that the coverage of these lists mentioned in this paragraph is not the same; therefore, the number of chemicals must be different. Especially, the OECD list goes beyond the definition of the Stockholm Convention that requests all alkyl-chain of eight perfluorinated carbon atoms; this results in 17 F atoms per molecule. The CAS numbers do not help at all to identify these compounds and therefore, it is highly recommended to combine the names of the chemicals together with their molecular formula and chemical structures. It shall be understood that the “octyl”-named carboxylic acids or the telomers do either not have eight perfluorinated carbons or are not perfluorinated. In addition, substances such as the hexylcyclic compound shown in Table 3 and structure in paragraph 48 are not PFOS related. Statements such as in paragraph 49: The figures illustrate the similarity of the compounds are misleading: the two molecules differ substantially: aliphatic vs. cyclic, different molecular formulae, perfluoro-4-ethylcyclohexanesulfonate (PFECHS) was not a contaminant in PFOS (according to information from

There is currently no knowledge of all existing highly fluorinated chemicals available.


37

Source of Comment


3M).

BAT/BEP Experts

14 46 it shall be noted that PFOS is an aliphatic compound and that there are also cyclic PFAS listed in this document, which are not covered here.

There is currently no knowledge of all existing highly fluorinated chemicals available.

BAT/BEP Experts

15 Table 3 It is recommended to also list the molecular formula for easy identification if the substances are comparable or can be degradation products or precursors.

It is not acceptable that two different compounds have the same abbreviation. Please change – or if the abbreviation is not needed later in the text; then, there is no need to introduce it.

Rejected

CAS no where available is sufficient for the identification of individual substances. Whether they are degradation products or manufacturing intermediates is described in appendix 2.

Revised tot wo separate lines in table 3 with abbr. PFBS and K PFBS accordingly.

BAT/BEP Experts

15 48 The pictogram describes FC-98 (see Table 3 top) and not the methyl ether sulfonate.

Revised to Potassium perfluoroethyl cyclohexyl sulfonate

BAT/BEP Experts

16 54-58 This document is not about an inventory and the information therein is not used anywhere

Rejected

Description of current production and use of PFOS is a part of the objective of the consolidated guidance doc.

BAT/BEP Experts

16 59 Consider deleting since no production quantity is provided in the text. Otherwise, please specify that substance CAS No.: 276-19-97-2 is produced in Germany.

Included

...with no production quantities reported,

BAT/BEP Experts

16 59 Please provide correct IUPAC name of this substance Rejected

1H,1H,2H,2H-perfluorooctanesulfonic acid is an scientifically accepted synomym for this substance, see reference

https://pubchem.ncbi.nlm.nih.gov/compound/119688#section=Other-Identifiers

BAT/BEP Experts

16 59 Consider deleting as this is not a scientific term Abbreviations such as H4PFOS: this substance is not an octyl perfluorinated chemical rather a fluorotelomersulfonate; the correct abbreviation is 6:2 FTS. The molecule has only 6 perfluorinated carbons and thus cannot convert into PFOS under environmental conditions – nor would PFOS transform into this compound.

Revised

BAT/BEP Experts

16 59 “is not considered a suitable substitution chemical for PFOS by Germany, given its persistence and estimated substance characteristics, which are similar to PFOS”

Please provide reference to this statement.

Included reference

UNEP-POPS-POPRC9FU-SUBM-PFOS-Germany-1-20140221.En

BAT/BEP Experts

16 Use It would help the reader to be specific about the years for which the country specific data are provided. Furthermore, it will be easier for the reader to sort the information chronologically.

Rejected

The latest use information from Parties is provided.

BAT/BEP Experts

16 60 - 69 All information in a table would be helpful; including production and import/export to avoid double counting.

Rejected

This is not the format of the consolidated guidance doc.

BAT/BEP Experts

17 Table 4 Inserting a table with more relevant current manufactured and/or imported quantities from the paras in this chapter might be more useful to the reader.

Rejected

Reported by Norway.

Included reference


38

Source of Comment



BAT/BEP Experts

17 Table 4 The names of chemicals are not capitalized Rejected

The substances are listed by name and CAS no.

BAT/BEP Experts

17 70 See Appendix I B for updates on Switzerland and list information here.

Noted

Quantities of PFOS are not mentioned in appendix 1B apart from this para so they complement each other.

BAT/BEP Experts

18 71 Please compare to table in Appendix 7 listing exports from Brazil. Values here and in the Appendix do not seem to match. >250t (Appendix 7) and 50t in para 71.

Noted

Quantities of exports explicity from Brazil of PFOS is not mentioned in appendix 7 so the information in this para reported by Brazil complement the information in appendix 7.

BAT/BEP Experts

18 72 Please check for accuracy of some text in this paragraph. For reference, please see Chapter 3.1. in:

https://www.ec.gc.ca/toxiques-toxics/Default.asp?lang=En&n=96A225B1-1

Noted.

The referred reference is a consultancy document for legal actions in Canada that is not the same as the information on use of PFOS provided by Canada in this para in their NIP.

BAT/BEP Experts

18 74 Consider deleting as no values are provided. Rejected

“However, the exact amount of PFOS imported under the 2923.90.00.90.19 HS Code is not known.” That is also relevant information on potential use of PFOS.

BAT/BEP Experts

18 77-78 Please list which are the options for the destruction of PFOS waste and make reference to the Basel Technical Guidelines.

Noted

Topics in this chapter are covered under the Basel Convention and Best Practices are outlined in the Guidance Document developed by the BAT/BEP Expert Group, that are also included references.

Referencing that work might be sufficient for this document to cover issues such as destruction of PFOS waste.

BAT/BEP Experts

19 - III.Alternatives to the use of PFOS and its related chemicals

Throughout this chapter inconsistency of utilization of sub-chapters occurs. For example, some “Specific Exemption“ or “Acceptable Purpose“ uses include sub-chapters on

The price of the chemicals

Cost effectiveness

Technical feasibility and efficacy

Health and environmental effects

Availability, accessibility and socio-economic consideration

while all, or some, are missing in other chapters. It would help the reader if all chapters would follow the same format and include this information and/or indicate data gaps.

Rejected.

If not available there will be empty sub-chapters in this guidance doc..

BAT/BEP Experts

19 - III.Alternatives to the use of

The reader would greatly benefit if paras for each chapter would be sorted chronologically.

Rejected since the relevance of this comment is unclear.


39

Source of Comment


PFOS and its related chemicals

BAT/BEP Experts

19 - III.Alternatives to the use of PFOS and its related chemicals

The reader would benefit if each chapter could clearly state if PFOS (or related substances) can be considered Best Available Technique (BAT) or not. That way, parties can more easily learn whether or not alternatives are accepted and in use.

Noted

The document summarizes available information on alternatives to PFOS based on publically available sources, where the principles of the General guidance on considerations related to alternatives and substitutes for listed persistent organic pollutants and candidate chemicals, UNEP/POPS/POPRC.5/10/Add.1, where BAT/BEP is only one component concerning the identification of alternatives.

BAT/BEP Experts

20 88 Check for accuracy of this information. “Anti-reflective agent” is not listed as a property for photo-imaging.

Noted.

Quote from the OECD 2006 reference.

“Other industrial uses of PFOS related substances at less than 10-tonne include as a component in

photo-resist formulations/anti-reflective coatings in the photo-microlithography processes to produce

semiconductors or other electronic or miniaturized devices” this reference is already included in the current draft guidance doc.

BAT/BEP Experts

20 92 Not in-line with BAT/BEP guidance document Noted

It is in line with UNEP/POPS/COP.7/INF/21, see page 27.

BAT/BEP Experts

20 93 Similar information to para 86? Different content.

Para 86 describe uses of certain PFOS related compounds and para 93 desired properties.

BAT/BEP Experts

20 B Semiconductors

Content of this chapter will be easier to understand for the reader if it were structured according to “Acceptable Purpose“ and “Specific Exemption“ applications.

Noted.

This understanding is reflected in para 94.

BAT/BEP Experts

20 B Semiconductors

Content is not aligned and does not reference chapter provided by BAT/BEP Experts.

Included reference


BAT/BEP Experts

21 100 Include text from BAT/BEP Guidance document, incl. References.

Included reference


BAT/BEP Experts

22 104 “According to the industry, no alternatives are currently available that would allow for the comprehensive substitution of PFOS in these particular applications.”

This is not quite correct. Please see WSC member commitment in para 105 “not to seek new uses“ and correct sentence accordingly

Revised as below

“According to the industry, no alternatives are currently available that would allow for the comprehensive substitution of PFOS in these particular and essential applications.”

Rejected

Essentially this sentence is correct, see


40

Source of Comment


reference

20th WSC Joint Statement May 2016 Seoul FINAL that is also included in this para.

BAT/BEP Experts

22 104 Semiconductor Industry Associations

Should be lower case letters or is a registered organization?

Rejected

Written in a correct way.

BAT/BEP Experts

22 106 ”BARC:

TARC: ”

Please write in full words

Rejected

The full words are written in para 97,98 and 99

BAT/BEP Experts

22 107 . “According to a submission from Japan, alternative methods are expected to be available in 2014.45”

I fnot available, should not be listed. Research in progress is not accepted as BAT (since is not AVAILABLE)

Rejected since the BAT/BEP and this guidance doc have different scope. It is important to the reader in this guidance that research is in progress.

BAT/BEP Experts

22 109 “new photo resist formulations contain much lower concentrations of PFOS”

This statement might be incorrect according to WSC committment in para 105 that no PFOS (or related substances) will be used in new formulations.

