01 June 2023
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Neil Roberts, Senior Technical Sales Manager at Climalife UK, explores the complex subject of 'Forever Chemicals'.
Over the last few months, you may have seen headlines from industry and national media outlets talking about ‘Forever Chemicals’ or PFAS, and how it could potentially affect the RACHP industry. But what is it really about?
As you might imagine it is a relatively complex and detailed situation, but the following is an attempt to explain where we are in the processes currently underway in both the European Union (EU) and Great Britain.
REACH
The legislation at the centre of all this is known as REACH (Registration, Evaluation, Authorisation and restriction of Chemicals). Every chemical used in quantities of 1 tonne per annum or more must have a REACH registration and be approved for use in the intended applications. Pre-2020 the UK conformed to the EU REACH legislation, but since 2020, Great Britain has followed its own UK REACH legislation and no longer has to conform to the EU legislation. There is a class of chemicals referred to as poly- and perfluoroalkyl substances (PFAS) which exhibit unique properties including tolerance to extreme temperatures and ability to repel oil and water that can be very desirable in many applications. But these very properties also make some of them slow to degrade meaning they can remain in the environment for many decades leading to them sometimes being referred to as ‘forever chemicals’.
Defining PFAS
There is no single globally adopted definition of what is a PFAS, but legacy products such as perfluorooctane sulfonic acid (PFOS) and perfluorooctane carboxylic acid (PFOA) have been regulated for some time, as they were identified as being highly persistent in the environment (P), bio accumulative (B) and toxic (T). In 2021 the Organisation for Economic Cooperation and Development (OECD) redefined what constitutes a PFAS, increasing the number of chemicals in the class to greater than 9000. This definition may include most of the fluorinated molecules used as refrigerants, with the exceptions of R-32, R-152a and R-23, and is based purely on molecules containing certain chemical structures and is not based on the PBT properties of the chemicals.
REACH Update Proposals
Using the new OECD PFAS definition, four EU member states and Norway published a Regulatory Management Options Analysis (RMOA), which is a non-binding technical document looking at the nature of the risks posed by PFAS and the most appropriate options for management of these risks. The proposal would ban the use of all the fluorinated refrigerants covered by the PFAS definition 18 months after entering into force with a few derogations for RACHP applications detailed in table 1.
This proposal from the four EU member states and Norway is now being reviewed by the European Chemicals Agency (ECHA). The next stages of the EU process will include a period where stakeholders will be able to submit their views on the proposals and provide more data to fill gaps, and committees within the European Chemical Agency (ECHA) will consider the proposals based on risk and social economic factors, using a fact and science-based approach.
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Restriction + 6.5 years of derogation |
Restriction + 13.5 years of derogation |
No time-limit derogation |
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low temperature refrigeration below -50°C |
laboratory test and measurement equipment |
HVACR-equipment in buildings where national safety standards and building codes prohibit the use of alternatives |
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mobile air conditioning-systems in combustion engine vehicles with mechanical compressors |
refrigerated centrifuges |
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transport refrigeration other than in marine applications |
maintenance and refilling of existing HVACR equipment put on the market before implementation and for which no drop-in alternative exist |
Table 1 - EU RMOA PFAS Derogations for RACHP Applications
Within Great Britain the Health and Safety Executive (HSE) supported by the Environment Agency (EA) were asked to prepare a RMOA for consideration by UK REACH and published their RMOA in April. Unlike the EU approach, the HSE chose to group compounds with similar physical-chemical properties and structures enabling group-level hazard evaluation and assignment of high or low risk categories. The report identified that compounds used in the RACHP industry are not persistent in the environment, not bio accumulative nor toxic and therefore posed a low risk. It was noted in the report that some of the compounds do breakdown in the atmosphere to form trifluoroacetic acid (TFA) which would require further consideration.
Research papers
Numerous peer reviewed research papers have been published on the presence of TFA in the environment. These papers have concluded that more than 95% of TFA found in the environment is formed from naturally occurring processes, e.g. chemical reactions in or around sub-sea volcanic vents, and the TFA produced from HFCs and HFOs would have a very small effect on the presence of TFA in the environment. These studies have also considered the growth in use of these molecules across the World and concluded that the effects are not significant.
This was recognised in a United Nations Environment Programme (UNEP) publication which stated “based on estimates of current and future use of HFCs, HCFCs, and HFOs, additional inputs to the global oceans, salt lakes and playas will add only fractionally (estimated to be less than 0.1%) to amounts already present from natural sources such as undersea vents and volcanic activity.”.
The HSE report also recognises that F-Gases are already heavily regulated and that the current legislation is under review which is likely to further limit the quantities of F-Gases being placed on the market.
In summary
The HSE are proposing to prepare background dossiers to support one or more UK REACH restrictions for high-risk products such as PFAS containing firefighting foams, coatings or cleaning agents and PFAS products used for textiles, upholstery, leather, apparel, rugs and carpets, paints, varnishes, waxes and polishes, cleaning products. The report also states “uses in sealed/contained systems (including use as heat exchange fluids in heat pumps and refrigeration systems), (low risk uses). These could be highlighted as derogations to any restriction proposal.”
The F-Gas legislation is already reducing the quantities of F-Gases placed on the market and encouraging users to move towards low global warming potential (GWP) alternatives. When looking at alternatives to higher GWP F-Gases it is important to have a full spectrum of options available to ensure compliance with safety standards and not sacrifice energy efficiency. At this stage both the EU and Great Britain RMOAs are just proposals, and there are still opportunities to influence the final outcomes by participating in the current or future stakeholder consultations. It is important that industry makes its voice heard to ensure that the final regulation does not impose severe and unnecessary restrictions for the RACHP industry. So, if you believe HFOs have a role to play in the future of the RACHP industry, make sure you keep up to date with the latest information from associations such as the British Refrigeration Association or refrigerant suppliers such as Climalife, and have a say in the future of your industry.
