Socio-Economic Analysis for a Reach Restriction Proposal on PFAS in the Upstream Oil & Gas, Oil Refining and Fuel Distribution Sectors, and in Carbon Capture and Storage
Concawe and the International Association of Oil & Gas Producers (IOGP) commissioned Ricardo AEA Ltd (Ricardo) to produce an independent Socio-Economic Analysis (SEA) for the potential EU REACH restriction of Per- and polyfluoroalkyl substances (PFAS), following the European Chemicals Agency’s (ECHA) guidelines.
The scope of the proposed PFAS restriction is wide, covering several groups of substances and uses across many sectors. Given this breadth, the SEA presented in this report focuses on a prioritised subset of PFAS containing materials that are critical to selected industrial activities. Specifically, the analysis focuses on fluoropolymers and fluoroelastomers used in sealants, coatings for wires, capacitors, and pipes; within upstream oil and gas operations, oil refining, fuel distribution, and carbon capture and storage (CCS).
This means that other PFAS groups, including fluorosurfactants, low molecular weight PFAS, fluorinated gases, and processing aids, are explicitly out of scope of this SEA.
Accordingly, references in this report to ‘PFAS-containing equipment or materials’ specifically relates to fluoropolymers and fluoroelastomers (and not, for example, to fluorosurfactants) unless otherwise stated. Understanding this distinction is essential to correctly interpret the findings. While certain non polymeric PFAS have been reported to be persistent, mobile and/or bioaccumulative, and toxic, these hazards have not been scientifically demonstrated for polymeric PFAS such as fluoropolymers and fluoroelastomers. Whilst fluoropolymers and fluoroelastomers are also environmentally persistent, they are also reported to be biologically inert and non-toxic.
In the absence of comprehensive sector specific emission and exposure data, this independent SEA adopts a precautionary and conservative analytical approach within the scope of this study which is consistent with our understanding of ECHA’s guidelines.
Potential PFAS emissions from fluoropolymer and fluoroelastomer containing equipment during normal use are considered to be very low, although quantitative data are limited.
From a life cycle perspective, PFAS emissions from fluoropolymer and fluoroelastomer containing equipment are likely during the manufacturing and end of life treatment of these polymers . Available evidence indicates that 83.5% of industrial PFAS-containing materials (of all forms) is sent for incineration , which at high temperature destroys polymeric PFAS. However, Concawe and IOGP confirm that these activities are largely outside the operational control of oil and gas operators.
Whilst the scope of this SEA study is narrow (fluoropolymers and fluoroelastomers used in sealants, coatings for wires, capacitors, and pipes), this does not imply that fluoropolymers and fluoroelastomers represent the only critical PFAS uses within the oil and gas value chain.
The industry also relies on these and other PFAS in many additional applications, including (non-exhaustive list):
• Anti-foaming agents – used in fluids management
• Oil, gas and water tracers
• Batteries – in multiple large and small equipment sources and hand-held device
• Building and construction equipment
• Conveyor belt/roller systems – across a range of sizes/scales
• Electrical and electronic systems - well beyond the capacitor use explained
• Fastenings / fittings - a large range of simple equipment in this category
• Fire Suppression systems - (not foam in another restriction) but ‘clean agent’ mists
• Hydraulic Fluids – in multiple systems fixed and mobile
• Environmental sampling and monitoring equipment
• Laboratory / testing equipment
• Lubricants / Greases – speciality needs in highly constrained environments
• Membranes and Filters – in chemicals / fuel processing / separation and water treatment
• Power management systems - UPS/switchgear etc
• Refrigerants & Gases – in process chillers, HVAC, compressors, heat exchangers, laboratory equipment etc
• Safety Equipment – specific items of use – providing resistance to chemicals/hazardous environments, including personal protective equipment (PPE)
In addition, while this study assesses impacts on industrial activities directly operated or influenced by Concawe and IOGP members, the potential impacts of restricting fluoropolymers and fluoroelastomers would extend well beyond the assessed applications.
These industrial impacts would propagate both up the value chain, affecting equipment manufacturers and service providers, and down the value chain, affecting users of oil and gas products and renewable fuels that underpin essential economic activities.
In sum, this means that the impacts quantified in this SEA represent only a subset of the potential socio-economic and environmental implications of a broad PFAS restriction.
Finally, Concawe and IOGP plans to use this study to support their response to European Chemicals Agency’s (ECHA) consultation on their proposed EU REACH restriction on PFAS, as assessed by the European Chemicals Agency’s (ECHA) Committee for Socio-Economic Analysis (SEAC).