UNIFE, the ‘voice of the European rail supply industry’, counts many train manufacturers and makers of components as their members, and also sees the risks of PFAS. “We support tackling the challenge posed by PFAS chemicals”, says UNIFE Director General Philippe Citroën. The transportation sector (including aviation, trains and boats) is “the largest sector by far” with 16,000 tons of fluoropolymers (part of the PFAS group) sold to the sector in 2020, according to a 2022 report by UK consultancy firm Wood. However, for many applications of PFAS, there is no current alternative available, it appears from an analysis of UNIFE, shared with RailTech.
PFAS in the rail industry
There are a myriad of uses of PFAS in the railway sector. RailTech spoke to Josu Alsua Ancisar, an engineer who has worked at Spanish train manufacturer CAF for 15 years and is now responsible for design for the environment. PFAS are ‘almost everywhere’ in a train, says Alsua, as in many other elements that we use on a daily basis. He lists a few examples: “They can be found in the windscreen wipers, the train control system, batteries, the train doors, on-board defibrillators, air supply systems, traction converters…” and he goes on for a while. Also in the signaling systems, both inside the vehicle as well as in the infrastructure, there are elements containing PFAS.
Even in the train seats, PFAS are used. “With so many people using the seats, you need to use some repellents, to keep them clean with risks of spillages. Those repellents currently contain PFAS. We are all surrounded by elements containing PFAS in our daily life and that is also the case for the trains”, says Alsua.
The restriction proposal
The European Chemicals Agency (ECHA) made a proposal to restrict per- and polyfluoroalkyl substances (PFAS) in the European Economic Area, under the so-called REACH Regulation. Companies and stakeholders had six months to comment on the proposal. By the end of the six-month consultation on 25 September 2023, ECHA had received more than 5,600 comments from organizations, companies and individuals on the proposal to restrict PFAS. The railway sector is not the only one where a ban on PFAS would have a large impact. The chemicals are widely used in many industrial sectors, such as electronics, energy, health care and food packaging.
The reason for this, as the ECHA puts it is that “due to their water solubility and mobility, contamination of surface, ground- and drinking water and soil has occurred in the EU as well as globally and will continue. It has been proven very difficult and extremely costly to remove PFASs when released into the environment. Without taking action, their concentrations will continue to increase, and their toxic and polluting effects will be difficult to reverse.”
The ECHA estimates that for the EU, 140000 to 310000 tons of PFAS were introduced to the market in 2020. This is expected to increase even further under the baseline scenario. Over a 30-year period, the expected mean PFAS tonnage in the European Economic Area is 49 million tons, leading to emissions of about 4.5 million tons during the manufacture and use phase when no action is taken. The emissions during the waste phase, which may be significant, are not accounted for in that estimate as they are highly uncertain. Hence, it can be assumed that emission estimates are severely underestimated, says the Agency.
Challenge to even map PFAS use
Two restriction options have been assessed in the proposal by the ECHA. A full ban with no derogations and a transition period of 18 months, and a full ban with some use-specific time-limited derogations, which would have an 18-month transition period plus either a five or 12-year derogation period. Although both restriction options are deemed proportionate to the risk, the Dossier Submitters propose the second one as the most balanced option, even though a delay in banning PFASs as a result of the proposed derogations will “shift the cost burden arising from health and environmental impacts to future generations”.
No safe alternatives available
The main issue now is that there are very few alternatives – and sometimes none – to elements containing PFAS for the rail industry and manufacturers like CAF. “As in many other industrial sectors, there are some elements in rail where we do not have any viable PFAS-free alternative available at the moment”, says the CAF engineer. “Many of the applications which rely on PFAS use are critical for various essential rail components and are also required for spare parts and maintenance activities, the ban will trigger a cascade of far-reaching consequences.”
He highlights that sometimes, the PFAS are crucial to ensure the safety of operations. For tanks transporting dangerous goods via rail, for example, there are sealants needed containing PFAS. In the analysis of UNIFE, no other alternatives for that purpose have been found. “Trains are not only a system with low carbon emissions, but also a really safe means of transport. Trains are used in a very intensive way, with thousands of kilometers driven a year and a lot of people transported. So we need very reliable and service-proven solutions”, says Alsua.
“The rail vehicles have to withstand very harsh environmental conditions such extreme temperatures, corrosion, pollution, humidity, mechanical stress… and the solution given by materials which include PFAS has represented a very reliable and safe solution for the industry”. In some cases, UNIFE does see alternatives to PFAS available, such as for casing in the air supply unit. “There is an alternative available, but not enough information about it. It is required to test and validate these alternatives before using them”.
‘Uncertainty bad for the industry’
Now that UNIFE and at least 4400 other parties have submitted comments and requests for derogations on the European Chemical Agency’s proposal, the ECHA will check the comments. They will look into Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) in various committees and will adopt an opinion which will be published. The five countries who prepared the initial proposal, Denmark, Germany, the Netherlands, Norway and Sweden, will also review the consultation input and may update their initial proposal based on it.
The ECHA will deliver their final opinions to the European Commission in the “shortest possible time frame”, but it is unclear how long this will take. Looking at the amount of responses to the consultation, this may take a while. The European Commission, together with the EU Member States, will ultimately decide on the restriction. Philippe Citroën, Director General of UNIFE: “We support tackling the challenge posed by PFAS chemicals. The timeframe contemplated as of now – a nearly total ban of all PFAS by 2027 – would nonetheless challenge rail manufacturing operations and put severe pressure on supply chains. The mapping exercises by the rail supply industry portray just how complex any transition away from these chemicals will be”, says Citroën.
One of the main concerns of the rail supply industry is also how to keep the trains working. Alsua: “If a full ban came into place, it would additionally be a problem for the maintenance, spare parts and refurbishments of the existing rail vehicles. In the end, you have to keep the trains moving, and you cannot always put alternative elements in an existing train without an extensive testing campaign.” If there is a 6-month review by the ECHA and then a new directive is in place, the manufacturer would have very little time to adapt their production chain and it is very unlikely that we will be able to find suitable alternatives in such a tight deadline, he stresses.
The unclear situation is, according to CAF engineer Alsua, “bad for the industry.” The proposed 18-month transition period after the ban is adopted is deemed too short to adapt to a new reality. “There are a lot of doubts about what will happen in the next months and years. We need to work with some certainty, the R&D projects to find alternatives will take several years. That is why we have asked for derogations in many cases for our applications of materials with PFAS. We will need time.”
Source: www.railtech.com