This statement is correct since the commitment from WSC concerning the phase out of PFOS include only critical or as they also address it essential applications.

BAT/BEP Experts

23 111 “No alternative substances have been commercialized for existing uses in PAG, BARC and TARC. Substitutes do exist for these non-critical uses, and the semiconductor industry has phased out PFOS for these uses”

This is confusing. It is correct that for developers and edge bead removers alternatives exist whereas for Photoresists, BARC and TARC no alternatives exist for “old“ uses but alternatives exist for new uses.

Examples of alternative substances used:

GKR Series KrF from Fuji Holdings America (http://www.fujifilmusa.com/products/semiconductor_materials/photoresists/krf/index.html)

ARC(r) Coatings from Brewer Science (http://www.brewerscience.com/arc)

AZ® Aquatar®-VIII Coating from EMD Performance Materials (http://signupmonkey.ece.ucsb.edu/wiki/images/b/bb/AZ_Aquatar_VIII-A_45_MSDS.pdf)

Dow™ Photoresists and Anti-Reflectants (non-PFOS) from The Dow Chemical Company (http://msdssearch.dow.com/PublishedLiteratureDOWCOM/dh_08fb/0901b803808fb120.pdf?filepath=productsafety/pdfs/noreg/233-00827.pdf&fromPage=GetDoc)

This is clarified in the current text as below

...uses e.g. Fuji describes photo-resists that are “PFOS & PFAS free.46. The scientific literature indicates that is should be possible to develop a PFOS-free photo-resist system.47 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.48,

49, 50

BAT/BEP 23 111 Please check definition of “non-critical“. Those are: Developers; Edge Bead Removers; De-gluing agents;

“Non critical” uses is a term used by WSC industries where those uses are

45 UNEP/POPS/POPRC.4/INF/17/Rev.1. 46 http://www.fujifilmusa.com/products/semiconductor_materials/photoresists/krf/index.html 47 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 48 https://www.google.com/patents/US20090181319. 49 https://www.google.com/patents/US8034533. 50 UNEP-POPS-POPRC11FU-SUBM-PFOS-20160108-En.doc.


41

Source of Comment


Experts Etching Agents already mentioned in para 111.

BAT/BEP Experts

23 112 Please include reference and outline difference of this application to all other etchant applications listed in this chapter.

Included reference UNEP/POPS/COP.7/INF/21

BAT/BEP Experts

23 115 Same as para 114. Please delete. Rejected

The content in these paras are different.

BAT/BEP Experts

23 115 “According to the manufacturers, this formulation helps prevent evaporation, fires, and corrosion”

Hydraulic fluids containing potassium perfluoroethylcyclohexyl sulfonate have been used in civil and military airplanes since the 1970s. Valves control the flow of hydraulic fluid to actuate moving parts of the aircraft such as wing flaps, ailerons, the rudder and landing gear. It was discovered that localized corrosion (referred to as erosion) occurs in the valves over time affecting their efficiency casing premature overhaul of mechanical parts. The fluorinated surfactant inhibits corrosion of mechanical parts of the hydraulic system by altering the electrical potential at the metal surface, thereby preventing the electrochemical oxidation of the metal surface under high pressure. For further information, see DEFRA 2004.

Noted

However not included since it is old detailed information in this context. If included at a later stage, please provide the exact reference.

BAT/BEP Experts

23 116 “has been used in hydraulic oils”

The fluorinated surfactant inhibits corrosion of mechanical parts of the hydraulic system by altering the electrical potential at the metal surface, thereby preventing the electrochemical oxidation of the metal surface under high pressure.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/183154/pfos-riskstrategy.pdf

Included reference


BAT/BEP Experts

23 116 “other C6 compounds”

The substance has 8 fluorinated carbons, not 6.

Revised to C8

BAT/BEP Experts

23 117 . “Aviation hydraulic fluids without fluorinated chemicals but based on, for example, phosphate esters exist,51 “

This statement is contradictory to earlier statements. The fluorinated surfactant is used as an additive in those fluids which are based on phosphate esters as the main fluid component.

Since no similar sentence has been mentioned in earlier paras, this is not a contradictory statement.

BAT/BEP Experts

23 117 “fluorinated chemicals other than PFOS can be used”

Please confirm that these alternatives exist and insert a reference.

Revised see below

“..fluorinated chemicals other than PFOS can be used as already mentioned potassium perfluoroethylcyclohexyl sulfonate”

BAT/BEP Experts

23 117 “These substances can absorb water and the subsequent formation of phosphoric acid can damage metallic parts of the hydraulic system. For this reason, phosphate ester-based hydraulic fluids are routinely examined for acidity as this determines its useful lifetime. “

Details on fluid itself – not relevant to this chapter. Please delete.

Rejected

since this is important to the reader since one main functionality was to prevent corrosion.

51 www.freepatentsonline.com/6319423.html and www.freepatentsonline.com/WO2006138081.html.


42

Source of Comment


BAT/BEP Experts

23 118 Please delete or add specific reference. Revise d as follows.

An anti-erosion agent added to the hydraulic fluid contains an unidentified residual organic fluorochemical which is most likely a by-product of the manufacturing process52. It is possible that this residual substance could be PFOS.

BAT/BEP Experts

24 119 Para 119 is not relevant to PFOS (or related chemicals) use. Consider deleting.

Rejected since this group of substances have been reported as alternatives to PFOS and related substances.

BAT/BEP Experts

24 119 “security”

Would “safe operation“ be more precise?

Security is the proper word.

BAT/BEP Experts

24 120 “known trade names and traders”

Please be specific which names on the list are the product names and which names are the names of the producers or distributors

Revised as follows

known trade names and from traders

BAT/BEP Experts

24 121 Accessed website on 10 June 2016

http://pds.exxonmobil.com/USA-English/Aviation/PDS/GLXXENAVIEMExxon_HyJet_IV-A_plus.aspx

http://pds.exxonmobil.com/USA-English/Aviation/PDS/GLXXENAVIEMExxon_HyJet_V.aspx

These links do not describe the chemical content in detail so the para content remain without revision.

BAT/BEP Experts

24 121 Can you please check for accuracy? Please see attached US SDS for HYJET 5. The reportable hazardous substances are non-fluorinated. However, Section 15 alerts of the presence of the fluorinated substances with CAS No.:

67584-42-3

68156-07-0

68156-01-4

3107-18-4

Noted.

Could not identify those CAS No in the referenced SDS in the provided links

BAT/BEP Experts

24 122 Consider deleting Rejected

BAT/BEP Experts

24 124 “and improve the work environment”

More prescise is to state that the use prevents Cr-VI emissions to air and therefore helps SMEs to comply with occupational safety regulations. See also comment in para 138.

Blepp et al. is included as reference.

Since chromium (III) is used instead of chromium (VI) for decorative metal plating there is no use of PFOS which is clearly reflected in the current draft guidance doc for that reason the commenter mention.

BAT/BEP Experts

24 124 “made PFOS use in decorative chrome plating obsolete”

This statement is incorrect. Please see BAT/BEP Expert submission.

See comment above. Also mentioned in UNEP/POPS/COP.7/INF/21 page 30.

BAT/BEP Experts

24 126 “Since it is structurally very similar to PFOS, its common name is THPFOS (Tetra Hydro PFOS).”

This is not a scientific term and is not commonly used in the industry. Please delete

Not deleted

Also mentioned in UNEP/POPS/COP.7/INF/21 page 33.

BAT/BEP 25 133 ”enclosure of the baths” Included reference

52 UNEP/POPS/POPRC.8/INF/17/Rev.1


43

Source of Comment


Experts Please check for accuracy. This creates a potential explosion hazard since hydrogen gas is being generated in the process.


BAT/BEP Experts

26 138 Content is similar to para 124. Consider to combine/consolidate.

Revised as follows

In addition, As mentioned earlier, chromium (VI) is a known human carcinogen

BAT/BEP Experts

26 138 “PFOS works by…”

The plating process is an electrolytic process that causes bubbles and mist to be ejected from the plating bath. This mist is released to the work 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. 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. Smaller bubbles in the plating bath and lower surface tension provide other process benefits that are well described in [Germany POPRC-11 follow-up submission].

Noted.

This is already reflected in the current text.

Included reference


BAT/BEP Experts

26 139 “PFOS was previously used for decorative metal plating, but new technology using chromium (III) instead of chromium (VI) has made this use mostly obsolete.”

Incorrect statement – see above.

It is correct.

Also mentioned in UNEP/POPS/COP.7/INF/21 page 30.

BAT/BEP Experts

27 145 Insert reference Included reference

Poulsen et al. Substitution of PFOS for use in nondecorative hard chrome plating, 2011, Environmental Project No. 1371 2011, Danish Ministry of Environment.

BAT/BEP Experts

27 146 Insert reference Included reference

Poulsen et al. Substitution of PFOS for use in nondecorative hard chrome plating, 2011, Environmental Project No. 1371 2011, Danish Ministry of Environment.

BAT/BEP Experts

27 147 “refill”

The term “refill“ is not quite correct, the surfactant amount has to be adjusted and “topped of“ since the plating bath still contains mist suppressant.

Rejected

Could not find any reference that use the expression “topped of”

BAT/BEP Experts

27 148 These references are 7 years old now and have not materialized in any substantive paper – consider to delete

Deleted

BAT/BEP Experts

27 150 “The sludge is sometimes used as a fertilizer for agricultural soil which can result in broad scale

This para describes a major challenge with PFOS contamination in food and


44

Source of Comment


contamination of agricultural fields with PFOS and provide a major emission source to food and water.53”

This practice does certainly not represent the BEP. Please consider to include wording here on BEP for the sludge as this will help Parties with a solution.. See BAT/BEP Guidance update.

water. Therefore it is relevant and remains with no revision.

