COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFCATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS

Disclaimer: Comments provided during the consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a substance of very high concern. 

Substance name: Perfluoroheptanoic acid and its salts
CAS number: -
EC number: -

The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: Toxic for reproduction (Article 57c);PBT (Article 57d);vPvB (Article 57e);Equivalent level of concern having probable serious effects to human health (Article 57(f) - human health);Equivalent level of concern having probable serious effects to the environment (Article 57(f) - environment)

PART I: Comments and responses to comments on the SVHC proposal and its justification

General comments on the SVHC proposal
Number / Date	Submitted by (name, submitter type, country)	Comment	Responses	
5623
2022/10/12	Norway,
Member State	The Norwegian CA supports that perfluoroheptanoic acid and its salts should be identified as substances of very high concern and should be included in the Candidate List. We agree with the dossier submitter that with the fulfilment of the criteria for classification as Repr. 1B H360D, perfluoroheptanoic acid and its salts meet the criteria for identification as a SVHC in accordance with Article 57 (c) of REACH. We also agree with the dossier submitter that with the fulfilment of the criteria for classification as STOT-RE 1 H372 (liver), perfluoroheptanoic acid and its salts fulfil the T-criterion according to Annex XIII of the REACH Regulation.
We support that perfluoroheptanoic acid and its salts fulfil the SVHC criteria in REACH Article 57 d) persistent, bioaccumulative and toxic (PBT) and Article 57 (e) very persistent and very bioaccumulative (vPvB). We agree with the weight-of-evidence approach the dossier submitter has used to identify the substances as PBT and vPvB.
Furthermore, we fully support this proposal to identify perfluoroheptanoic acid and its salts as substances of equivalent level of concern to Art. 57 a to e. The equivalent level of concern has been clearly described and follows a case-by-case approach using the weight of evidence evaluation. The Norwegian CA strongly supports this case-by-case approach demonstrating ELoC.
	Thank you for your comments in support of the Annex XV dossier. 	
				
5628
2022/10/13	Daikin Industries, Ltd.,
Company,
Japan	In Daikin’s view,
(page 1 through 2)
1. Bioaccumulation of PFHpA and its salts is scientifically not proven.
One of the reasons is that half-life is not enough as evidence for B-assessment.
Also, half-life estimates based on urinary excretion are less certain.
When the B/vB is scientifically not justified, criteria of PBT/vPvB is not considered to be fulfilled.
(page 2 through 3)
2. SVHC listing of PFHpA and its salts because of ELoC to PFOA is not appropriate due to lack of individual assessment.
(page 3)
3. There is no sufficient necessity of listing PFHpA and its salts to SVHC list due to lack of information on application/uses and REACH registration.	Thank you for your comments and considerations.

Regarding your comment on bioaccumulation: Please see our response to comment 5628 2022/10/13 in the “Specific comments on the justification” section of this RCOM.

Regarding your comment on the ELoC assessment of PFHpA: We note that the ELoC assessment in the SVHC proposal used the available data on PFHpA (e.g. data on adsorption, monitoring, long-range transport potential and toxicity), as well as data available for the structurally related substances PFOA, PFHxA and HFPO-DA. The read-across to these substances has been justified in the SVHC proposal. Therefore, NL does not agree with your comment that there was no individual assessment of PFHpA.

Regarding your comment on the necessity to identify PFHpA as SVHC: We consider that SVHC listing of PFHpA is necessary as the substance meets several SVHC criteria and is ubiquitously present in the environment. While PFHpA itself is indeed not registered under REACH, longer chained PFAS that act as precursors are registered under REACH. SVHC identification of PFHpA will impact the use of these precursors and thus reduce emissions of PFHpA.	
		Attachment: 5628_Daikins opinion on PFHpA SVHC listing proposal (20221013).pdf
		
5631
2022/10/13	Health and Environment Alliance (HEAL),
International NGO,
Belgium		See our response to comment 5631 2022/10/13 in the “Specific comments on the justification” section of this RCOM. 
	
