PFAS: Four letters, endless confusion

Simone Wilson

4 letters, endless confusion PFAS - the debate on so-called perpetual chemicals such as per- and per- and polyfluoroalkyl substances is raging, the authorities want an EU-wide ban, the industry wants exceptions. How can we ensure that progress does not become a step backwards? Where do we stand in the current restriction process? What role does the Federal Institute for Occupational Safety and Health (BAuA) play in the current PFAS discussion? Welcome to the IDT podcast, which provides new perspectives and fresh impetus for the industry and sealing technology. I am delighted to welcome BAuA expert and chemist Dr. Frauke Averbeck to today's talk. Hello Ms. Averbeck.

Dr. Frauke Averbeck

Hello, how do you do?

Simone Wilson

With my colleague Jörg Skoda, I also have a source of knowledge at my side who has been involved in the PFAS discussion from an industry perspective from the very beginning. Hello Jörg.

Jörg Skoda

Hello Simone, hello Mrs. Averbeck.

Simone Wilson

My name is Simone Wilson. I am the CEO of sealing specialist IDT and a journalist in my first life. That's why I'm delighted to take on the role of presenter in our podcast, to have exciting conversations, to ask questions and queries and to capture trends, innovations and developments that will shape the sealing technology of tomorrow for all of you who listen to or watch this podcast. Yes, Ms. Averbeck, welcome again. Nice to have you here. Nice that you have found your way to us from Dortmund. Of course, I'm already very excited. I know that the RAC and SEAC meetings took place at the beginning of this month, but before we get really deep into the discussion, I would perhaps first like to know what the role of the BAuA is and, for those listeners who don't know the BAuA that well, what the BAuA actually is. So perhaps you could briefly introduce who the BAuA is and what its main areas of activity are.

Dr. Frauke Averbeck

Yes, with pleasure. Exactly the BAuA, as you said, the Federal Institute for Occupational Safety and Health. We have around 730 employees at 3 locations in Dortmund, Berlin and Dresden, and the BAuA's main areas of activity are of course in the field of work, i.e. everything to do with work, ergonomics in the workplace, mental stress. working time. We also have sovereign tasks. These are the regulations, so to speak, chemical regulations, which we will come to in a moment. And we also have an exhibition, the German occupational health and safety exhibition, DASA.

Simone Wilson

Ah yes, that's a broad spectrum that is located at the BAuA.

Jörg, you were already in contact with the BAuA before this whole PFAS issue came to a head. Can you still remember your first contact?

Jörg Skoda

Yes, relatively well actually. However, it was not about PFAS and we have just heard from Dr. Averbeck that there are several areas at the BAuA, not just one. We had our first contact with the TRGS variants, i.e. technical rules for hazardous substances. Yes, that was the first contact and the contact came much later, so to speak. We had our first contact with the BAuA 8 years ago.

Simone Wilson

Mmm. Okay, but now it's like this, of course, as you've just shown. There are different areas in the BAuA and you are also in a very specific area, namely Department 5. This is the Federal Agency for Chemicals, which is particularly dedicated to the protection of humans, animals and the environment from the harmful effects of chemicals. Of course, I would also like to know more about this. How can I imagine the work in this department, what specific tasks do you carry out and what is the focus?

Dr. Frauke Averbeck

As a federal agency, the Federal Agency for Chemicals, we have a somewhat special role within the BAuA because we are mainly responsible for sovereign tasks. We are designated as the competent German authority for REACH, CLP and biocides. The whole thing is anchored in the German Chemicals Act and our task is basically to manage the procedures that are anchored in these regulations. The cooperation... we have 3 assessment bodies that we work with. They are based at the Federal Institute for Risk Assessment in the areas of human health, toxicology and consumer protection. Then there's the Federal Environment Agency, which is responsible for environmental assessments, and our Department 4, the Occupational Health and Safety Assessment Body, which deals with all issues relating to occupational health and safety. And our task within the process is to bring together the contributions of these three assessment bodies, so to speak, and to ensure a German authority position, which we then also represent externally. This means that we are also the point of contact with the outside world, with industry, but also with the European Chemicals Agency, in some cases also with the Commission, and of course with the authorities from the other member states. And we are also home to the national information office, which is intended to support small and medium-sized enterprises in particular in fulfilling their obligations and tasks under this regulation.

Simone Wilson

That sounds like a very wide range of tasks. How many people are in your department?