BAT/BEP Experts

28 152 3,3,4,4,5,5,6,6,7,7,8,8,8-Tridecafluorooctane-1-sulphonate).54

To be consistent with nomenclature used for the other substances mentioned in this para.

Rejected

1H,1H,2H,2H-perfluorooctanesulfonic acid is an scientifically accepted synomym for this substance, see reference

https://pubchem.ncbi.nlm.nih.gov/compound/119688#section=Other-Identifiers.

See also para 59

BAT/BEP Experts

28 154 “There are promising emerging technologies to replace the hazardous chromium (VI) in hard metal plating with the less hazardous chromium (III).55 To what extent this technology would eliminate the need for PFOS as mist suppressant is not clear, but looking at decorative metal plating where chromium (III) is already applied in commercial scale, there is currently no need for PFOS as mist suppressant”

Incorrect – please see above.

No revisions since the included reference

E. Jennings Taylor, “Functional chrome coatings electrodeposited from a trivalent chromium plating electrolyte (FARADAYIC®,1 TriChrome Plating)” (2013).

Indicate exactly what’s written in this para.

BAT/BEP Experts

28 158 “99% efficiency on 1 micron sized particles while PBS operates with over 98% efficiency removal of chromium (VI) aerosols.”

Please clarify: In facilities that operate such equipment, no PFOS is being used?

This para does not describe any use of PFOS but the use of Composite Mesh Pads (CMP) or Packed Bed Scrubbers (PBS) that substantially reduce chromium (VI) in air which is exactly the purpose with PFOS so these applications have been suggested to be alternatives to PFOS for metal plating.

BAT/BEP Experts

28 158 “but these installations cost more than current operations”

Please be more specific. Does that mean that mist suppressants such as PFOS provide a cost effective method to achieve the occupational safety standard? This might be an important point, in particular for SMEs and facilities located in developing nations that might not be able to afford expensive engineering control technology.

Deleted since there is no back up reference to this statement.

BAT/BEP Experts

29 159 “are not used “

Please check for accuracy.

This is confirmed in the included references and only relevant when chromium (VI) is used.

BAT/BEP Experts

29 160 “No assessments or reports have been made regarding alternatives to uses listed above.”

This statement is unclear. Please rephrase or delete.

Deleted

BAT/BEP 29 163 “CMP56 and PBS57 are” Included reference

53 Krofges P, Skutlarek D, Farber H, Baitinger C, Godeke I, Weber R., PFOS/PFOA Contaminated Megasites In Germany Polluting The Drinking Water Supply Of Millions Of People Organohalogen Compounds Vol. 69 (2007). 54 Presentation by Jun Huang, Tsinghua University, at the national workshop on nine new persistent organic pollutants and the implementation of the Stockholm Convention in China, Beijing, 1–2 July 2010. 55 E. Jennings Taylor, “Functional chrome coatings electrodeposited from a trivalent chromium plating electrolyte (FARADAYIC®,1 TriChrome Plating)” (2013). 56 http://www.faculty.ait.ac.th/visu/images/pdf/Romchat%20Dissertation1.pdf


45

Source of Comment


Experts See comment above. Please clarify that no PFOS use is necessary in facilities with such devices in operation.

https://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=208517F9-1

that clarifies that PFOS is not used.

BAT/BEP Experts

29 165 There are no currently available alternatives for metal hard plating and decorative plating.

This is not in-line with earlier statements.

Revised as follows

There are no currently available alternatives for metal hard plating and decorative plating.

BAT/BEP Experts

29 166 “alternative”

Would a better word be “substitute“ as this substance cannot be considered an alternative to PFOS.

Not revised since “alternative” is used in all documents related to the SC work on PFOS.

BAT/BEP Experts

29 167 Repeated from earlier. Moved to para 163

BAT/BEP Experts

30 168 Repeated from earlier. Please provide references Included reference

Poulsen et. al, Substitution of PFOS for use in nondecorative hard chrome plating (2011), Danish Ministry of Environment, p 32. http://www2.mst.dk/udgiv/publications/2011/06/978-87-92779-10-6.pdf.

BAT/BEP Experts

30 169 “There is little…”

Please quantify and list the available scientific references here.

Already reflected and included in the references

UNEP/POPS/POPRC.10/INF/7/Rev.1, UNEP/POPS/POPRC.10/INF/8/Rev.1.

BAT/BEP Experts

30 171 “…must be the result.”

Has this been quantified? Please include reference.

Included reference

Danish Ministry of Environment, “Short-chain Polyfluoroalkyl Substances (PFAS).

A literature review of information on human health effects and environmental fate and effect aspects of short-chain PFAS” Environmental project No. 1707, 2015, http://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-15-5.pdf

BAT/BEP Experts

30 172 “..toward non-fluorinated alternatives”

As long as they fulfill the occupational safety standard requirements.

Noted but not included since occupational safety is a BAT/BEP issue and not primarily the scope for this guidance. However the BAT/BEP guidance is a reference where applicable.

BAT/BEP Experts

30 174 F53-B (potassium 1,1,2,2-tetrafluoro-2-(perfluorohexyloxo) ethane sulfonate),

A recent study estimates the mean biological half-live via all routes of excretion (total elimination) in humans to be 18.5 years.

Y. Shi et al., Env. Sci. Technol., 50, 2016, 2396-2404

Included in appendix 3

BAT/BEP Experts

30 - Availability, accessibility and socio-economic

Information on available and in-use alternative substances is missing. For details, see e.g., Germany POPRC-11 follow-up submission.

Included in appendix 4 where a non exhaustive range of commercial brands and traders are listed.

57 http://archive.defra.gov.uk/environment/quality/chemicals/documents/pfos-riskstrategy.pdf


46

Source of Comment


consideration

BAT/BEP Experts

32 193 “The short chain perfluoroalkyl sulphonates perfluorobutane sulphonate (PFBS) has never been applied or successfully used in fire fighting foams due to its non dispersive properties58. This is also the case for perfluorohexane sulphonate (PFHxS) that currently is considered as a long chain PFC according to the OECD definition59.”

These are not alternatives. Please consider deleting

Not deleted since this is exactly what this para mention.

NotedBAT/BEP Experts

32 194 of fluorosurfactants Revised

BAT/BEP Experts

32 196 “stopping fires at chemical plants”

Class B fires

Included

BAT/BEP Experts

33 198 “may still be used around the world in accidental oil fires.”

This statement is incorrect as some countries/regions banned the use, e.g. the EU.

“Accidental oil fires” Class B fires

Not revised

This para expresses the world and not only the EU.

BAT/BEP Experts

33 201 Chemguard and Dynax

Please see:

http://www.chemguard.com/specialty-chemicals/catalog/fire-fighting-foam-surfactants/

for Product Names, compositional information and links to SDS and Technical Data Sheets

http://www.dynaxcorp.com/technical-data/technical-bulletins.html

Technical Bulletins and SDS are avaible to download.

Noted


BAT/BEP Experts

33 201 Dodecafluoro-2-methylpentan-3-one (3M);

See para 207. This substance is used for CEA and not for AFFF to fight Class B fires. CEA is n ot in-scope of this work.

This is already reflected in para 202.

BAT/BEP Experts

34 206 “…except for existing stocks in USA”.

This is not quite correct as PFOS containing foam is still permitted to be used in other countries/regions, such as China.

Revised as follows

“…except for existing stocks in different parts of the world such as China.

BAT/BEP Experts

34 207 “Dodecafluoro-2-methylpentan-3-one (CAS No: 756-13-8) is mentioned as an alternative to PFOS in aqueous fire fighting foams (AFFF).”

Please clarify is this substance is suitable to fight Class B fires in foam applications – see last sentence of this para.

Revised

BAT/BEP Experts

34 211 Can the authors provide more context? The chapter mainly focuses on fluorinated surfactants used in foams to fight Class B fires.

Included reference that quote this para:

UNEP-POPS-POPRC7FU-SUBM-PFOS-OpenApp-China-120302.En.doc

BAT/BEP Experts

35 213 “Compressed air foam fire engines and Class A foam fire extinguishing agent are commercially available in China,”

Can the authors provide more context? Which



58 Communication with Dr. Roger Klein. 59 http://www.oecd.org/ehs/pfc/.


47

Source of Comment


alternatives are used to fight Class A fires in China? Is PFOS used to fight Class A fires in China?

BAT/BEP Experts

35 214 “Class A fire extinguishing agent has been around for over 30 years. In the last decade, Class A foam fires extinguishing agent and compressed air foam system engines have gradually become more and more popular in China.”

Please include content on Class B fire fighting.



BAT/BEP Experts

35 219 “annual volume of up to 17 tonnes”

Compare to Appendix 7 with quantities of >250t.

Noted.

Quantities of exports explicitly from Brazil of PFOS is not mentioned in appendix 7 so the information in this para reported by Brazil complement the information in appendix 7.

BAT/BEP Experts

35 220 “Both chemicals have other uses, for example as cleaning agents. PFOS derivatives were used in pesticides because they were considered rather inert and non-toxic.”

Please clarify where these are used. This use might be regulated in the USA.

Can you comment on the performance property why these substances may have been used?

Revised since this is only relevant for RIFA and other pests than leaf cutting ants.

BAT/BEP Experts

35 221 “ant bait or insecticides against beetles and ants in “

Does not focus on leaf-cutting ants – move to later chapter?

Revised since this is only relevant for RIFA and other pests than leaf cutting ants.

