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:
Submitted restrictions under consideration - ECHA
This table shows ongoing consultations on conforming restriction proposals and SEAC draft opinions; the links to the…
Here’s an example of what a comment looks like from W.L. Gore — cliff notes. They are invoking the 5th.
“unless there is an overriding public interest in disclosure…”