What perfluorinated chemicals are covered?
A perfluorinated carbon chain refers to the structure of F-(CF2)n in a chemical substance. The perfluorinated carbon chain could be a portion of the chemical or polymer. The perfluorinated carbon chain in polymers may be incorporated in the structures of monomers.
In molecules such as PFOS and PFOA, the perfluorinated carbon chain length (n) is eight and seven, respectively. However, chemicals with shorter perfluorinated carbon chains (n = 4, 5 or 6) are being introduced into commerce increasingly as new chemicals, as Industry seek to shift their technologies away from PFOS and PFOA.
The US EPA PMN exemption rule has a cut-off of n=2 for fluorotelomers and n=1 for other perfluoroalkyl moieties in polymers. The US EPA also proposed significant new use rule on PFAS substances with a fluorinated chain equal and greater than five carbons. Environment Canada proposed restrictions on four chemicals with n³4 perfluorinated carbon chains.
Based on the scientific evidence and overseas regulatory agency actions, NICNAS has determined that the additional data requirements, in Australia, apply to new chemical substances with a perfluorinated carbon chain length (n) equal to or greater than four carbons, whether linear or branched.
An upper limit of a perfluorinated carbon chain length will be set on practical grounds, and where the perfluorinated chain length is greater than 24 carbons, these will no longer be considered to be covered by this action plan for assessment and management of PFCAs and PFASs.
NICNAS has determined that, for new chemical notifications, the additional data requirements apply to:
- Perfluorinated chemicals and polymers listed in the 'Preliminary lists of PFOS, PFAS, PFOA and related substances' (consisting of approximately 600 chemicals), where these are being introduced to Australia for the first time.
- Chemicals and polymers other than those on this list where these include a perfluorinated carbon chain of length (n) equal to or greater than four carbons, whether linear or branched, other than those in the categories listed below.
Importantly, the additional data requirements will not apply for:
- Chlorofluorocarbons(CFCs), hydrochlorofluorocarbons (HCFCs), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), hydrofluoroethers (HFEs), perfluoroethers (PFEs) and polymers with fluorinated backbone structures, except where these have side chains meeting the above description which are separated from the backbone by non-fluorinated segments.
In specific cases where it is not clear to a notifier whether these requirements apply, NICNAS will assist the notifier in reviewing the chemistry and advise of data requirements for notification.
Last update 13 August 2018