BAT/BEP Experts

41 271 “..mining industry in member countries as suppressing agents”

Can the authors please clarify whether or not this use is still permitted under the Convention?

Para 318 under sub-chapter “Other uses not exempted”

“PFOS derivatives may be used as surfactants in the mining industry to enhance the amount of recovery of metals from the ores in copper and gold mines”.

BAT/BEP Experts

42 K.Uses not exempted: carpets, leather and apparel, textiles and upholstery

This chapter combines three different specific exemptions as listed under the Convention:

Carpets

Leather and apparel

Textiles and upholstery

The authors may consider breaking this chapter into three different chapters to follow the outline of specific exemptions under the Convention.

Please note products used to treat carpet are different from products used to treat leather and are different from products to treat textiles – see chapter text provided by the BAT/BEP Experts.

Rejected

since this is the formulation as written in the Convention

BAT/BEP Experts

43 285 “In addition fluorotelomer-based polymers have also been used.”

These are Alternatives to the PFOS-related chemistry.

Noted.

That’s why this sentence is there.

BAT/BEP Experts

44 Technical feasibility

Information in regards to the Alternatives seems to be missing here.

This is to some extent reflected in para 286 to 290.

BAT/BEP Experts

44 Health and environmental

Information in regards to the majority of Alternatives seems to be missing here

This is described in appendix 3


48

Source of Comment


effects

BAT/BEP Experts

44 Cost effectiveness


Main reason is that there are substantial data gaps.

BAT/BEP Experts

44 Availability....


Main reason is that there are data gaps.

Some market information on certain open uses are listed in appendix 4.

BAT/BEP Experts

45 303 “Currently polyflouroalkyl phosphonic acids (PAPs) are used in food-contact paper products “

This statement is not correct – see comment for para 353.

Revised as follows:

“Currently polyflouroalkyl phosphonic acids (PAPs) are may be still used in food-contact paper products”

BAT/BEP Experts

46 312 Short chain fluorotelomer-based surfactants (e.g. Capstone® products);60 or Chemguard

http://www.chemguard.com/pdf/specialty-chemical-brochure.pdf

Page 5 and others.

Included

BAT/BEP Experts

49 Properties of alternative substances

Content of the subchapters is inconsistent and should be made consistent. For example, Chapter IV. H. and I. contain a subchapter that repeats in Appendix 2 B. Should those subchapters be deleted here because Appendix 2 B contains that information?

Rejected since this chapter gives an introduction and overview of identified alternatives where appendix 2B provides additional information.

BAT/BEP Experts

49 Properties of alternative substances

Please consider specificity in the all chapters on “Health Effects“ and include the concentration at which effects are observed. Otherwise the information might be misunderstood or misleading those Alternatives might not be safe for intended use.

Included preferably in appendix 3 where available.

BAT/BEP Experts

49 326 Please describe the properties of the polymeric substances as well as they modify surfacte properties (i.e., provide oil, grease, stain and water repellency) as well as inique optical properties needed for specific semiconductor manufacturing processes.

Revised as follows

The key to the performance of fluorosurfactants is extremely low surface tension and for polymer surfaces extremely low surface energy. Because of environmental and health concerns, other surfactants could be used as alternatives where very low surface tension levels are not needed.

BAT/BEP Experts

50 334-336 This information is interesting but not necessarily relevant for this chapter. Here considerations have to be given on which criteria are acceptable for alternatives and which would results in a “POP” definition.

Relevant since article 9.5 in the Convention states

“For the purposes of this Convention, information on health and safety of humans and the environment

shall not be regarded as confidential”

BAT/BEP Experts

50 337-339 This information is interesting but not necessarily relevant for this chapter. Here considerations have to be given on which criteria are acceptable for alternatives and which would results in a “POP” definition.

Relevant since article 9.5 in the Convention states

“For the purposes of this Convention, information on health and safety of humans and the environment

shall not be regarded as confidential”

BAT/BEP Experts

50 334 “and PFHxS (C6)”

This is a not a short-chain alternative. Please delete

Not deleted.

That PFHxS is not a short chain

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


49

Source of Comment


here and later on. fluorinated alternative is already reflected in the current text, see para 191, but this PFHxS and its related chemicals have been identified for uses where PFOS has been used.

BAT/BEP Experts

50 335 The term PFC is no longer used and has been replaced by PFAS

Not revised.

BAT/BEP Experts

51 C.Shorter-chain perfluoroalkyl ketones and ethers

Please confirm that this chemistry is used as alternatives to PFOS (and related compounds). Otherwise delete.

Not deleted

Applications for this fluorinated ketone include clean fire extinguishing agents (CEA) which is reflected in para 202 and in that sense an alternative to PFOS related substances.

BAT/BEP Experts

51 340 “gaseous fire suppression”

Not a specified use PFOS

Applications for this fluorinated ketone include clean fire extinguishing agents (CEA) which is reflected in para 202 and in that sense an alternative to PFOS related substances.

BAT/BEP Experts

51 341 “commercial and industrial cleaning”

Not a specified use for PFOS

Included reference in para 249

RPA, 2004


It describes PFOS related substances used for commercial and industrial cleaning.

BAT/BEP Experts

52 E.Fluorotelomers and fluorotelomer-based phosphates

This chapter seems outdated as it focuses mainly on long-chain fluorotelomer based substances. Those are no longer considered the BAT and have been phased out by major producers at the end of 2015 or earlier.

Please update content of this chapter accordingly.

Not revised.

The document summarizes available information on alternatives to PFOS based on publically available sources and has another scope than the BAT/BEP document.

BAT/BEP Experts

53 353 “The polyfluoroalkyl phosphonic acids and phosphoric acids and their diesters (PAPs and diPAPs), used mainly in food packaging, have recently been discovered in the environment and in people.61 “

This information seems outdated. See e.g. U.S. Fed. Reg. Vol. 81, No. 1, January 4, 2016 p. 5-8; amended “the food additive regulations to no longer provide for the use of three specific perfluoroalkyl ethyl containing food-contact substances (FCSs) as oil and water repellants for paper and paperboard for use in contact with aqueous and fatty foods”. The document also mentions that the use of three classes of such substances has been abandoned.

Chemical names listed are:

Revised as follows:

The polyfluoroalkyl phosphonic acids and phosphoric acids and their diesters (PAPs and diPAPs), used mainly in food packaging62, have recently been discovered in the environment and in people.63

61 D’eon JC, Crozier PW, Furdui VI, Reiner EJ, Libelo EL, Mabury SA. 2009. Observation of a commercial fluorinated material, the polyfluoroalkyl phosphoric acid diesters, in human sera, wastewater treatment plant sludge, and paper fibers. Environmental Science and Technology 43: 4589–4594. 62 U.S. Fed. Reg. Vol. 81, No. 1, January 4, 2016 p. 5-8; 63 D’eon JC, Crozier PW, Furdui VI, Reiner EJ, Libelo EL, Mabury SA. 2009. Observation of a commercial fluorinated material, the polyfluoroalkyl phosphoric acid diesters, in human sera, wastewater treatment plant sludge, and paper fibers. Environmental Science and Technology 43: 4589–4594.


50

Source of Comment


BAT/BEP Experts

54 354 “perfluorononanoic acid (PFNA) and perfluorodecanoic acid (PFDA), in organisms and in nature.”

Precursors to these acids are not considered BAT. Please mention that fact in the text or omit this information.

Not revised

The document summarizes available information on alternatives to PFOS based on publically available sources and has another scope than the BAT/BEP document.

BAT/BEP Experts

54 F.Fluorinated co-polymers

Is a better term “side chain fluorinated polymers” to be consistent with literature and commonly used nomenclature?

Revised as follows

“side chain fluorinated polymers”

BAT/BEP Experts

55 Health effects of fluorinated co-polymers

Can you please include wording that polymeric substances are typically of low toxicity

Rejected

Since this a too general statement and the definition of polymer is still unclear in this context.

BAT/BEP Experts

56 374 Reference is missing Included reference

Posner et.al, “Per- and polyfluorinated substances in the Nordic Countries, Use, occurrence and toxicology”, TemaNord 2013:542, ISBN 978-92-893-2562-2, (2013), http://norden.diva-portal.org/smash/get/diva2:701876/FULLTEXT01.pdf.

BAT/BEP Experts

56 H.Silicone polymers

This chapter does not seem to mainly focus on the alternatives but on precursor materials. It might be beneficial to the reader to highlight that.

This chapter describes that the manufacturing intermediates, the linear and cyclic siloxanes, are used to produce siliconpolymers that are alternatives to certain uses of PFOS.

BAT/BEP Experts

63 I.Propylated aromatics

These are solvents. For which use are these actually alternatives to PFOS or related substances?

In para 400 a range of uses of these substances are described that are/have been uses for PFOS.

BAT/BEP Experts

66 J.Sulfosuccinates

For consistency and accuracy, please ensure that these are listed as alternatives in the chapters above and are also listed in the Appendices Tables below.

Suflosuccinates are listed in the appendices as well.

BAT/BEP Experts

67 K.Stearamidomethyl pyridine chloride

For consistency and accuracy, please ensure that these are listed as alternatives in the chapters above and are also listed in the Appendices Tables below.

Stearamidomethyl pyridine chloride is listed in the appendices as well.

BAT/BEP 67 L.Polyp For consistency and accuracy, please ensure that Polypropylene glycol ethers are listed


51

Source of Comment


Experts ropylene glycol ether, amines and sulfates

these are listed as alternatives in the chapters above and are also listed in the Appendices Tables below.

in the appendices as well.

