EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

Europaudvalget 2022-23 (2. samling)
EUU Alm.del
Offentligt

Water Technologies & Solutions

3600 Horizon Blvd

Trevose, PA 19053

Tuesday 7 June 2022

Mr. Martin Beekman – Netherlands

Dr. Mandy Lokaj – Germany

Ms. Jenny lvarsson – Sweden

Mr. Toke Winther – Denmark

Mr. Audun Heggelund – Norway

Mr. Mark Blainey

–

ECHA

Dear Madam or Sir,

Suez Water Technologies and Solutions (WTS) is a provider of ultrafiltration membranes

made of fluoropolymer (PVDF), as well as Polyether Sulfone (PES). We supply our

technologies to Water and Wastewater plant constructors and operators in Europe and the

rest the world, who are like us, committed to healthier potable water, and water resource

protection and sustainability through direct reuse for irrigation, industrial usages, and

replenishment of our surface and ground waters.

Suez WTS has also developed and introduced a range of removal and remediation

technologies and services to address contamination of PFAS for industrial, military, and

municipal sites as described in the Appendix A. This offer is unmatched in ability to be

tailored to specific situations at the lowest possible capital and operating expenditure.

We made the decision to contact you directly through this letter in order to provide an

explanation of the criticality of both PES and PVDF filtration membranes for water and

wastewater treatment which are both essential to our society. WTS manufactures

membranes at our factory located in Europe (Hungary) and we are able to provide solutions

for different applications and achieve the highest finished water purification, including

eliminating pathogens (parasites, bacteria and viruses), micropollutants (such as pesticides,

pharmaceuticals, personal care products (PCPs), endocrine disruptors (EDCs)) and

microplastics. The WTS PES membrane is used for potable or industrial water production

where source water contains low levels of solids and dissolved organic matter (e.g., ground

water sources or low turbidity surface water). The WTS PVDF membrane is used for

treating municipal sewage and industrial wastewaters and, increasingly, surface water

bodies subject to runoff due to Climate Change. These impacted surface waters contain

high levels of turbidity and pollutants. PVDF membranes have superior properties that allow

them to be used in these challenging applications, whereas PES membranes are not

suitable. For this reason, the water and wastewater industry relies on PVDF membranes for

these critical applications and considers this polymer to be essential to sustaining a

substantial install base of existing water and wastewater treatment plants and to meet the

growing need for this advanced treatment solution across Europe and the rest of the world.

[email protected]

Jenny. [email protected]

[email protected]

[email protected],eu

EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

Our PVDF membrane characteristics and applications are described in more details in the

Appendix B. Our list of references can be found in the Appendix C, detailed by country and

essential uses for water and wastewater treatments.

WTS is aware of the concerns raised over certain PFAS compounds. For this reason, it is

important for us to highlight the significant differences in the properties between PVDF

which belongs to the “polymeric PFAS” group of compounds and the “non polymeric PFAS”

type of compounds (e.g., PFOA and PFOS). PVDF has high molecular weight, is insoluble

in water and is not able to penetrate human and animal cells. WTS is not aware of any

issues raised in regard to the break-down of our PVDF membranes or PFAS compounds

leaching from our PVDF membranes throughout our extensive installations of water and

wastewater treatment plants. In summary, we see no risks associated with PVDF and to the

contrary we see PVDF as necessary in the industrial use of membranes for water and

wastewater treatment which is critical to public health and to protecting the environment.

We attached in Appendix D and E two position papers that illustrate more in details the

impact of both categories of PFAS and the distinction that should be made between the

“Polymeric” and the “Non Polymeric”.

We are at your disposal for any questions that you may have before completing your

evaluation on PFAS. You can contact:

•

Peter Ohle, UF Commercial Leader in Europe, [email protected]

Nick Adams, UF and RO Global Technology Leader, [email protected]

Eric Landais, Chief Technology Officer, [email protected]

Best regards,

Greg Brickett

Vice President

Global ZeeWeed Business Line

Attached Appendices:

•

Appendix A: WTS brochure for PFAS remediation and removal,

Appendix B: Information on WTS PVDF membrane applications, critical properties and

impact of transitioning to a non-fluoropolymer alternative,

Appendix C: WTS installed base in Europe of PVDF membranes,

Appendix D: A critical review of the Application of Polymer of Low Concerns (Author:

Barbara Henry – 30 January 2018),

Appendix E: A critical review of the Application of Polymer of Low Concerns II (Author

S.H Korzeniowski– 5 June 2022).