Dr. Frauke Averbeck

Just over 100.

Simone Wilson

Ok, now you said earlier REACH is probably day-to-day business for them, but for those who don't have to deal with it every day, what exactly is REACH?

Dr. Frauke Averbeck

REACH stands for Registration, Evaluation, i.e. E = Evaluation, the A then stands for authorization. And CH for chemicals. In other words, the registration, evaluation and authorization of chemicals. Overall, the point of restriction is missing, which of course plays a role in the PFAS issue, and within the framework of REACH there are obligations for industry to provide evidence. That substances that are manufactured or imported in the EU can be used safely. And there is a so-called registration obligation. This applies to one tonne per year, so companies have to submit data on their substances to the European Chemicals Agency and the amount of data that has to be provided increases with the tonnage and also includes testing. On the health and environmental hazards of the substances.

Simone Wilson

And the work assignments, if I may put it that way, are given to them from the outside and from the inside, or how should I imagine it?

Dr. Frauke Averbeck

Both as well as. So, what we as authorities ourselves, and that is also the special thing about REACH, is that we as authorities have a right of initiative that no one else has in very few other areas in the EU, usually the Commission acts, and with REACH we actually have the opportunity as authorities to initiate procedures ourselves, and what we as German authorities want to initiate or regulate, we basically choose ourselves. However, we are of course also involved and others, when authorities from other countries or the European Chemicals Agency initiate procedures, then of course we also have the opportunity to participate, provide information and comment. In other words, this is triggered from outside.

Simone Wilson

Okay, so first of all, it sounds to me like they never get bored.

Dr. Frauke Averbeck

Not so fast, no.

Simone Wilson

All right. So, of course we are here today to talk about the issue of PFAS. This hasn't just been boiling over since yesterday, but has been boiling over for two years, almost exactly two years. On February 7, 2023, ECHA published a preliminary version of the PFAS restriction dossier on its website. And the dossier is based on the initiative of the BAuA and state organizations, as they had just said. From 4 other EU countries in its original form, the document provides for an EU-wide ban on the manufacture, placing on the market and use of all substances defined as PFAS. So Jörg, you had contact with the BAuA years ago and I think that was also a bit, yes, PFAS has been heard about. You also heard a bit about what was going on and then you were told: Okay, so BAuA is a co-initiator, what was your first reaction to that?

Jörg Skoda

The first reaction was quite simple: "Oh my God, not the BAuA. We had work to do in the specialist departments and that's where we found this typical government work and they don't make any mistakes and it's all useless. That was my first reaction. And then the work began and I had to say quite clearly. For me, PFAS was a term for most people who had never heard of this system. So the work started anew, what's behind it, we're affected, what can you do, in which areas do you have to look and the deeper you dig in and find out what it's actually about, the more interesting it becomes. But it also becomes more and more difficult, that's always the problem you have, but the first impression was: oh God, why the BAuA? It then became clear that this is quite different in the area of the REACH PFAS Regulation.

Simone Wilson

Exactly, but I think that's also a bit of a reflection of the lack of understanding in the industry. So what is the BAuA actually doing, why is this authority there now and pushing this forward? I'd be interested to hear that again, specifically in relation to PFAS, because as you've just explained, it's not just the BAuA, it's actually your department that's dealing with this topic. But if you could perhaps say again what role the BAuA has in this procedure?

Dr. Frauke Averbeck

Exactly, you have already said that we helped initiate this restriction procedure, so to speak. Of course, we did not do this alone, but with the authorities from 4 other Member States, as you have already mentioned, and of course with the support of our assessment bodies, i.e. the Federal Environment Agency, of course, and also the Federal Institute for Risk Assessment. And our role in the Federal Agency is, on the one hand, to coordinate the national activities and then to feed in the consortium from the 5 Member States. On the other hand, we have also assumed overall leadership together with our Dutch colleagues. In other words, our task is actually to have a bit of an overview of who has to do what, where and by when. We are also the main point of contact with ECHA, which has been managing the procedure since it was submitted here. We talk to the stakeholders. We go to events, give presentations, provide information on the status of the procedure and that's why, I think, we're here today. That is precisely our role in the whole thing.

Simone Wilson

Was there any urgency at the time to initiate this restriction dossier or this restriction procedure? Or was it in the course of what you explained earlier, i.e. that you as an authority can of course also look for things that you want to initiate?

