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Werkfeuerwehrverband Deutschland

WFVD

Die Werk- und Betriebsfeuerwehren sowie die betrieblichen Brandschutzbeauftragten haben im Rahmen der dem Brandschutz dienenden Organisation eine besondere Aufgabe.

Lobbying Activity

Response to Persistent organic pollutants: long-chain perfluorocarboxylic acids, their salts and related compounds.

15 Dec 2025

The Werkfeuerwehrverband Deutschland (WFVD) (German Industrial Firefighters Association) welcomes and supports the proposed amendment to Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), which seeks to list perfluorocarboxylic acids (C9-21 PFCAs), their salts and related compounds, as decided at the twelfth meeting of the Conference of the Parties to the Stockholm Convention, in Annex A, in accordance with Article 15(1) of Regulation (EU) 2019/1021. However, we suggest adopting the same UTC limit values recently introduced for PFOA by the Commission Delegated Regulation 2025/1399 also for long-chain perfluorocarboxylic acids in firefighting foam to avoid regrettable substitution, for the reasons outlined in the attached document.
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Response to Persistent organic pollutants – PFOA limits and exemptions

6 Dec 2024

We welcome and fully support the proposed amendment to Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), which seeks to extend the specific exemption for the use of perfluorooctanoic acid (PFOA), its salts, and PFOA-related compounds in fire-fighting foams until 3 December 2025 and to set a specific Unintentional Trace Contaminant (UTC) limit for PFOA-related compounds in fire-fighting foams for a period of 3 years. Avoidance of Regrettable Substitution The proposal is particularly commendable as it reduces the risk of "regrettable substitution," where PFOA-containing foams are replaced with alternatives that are PFOA-free but still contain other per- and polyfluoroalkyl substances (PFAS). Allowing operators additional time provides an opportunity to transition directly to fluorine-free alternatives, which is more complex and requires technical changes at systems. A transition from PFOA-containing foams to PFOA-free AFFF that still contain other PFAS is relatively easy and tempting if insufficient time is allowed for a complete transition. Requirement for Adjusted Limits on PFOA While we support the introduction of a Unintentional Trace Contaminant (UTC) limit for PFOA-related compounds in fire-fighting foams, we strongly urge the Commission to also adjust the limits for PFOA itself. Evidence indicates that PFOA is present in fire-fighting foams at concentrations significantly exceeding the established limits. We would like to draw attention to the attached study, which highlights the prevalence of PFOA in fire-fighting foams at levels exceeding the current thresholds. This underscores the necessity of revising the UTC limit for PFOA to address the practical challenges faced by operators in complying with the regulation. Proposed PFOA Limit Based on the findings of the attached study and the need to ensure consistency and feasibility in regulatory compliance, we propose setting the UTC limit for PFOA in fire-fighting foams at 1000 µg/kg. This adjustment provides a pragmatic balance between ensuring the effectiveness of the regulation and addressing the technical constraints associated with a transition to PFAS-free foams.
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Response to Persistent organic pollutants – Annex I amendment

22 Dec 2023

Dear Madam or Sir, Please consider the attached feedback on the draft delegated regulation Persistent organic pollutants PFOS limits and exemptions concerning transition periods and the UTC for the use of PFOS in firefighting foam. Best regards, Eike Peltzer
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