BAT/BEP Experts

73 Comparative assessment of PFOS and possible alternatives

The BAT/BEP Guidance document should be referenced in this chapter as it outlines the BAT and the BEP.

The BAT/BEP Guidance document is referenced where applicable and relevant.

BAT/BEP Experts

73 448 “...safety considerations.”

Please be more specific. Are you refering to hazards when handling the chemicals for intended use?

Revised as follows for clarification

“…safety considerations that include hazards when handling the chemicals for intended use”

BAT/BEP Experts

73 449 “C6-chemistry “

Please specify that PFHxS is considered a long-chain PFAS. Use of “C6“ here is confusing.

Revised as follows

“C6-chemistry “ short chain

BAT/BEP Experts

73 449 “…is not sufficiently safe”

See comment for para 448

Clarified, see para 448

BAT/BEP Experts

73 451 “Economically useful publically available data is scarce”

However, the BAT/BEP Guidance document developed by the expert group under the Stockholm Convention provides details on the BAT indicating that sectors have adopted alternatives and therefore deemed them economically feasible.

Noted.

Still economic data is scarce which is described in references included in this guidance doc.

BAT/BEP Experts

74 Low surface tension is a key function

This is certainly true for the surfactant. Another key aspect is the chemical and thermal resistance of PFOS.

Noted.

This para discusses fluorosurfactants and not specifically PFOS so the chemical and thermal resistance of PFOS is not included in this para, but these properties are of importance for some uses of PFOS.

BAT/BEP Experts

74 Substitutes for PFOS are available

Please include a reference to the BAT/BEP Guidance document that contains that information

Included reference


BAT/BEP Experts

74 Need for better alternatives

Please define “better“. What context are you trying to address? Performance, EHS-related topics, pricing? All these?

Included for clarification in new para 449:

There is a need for better alternatives to PFOS in line with the “General guidance on considerations related to alternatives and

substitutes for listed persistent organic pollutants and candidate

chemicals” UNEP/POPS/POPRC.5/10/Add.1

BAT/BEP Experts

74 458 “There is a need however to release this information and to properly evaluate health and environmental

This statement is relevant, see argument below.


52

Source of Comment


impact from these alternatives.”

This statement is too broad and therefore incorrect. Data are available in Safety Data Sheets. GHS format SDS has such data listed in Section 11 and Section 12.

SDS is an EU format regulated in REACH article 31 and annex II and has no legal similarity elsewhere worldwide. Since the Stockholm Convention is global and EU and additionally we have many poor examples of SDS provided from far East production countries and a few other examples so there is a real need to set a global standard in this issue. It would of course be great if EVERY chemicals producer really applied the SDS as described in the REACH regulation article 31 and annex II but this is unfortunately not the case e.g. where critical and important chemicals in a mixture needs to be described in section 3 there is "trade secret" written instead of these important CAS No which makes it impossible to proceed with any sort of proper risk assessment. Additionally ingredients in concentrations < 0.1% need not to be mentioned on a SDS.

BAT/BEP Experts

74 459 “There is still little or no publicly available independent and reliable information on the toxicological and ecotoxicological characteristics of several fluorinated, especially short chain chemicals, and non fluorinated alternatives to PFOS”

This broad statement is incorrect. See comment for para 458. Data exist and are publicly available for many alternatives.

This statement is correct and has been reflected in this guidance through a number of independent publically available sources of information.

BAT/BEP Experts

74 460 “Since either little or no information is publically available concerning how these alternatives are actually used and their path ways and environmental fate,”

This broad statement might be incorrect as Technical Data Sheets for many products are available from companies offering these alternatives.

This statement is correct, see comments for para 458 and 459 above.

BAT/BEP Experts

74 461 “It is therefore strongly recommended to improve transparency of chemicals manufacturers on health, environmental and safety information,”

This broad statement is incorrect – see comment for para 458.

This statement is correct, see comments for para 458 and 459 above.

BAT/BEP Experts

75 463 “…articles containing PFOS, its salts and PFOSF “

This statement might be confusing to Parties. Please be more specific which articles actually may contain these substances. The remaining Acceptable Purpose uses are all “non consumer uses“, such as in fixed system installations containing fire fighting foam or in airplane hydraulic systems.

This is in line with the current text in the Convention.

BAT/BEP Experts

75 464 “..labelling systems for products “

Such a system is in existence. Products are labeled according to local regulations and detailed information provided on SDS.

Suggest that the labelling issue is further discussed at POPRC12.

BAT/BEP Experts

75 465 labelling of POPs in articles

See comment above

Suggest that the labelling issue is further discussed at POPRC12

BAT/BEP Experts

75 465 “...and chemicals”

This statement is incorrect. A labeling requirement

Suggest that the labelling issue is further discussed at POPRC12


53

Source of Comment


may exist in countries/regions that have such chemicals regulated. For example, a US SDS needs to list in Section 15 if the substance contains e.g. PFOS.

BAT/BEP Experts

75 469 “...e.g. PFOS by establishing requirements or setting references. “

Relevance? Please see comment for para 463.

Relevant. The para is not revised.

BAT/BEP Experts

76 474 “Much fewer data are currently available publicly on the alternatives than on PFOS.”

This is a broad statement and is most likely incorrect. Please add more specificity when referring to “fewer data“.

This statement is correct, see response to para 458, 459 and 460.

BAT/BEP Experts

76 475 “Chemicals with structures similar to those of the listed PFOS substances could cause concerns similar to those related to the latter substances. “

This is a broad statement and might be incorrect. Substances with much different structures could give reason for more concern. Please consider rephrasing to be more specific or delete.

This statement is correct, see para 46.

BAT/BEP Experts

76 476 “A strategic integrated approach to testing is needed to speed development of the data required to understand the issues and concerns relating to the various types of alternatives. The private sector has a key responsibility in this regard.”

This is a broad statement. What data exactly are needed in addition to data provided to competent authorities for substance notifications and for information provided on the SDS? Please be specific and concise.

For clarification, see response to para 458, 459 and 460

Additionally since often data are provided by the chemicals industry, there is a wide spectrum of quality data provided to an Authority. For instance in the registration system of the European Union regulatory frame work of REACH there are four levels of quality data from 1 to 4 where level 1 is the best and 4 is a level with no quality data at all. Some data provided to a competent Authority are sometimes confidential that cannot be obtained in the POPRC assessment process since only publically available data are used.

BAT/BEP Experts

77 477 “..to provide information to customers and consumers so that they can develop informed opinions about the possible need to change products or processes”

This statement is confusing. See comments on “use in articles further above”.

Revised as follows

. It is also important to provide relevant information to customers and consumers so that they can develop informed substantiated opinions about the possible need to change products or processes.

BAT/BEP Experts

78, 83 App. 1

A and B

This table is not needed. Provision of link is sufficient for consultation.

Rejected

Link is supportive to the reader.

BAT/BEP Experts

87 App. 2 “Use status”

Please be more specific and describe whether or not alternatives exist and are in use. Alternatives in use are listed earlier in the document.

Appendix 2 is a summary of the descriptive text in this guidance doc, where details can be obtained.

BAT/BEP Experts

87 App. 2 “Priority action

Highest action priority?

It is unclear what this exactly means and who should act on what? Can you please better define?

This is a summary conclusive recommendation of our current publically available information on volumes, uses etc that has been provided to POPRC and is described in the current text of the guidance doc.

BAT/BEP Experts

87 App. 2 “Identified alternatives”

Please be specific throughout this table and list the

Appendix 2 is a summary of the descriptive text in this guidance doc,


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substances and/or trade names.

Please note, sometimes the alternatives listed are not correct or the list is incomplete when compared to text in the earlier chapters.

where details can be obtained.

Trade names and brands are listed in appendix 4.

BAT/BEP Experts

89 App. 2 “The use of PFOS-related substances in new products has been in many countries. Stocks are still being used up.”

The sentence is incomplete.

Revised as follows:

“There is still use of PFOS-related substances in new products in many countries”

BAT/BEP Experts

90 App. 2 “Metal plating (hard metal plating)”

Please check content of this table with text in earlier chapters. Information might be missing on alternatives and on alternative technologies

Nothing missing on specific alternative substances with the current text in this guidance doc.

BAT/BEP Experts

92 App. 2 “Carpets, leather and apparel, textiles and upholstery.”

The “identified alternatives” in this table are not used as alternatives. Please see chapter specific to these uses.

Appendix 2 is a summary of the descriptive text in this guidance doc, where details can be obtained where identified alternatives are being described.

BAT/BEP Experts

93 App. 2 Non chemical:

Hyperbranched hydrophobic polymers (dendritic, i.e., highly branched polymers) and specifically adjusted comb polymers as active components is one example of nonfluorinated alternative technologies that can provide superhydrophobic surfaces (but not provide oil repellency, soil and stain release), meaning contact angles larger than 150° that can be applied in coatings, textile, leather etc. Dendrimers may be in the region of nano sized materials meaning features with an average diameter between 1 to 100 nm.

The text outlines chemical alternatives but the header states “non chemical“.

The header outlines

“Alternatives to PFOS, their occurrence and applications” and sub header “identified alternatives” where “non chemical” is to clarify to the reader that this identified alternative is not chemical.

BAT/BEP Experts

95 App. 2 “Not exempted”

This section is “Not In Scope“. Please consider deleting

Rejected since this wording is in line with decisions by the Conference of the Parties and POPRC.

BAT/BEP Experts

94 App. 2 For the most part, the listed alternatives do not appear to be surfactants. Please check for accuracy and update accordingly.

This is clarified in appendix 2B and the text of this guidance doc.