		Attachment: 5631_HEAL Comments-Perfluoroheptanoic acid and its salts.pdf
		
5675
2022/10/17	ANSES,
National Authority,
France	Page 57: Please add a reference to the following statement : These half-lives exceed the range of guiding values for biomagnificating substances in humans that are considered to be in the range of 30 to at most 70 days.	Thank you for the question. The reference to these guiding values is the discussion paper on bioaccumulation in air-breathing organisms that is being drafted for ECHA, as well as the upcoming revised R.11 guidance. However, as these sources have not yet been published, they cannot be referenced. Therefore, we decided to remove the referencing to guiding values altogether. Instead, we elaborate in the supporting document on the critical half-life value of 70 days that has been derived by Goss et al. (2013) based on the assumptions that the food and human body have equal lipid contents and that an average person of 70 kg person eats 0.7 kg food each day (0.01 kg food/kg bw/d). We further explain that a more realistic food intake of 1 kg food per day results in a lower critical value of 50 days and reason that the critical value can be as low as 30 days, depending on the food intake rate. As in all human studies the arithmetic and geometric mean half-lives exceed both critical values, it can be concluded that PFHpA will biomagnify in humans, and thus is to be considered very bioaccumulative. 

5721
2022/10/17	3M,
Company,
Belgium		See our response to comment 5721 2022/10/17 in the section “Specific comments to the SVHC proposal”

		Attachment: 5721_3M comments on SVHC proposal for pFHPA.pdf

Specific comments on the justification
Number / Date	Submitted by (name, submitter type, country)	Comment	Responses	
5628
2022/10/13	Daikin Industries, Ltd.,
Company,
Japan		Regarding your comment that bioaccumulation of PFHpA and its salts is scientifically not proven we note the following:
 
According to Sections 3.2.2 (b) and (c) of Annex XIII of REACH the bioaccumulation potential of a substance can be determined by comparing bioconcentration factors to the numerical B and vB criteria, but also by assessing in a weight of evidence (WoE) approach information such as: elevated levels in biota, information on the ability of the substance to biomagnify in the food chain, data from analysis of human body fluids or tissues and assessment of toxicokinetic behaviour of the substance. We followed a WoE approach as envisaged by REACH. According to the Annex to Annex XIII, section 3, the inclusion of this information in the assessment is not optional but mandatory.

Your comment that R.11 guidance clearly shows that B and vB criteria cannot be determined only by half-lives is considered misleading. You base this argument on the sentence “However, it should… is necessary” from page 84 of the guidance, without reflecting on the necessary context. The respective “Log Koa” section as well as the section “Toxicokinetic studies with mammals” (page 81) do note that specific cut off criteria to compare elimination data with the B/vB criteria are not recommended. The underlying reasoning is not that such data are unsuitable, but that at that time insufficient knowledge was available on the factors determining elimination rates (e.g. allometry in physiological and metabolic processes of species). In the section “Toxicokinetic studies with mammals” it is stated that elimination rates and half-lives are useful metrics indicative of the bioaccumulation potential. Furthermore, the section concludes that the use of toxicokinetic data in B-assessment is under scientific development and that the qualitative recommendations given in the guidance are based on current knowledge and experience. Considering that in the meanwhile knowledge has been gained on the use of toxicokinetic data in B-assessment (which will be incorporated in the upcoming R.11 guidance update), we consider that our WoE approach, where information on the bioaccumulation potential of PFHpA in laboratory mammals and humans as well as data from analysis of human body fluids was used, clearly shows that PFHpA is very bioaccumulative. Especially when considered that daily food intake in humans is higher than earlier assumed resulting in a lower critical half-life in humans (for details see response to comment 5675 2022/10/17 above). 

Your comment that half-life estimates based on urinary excretion are less certain, is agreed upon. In the proposal we discussed the associated uncertainties extensively and concluded that despite the identified uncertainties the derived half-lives and BMF values are considered reliable and rather underestimate and not overestimate the bioaccumulation potential of PFHpA in pigs due to the considerations mentioned in SVHC support document. We also note in the conclusion on human toxicological half-lives (section 4.1.3 of the support document) that the method (rate of urinary excretion or time series of blood/serum concentrations) has only limited influence and that for both methods half-lives in the same order of magnitude are obtained.
	
