19 November 2011

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

Substance name:	Sulfurous acid, lead salt, dibasic	
CAS number:	62229-08-7	
EC number:	263-467-1	

The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: Repr. 1A

Disclaimer: comments provided during public consultation are made available in this document as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information.

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

General comments on the SVHC proposal
#	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
14	2012/10/18	International NGO
Health and Environment Alliance
Belgium	We support the adoption of this chemical to the Candidate List.	Thank you for your opinion.	
13	2012/10/18	Individual
Belgium	Fonderie & Manufacture de Métaux SA is a member of the International Lead Association or the Lead REACH Consortium. ILA has provided a consolidated response on behalf of members of the Lead REACH consortium. As a consequence, Fonderie & Manufacture de Métaux SA fully supports and subscribes to the comments made by ILA.	Thank you for your comment.

Please refer to response to comment #5 in section “Specific comments on use, exposure, alternatives and risks” (see below).
	
12	2012/10/18	Individual
Germany	Weser-Metall GmbH is a member of the International Lead Association or the Lead REACH Consortium. ILA has provided a consolidated response on behalf of members of the Lead REACH consortium. As a consequence, Weser-Metall GmbH fully supports and subscribes to the comments made by ILA.	Thank you for your comment.

Please refer to response to comment #5 in section “Specific comments on use, exposure, alternatives and risks” (see below).
	
10	2012/10/18	Company
Netherlands	Martens kunststoffen b.v. fully supports and subscribes to the comments made by ILA	Thank you for your comment.

Please refer to response to comment #5 in section “Specific comments on use, exposure, alternatives and risks” (see below).	
9	2012/10/18	Company
Britannia Refined Metals Ltd.
United Kingdom	Britannia Refined Metals Ltd. is a member of the International Lead Association and the Pb REACH Consortium. ILA has provided a consolidated response on behalf of members of the Pb REACH consortium. As a consequence, Britannia Refined Metals Ltd. fully supports and subscribes to the comments made by ILA.	Thank you for your comment.

Please refer to response to comment #5 in section “Specific comments on use, exposure, alternatives and risks” (see below).
	
8	2012/10/18	Member State
Norway	It is recognised globally that lead and its compounds pose a significant risk to human health and the environment and that there remains a need for a continued focus on reducing the risks posed by these substances. The concerns for lead compounds are their reprotoxic/neurotoxic properties. The Committee for Risk Assessment under REACH has stated that no threshold for the adverse effect of lead has been identified in humans.  We would also like to stress that the long lasting harmful effects to the environment are of serious concern (cf. classification of lead compounds in general and a number of specific lead compounds in CLP concerning environmental hazard;  "Aquatic Acute 1" ("Very toxic to aquatic life") and  "Aquatic Chronic 1" ("Very toxic to aquatic life with long lasting effects"). 

The Norwegian CA supports that sulfurous acid, lead salt, dibasic should be identified as a substance of very high concern and should be included in the Candidate List.	Thank you for your opinion.	
6	2012/10/17	National NGO
Naturskyddsföreningen, Swedish Society for Nature Conservation (SSNC)
Sweden	The Swedish Society for Nature Conservation (SSNC) supports the proposal to categorise Sulfurous acid, lead salt, dibasic as a Substance of Very High Concern.
 
The SSNC is the largest and most influential environmental organisation in Sweden, currently with 192,000 members nationwide. The SSNC works to protect the natural environment and human health, and to strengthen global solidarity.	Thank you for your opinion.	
7	2012/10/17	Industry or trade association
ELSA (ESPA)
Belgium	To our astonishment there has been no analysis of the information provided in the registration dossier of this substance. ELSA is of the opinion that such information has to be taken into account. Therefore we have inserted an attachment in Section IV of the commenting form.	Thank you for the information provided. 

If the substance is identified as SVHC, this information, where relevant, will be taken into account at later stages of the authorisation process.

Even though information provided during public consultation is taken into account, we would like to stress that the registrations are the standard tool and route to communicate information on a substance and its uses to the authorities The registrations are the authorities’ principal source of information when assessing the need of further risk management for a substance or (some of) its uses. Therefore, it is of utmost importance that registrants keep the information provided in the registration dossiers up to date and adequately describe the current use and exposure situation, including the operational conditions and risk management measures in place.

If certain uses are not covered by the provided exposure scenarios, downstream users can either communicate this through supply chain communication (via their suppliers) to the registrants, who then need to update their registrations accordingly, or prepare their specific chemical safety report and submit a downstream user report to ECHA.