BAT/BEP Experts

102 App. 3 “Appendix 3: Characteristics of alternatives to PFOS for various applications”

No need to paraphrase literature: only important is “viable alternative?” yes or no

This table must be in a concise format to help decision makers and not reflect ongoing research or scientific opinions.

Each cell in this column must contain the same information; otherwise, it is useless for practitioners/decision makers

This table does not only list alternative substances. Please correct title or table content.

Each cell in this column must contain the same information; otherwise, it is useless for practitioners/decision makers.

Rejected


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BAT/BEP Experts

102 App. 3 ”Characteristics64”

Several comments:

1. Please be consistent throughout this table and address the same characteristics for each row.

2. Be specific and list details on e.g. toxicity. All substances are toxic at a certain level, even water and oxygen. Providing wording like “toxicity has been reported” has no meaning without context. For example, can you include information whether or not toxicity occurs at relevant exposure concentrations for workers, consumers and the environment? Maybe including information whether or not the substances are classified as CMR or not might be an advantage since this was one of the requirements to be a suitable alternative.

This table contain available hazard and environmental information from publically available sources to date.

When e.g. certain hazard classification has been done, this is mentioned in the context of the alternatives in question.

BAT/BEP Experts

102 App. 3 “Literature describes phosphate compounds e.g. tri-alkyl phosphates, tri-aryl phosphates, and mixtures of alkyl-aryl-phosphates”

Please check for accuracy. To the best of our knowledge no substitutes exist for the perfluoroethylcyclohexyl sulfonate.

This is the current status of information obtained from Parties and publically available sources of information.

BAT/BEP Experts

102 App. 3 “Monitoring data: 6:2 FTS has been detected in environmental samples including water, soil, air particulates and biota.

During the EU-project PERFORCE65, FTS were detected in several environmental samples. 6:2 FTS was present in the particle phase of UK air samples with unknown origin so it may be possible that non-volatile ionic FTS might directly undergo atmospheric transport on particles from source regions. 6:2 FTS observations has been done in the Arctic. More publically available data is needed to determine its origin and whether it is a LRT substance or not.”

No need to paraphrase literature: only important is “viable alternative?” yes or no

This is the current status of information obtained from Parties and publically available sources of information

BAT/BEP Experts

103 App. 3 “Potential degradation product from short chain (C6) fluorotelomer-based surfactants.”

I do not understand why this a category.

Since degradation products are discussed in this guidance in context to short chain fluorotelomers it is important to the reader to understand the connection between these categories of highly fluorinated substances.

BAT/BEP Experts

107 App. 3 “556-67-2 (D4)“

Please be specific. Is D4 used as an alternative substance?

This is described in para 202 and in appendix 2B.

BAT/BEP Experts

119 Appendix 4

“Composition”

Please be specific and explain the difference between “trade secret“, “Information gaps” and “exact chemical composition is trade secret“? Does that mean that no compositional information is available at all?

This is described in the current text of the guidance doc.

64 This table provides a selection of the characteristics, a full overview of the characteristics of the substances is provided in UNEP/POPS/POPRC.10/INF/7/Rev.1 and UNEP/POPS/POPRC.10/INF/8/Rev.1. 65 http://www.science.uva.nl/perforce/index.htm?http%3A//www.science.uva.nl/perforce/events.htm.


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BAT/BEP Experts

120,121

App. 4 “Fluor-based non-PFOS66”

Would a better term be “fluorosurfactant” as stated earlier in this table?

Not revised.

This is to clarify fluorochemistry without PFOS.

BAT/BEP Experts

122 App. 5 Please ensure consistency and completeness of content here after correcting/adjusting content in previous tables/chapters.

Rejected .

BAT/BEP Experts

125 App. 6 Please check for correctness as the different chapters addressing these uses list sometimes non-chemical alternatives that are not mentioned here.

For example, “Digital Techniques“ for Photo Imaging

“Engineering Controls“ for Metal Plating

And others

Included to photo imaging:

“Non-chemical alternatives to PFOS include shifting to digital photography

BAT/BEP Experts

129 App. 8 Please specify the year for each individual Parties‘report, incl. the reference.

All these reports are feasible.

Included references

http://chm.pops.int/Countries/Reporting/NationalReports/tabid/3668/Default.aspx

http://chm.pops.int/Countries/NationalReports/ThirdRoundPartyReports/tabid/4470/Default.aspx

BAT/BEP Experts

132 App. 8 “Romania: BIO HYDROPOL 6 containing 5-10% 2-(2-butoxyethoxy)ethanol (CAS No: 11234-5; EC 203-961-6)

Physicochemical properties of 2-(2-butoxyethoxy)ethanol: Vap.pres. = 0.02 hPa at 26.9ºC; Wat.sol.ct.= miscible at 20 ºC; logPow = 0.15-0.4

Quantities of use per year: 5729 kg BIO HYDROPOL 6

PROFOAM 806G containing 2-6% Hexylene glycol (CAS No: 107-41-5, EC 203489-0); hydrolyzed protein [70-80%], metallic salt: NaCl+MgCl2 [8-15%]; FeSO4*7H2O[0-2%]

Physicochemical properties of Hexylene glycol: Vap.pres. = 0.07 hPa at 26.9ºC; Wat.sol.ct.= Miscible with water in all properties; logPow < 0.14 at 25 ºC

Quantities of use per year: 15799 kg PROFOAM 806G”

Please compare to information provided in Appendix 4 Table A. Are these foam concentrates containing fluorinated surfactants?

Included in appendix 4A:

“BIO HYDROPOL 6

A fluorosynthetic versatile AR foam concentrate containing 5-10% 2-(2-butoxyethoxy)ethanol (CAS No: 11234-5; EC 203-961-6)”

And

“PROFOAM 806G containing 2-6% Hexylene glycol (CAS No: 107-41-5, EC 203489-0); hydrolyzed protein [70-80%], metallic salt: NaCl+MgCl2 [8-15%]; FeSO4*7H2O[0-2%]”

BAT/BEP Experts

135 App. 9 Note to the Secretariat: Does this list include all the relevant references pertaining to the work of the BAT/BEP Expert Group?

All references in appendix 9 are relevant where the latest BAT/BEP guidance, UNEP/POPS/COP.7/INF/21 is already included.

Fluoro Council

13 Table 2 Perfluorooctane sulfonamide sulphonamide

N-Methyl perfluorooctane sulfonamide sulphonamide

Not revised since it can be spelled both ways.

Fluoro Council

16 59 “and estimated substance characteristics, which are similar to PFOS”

This is an incorrect assumption and statement. The properties of PFOS and 6-2 FTS (not H4PFOS and not THPFOS) are widely dissimilar in almost all

Not deleted.

Reference included

66 There are many more fluorinated substances listed in the Danish Ministry of Environment report.


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properties with the exception they both are persistent. UNEP-POPS-POPRC9FU-SUBM-PFOS-Germany-1-20140221.En

Fluoro Council

30 169 There is little independent and reliable information available on the toxicological and ecotoxicological characteristics of these polyfluorinated substitutes or their persistence and degradation products. Nevertheless

This statement is incorrect and should be revised. Data related to 6:2 FTS is available, and the following references should be added to the document:

Toxicology data for alternative “short-chain” fluorinated substances. In Toxicological Effects of Perfluoroalkyl and Polyfluoroalkyl Substances, DeWitt, J. C., Ed. Humana Press: 2015; pp 451-477. http://www.springer.com/us/book/9783319155173

Aquatic Hazard, Bioaccumulation and Screening Risk Assessment for 6:2 Fluorotelomer Sulfonate. Chemosphere 2015, 128:258-265. http://dx.doi.org/10.1016/j.chemosphere.2015.01.033

Not deleted but revised as follows

“There is little independent and reliable information available from publically available sources on the toxicological and ecotoxicological characteristics of these polyfluorinated substitutes or their persistence and degradation products.”

Fluoro Council

30 170 Use of “THPFOS” should be avoided as it is misleading, please remove.

Deleted.

Fluoro Council

30 171 In addition, these alternatives tend to adsorb less to the sewage sludge of wastewater treatment plants - e.g. so that in sum remarkably higher emissions to the environment than in case of using PFOS must be the result. Therefore, it is crucial that the most recent BAT/BEP guidance are applied in order to reduce emissions to its lowest level possible Therefore problems might occur again for soil and in particular for groundwater as well as for surface water and related drinking water67.

Not deleted.

but added “Therefore, it is crucial that the most recent BAT/BEP guidance is applied in order to reduce emissions to its lowest level possible68” with included reference UNEP/POPS/COP.7/INF/21

Fluoro Council

30 172 The frequent presence of persistence, higher emissions, unknown toxicity and degradation to persistent substances observed with fluorinated alternatives to PFOS should incline choice of alternatives toward non-fluorinated alternatives

See above, toxicological data is available, please consider rephrasing this paragraph.

Fluoro Council

32 192 During this same time, AFFFs based on long-chain as well as short-chain fluorotelomers were also available for the same fire-fighting uses.

Included.

Fluoro Council

32 193 Over the past several years decade, manufacturers of fluorotelomer AFFF manufacturers have been replacing PFOS based products with fluorotelomer-based fluorosurfactants. There was a concern that these fluorotelomer-based products would lead to higher exposures to perfluorooctanoic acid (PFOA) which has similar hazard characteristics as PFOS.69 The current effort is to complete the replacement of these PFOA based any remaining long-chain fluorosurfactants with shorter-chain fluorosurfactants such as perfluorohexylethanol (6-2 FTOH)6:2

Revised as suggested except for perfluorohexylethanol (6-2 FTOH)6:2 fluorotelomer sulfonate derivatives, since 6:2 FTOH is a precursor to 6:2 FTS.