		See the corresponding embedded attachment in table 1 of Part I: 5628_Daikins opinion on PFHpA SVHC listing proposal (20221013).pdf		
5631
2022/10/13	Health and Environment Alliance (HEAL),
International NGO,
Belgium	The Health and Environment Alliance (HEAL) thanks the Dutch Competent Authority for its proposal and fully supports the identification of PFHpA and its salts as a substance of very high concern (SVHC) due to its reprotoxic properties (article 57(c)), its PBT properties (Article 57(d)), its vPvB properties (Article 57(e)), and its endocrine disrupting properties relevant for human health and the environment (article 57(f)). Our detailed comments can be found in the attached document.
	Thank you for your comments in support of the Annex XV dossier.
Regarding your proposal to look at PFAS as a group when evaluating toxicity, NL would like to note that for this SVHC proposal it is relevant that PFHpA has a harmonised classification as Repr. 1B (H360D) thus meeting Art 57(c) requirements as well as the T-criterion of the PBT assessment. That said NL noted in the proposal that literature indicates that different PFAS have similar, additive, effects, increasing the concern for serious effects in the environment. We also pointed toward this in our paper “Risk Assessment of Per- and Polyfluoroalkyl Substance Mixtures: A Relative Potency Factor Approach” (https://doi.org/10.1002/etc.4835).

We considered the references you included, but as they did not provide data on PFHpA we did not include them in the support document, i.e. Papadopoulou et al. (2019) and Zhang et al. (2022) studied C8- to C11-PFCAs, but not PFHpA; and your factsheet on PFAS contains general information no PFAS.	
		Attachment: 5631_HEAL Comments-Perfluoroheptanoic acid and its salts.pdf
		
5635
2022/10/14	Germany,
Member State	The German CA supports the identification of perfluoroheptanoic acid and its salts as substances of very high concern (SVHC). The substances are proposed to be identified meeting several criteria according Article 57 (c), (d), (e) and (f) of Regulation (EC) No 1907/2006 (REACH) due to its respective hazardous properties.

4.1.1 Non-human information
1st paragraph, 2nd sentence: Toxicokinetics data are available for mice. Please see Fujii et al., 2015 and supplemental material. DOI: 10.1539/joh.14-0136-OA.

Generally, the term PFASs in this section probably rather refers to PFCAs or PFAAs than to all PFASs. In general, we suggest a list of PFASs that were investigated in each of the described studies.

Rats
It is unclear, whether Kudo et al. 2001 also measured PFHpA.

4.1.2 Human information
Reference missing within study description of Freberg et al., 2010.

5.2.2 Endocrine Disruption
The reference for the study following OECD TG 422 is missing.
	Thank you for your comments, information provided and suggestions for further improvement of the Support Document.

Regarding toxicokinetic data for mice, we added the suggested study (Fujii et al., 2015) to Section 4 of the Support Document.

Regarding your suggestion to list all studied PFAS in each of the describes studies, we consider it clearer to include only read-across relevant substances (C4- to C14-PFCA’s). 

Regarding your comment if Kudo et al. 2001 measured PFHpA, the answer is confirmative. The study uses the abbreviation PFHA for perfluoroheptanoic acid. This is evident from earlier work from Kudo et al. to which is referenced (Kudo et al. 2000; https://doi.org/10.1016/S0009-2797(99)00150-7).

Regarding section 4.1.2, we fixed the cross reference to table 8 in the study description of Freberg et al. 2010.

Regarding section 5.2.2, the requested reference has been included added to the support document.	
				
5649
2022/10/14	Sweden,
Member State	The Swedish CA thank the Netherlands for this proposal and agrees that PFHpA and its salts meets the criteria according to Article 57(c), 57(d) and 57(f) in REACH and is thus eligible for identification as a substance of very high concern.
However, as regards the criteria of Article 57 (e) we are not convinced that PFHpA and its salts are vB. The reason for this is that such a conclusion would be inconsistent with the conclusions drawn when PFOA was identified as a substance meeting the B-criteria of Article 57 (d). The weight of evidence approach used for the B-criteria for PFOA includes among other things also half-lives in humans in the range from 2 – 4 years. As the argument of half-lives in humans and other species also is used for PFHpA, but the half-lives for PFHpA in all studied species always are shorter than those of PFOA, we find the conclusion that the half-lives of PFHpA supports vB not being consistent with the conclusions previously drawn for PFOA.	Thank you for your comments in support of the SVHC identification based on Article 57(c), 57(d) and 57(f). 