Dr. Frauke Averbeck

There are two sides to it. On the one hand, the German authorities have always been interested in the subject of PFAS. And also sensitized to the problem. And in 2009, I don't know, we started or submitted a proposal to restrict the substance PFOA, which is a certain PFAS and its precursor compound, in the European Union and after we launched this dossier, we realized, OK, the industry is now avoiding it, alternatives are being sought, but alternatives were being sought within the PFAS substance group, then we took on the next subgroup. Again and again, we simply switched to other PFAS and didn't look outside. And then, after we had launched the third dossier, we had the idea. Yes, perhaps we need to do something more holistic, something more comprehensive, in order to prevent this constant switch to new PFASs, as they actually have the same hazardous properties and are just as questionable as the substances that we previously restricted. And the European Commission's chemicals strategy for sustainability came out at the same time as all this, where the political will to find a regulation for PFAS was also documented. Within the EU and also our Dutch colleagues had thought a bit independently of us about going in this direction and so we, well, we then found each other. We then came together. The Scandinavian countries have a long history anyway, including with PFAS and PFAS regulations. And so the five member states came together to tackle this project together.

Simone Wilson

OK, so that means that when we complain that we've been struggling with it for two years, they've known about the issue for much longer than we have, so it's absolutely nothing new to them, and that's very, very exciting in any case. Jörg, after you had, of course, initially railed against the BAuA and scolded them - I'm very close to you in our office - you went on the offensive and, among other things, injected the Working Group on Technical Plastics, i.e. got the industry on board and really went on the offensive towards the BAuA, but with an outstretched hand, so to speak. So we have massive problems here, we would like to understand them. Why was that important to you?

Jörg Skoda

I think it's just like in real life. Even if you argue in a marriage, you have to get along and talk to each other and only people who talk to each other can get things moving. Once again today, I noticed in all the information I received that yes, the industry is evil and doesn't want any of this and yes, the BAuA has no idea, sorry to say it so openly, but that's how it was and just to break the lances, they say that the authorities need the information and the industry has the information, please sit down at my table, exchange this information and then only when the authorities understand where the fire is can they react. And if the industry also understands what they are doing themselves. What everyone is looking for has to be thrown into the room. Can such problems be solved together? That was actually always the problem we had and that's why I actually approached the BAuA quite actively. I simply called and asked. Don't you want to talk to us anymore? And that was well received. And I also believe that a lot was exchanged on both sides.

Simone Wilson

Yes, I don't want to reopen the entire process since the beginning of 2023. Most people also know that, of course, a huge number of appeals have been received and that's why it's currently taking so long. Until a decision is made. The ECHA is still working on it. So I think these issues are well known, but what would interest me again is how important such dialog partners are for them in such a procedure, i.e. that they really have contact with the industry, that they can perhaps also obtain expert opinions of expert knowledge.

Dr. Frauke Averbeck

Yes, I think Mr. Skoda has just said that. The dialog is simply extremely important, the exchange between authorities and industry, because we can't have the detailed information. So we have these registration dossiers, which I explained earlier, with information on the hazard properties and there is also a bit of information there. Where these substances are used, but how they are used in detail and how you really have to imagine this in the plant, that is of course not there and we do not have this knowledge. That really lies within the companies, so this exchange is extremely important for us. Before we submitted the dossier, we also tried to obtain information in two calls for evidence, let's call them requests for information, and also held discussions with those who responded. But we also found that for a very long time there were still many companies and associations that were not even aware of this because they were not actually aware that PFAS were being used. And yes, I think there's still a lot of work to be done. Perhaps we can also improve in this area by finding better ways of publicizing such projects at an early stage and then engaging in dialogue.

Simone Wilson

Admittedly, gaskets are only a very small area in this whole PFAS topic, simply out of personal interest: have you learned anything about gaskets in that time?

Dr. Frauke Averbeck

In any case, yes, you still learn a lot when you think that you already know a lot at the start of the process and that you're fully informed. But what you then learn from all the comments and conversations. It's a lot of information.

Simone Wilson

Yes, I also imagine it will be very exciting now. We are also sitting here today because the first RAC and SEAC meetings on the PFAS restriction procedure for this year have of course just taken place. Can you say something about the current status?

Dr. Frauke Averbeck

So now in March, 3 sectors were discussed at the meetings. The area of fluorinated gases and their applications, the area of energy and the area of transportation. It has to be said that the RAC discussed these three sectors and the SEAC actually only discussed the application of fluorinated gases and postponed the detailed discussion on energy and transportation until the June meetings, simply because these are three areas where a great many comments were made and our colleagues simply need time to really get to grips with them.

