Did you know that more than 4,000 individual substances are categorized as per- and polyfluoroalkyl substances (PFAS)? PFAS have been used in a wide range of products that have included ski wax, automotive gaskets and seals, and medical devices.
That is why “one-size-fits-all” regulation of all 4,000+ PFAS is bad policy. For purposes of regulation, it is critical to draw distinctions between PFAS with environmentally persistent and bioaccumulative properties and those without them – such as HFCs and HFOs.
The European FluoroCarbons Technical Committee (EFCTC) released a position statement on regulation pertaining to PFAS: “any regulatory action should be at the subset or individual substance level and not at the PFAS group level and should be based on sound scientific evidence that takes into account specific structures and properties.”
globalFACT endorses the position of EFCTC: low-GWP HFCs and HFOs are critical to the world’s HVACR operations and do not pose an environmental risk. They should not be included in broad definitions of PFAS for purposes of regulation.
The full EFCTC policy position paper is available here.