Regarding your comment that you are not convinced that PFHpA is a vB substance, as such a conclusion would be inconsistent with the conclusions drawn when PFOA was identified as a substance meeting the B-criteria of Article 57 (d), we note the following: PFOA has indeed much longer half-lives in all studied species with half-live values in humans ranging 2 to 4 years. In our view PFOA should have been proposed as vPvB (Article 57e) next to Toxic for reproduction (Article 57c) and PBT (Article 57d). This is supported by the conclusion of the Persistent Organic Pollutants Review Committee (POPRC) that concluded at its twelfth meeting in September 2016 that PFOA is persistent, bioaccumulative and toxic to animals including humans (UNEP/POPS/POPRC.12/11/Add.2). Under the POP regulation the B criterion is defined as 5000 L/kg, which equals the vB criterion under REACH. Therefore, we do not consider PFHpA identification as vPvB to be inconsistent. The inconsistency is that PFOA was not proposed and identified as a vPvB substance under REACH in 2013. We have added this to the SVHC support document.

5670
2022/10/17	Finland,
Member State	We thank the Netherlands for this proposal. We would like to present the following comments on the Annex XV report:

page 8: “This value fits well between values derived for PFOA (236) and PFHxA (4.1).”

Comment: Please specify in the text the reasons why these substances are referred to (e.g. the closest structural analogues differing only by one carbon in chain length?) and indicate the parameter for the values 236 and 4.1.

page 12: “The observed probable serious effects for human health and the environment are reproductive toxicity and yet unknown environmental effects.”

Comment: Please clarify the sentence (observed effects cannot include unknown effects).

page 52: “Indeed, the half-lives exceed the range of guiding values for biomagnification of substances in humans, which are proposed to be in the range of 30 (B) to at most 70 (vB) days”

Comment: A source for these guiding values is not presented in the document and at least we are not aware where these values are proposed. Is this based on published information? We propose to include more information regarding how these values are derived, considering that there are no criteria for elimination half-lives in REACH regulation or guidance to be used for concluding on the B and vB.
	Thank you for your detailed comments and suggestions for improvement of the Support Document. 

Regarding you comment on the elimination half-life values in pigs, we adopted the support document as you suggested.

Regarding your comment on unknown effects, in section 6.3.2.6 (page 62) unknown effects are explained as effects that may, due to substance properties, emerge only after life-long exposure and that may not be observed in standard toxicity tests. As you pointed out the sentence on page 12 needs rephrasing. We have adopted the respective sentence on page 12 as well as on page 68 in the support document as follows: “The observed probable serious effects for human health and the environment are reproductive toxicity. However, the combination of substance properties may also lead to yet unknown environmental effects that are not detectable in standard toxicity test and that may only emerge after life-long exposure.”.

Regarding your comment on the guiding values, see our response to comment 5675 2022/10/17 in the “General comments on the justification” section of this RCOM. 

5675
2022/10/17	ANSES,
National Authority,
France	ANSES supports the proposal of identification of Perfluoroheptanoic acid and its salts (PFHpA and its salts) as SVHC according to articles 57c, 57d, 57e, 57f.

• Based on a weight of evidence approach, the Substances fulfil the criteria for PBT/vPvB substances according to annex XIII or the REACH Regulation.

PFHpA and its salts are expected to undergo no or extremy limited degradation in the environment, this is because of the stability of the C-F bond and the read-across with substances such as PFHxA, HFPO-DA, PFOA, PFNA, PFDA and C11-C14 PFCAs, which their persistence/very persistence properties have already been confirmed by the Member State Committee. Monitoring data of PFHpA, especially in remote areas such as the Arctic (in air, snow, fresh- and marine water (including sediments) and soil) and the Antarctic (snow), locations that are far away from point sources, support the persistence of the substance. Considering the available information, PFHpA and its salts fulfil the P/vP criteria. The Substances exhibit a low bioaccumulation potential for aquatic organisms. However, in air-breathing organisms such as humans and pigs, PFHpA is very bioaccumulative. The geometric mean elimination half-life for pigs is 74 days, resulting to a biomagnification factor of 2.7, therefore PFHpA and its salts have the potential to biomagnify in pigs. In humans, the highest elimination half-live value reported is 3.3 years (average elimination half-life is at least 76 days). Taking into account the overall information, especially in humans and pigs, the Substances fulfil the vB criterion. Regarding toxicity, PFHpA has an harmonized classification for reproduction category 1B and STOT RE 1. Therefore, PFHpA and its salts meet the toxicity criterion (T) in accordance with Annex XIII, of the REACH Regulation.

