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oldschoolskier

Making fresh tracks
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Joined
Dec 6, 2015
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4,229
Location
Ontario Canada
I have at least one 1l bottle of fluoro raw material micro ground, ready to be mix into wax (several years back looked at making custom wax blends). Not to mention a couple of secret ingredients for ultra high performance waxes. Project fell on the back burner (just not enough spare time).

Guess I’m good for life on fluoro. :D
 

Skibie

Respect snow
Skier
Pass Pulled
Joined
Sep 7, 2019
Posts
3
Location
Brussels
This is from Thanos at Dominator Wax.

"
This is Thanos Karydas, and I am the founder and technical director of DOMINATOR. During the past season a number of wax companies have not delivered fluorinated waxes to their customers and a variety of explanations have been offered. We are hearing comments like “fluoro waxes have been banned,” and “the EPA is going after all the wax companies,” both of which are inaccurate. As is often the case when limited information is available, and especially in technical matters, confusion reigns supreme as misinformation is passed around. For the benefit of wax users I feel it is necessary to clarify the situation, but this will involve a somewhat lengthy explanation that goes back to basic definitions and rules. I will first explain the role of fluorochemicals in ski and snowboard waxes, and then describe how the use of fluorochemicals is controlled by government regulations. Today’s situation with fluoro waxes will become clear to everyone who reads this.

About fluorochemicals
Since the 1950’s, fluorochemicals have been widely used in many industrial and commercial applications because they offer low friction and high water and oil repellency. The best known fluorochemical is Teflon®, DuPont’s trade name for polytetrafluoroethylene or PTFE, which is used as a coating for non-stick cookwear and other metallic surfaces, on printed circuit boards, and engine components. It prevents oil, dirt and aqueous stains from sticking to the surfaces, so they stay clean. Similarly, other fluorochemicals are used in the treatment of textiles like tablecloths, raincoats and upholstery to resist rain and aqueous and oily stains.

It is often necessary to treat paper so it resists penetration by oily and water-based fluids. During a BBQ you do not want sauce, grease or salad dressing going through the plate and ending up on your lap; the inside of a microwave popcorn bag is coated to prevent the oil from migrating to the outside of the bag; and, animal food bags are coated to prevent oils and fats from soaking the bag.

Fluorochemicals are also used in the ski and snowboard wax industry. They prevent water and dirt from sticking to the base, so the base glides faster on snow.

To visualize how fluorochemicals work, think of them as microscopic umbrellas. When certain fluorochemicals are placed close to each other, they form regions of little umbrellas that are frozen in place, packed tightly, upright and parallel to each other.

This umbrella network forms a barrier that water and oil cannot go through so they roll off the treated surface. In the case of a treated ski or snowboard base, dirt and water do not stick to it, so it glides easily on wet snow and stays clean when gliding on dirty snow. Fluoro waxes were game changers for the ski and snowboard wax industry and the reality is that competitions cannot be won without them.

Because of their unique repellency properties, fluorochemicals have been used in extremely large volumes for industrial, military, and consumer applications for more than 50 years. Concerns started to develop in the 1990’s. Two synthetic chemicals, perfluorooctanoic acid (abbreviated PFOA) and perfluorooctyl sulfonic acid (abbreviated PFOS) were detected globally in the environment, and in wildlife and humans. These acids have been shown to be persistent in the environment, to bio accumulate (when they get in the body, they stay there for long periods) in wildlife and humans, and to have toxicological properties of concern.

In response to these environmental and health concerns, in 2006 the US Environmental Protection Agency (EPA) invited the eight major fluorochemicals manufacturers to join in a global stewardship program and commit to working toward the elimination of these chemicals from emissions and products by 2015.

The fluorochemicals that may lead to the generation of PFOA and PFOS belong to a class called C8 fluorochemicals. Studies have found that fluorochemicals belonging to a class called C6 do not demonstrate the health and environmental concerns demonstrated by the C8 fluorochemicals. When the EPA announced the stewardship program in 2006, DOMINATOR initiated a research program aimed at replacing all C8 with C6 technology; we were soon successful and C6 technology was incorporated in our waxes long before the EPA deadline.

I believe that some on the confusion related to the perceived “ban” of fluoro waxes is related to the withdrawal of C8 technology from the market. It is important to realize that fluoro waxes are still available, but they are now based on C6 rather than C8 technology. To conclude, fluoro waxes have been reformulated but are still available.

The EPA petition process as it relates to manufacturing and importation:
Environmental stewardship, which is a means to a more sustainable future, is the responsibility for environmental quality shared by all those whose actions affect the environment. This clearly includes all chemicals manufacturers and importers, wax companies amongst them. But it is not an unregulated process, left up to the individual. The Toxic Substances Control Act (TSCA) is a United States law administered by the U.S. EPA that regulates the introduction of new or already existing chemicals in the United States. Before a new substance is manufactured or imported for the first time, the manufacturer or importer must petition the EPA for permission.

