Tuttlingen – You have the opportunity to take part in the consultation on the PFAS restriction process on the European Chemicals Agency ECHA website until September 25th. MedicalMountains GmbH has already contributed its position paper.
This dossier, submitted by authorities from Germany, the Netherlands, Sweden, Norway and Denmark, is causing quite a stir. According to the current status, almost 3,000 individual entries have been made since March, from manufacturers, associations and research institutions, from across the EU as well as from Switzerland, Japan and the USA. After the internal count, the statement from MedicalMountains GmbH can be found under ID 6609.
“We have been in contact with numerous manufacturers over the past few months and have looked at the topic of PFAS together,” says Meinrad Kempf, project manager at MedicalMountains GmbH. “What went into our position paper and correspondingly into the consultation process reflects the assessments of our network.” What is at the top: a differentiated, risk-based approach is needed. “We do not fundamentally reject the restriction procedure,” emphasizes Meinrad Kempf, “because there is no doubt that substances with a high risk potential should be regulated.” This has already happened in the past. But now thousands of individual substances are threatened with a blanket ban - and with it those fluoropolymers and elastomers that differ significantly from compounds of concern. “They are essential for safe and innovative medical technology,” says Meinrad Kempf, summarizing the feedback. Neither currently nor in the future can the unique properties be completely replaced by alternatives. “It means that a number of applications will fall by the wayside,” he fears.
Further statements can be submitted until September 25th, although the overall process is low-threshold. Entries can be made either publicly or confidentially. Comments relating to the procedure can first be entered using a text field. More specific points on emissions, recycling or missing fields of application follow. There is no obligation to fill out these fields. The same applies: You can initially keep the information general and add it at a later date. “It is important to take part in the consultation at all,” says Meinrad Kempf – even if it is at the last possible moment.
- The MedicalMountains GmbH position paper can be obtained free of charge in file version 2.0 from this link and used for your own argument.
- This link leads to the ECHA consultation process.