Simone Wilson

Could you perhaps briefly explain to the listeners what RAC is and what SEAC is?

Dr. Frauke Averbeck

The Committee for Risk Assessment, based at the ECHA, is a scientific committee. The members are independent, but appointed by the Member States, each Member State can appoint 2 members and the RAC deals with the following. With the hazard properties of the substances, with the risk, with the hazard properties of alternatives and with the emissions. Yes, SEAC is the Committee for Socio-Economic Analysis, which has the same members as the Rack, i.e. two independent members per Member State, and it actually deals with the socio-economic aspects. It looks at the costs of the restriction, i.e. what are the costs of replacing the substances? And how do these costs compare with the benefits of the restriction if, as in the example of PFAS, I then have no emissions or only low emissions into the environment? And the SEAC also deals with the alternatives, but here more with regard to availability and how far the development of alternatives has progressed. In the end, both committees make a recommendation on the restriction proposal that has been submitted and the whole thing then goes on to the political process.

Simone

Yes, thank you very much. Jörg, the November meeting was really interesting for us and for our sector and probably also for the industry, because there was a progress update. And in it, the BAuA and the four other dossiers and mothers paid particular attention to pre-polymers. This is a neutral formulation for the time being and ultimately also for gaskets, i.e. gaskets with a broad spectrum of fluorine, polymers for private, commercial and industrial applications were included as an additional area of application. Has this changed the mood in the working group on engineering plastics in industry among the people you talk to?

Jörg Skoda

Conditionally. You could say that a rethink is taking place, even among the operators. I would also like to start by taking up the cudgels for the industry, because I hear in many publications that the industry is evil, it doesn't want all this, the industry, there are people who have children and grandchildren just like us and want the environment to be preserved. So let me start by saying this, because it is quite important to me to make it clear that the uncertainty remains, we are talking about 10,000 different PFAS substances, what we are looking at here are only the fluoropolymers in sealing technology, but the substances are much more extensive. Many things would already be banned by the industry today, so ultimately saying, OK, I don't need it on toilet paper so that it slips better, can be banned, make-up can be banned. But it's not possible in the process, we have to wait until the process is over and all those who want to invest now are simply faced with the challenge: I have a chemical plant, there are PTFE fluoropolymers in it, can I use them at all in the future? So how is the future planning, the planning of new plants in general, that is still an issue for them, but you can also see, we also have exchange discussions with the BAuA, that the industry is really trying to do without PFAS wherever possible.

Simone Wilson

Yes, I would take up what Jörg has just said again. So in many areas. It has also turned out that PFAS still has no alternative. To what extent is this taken into account in the restriction procedure?

Dr. Frauke Averbeck

This is definitely an important aspect that is taken into account. On the one hand, we are carrying out a socio-economic analysis, i.e. comparing the costs with the benefits, and on the other hand, of course, we are also looking at how far we have come with alternative development, for which areas of use do we already have alternatives that can perhaps already be used, and in which areas does further research and development still need to be carried out? And all of this has been incorporated into the transitional periods that we have proposed as part of our dossier. So, if we have seen that there are already alternatives in an area, and they are also available in sufficient quantities, for example for many consumer products, then we have just said, okay, this usual transitional period of 18 months, as is actually standard in restrictions, is actually sufficient here, and we don't need any further transitional periods here. If we have seen that alternatives are already available, but perhaps not in sufficient quantities or it simply needs a little more time than these 18 months so that companies have time to switch to alternatives, then we have given or propose to give an additional 5 years to complete this process. And for areas of use where there are currently no alternatives, where research and development needs to be carried out, or in areas where certifications are still required before switching to alternatives, we have given an additional 12 years, i.e. a total of thirteen and a half, until the changeover should have taken place.

Simone Wilson

And if I were to realize now that I won't be ready in 5 years or that you won't be ready in 5 years, for example. So I'm just going to take this example: is there the possibility of changing this at some point?