At DOMINATOR, we manufacture our own fluoro additives that go into our waxes and, in 1994, our first year of operation, we successfully petitioned the EPA before introducing our fluoro waxes to the market. Later on, we converted from C8 to C6 technology to comply with the EPA stewardship directive. Importers and distributors have the same petition obligations as manufacturers and, to comply with environmental law, must know what they are importing. They must petition before the first importation and, during subsequent importations, must sign a statement that the imported products are either TSCA compliant on not subject to TSCA. Clearly, an importer must not sign this statement without knowing what is included in the imported products as there are very serious implications to non-compliance. Knowingly signing a false statement is punishable by law; signing something you don’t understand is, at the very least, foolish, and if it is a false statement, is equally punishable by law. In either case, either tell the truth or, if you don’t understand the question, find somebody who does. There is no excuse for environmental irresponsibility, the law is crystal clear on that.

The Toxic Substances Control Act (TSCA) gives EPA the authority to obtain information, reports, documents, or answers to questions to assess a company’s compliance to the law.
Starting, we believe, in early 2018, the EPA exercised this authority by sending requests for information regarding the use of fluorochemicals to many wax companies operating in the US, ours included. DOMINATOR responded to this request for information and continued business as usual. I understand that a number of companies voluntarily quarantined their fluorinated waxes. We have no way of knowing their motives for this action but the law is very clear: Once you state that you believe you may be in violation of the environmental law, you must immediately stop all commerce (importing, selling and distributing). Failure to do so will be seen as a criminal act and transform the case to a criminal one with everything that implies.

I am fairly certain that the unavailability of some fluorinated waxes is related to the EPA’s request for information; there is certainly no ban on fluorinated waxes that are in compliance with EPA regulations.

Some in the industry have said that the EPA is targeting wax companies, with huge possible fines that may put the smaller ones out of business. It is very wrong to see the EPA as the villain in this situation. The role of EPA is that of a gate keeper, protecting the environment and the people living in the US. Everything that we are exposed to must be scrutinized, whether it is baby powder or nuclear waste. It would be catastrophic if companies were given free rein to import or manufacture, unchecked, whatever they wanted. The EPA petition process may be time consuming and complex, and with significant costs, especially for small companies. But, for both ethical and legal reasons, it is a process that should not be bypassed.

In closing, the EPA has not banned the use of fluoro waxes; any restrictions, voluntary or involuntary, that may have been imposed are a result of compliance being scrutinized. At DOMINATOR we have complied fully with EPA regulations, and all our waxes are available and ready to ship."


Many conscientious manufacturers have already switched to the “safer” PFCs that have only 6 or less perfluorinated carbon atoms, also called “C6”. These are allowed because they are believed to degrade faster than the C8 PFCs and because do not appear to accumulate as much in the human body. Because C6 is not banned at this time, you will find this toxin in your sports apparel, hiking jackets and carpet. However, many knowledgeable people recognize that C6 PFCs are suspected carcinogens. In fact, C6 PFC has a sizeable "impurity" of the banned C8 PFC. Some unscrupulous chemical suppliers intentionally keep a high impurity level of C8 in their C6 - to make it work better!

This is starting to sound like the “good” white asbestos and the “bad” blue asbestos of years ago. Both forms of asbestos were known to be carcinogenic, but blue asbestos was banned about 15 years before white asbestos was banned. During that time, countless people were exposed to this carcinogen and homes and businesses were built using white asbestos that later needed to be removed - at great cost. The delay was "needed" because there was "no substitute" – until there was a substitute. Do we use asbestos today? Is it missed? Same with PFCs. The substitute for PFCs already exists - despite the vocal denials of major apparel brands.

A valid question for C6 PFCs is, “are these safe”? But the wiser question is whether we need PFCs at all?

https://www.linkedin.com/pulse/c6-c8-see-evil-gary-s-selwyn-phd/
 

RaceWax.com

Putting on skis
Skier
Joined
Nov 22, 2018
Posts
24
Many conscientious manufacturers have already switched to the “safer” PFCs that have only 6 or less perfluorinated carbon atoms, also called “C6”. These are allowed because they are believed to degrade faster than the C8 PFCs and because do not appear to accumulate as much in the human body. Because C6 is not banned at this time, you will find this toxin in your sports apparel, hiking jackets and carpet. However, many knowledgeable people recognize that C6 PFCs are suspected carcinogens. In fact, C6 PFC has a sizeable "impurity" of the banned C8 PFC. Some unscrupulous chemical suppliers intentionally keep a high impurity level of C8 in their C6 - to make it work better!

This is not possible for all "approved" waxes in the USA (as stated in the Swix/Toko thread I started here). The EU laws allow for impurities below certain concentration levels. USA laws set by the EPA require 100% accounting of all chemicals (including identification of impurities). The law literally requires 100% accounting, so for example if the red dye in the wax is a blend of 20 different chemicals each one of the 20 require approval no matter how minuscule. Swix/Toko waxes are recently approved. Any other waxes that are for sale either need to obtain/declare approval, apply for approval, or cease sales. If there are waxes out there that have C8 and/or other impurities they won't be around for long. It's only a matter of time; the consequence is costly. Actually all three options are costly, but defying the EPA is more costly.
 

neonorchid

Making fresh tracks
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Joined
Nov 21, 2015
Posts
6,693
Location
Mid-Atlantic
 

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