Equivalent level of concern (Article 57f)

PFHpA and its salts exhibit very low log Koc values of 1.63-1.7, which implies a very low adsorption potential, thus a high mobility capacity of the substance in the environment. The detection of PFHpA or its salts in tap water, bottled drinking water and groundwater supports the conclusion that PFHpA and its salts are mobile in water. The removal of PFHpA or its salts from the aquatic environment and from drinking water is difficult as the available information shows that current conventional water purification techniques do not readily remove the substance; this also explain the occurrence of the substance in drinking water in Europe. Humans are exposed to PFHpA or its salts via the environment directly and continuously during their whole life, which is critical because the substance is classified as reproduction category 1B (H360D: ‘May damage the unborn child’).
According to modelling data, PFHpA and its salts also exhibit a high potential for long-range transport in the environment, which takes place via the atmosphere and oceanic currents, this conclusion is supported by the occurrence of PFHpA on polar regions as well as a high altitude remote areas in the European Alps.
On this basis, ANSES agrees that several concerns are caused by these intrinsic properties of PFHpA and its salts justifying SVHC identification under articles 57c, 57d, 57e, 57f.

	Thank you for your support.	
				
5688
2022/10/17	CHEM Trust Europe,
International NGO,
Germany	CHEM Trust supports the inclusion of perfluoroheptanoic acid and its salts in the REACH candidate list because of its reproductive toxicity (article 57(c)) as well as due to its PBT and vPvB properties (articles 57 (d) and (e). The dossier makes a convincing case based on a weight-of-evidence determination according to the provisions of Annex XIII, bringing together the evidence for a combination of these harmful properties. The very high persistence together with low adsorption potential and high mobility imply a very high potential for increasing pollution stock in the environment and for irreversible and increasing exposure of both wildlife and humans exposed via the environment. Also, their low adsorption potential and high water solubility mean that PFHpA and its salts are highly bioavailable for uptake via water. The additional concern due to the substances´ high mobility in water, the potential for being transported in the water phase over long distances, difficulty of remediation and water purification is an important justification for an equivalent level of concern identification, i.e. including it also under article 57 (f).	Thank you for your support.

5700
2022/10/17	ChemSec,
International NGO,
Sweden	ChemSec supports the addition of these substances to the SIN List based on the classification as toxic for reproduction, category 1b AND the being a vPvB AND a PMT as is proven in the dossier.	Thank you for your support.	
				
5721
2022/10/17	3M,
Company,
Belgium	3M disagrees with the conclusions on the identification of the Substance as i) PBT and vPvB under Article 57 (d) and (e) and ii) substance of equivalent level of concern to the substances listed in Article 57 points (a) to (e) under Article 57 (f), for many reasons listed in our more detailed comments (please see in pdf attached).
	Thank you for your comments and considerations.

Regarding your comment that the proposal is based on unsubstantiated and unjustified read across with PFCAs we note that read-across to HFPO-DA and C4- to C14-PFCA’s has been sufficiently justified in the SVHC proposal and Annex 1 to the proposal. It has been shown that these PFCAs have a highly similar chemical structure, i.e. a chain of perfluorinated carbon atoms and a carboxylic acid group. They differ only in the length of the (linear) perfluorinated carbon chain, except for HFPO-DA that has an additional ether bond. Based on the available experimental and estimated data (as given in Table A.2 in Annex 1 to the proposal) it can be stated with sufficient reliability that the behaviour of the PFCAs follows a regular pattern: an increase in the chain length results in a decrease in water solubility and an increase in sorption potential. 
Regarding your comment that the proposal fails to note that PFHxA is not a PBT/vPvB substance we note that on several occasions it is noted that PFHxA has been assessed by ECHA’s Risk Assessment Committee as mobile. However, indeed the proposal did not explicitly note that PFHxA is not bioaccumulative. We therefore modified the following sentence by adding the bold text: “Therefore, PFHpA and its salts can be expected to have very similar properties to PFHxA, HFPO-DA and PFOA, leading to potential PBT/vPvB based on PFOA and potential mobility properties based on PFHxA and HFPO-DA”.

