Let us deal again with the matter that is playing a co-protagonist role with the Fgas Regulation in the field of the restrictions to the use of fluorinated gases, to understand what is happening, what are the reasons on the field and what the future dynamics, from both a point of view of regulatory procedure and of technical, industrial and economic consequences.
Please, note this date: September 25th. It is the deadline to deliver the competent Commission Committees of the European Chemical Agency (ECHA) stakeholders’ observations about the PFAS dossier under analysis by the body that supervises the indications on the matter of REACH, Registration, Evaluation, Authorization and Restriction of Chemicals and that will submit a non-binding, but certainly determinant, opinion in the European Commission’s decision about the topic.
It is an important date, because from that time onwards the decision will no longer have influenceability terms by the subjects who operate in the market and this engages all those who have something to say on the matter to draw up observations, questions and indications (supported, if possible, by numerical scientific or economic evidences) and to transmit them in such a way as to make them available for the two work teams who will produce the final outcome.
Questions in cascade
- The question of fluorinated refrigerants recovered and considered (at present) also by the Fgas Regulation as usable has a manifold meaning also in terms of circular economy, because they generate longer life times and a softer approach to the life end than those feared by the many subjects frightened by an immediate scrapping of “forbidden” machines because there is no more available refrigerant to make them work.
- Industrial and applicative feasibility: how can we claim to install the 30 million heat pumps indicated as target by RePower EU if we have not an industry able to manufacture and a team of installers who can set the heat pumps in operation with alternative refrigerants that satisfy both the Fgas Regulation’s requirements and the restrictions that the Council of Europe, European Parliament and ECHA will provide for PFAS?
- Energy saving: are we sure that a restriction to the use of synthetic refrigerants, like the one that the combined Fgas-PFAS will produce, does not determine a short-term increment of the carbon footprint? The opinions about the achievable energy efficiency with alternative refrigerants are not univocal (on the contrary, they are not at all) and –in the case of harmful refrigerants – we will have to choose secondary circuits whose efficiency is by definition lower than the direct expansion one.
- Safety: we have just stated it, but is worth writing it clearly, alternative refrigerants belong to higher risk classes that those today in use, because they are flammable, toxic and asphyxiating. Therefore, we have to create a technical culture that grants their use under safety conditions for operators and those who make use of the equipment performance.
- Components: many of the elements that make up the plant contain components in which the use of fluoropolymers is determinant part of the manufacturing cycle and the efficient and efficacious replacement of these proceedings takes a time of scientific and technological processing that is hardly evaluable by the author of the article.
Somebody will tell us that all these issues are of industrial character and do not consider the key target of citizens’ health, but our opinion is different.
(Non) in conclusion
The discussion is open and it does not stop on September 25th, on the contrary: irrespective of the weight of the observations received by ECHA, how much proponents’ dossier will be discussed in Committees, how the final decision will be mediated or unbalanced are certainly fundamental data but they do not close the debate, under certain respects, on the contrary, they relaunch a method consideration that is not put on the table for the first time.
The issue of the environment and of cold technologies’ impact on the health of all those who work in refrigeration industry or make use of cold is at the core of the concerns of industry and of the applicative chain of refrigeration players, who are citizens as well and then interested in living in a planet where it is possible to live well, but they are also holders of a fundamental instance for whatever intervention on these matters: the concrete feasibility.
In the spirit of producing an ameliorative environmental condition for us and for future generations, problems must be faced, all, without ifs and buts, but with an overall direction perspective that does not create a system of communicating vessels in which, to stop PFAS, we create other environmental and safety risks.
PFAS are a problem in a context, an element in a scenario: we wish – from these pages and well as from the daily work that we carry out in this sector – it is solved without creating others.