67 Danish Ministry of Environment, “Short-chain Polyfluoroalkyl Substances (PFAS). A literature review of information on human health effects and environmental fate and effect aspects of short-chain PFAS” Environmental project No. 1707, 2015, http://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-15-5.pdf. 68 UNEP/POPS/COP.7/INF/21 69 PFOA meets the Annex D screening criteria, and is currently under evaluation by the POPRC as a candidate for listing in the Stockholm Convention.


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fluorotelomer sulfonate derivatives

Fluoro Council

32 194 a Fluoro-protein foams (FP) used for hydrocarbon storage tank protection and marine applications;

Included.

Fluoro Council

33 198 As fire-fighting foams have a long shelf life (10–20 years or longer), PFOS-containing fire-fighting foams, such as Light Water

Included.

Fluoro Council

34 206 Fire fighting foams with PFOS-related chemicals are no longer used, except for existing stocks in the U.S. The specific identities of replacements or substitutes for PFOS, PFOS-related chemicals and mixtures have been claimed as CBI70 to the extent they have been disclosed to the U.S. government,71 but chemical structures of major fluorosurfactants used in AFFF have been well documented

Please consider adding the following reference that details AFFF surfactant structures - Zwitterionic, Cationic, and Anionic Fluorinated Chemicals in Aqueous Film Forming Foam Formulations and Groundwater from U.S. Military Bases by Nonaqueous Large-Volume Injection HPLC-MS/MS; Will J. Backe, Thomas C. Day, and Jennifer A. Field* Environ. Sci. Technol., 2013, 47 (10), pp 5226–5234

Revised as follows:

“…but chemical structures of major fluorosurfactants used in AFFF have been analyzed through an independent scientific study in 201572, see comment from Austria.”

Fluoro Council

34 207 Dodecafluoro-2-methylpentan-3-one (CAS No: 756-13-8) is mentioned as an alternative to PFOS in aqueous fire fighting foams (AFFF). This material is manufactured and sold by 3M as a clean extinguishing agent an alternative to halon


Fluoro Council

35 207 Applications for this fluorinated ketone include clean fire extinguishing agents (CEA). Although CAS No: 756-13-8 has been used as an extinguishing agent, it is not designed for flammable liquid fires clear to what extent dodecafluoro-2-methylpentan-3-one (CAS No: 756-13-8) has replaced PFOS AFFF since it is used as a fire protection fluid

Not revised since this is already reflected in this para.

Fluoro Council

35 209 but due to scarce publically available data for short chain 6:2 fluorotelomers more information is needed to confirm this hypothesis

Competent authorities have acknowledged the fact that they are less bioaccumulative and less toxic. This sentence should be removed

Rejected .

FC is required to provide independent and publically available references to revise this para.

Fluoro Council

35 210 -carbon telomere-based fluorosurfactants have not been assessed in Canada under the Canadian Environmental Protection Act 1999.

Short-chain, six fluorinated carbon, flurootelomer-based surfactant products have been reviewed by Environmental and Health Canada and approved for commercial use. Please remove this paragraph.

Deleted.

Fluoro Council

44 291 Please consider modifying as suggested in order to clarify.

Revised as follows:

“Generally speaking, however, These registered substances and mixtures have included short-chain PFAS and various fluorinated telomers.”

70 There is no explanation from US to CBI in their contribution. US need to expain CBI. 71 There is no explanation from US to CBI in their contribution. US need to expain CBI. 72 Will J. Backe, Thomas C. Day, and Jennifer A. Field*, Zwitterionic, Cationic, and Anionic Fluorinated Chemicals in Aqueous Film Forming Foam Formulations and Groundwater from U.S. Military Bases by Nonaqueous Large-Volume Injection HPLC-MS/MS; Environ. Sci. Technol., 2013, 47 (10), pp 5226–5234


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Fluoro Council

45 303 This information seems outdated. See e.g. U.S. Fed. Reg. Vol. 81, No. 1, January 4, 2016 p. 5-8; amended “the food additive regulations to no longer provide for the use of three specific perfluoroalkyl ethyl containing food-contact substances (FCSs) as oil and water repellants for paper and paperboard for use in contact with aqueous and fatty foods”. (https://www.gpo.gov/fdsys/pkg/FR-2016-01-04/pdf/2015-33026.pdf) The document also mentions that the use of three classes of such substances has been abandoned:

1. Diethanolamine salts of mono- and bis (1H,1H,2H,2H perfluoroalkyl) phosphates where the alkyl group is even-numbered in the range C8–C18 and the salts have a fluorine content of 52.4 percent to 54.4 percent as determined on a solids basis;

2. Pentanoic acid, 4,4-bis [(gamma-omegaperfluoro- C8-20-alkyl)thio] derivatives, compounds with diethanolamine (CAS Reg. No. 71608–61–2); and

3. Perfluoroalkyl substituted phosphate ester acids, ammonium salts formed by the reaction of 2,2-bis[([gamma], [omega]- perfluoro C4-20 alkylthio) methyl]-1,3- propanediol, polyphosphoric acid and ammonium hydroxide.

Noted.

No revision is done since there is no contradictory in the current para to the comments provided by FC.

Fluoro Council

49 328 Since 2006, the major manufacturers of long-chain fluoro telomers (i.e.8:2 fluorotelomers) in the EU, Japan, and US have been working towards the elimination of C8-based and longer-chain-based PFCs by year-end 2015, in accordance with the United States Environmental Protection Agency’s voluntary 2010/2015 PFOA Stewardship Program.73 Global producers that did not sign up for the Stewardship Programme outside these regions not included in the partnership. Currently, C6-fluorotelomers increasingly dominate the trade. Thus far it has been difficult for. Non-fluorinated alternatives have made some gains in the marketplace, especially in textile treatments and fire fighting foams. to gain a firm foothold in the market Further gains for the non-fluorinated alternatives will be based on their ability to provide the performance customers require as well as on the partly because of established supplier relationships and partly due to regulatory policies that permit continued use of fluorinated chemicals in commerce.74, 75, 76


Fluoro Council

52 349 All references to long-chain products manufactured by DuPont (Zonyl, Forafac, Foraperle) should be removed as they are no longer available. Please remove all these paragraphs as suggested.

Deleted.

Fluoro Council

53 353 Same comment as paragraph 45.

Noted.

No revision is done since there is no contradictory in the current para to the comments provided by FC.

73 www.epa.gov/oppt/pfoa/pubs/stewardship/index.html. 74 www.epa.gov/oppt/pfoa/pubs/stewardship/index.html and www.epa.gov/oppt/existing chemicals/pubs/actionsplans/pfcs.html. 75 http://www.ec.gc.ca/epe-epa/default.asp?lang=En&n=AE06B51E-1. 76 http://www.ec.gc.ca/toxiques-toxics/Default.asp?lang=En&n=6B9B6B28-1&xml=F68CBFF1-B480-4348-903D-24DFF9D623DC.


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Fluoro Council

54 359 DuPont markets many Zonyl® co-polymers for various purposes, such as Zonyl® G Fabric Protector for textiles, which consists of 2-methyl-2-propenoic acid dodecyl ester polymer with 10-15% -fluoro--[2-[(2-methyl-1-oxo-2-propenyl)oxy]ethyl poly(difluoromethylene) (CAS No: 65605-58-5).

Deleted.

Fluoro Council

55 360 Foraperle® 225 (DuPont) is an acrylic fluorinated co-polymer (25%) in a solvent medium (75% butyl acetate) used for finishing and protection of leathers and car upholstery through water and oil repellence. It contains the compound 2-propenoic acid, 2-methyl-, hexadecyl ester (hexadecyl methacrylate), polymers with 2-hydroxyethyl methacrylate, --perfluoro-C10-C16-alkyl acrylate and stearyl methacrylate (CAS No: 203743-03-7). Another acrylic fluorinated co-polymer is dodecyl methacrylate polymer with α-fluoro--[2-[(1-oxooctadecyl)oxy]ethyl]-poly(difluoromethylene) (CAS No: 65530-65-6), which is used in a concentration of 0.085–0.45%.

Deleted.

Fluoro Council

74 455 In addition to stability, a key factor in the performance of fluorosurfactants is their extremely low surface tension, which currently cannot be matched with other non-fluorinated surfactants. PFOS is with current knowledge the optimal substance with regard to that property

Revised.

See also comment from IPEN.

Fluoro Council

74 456 higher homologues by the end of 2015

The voluntary agreement does not apply to producers who did not sign up for the Stewardship Program in other countries. As a result, there has been a shift by these Stewardship Program producers to short-chain alternatives such as C6-, C4- and C3-perfluoroalkylated chemicals.


Fluoro Council

75 459 As noted in comment on para 169, this statement is incorrect.

Not revised0

See response to para 169.

Fluoro Council

121 etc

App. 4 6:2 FTS (=H4PFOS) DuPont Chemours . Revised.

Fluoro Council

124 etc

App. 5 DuPont Chemours. Revised.

Global Silicones Council (GSC)

Comments from GSC 17 June 2016 on the second draft of the Consolidated guidance doc.

The outcome of POPRC10 cannot be changed. Additionally assessments may constantly change with time and therefore these comments are currently noted but not included in this guidance document.

International POPs Elimination Network (IPEN)

15 50 “According to fluorochemical producers, these are considered critical properties of PFOS and perfluorinated surfactants polymers in a number of applications.”

Included.