Dr. Frauke Averbeck

So the European Commission always has the option of reopening existing restrictions at any time. Of course, it can also write itself in from the outset via a review clause, which it is rather reluctant to do. We will have to see whether it does that in this case and otherwise my recommendation would be to actually approach the Commission as early as possible. To explain that. If possible, perhaps not as an individual company, but via an association, which can then also show that it is perhaps not just the problem of one company, but of an entire industry. And then the European Commission will certainly investigate. It will probably issue a request for an investigation to the ECHA, the European Chemicals Agency, and then we will have to see how the procedure goes. But there are definitely opportunities to review existing restrictions.

Simone Wilson

Very good. Yes, the length of the process is also an issue and is often criticized by the industry, which wants planning security. That's understandable, of course, Jörg. You just mentioned it again. Now, of course, you're on the grievance box for our customers and have a keen sense of the concerns, fears and needs of the industry. What's on companies' minds, i.e. what are you observing? You've just said a bit about this, but perhaps you could also describe a specific case, something that you remember.

Jörg Skoda

The industry is definitely looking for alternatives. They are not just a classic example of phosphoric acid and sulphuric acid, always critical applications, where PTFE as a fluoropolymer actually works excellently at the moment, provides me with corresponding safety, I also do not believe that we will find a solution in all areas, so this idea of being able to replace substances that are technically produced, such as fluoropolymers, with a natural product is already fatal in my opinion. We have been working intensively for two years to examine alternatives - and the challenge remains. We will not be able to avoid fluoropolymers in many areas. And I don't believe that thirteen and a half years will be enough to make the switch. It is also important that we think about the life cycle. What happens during production, what happens during disposal. The word fluoropolymer has been burned, you have to be aware of that, the public service media have done a great job with their publications. It was always negative. They often fail to mention that PTFE is also used in the medical field. For example, in the case of a heart attack: in such cases, a stent is inserted that is made of pure fluoropolymer. So what is considered "toxic" can save lives in an emergency. You rarely hear information like this. And that's also what the industry keeps complaining about: we're talking about 10,000 to 14,000 different PFAS substances. Are they all toxic? At what point are they really toxic? I'm a mechanical engineer, I have no idea, so I'm always happy to hear from a chemist. At the end of the day, you have a lot of concerns about whether you can get to grips with it?

Simone Wilson

You had just mentioned the time exceptions. Mr. Skoda now says that he is very critical of this, are there any other options?

Dr. Frauke Averbeck

Yes, there actually are. We also tried to make this clear in our Progress Update in November, where we received information in the consultation that there are other ways to minimize emissions of PFAS into the environment. Of course, this must also be ensured over the entire life cycle, i.e. from production to disposal. But if we see that there are such possibilities, it would be possible, in our view, to stipulate something like this in the restriction, so to speak, i.e. to lay down requirements for safe handling and safe disposal, and this could then also be possible for an unlimited period of time. The important thing for us, and that is the goal we are pursuing with the whole project, is simply to minimize emissions into the environment. And if we can achieve this without a blanket ban, then we will have achieved a great deal.

Simone Wilson

We still have a lot of work to do here in the.

Dr. Frauke Averbeck

That in any case.

Simone Wilson

Ms. Averbeck, what is your assessment of the timetable, i.e. the critical component, even after the March meeting

Dr. Frauke Averbeck

So it is very difficult to estimate at the moment, there are now 9 or 10, don't pin me down to the exact number, sectors that have been discussed in the committees. But there are still a few more to go. We also informed you in our Progress Update in November that there are additional sectors that we will be looking at or have already looked at from a dossier-submitter perspective. Seals, for example, is an area that is now being added across the board, so to speak, and the committees will also have to deal with these new sectors. This means that the process there at the scientific level will certainly take until the end of the year, perhaps even early next year. It depends a little on how quickly they can familiarize themselves with the new areas. And then we still have a second consultation outstanding. Once the SEAC's draft statement is available, there will be another 60-day consultation period to submit comments on this statement. I can only recommend doing this and preparing for it now, if possible, and not waiting until this consultation starts. That's exactly when you have to see, I think, how many comments come in, how long it takes to work through them all, that's SEAC's job, fortunately we're out of it as the authorities submitting the dossier. And when it's finished, the political process starts and then the European Commission has it on the table. And here, too, we have had a wide range of experiences, from a few months to years, until a proposal is presented by the Commission. And we have seen from the example of microplastics that the discussion can sometimes take longer than a year until the REACH regulation is amended and the restriction comes into force.