Regarding your comment that PFHpA cannot be considered P/vP on the basis of an unsubstantiated and unjustified read across, we refer to our response given above with regard to the read-across. We further note that the available experimental biodegradation data discussed in the proposal as well as the theoretical consideration that the C-F bond is extremely strong is sufficient to conclude that PFHpA is very persistent. This is confirmed by monitoring data showing the ubiquitous presence of PFHpA in the most remote regions of this planet.

Regarding your comment that PFHpA cannot be considered B/vB on the basis of unreliable studies, we note that we have assessed the available studies with respect to their reliability. Uncertainties have been identified and discussed in the proposal. Only reliable data were considered in the Weight of Evidence approach to conclude on the very bioaccumulative properties of PFHpA. You also pointed out that the studies on which the conclusions are based on are not well documented. This remark seems not justified as all studies discussed in the bioaccumulation assessment are properly referenced and can be traced on this basis. You indicated that the section on biomagnification factors in pigs is unclear. We adopted the support document to make the respective section clearer. Your remark that we listed only high half-live values is not correct. The study summaries report, depending on availability, individual half-live values (Nilsson et al 2013) or ranges (Numata et al 2014; Xu et al 2020). In figures 2 and 4 summary data (including variability) are shown for pigs and humans, respectively. You consider the use of an ‘average’ half-life unjustified and consider that other statistical approaches (e.g. the mean) would be more appropriate. While your comment is not completely clear, we note that, depending on availability, study summaries report geometric mean, arithmetic mean and median values. For Nilsson et al (2013) we added the arithmetic mean and median values to the support document. We note that our conclusion does not depend on the choice for arithmetic or geometric mean values. 

Regarding your comments that SHVC identification based on Article 57f is not justified as the proposal fails to demonstrate the probable serious effects of PFHpA, and fails to demonstrate the equivalent level of concern to CMR, PBT and vPvB substances. We note that the proposal shows that specific properties of PFHpA, being very persistent, reprotoxic, bioaccumulative and mobile in the environment can lead to unknown effects that emerge only after life-long exposure and that may not be observed in standard toxicity tests. These arguments clearly show that SVHC identification based on Article 57f is warranted.
	
		See the corresponding embedded attachment in table 1 of Part I: 5721_3M comments on SVHC proposal for pFHPA.pdf		
5730
2022/10/17	European Environmental Bureau,
International NGO,
Belgium	The EEB supports the proposal submitted by The Netherlands to identify Perfluoroheptanoic acid (PFHpA) and its salts as Substances of Very High Concern in accordance with REACH Articles 57 (c), (d), (e) and (f), due to their classification as reprotox cat 1B, and PBT, vPvB, PMT and vPvM properties. We note the detection of PFHpA or its salts in groundwater, tap water and bottled water. The substance led to widespread contamination across the globe, ranging from the Arctic to the Antarctic. The widespread pollution of the environment by PFHpA and its salts is irreversible and leads to lifelong exposure of wildlife and humans, including future generations through nutrition and drinking water.
	Thank you for your support.	

PART II: Comments and responses to comments on uses, exposures, alternatives and risks

Specific comments on use, exposure, alternatives and risks
Number / Date	Submitted by (name, submitter type, country)	Comment	Responses	
5628
2022/10/13	Daikin Industries, Ltd.,
Company,
Japan		Thank you for your comment and the information provided. Comments regarding use, exposure, alternatives and risks may, when relevant, be considered at later stages of the risk management process.	
		See the corresponding embedded attachment in table 1 of Part I: 5628_Daikins opinion on PFHpA SVHC listing proposal (20221013).pdf		
5631
2022/10/13	Health and Environment Alliance (HEAL),
International NGO,
Belgium		Thank you for your comment and the information provided. Comments regarding use, exposure, alternatives and risks may, when relevant, be considered at later stages of the risk management process.	
		See the corresponding embedded attachment in table 1 of Part I: 5631_HEAL Comments-Perfluoroheptanoic acid and its salts.pdf		
5721
2022/10/17	3M,
Company,
Belgium		Thank you for your comment and the information provided. Comments regarding use, exposure, alternatives and risks may, when relevant, be considered at later stages of the risk management process.	
		See the corresponding embedded attachment in table 1 of Part I: 5721_3M comments on SVHC proposal for pFHPA.pdf