IPEN 18 Products in waste streams likely to contain PFOS …

We found some of the deleted text in this section to be quite informative and hope that the drafters consider restoring it. The Stockholm Convention has different goals and objectives than Basel and a brief section on wastes is entirely appropriate and helpful in this document.

Noted, see para 78.

There is already extensive provided on PFOS containing waste in the Technical guidelines on the environmentally sound management of wastes consisting of, containing or contaminated with perfluorooctane sulfonic acid, its salts and


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perfluorooctane sulfonyl fluoride under the Basel Convention.77

IPEN 23 111,116 “claimed trade secrets”

Trade secrets are not inherent parts of substances or processes – they are claimed by manufacturers

Not added since these are “trade secrets” as mentioned in a number of reports that compose this consolidated guidance.

IPEN Rev25

127 “Some fluor-free alternatives such as TIB Suract CR-H are also used on the market”

This information from the previous draft seems very useful in this section

Not included but mentioned in appendix 4.

IPEN 32 188 “In 2012, the POPRC recommended that since alternatives are available, “parties should stop using PFOS” for this use. “

A POPRC document should be able to briefly summarize a relevant POPRC recommendation for relevant uses.

Included as new para 188. “In 2012, the POPRC recommended that since alternatives are available, “encouraged parties should stop using PFOS” for this use78 as a recommendation to COP.”

IPEN 32 191 “protect both lives and property extinguish fires”

This is its use. The purpose of this section is not to promote AFFF but neutrally describe their function. Sales talk is not appropriate.


IPEN 32 191 Unique certain Revised as suggested.

IPEN 33 200 “Manufacturers, distributors and users of AFFF fire-fighting agents and their chemical components have formed a not-for-profit trade association, the Fire Fighting Foam Coalition (FFFC), whose stated aim is to ensure that accurate industry information about PFOS alternatives, including telomer-based products, is disseminated to appropriate audiences. The industry position was published in the June 2008 issue of Asia Pacific Fire Magazine”

Industry public relations organizations have their own budget to promote their point of view and should not be included here in this manner. Can trade unions, victims of foam poisoning, community governments who have to clean up PFOS pollution from foam use, and public interest orgs all get their paragraph too?

Deleted.

IPEN 34 202 “FFFC has claimed that fire-fighting foams made from fluorinated surfactants have been shown to be the only technology that can quickly and effectively extinguish fires resulting from highly combustible and flammable materials. FFFC indicated that fluorine-free fire-fighting foams can provide an alternative in some applications but cannot provide the same level of fire suppression (capability, durability, etc.). “

The information above is a sufficient public relations plug for the industry. Repeating their claims provides manufacturer sales information and is not appropriate

Deleted.

IPEN 37 225 “An adequate insecticide used to formulate bait for the control of leaf-cutting ants should be lethal at low concentrations or otherwise prevent the ant feeding or reproducing, act by ingestion and present a delayed toxic action”

Included.

IPEN 38 233 “One of the largest studies of parasites associated with leaf-cutting ants demonstrates a new possible

Included.

77 UNEP/CHW.12/5/Add.3/Rev.1. 78 POPRC 8/8.


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non-chemical control method for these two species of leaf cutting ants in the form of specialized parasites.79 Escovopsis is a group of parasites that attack the fungal crops raised by the ants. Interestingly, a variety of forms of Escovopsis are present in the same ant colony and the parasite has the capability to invade distantly-related fungus-growing ant species, including those found in Brazil”

IPEN 38 234 “Baits prepared with neem oil (Azardirachtin) reduced ant foraging by 75.5% for Atta ssp, and 83.5% for Acromyrmex spp in a field trail in Brazil. Baits prepared with sesame oil reduced ant foraging by 55.9% and 67.6% of Atta spp. and Acromyrmex spp., respectively.80”

Included.

IPEN 39 236 The reported chemical alternatives to sulfluramid Included.

IPEN 39 238 Suggested revision:

“Some of these pesticides listed above are all available as commercial products on the Argentinean market. Argentina has prohibited the import, production, trading and use of chlorpirifos in formulations of household sanitary products81 but not for the pesticide uses on leaf cutting ants. There is an ongoing legislative prohibition process for fenitrothion for house hold uses and additionally for agriculture purposes of grain. The alternatives to sulfluramid in Argentina can be divided in two main groups namely chemical alternatives (synthetic insecticides) and non-chemical alternatives. The common chemical alternatives are Fipronil, applied on the total surface or as a component of a bait and Chlorpirifos, applied using fogging machines in all main principal entries of the nest.”

Cleaning products? Not sure what sanitary products are.


Included footnote for clarification: “For household sanitary products biocide uses are applied only”

IPEN 39 239 “The conventional non-chemical alternatives include” Revised as suggested.

IPEN 40 242 “However field trials in 2016 have shown considerable promise. For example, neem baits reduced ant foraging by 75.5% for Atta ssp, and 83.5% for Acromyrmex spp in a field trail in Brazil. PFOS-related chemicals are no longer”

Included.

IPEN 40 245 “Pesticide resistance is a genetically based phenomenon resulting from overuse of pesticides.”

Rejected since this does not provide any new information to this para.

IPEN 43,45,47

Carpets, leather and apparel, textiles and upholstery

Language is a little difficult to understand; “Prohibited uses no longer exempted“

Rejected.

IPEN 51 334 “Information about PFBS, its potassium salt (PFBSK) and PFHxS (C6) is available, including toxicity studies are available. A variety of impacts of C6-C4


79 Meirelles LA, Solomon SE, Bacci M, Wright AM, Mueller UG, Rodrigues A (2015) Shared Escovopsis parasites between leaf-cutting and non-leaf-cutting aants in the higher attine fungus-growing ant symbiosis, R. Soc. Open Sci 2:15027 - 15038 80 P Boff, A Giesel, MIC Boff. 2016. No-residual baits and farmer perception to manage leaf-cutting ants. Agroecology and Sustainable Food Systems 40(5):451-465 81 For household sanitary products biocide uses are applied only.


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substances have been”

IPEN 51 335 “It has been claimed by the industry that PFBS” Included.

IPEN 51 335 “PFBS and PFHxS along” Included.

IPEN 74 443 “In addition, a chemical alternative should not have hazardous properties that raise serious concern, such as mutagenicity, carcinogenicity, or adverse effects on the reproductive, developmental, endocrine, immune or nervous systems (UNEP/POPS/POPRC.5/10/Add.1). Non-chemical alternatives should also be considered and may include alternative industrial processes and innovative practices (UNEP/POPS/POPRC.5/10/Add.1).”

This part of the POPRC guidance document is extremely important to avoid costly regrettable substitution

Included.

IPEN 74 448 “less hazardous and less persistent than PFOS.”

This is an important property of PFOS and the Stockholm Convention

Included.

IPEN 75 455 “In addition to stability, a key factor in the performance of fluorosurfactants is their extremely low surface tension, which currently cannot be matched with other surfactants in currently designed processes.”

Important to note that process design is linked to function. There may be other process designs where PFOS does not have this large of an advantage. The way this para is currently framed reminds us of the way asbestos has been portrayed as “un-substitute-able“


IPEN 75 455 PFOS is with current knowledge the optimal substance with regard to that property

redundant

Deleted.

IPEN 76 456 Properties meet Annex D screening criteria, “and are currently under evaluation by the POPRC as a candidate for listing in the Stockholm Convention.82”

Not included.

Already mentioned as a footnote.

IPEN 76 456 “For that reason Producers of fluorochemicals in the EU, Japan, and US”


IPEN 76 458 “There are still considerable gaps in publically available information concerning the specific and particularly exact chemical composition of alternatives to PFOS though some of these alternatives have been established on the market for several years. One major reason is that this information is considered as confidential by manufacturers (CBI). There is a need however to release this information and to properly evaluate health and environmental impact from these alternatives. In addition, due to analytical capacity, it is likely that manufacturers know the precise chemical composition of their competitor’s products.”

This is a fact of corporate life and should be openly stated here. “Confidential” does not really inhibit other corps from getting precise composition because


Not included since this is not confirmed and referenced information.

82 PFOA meets the Annex D screening criteria, and is currently under evaluation by the POPRC as a candidate for listing in the Stockholm Convention.


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Source of Comment


they all analyze each other’s products.

IPEN 76 461 “It is therefore strongly recommended to improve transparency of chemicals manufacturers on health, environmental and safety information, noting as stated in Article 9 of the Convention, that health and safety information shall not be regarded confidential. In addition, manufacturers should”

Key principle of chemical safety and stated in Article 9 para 5: “For the purposes of this Convention, information on health and safety of humans and the environment shall not be regarded as confidential.”

Included since article 9.5 in the Convention states:

“For the purposes of this Convention, information on health and safety of humans and the environment shall not be regarded as confidential”

IPEN 77 470 “The labelling system must be practical, effective, enforceable, and easy to implement and consider the socio-economic impact on companies”

Public right to know is not subordinate to inflated industry claims of high cost.

Revised as follows:

“The labelling system must be practical, effective, enforceable, and easy to implement, and independently consider the socio-economic impact on companies.”

IPEN 78 473 “Assessment of the economic implications of switching to alternatives to PFOS can be facilitated by knowing manufacturing costs as well as costs to human health and the environment” rests on cost effectiveness considerations.”

Not really; regulation has a way of cutting through inflated claims of high costs – there are many examples of this. In addition, cost-effectiveness usually ignores benefits of regulation so it is important to state them here.

Not included since this does not facilitate cost assessments, but are important factors to consider.

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Stockholm Convention Pollutants

Documents

Transcript of Stockholm Convention Pollutants