Simone Wilson

If I were to pack small packages now, it sounds to me as if it could be, I would simply say, that by the middle of next year, the entire use cases, sectors, will have been discussed and perhaps this objection phase for the revised dossier will be over by the end of the year. I don't think we can influence that yet. That would of course be desirable, it is also clear that you cannot influence that, but you have just said something very nice, prepare for it now. How can we do that?

Dr. Frauke Averbeck

Firstly, you can look at how previous consultations with SEAC went. You can find this on the website of the European Chemicals Agency, where you can see what questions SEAC actually asked, what information it was interested in and you can also see what information was provided and what SEAC did with it. So that gives you an impression of what is really useful or what might be helpful. And then, of course, you can go back to your input from the first public consultation and see if there is an opportunity to refine it with regard to issues that are of interest to the SEAC, i.e. costs, benefits and the availability of alternatives. Perhaps a lot has happened in the last 2 to 3 years that could perhaps be updated or made a little more specific. So there are certainly possibilities, even without knowing exactly where we are heading and what will be at the end of the statement, to perhaps start thinking about it now.

Simone Wilson

Yes, that's a very good tip, thank you very much. It's always a bit of a balancing act between existence and health hazards. Technological progress is not yet possible in many industries without the use of PFAS. Jörg, you mentioned pacemakers in the medical field, but also in hydrogen ramp-up. Perhaps I could ask you again, Ms. Averbeck, how do you think it is possible to reconcile the well-being of people and the environment with this economic upturn and technological progress?

Dr. Frauke Averbeck

So of course we can look at the scientific side and see what is possible. It is also a requirement of the REACH Regulation that a socio-economic analysis is also carried out as part of such a restriction dossier. And such aspects are naturally included in this. The question is always to what extent you can really estimate this quantitatively, but at least qualitatively such things are of course discussed. On the one hand, of course, I would like to replace PFAS, but on the other hand, I may need them in order to be able to continue to treat people well within the framework of medicine. This is a consideration where we can lay the foundations, so to speak, but in the end it is also a decision that has to be made politically by the Commission and the Member States, where we can only provide the information, so to speak.

Simone Wilson

Yes, as we all know, life is not a concert of wishes. Jörg, if you could make a wish with regard to the PFAS restriction procedure. What would that be?

Jörg Skoda

I hope that the REACH regulation that is coming will be implemented with expertise and sense and, above all, with practical consideration. That is very important to me, because I believe that we need to talk to each other, and that is basically the wish that is linked to my second wish: we need to talk to each other. Anything else is useless, as we have just heard, there will be a second objection phase. Here, too, I can only say to every industry association, don't go through the associations, please submit the objections you have yourselves. Because anything else won't help, we definitely have to work together on the story and I believe that together we can also work out a sensible solution, not just for the PFAS procedure, but for all the procedures that are still there.

Simone Wilson

I can see that Jörg has a new career.

Jörg Skoda

I'm starting at the BAuA, yes.

Simone Wilson

But you can also make a wish, Ms. Averbeck, with regard to the PFAS process. What would you wish for?

Dr. Frauke Averbeck

So before I express my wish, I would first like to say that I think we have already initiated a lot with the proposal or the dossier alone, which we have brought into the process, and have already set a lot in motion. On the one hand, we are seeing real efforts on the part of industry to participate constructively in the process, which I think is very nice. There is this exchange, this dialog, which is very important and I think very good. I would actually like to see more, perhaps looking to the future, that we have this exchange and this constructive cooperation in future procedures, perhaps earlier in the process, because it is simply important, as I tried to point out earlier, for us to get this information and the earlier we have the information, the more targeted and precise our regulatory proposals can be. That would be my wish.

Simone Wilson

So that would mean for us, as soon as we notice the first currents, we should perhaps take a closer look and then get in touch. That would also help you.

Dr. Frauke Averbeck

In any case.

Simone Wilson

Yes, an intensive exchange about PFAS is coming to an end, but the debate itself naturally remains highly topical. Ms. Averbeck, thank you very much for sharing your expertise with us today and giving us an insight into the work of the BAuA. Jörg, thank you too for your insight and the open exchange and for providing me with advice and support. Now I have to go here. Yes, if I could wish for anything, it would of course be equally great guests for our next podcast and especially the voices from industry. Because in the end, that's where change happens. If you enjoyed this episode, have any questions or suggestions: we are testing the format in 4 episodes this year and would therefore be delighted to receive your feedback. Thank you for listening, stay in touch. See you next time on the IDT podcast for new perspectives and fresh impetus in the industry and sealing technology.