The ECHA’s 5600 Comments on PFAS From Stakeholders.

This article is only relative to the textile segment for Structural Firefighter PPE.

Diane Cotter
3 min readOct 16, 2023

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ECHA goes through a long process of gathering data, comments, compiling, compartmentalizing, and disseminating data. Still, it’s not easy to understand or surf. After the comments there will be next steps — we’ll be watching to see if industry wants to ‘derogate’ your turnout gear all together like they did in 2014 when ECHA held the line and said ‘no way’ —

If you recall you got what industry said was a ‘safety standard’ of 1 ppb PFOA and 25 ppm precursor — it wasn’t anything to do with health or safety it was a compromise.

ECHA BACKGROUND DOCUMENT ON PFOA — 2015:

ECHA does a very good job on disseminating the stakeholder comments and the intentions of ECHA. The difficulty is there is so much data, I’d of been discouraged if I had not surfed in their ocean before, but I was able to find the pieces I needed reference. The ECHA Background Document on PFOA was the first document I read back in 2016 after discovering PFOA may be in your gear. It is 371 pages and is filled cover to cover with everything you want to know to protect yourself. You’d have to be industry or in bed with industry if you could dismiss the intention of this powerful document.

We are looking at the ‘TULAC’ segment; Textiles, Upholstery, Leather, Apparel, and Carpets.

USE THIS INDEX TO ACCESS ALL COMMENTS:

Here’s an example of what a comment looks like from W.L. Gore — cliff notes. They are invoking the 5th.

Actually it’s Article 4 Section 2 of European Union Law here:

“unless there is an overriding public interest in disclosure…”

W.L. GORE to the EUROPEAN UNION:

MEASUREMENTS OF TOTAL FLUORINE in FIREFIGHTER PPE. THIS IS FOUND IN THE EXCELL SPREADSHEET IN THE INDEX.

(APPENDIX E4 in Restriction report annexes)

THANK YOU DR PEASLEE FOR SUBMITTING OUR STUDY. IT’S THE ONLY PEER REVIEWED MATERIAL ECHA HAS ON FIREFIGHTER PPE PFAS NUMBERS FOR TOTAL FLUORINE.

TAKE A LOOK AT THAT TOTAL FLUORINE…

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Diane Cotter

A very private individual who fell into a very public rabbit hole of epic proportions. I call it the #greatestdeceptionever - really, EVER.