POSITIONS
Afecor has in the past developed positions on safety relevant aspects of the industry and technical progress and will continue to do so. The most important statements are presented here for reference.
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Afecor position on proposed restrictions for per- and polyfluoroalkyl substances PFAS (Sept. 2023)
In March 2023 the EU’s Chemical Agency (ECHA) proposed to restrict PFAS (Per- and polyfluoroalkyl Substances). However, restrictions could have critical consequences for several EU sectors/industries, including Afecor members. Essential parts of safety relevant controls are made of fluoropolymers, for example O-rings.
Following the approach to restrict all PFAS groups including fluoropolymers while not considering their specific applications and addressing alternatives this potential restriction will have major socioeconomic, industrial and environmental impacts.
Afecor has submitted a position paper in response to the public consultation.
Afecor supports a Joint Industry Statement on a binding biomethane target for 2030 (Jan. 2023)
The European Union has released a plan to diversify energy supply for Europe (REPowerEU). This plan does also include an increase of biomethane production.
Organizations in the entire value chain of biomethane have co-signed a statement which aims at making a biomethane target of 35bcm by 2030 binding.
Afecor supports the Hydrogen standardization process (April 2021)
Hydrogen appliances fall under the Gas Appliance Regulation (GAR) (EU) 2016/426. There are currently no generally recognized European documents for the certification of hydrogen appliances.
Afecor is working with CEN/TC 58 (European Technical Standardization Committee for safety and control devices for burners and appliances burning gaseous or liquid fuels) to adapt the existing product standards to the use of Hydrogen.
Afecor policy for the introduction of Hydrogen as a renewable fuel (April 2021)
One of the major priorities of the European policies is to promote the "European Green Deal", which is the European implementation of measures to reach the Paris climate goals.
Afecor does actively support these goals. Afecor is a member of the European Hydrogen Alliance and several research projects to facilitate the introduction of Hydrogen.
Afecor members are currently working to complete their Hydrogen product portfolios.
Reconditioned Controls under the Gas Appliance Regulation (November 2020)
Reconditioned Controls are all those controls, that are collected or bought by companies or individuals taking ownership of these products to do repairs or refurbishment. To finally put them back on the market still under the name of the original manufacturer without his authorization. This is an existing business that can cause significant safety issues.
The Afecor opinion is that the regulations as the Gas Appliance Regulation and as they have been implemented into National Law are sufficient to cover this issue.
Revision of standards and validity of certificates (July 2020)
For the safety assessment of products to the Essential Requirements of a Regulation typically product standards are being used. These standards do not only reflect Essential Requirements but may also include additional requirements covering performance or classification of products.
Unless the Essential Requirements have changed in between one edition of a standard and the next, the assessment which has already been made using a standard for the product does stay valid.
Products certified to the previous version of the standard can still be placed on the market unless a safeguard clause is issued and demands a different procedure.
Afecor statement on designed lifetime of safety relevant controls (October 2018)
Appliances and controls are designed for a certain lifetime, subsequently referred to as ‘designed lifetime’. The designed lifetime is expressed as a number of operating cycles or years. The number of years is being derived from the cycles assuming a typical use of the appliance. Beyond the mentioned designed lifetime, safe use of the product requires additional measures as described below.
To decide on the need for checks and measures, the number of operating cycles or years for certain types of safety relevant controls triggers additional measures. The procedure for inspection/maintenance of a specific appliance/control is given in the instruction manual of the manufacturer. In case of any doubts, the manufacturer should be consulted.