Topics such as the availability and suitability of alternatives, socio-economic considerations regarding the benefits of a use or the (adverse) impacts of ceasing a use as well as information on the low level of risk associated to a use are important. Information regarding these topics should be provided as part of the application for authorisation (e.g. in the analysis of alternatives, the chemical safety report or the socio-economic analysis). This information will be taken into account by the Risk Assessment and Socio-Economic Analysis Committees when forming their opinions and by the Commission when taking the final decision. It may impact the decision on granting the applied for authorisation and the conditions applicable to the authorisation, such as e.g. the length of the time limited review period of the authorisation.

The current proposal for identifying the substance as a substance of very high concern (SVHC) is in accordance with REACH Article 59(2) based on its harmonised classification in Annex VI of Regulation (EC) No 1272/2008 (CLP Regulation). The additional mentioned information is not relevant for determining whether the substance meets the criteria for identification as SVHC. However, when examining whether the substance should be recommended for inclusion in Annex XIV, ECHA will indeed have to assess available information on uses and exposures. In addition, information on work already done by industry to identify and assess potential alternatives is used in defining transitional arrangements in the draft Annex XIV entries for the recommended substances. This information will be collected by ECHA before prioritising the substances and defining the transitional arrangements for its recommendation. The generic approaches for prioritisation and defining the draft Annex XIV entries are available at: http://echa.europa.eu/documents/10162/13640/axiv_prioritysetting_general_approach_20100701_en.pdf and http://echa.europa.eu/documents/10162/13640/draft_axiv_entries_gen_approach_4th_en.pdf.
If ECHA intends to recommend the substance for Annex XIV inclusion, interested parties can provide comments on ECHA’s recommendation, including the suggested transitional arrangements in accordance with Article 58 of REACH.

Nevertheless, ECHA agrees on the importance of identifying the most appropriate route(s) for risk management and on the co-operation and co-ordination of the regulatory risk management activities between the authorities. 

Finally, regarding your comment in respect to the recommendation that has been made by the German Competent Authority in their RMO analysis concerning the use of lead compounds in PVC-products, please refer to response to comment #3 in this section (see below).
	
			See also:
Comment 7 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-62229-08-7.pdf).pdf		
11	2012/10/16	National NGO
IEW
Belgium	We support the nomination of this chemical to the Candidate List as a substance of very high concern	Thank you for your opinion.	
4	2012/10/15	Company
REHAU AG + Co.
Germany	This dossier seems to be written superficially without any reference to recycling material, inclusion of the substance in the matrix of plastics and without any consideration of the voluntary phase out of the use of lead compounds of the PVC-processing industry.	Thank you for your comment.

If the substance is identified as SVHC, the information you are referring to will, where relevant, be taken into account at later stages of the authorisation process.

See also response to comments #7 and #3 in this section.

Please refer also to response to comment #4 in section “Specific comments on the justification” (see below).
	
3	2012/10/11	Member State
Germany	According to REACh Regulation it is formally correct to identify substances as SVHC based on their CMR classification listed in Annex VI of the CLP directive solely. However, up to now MS have provided some specific information to identify concerns. Therefore, the instrument of preparing RMOA prior to annex XV preparation has been established e.g. to avoid duplicate work. The German CA would appreciate to continue this practice. This guarantees that relevant substances are prioritised.

Referring to the Risk Management Option Analysis (RMOA) concerning “Lead compounds in PVC-products” carried out and submitted by the German CA we want to comment on the proposal for identification as SVHC of the following substances:

Neutral lead stearate (91031-62-8)
Dibasic lead stearate (12578-12-0)
Dibasic Lead Phthalate (69011-06-9)
Trilead Dioxide Phosphate (12141-20-7)
Tetralead Trioxide Sulphate (12202-17-4)
Pentalead Tetraoxide Sulphate (12065-90-6)
Basic Lead Carbonate (1319-46-6)
Sulfurous Acids, lead salt, dibasic (62229-08-7)

After evaluation of the above mentioned substances, the derivation of their use in the production of PVC-products and extensive discussion with the European stabiliser producers  the RMOA drew the conclusion that no action for these substances concerning the use in PVC is necessary at the moment. As conducted in the RMOA-document, industry has initiated a community-wide self-commitment aiming at the complete phase-out of lead in PVC-products by 2015. The transparency and reliability of the commitment were ensured as the progress was accompanied and rated by independent experts as well as by the EU-commission.

One principle on which Regulation (EC) No. 1907/2006 is based is that manufacturers, importers or downstream users should ensure that their substances have no adverse effects on human health and the environment (article 1(3)) by precautionary action. From the German CAs point of view the European initiative (Vinyl2010, followed by VinylPlus) has taken this responsibility by traceable reducing the use of lead and the introduction of alternatives. Therefore, the German RMOA concluded that the best measure at the moment was to accompany the progress until 2015 and initiate an Annex-XV-process for restriction in case the self-commitment does not reach its desired goals.

The German CA is aware that the substances concerned in this comment as well as the RMOA are not solely used in plastic products. Tetralead trioxide sulphate and pentalead tetraoxide sulphate are used in lead acid battery production, also. Nevertheless, Germany wants to point out some aspects regarding recycling are of importance once the substances are listed in the Candidate list – especially when thinking further to the prioritisation process for Annex XIV.

Considering the long lifetime of PVC-products (profiles, wires, pipes, flooring etc.) and that the production of lead-free PVC started approximately only 10 years ago, we assume that the major part of volumes used for recycling (800 000 t/a planned for 2020) probably consist of lead-containing PVC. This will consequently lead to a slow dilution of lead in PVC since new lead-free PVC will emerge in the recycling cycle only in the future. Based on our current understanding of the authorisation process companies conducting recycling of lead containing PVC may be obliged to acquire an authorisation for their recycling use. If recycled PVC was subject to authorisation this would clearly contradict sustainability efforts. Similar considerations would also be relevant for lead battery recycling.

The German CA still favours to await the outcome of the self-commitment prior to the initiation of other REACh legislative routes	Thank you for your comment. 

ECHA has received a request from the Commission in accordance with REACH Article 59(2) to prepare an Annex XV dossier proposing the identification of this substance as SVHC.

Preparation of a risk management options analysis (RMOA) before proposing the identification of a substance as SVHC is a voluntary step in the co-ordination of risk management activities among the Competent Authorities for REACH but not a requirement of REACH. 

Nevertheless, ECHA agrees on the importance of identifying the most appropriate route(s) for risk management and on the co-operation and co-ordination of the regulatory risk management activities between the authorities. 

The RMOA submitted by the German CA will be taken into consideration before further risk management activities for this substance, beyond identification as SVHC, are initiated.
	
2	2012/09/25	National NGO
Danish Consumer Council
Denmark	The Danish Consumer Council (DCC) supports the inclusion of the substance in the candidate list. The DCC wants dangerous chemicals in consumer products to be banned or at least minimized to the lowest possible levels. The inclusion of this substance to the candidate list is a strong signal to producers that the use of this substance should in time be stopped, and substituted with a less dangerous one.	Thank you for your opinion.	

Specific comments on the justification
#	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
4	2012/10/15	Company
REHAU AG + Co.
Germany	pages 7 and 8:
The entry in Annex VI, table 3.1 and table 3.2 is a group entry for lead compounds only, not specific for this substance. Several species of lead compounds included in a matrix of PVC cannot be distinguished by analysis easily.
	As noted in page 7 of the Annex XV report, the specific lead substance is covered by the group entry in Annex VI, table 3.1 and table 3.2 of the CLP Regulation.

Please note that when a company has to check whether it has obligations according to the Articles 7(2) and 33 of REACH, the suppliers could be asked directly on whether the content of any specific (lead) substance on the Candidate List is above a concentration of 0.1% (w/w).

Regarding recycled materials, please see response to same comment #4 in section “Specific comments on use, exposure, alternatives and risks”.

3	2012/10/11	Member State
Germany	No information about the physical properties is given in the report or in the technical dossier. In the report a link to the Chemical Substance Search on the ECHA website is given instead. It would be better to provide these data directly in the report (and the technical dossier), so that no further search in a database is necessary.	The proposal for identifying the substance as SVHC is based on its harmonised classification in Annex VI of Regulation (EC) No 1272/2008 (CLP Regulation). The physical properties of the substance are in this particular case neither necessary to define the identity of the substance addressed in the dossier nor to demonstrate that it meets criteria set out in Article 57.

If however information on the physical properties would be required to describe the substance identity or to conclude on its SVHC properties those data should be included in the Annex XV dossier.	

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

Specific comments on use, exposure, alternatives and risks
#	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
7	2012/10/17	Industry or trade association
ELSA (ESPA)
Belgium	To our astonishment there has been no analysis of the information provided in the registration dossier of this substance concerning Use, Exposure and Alternatives  and Risks. ELSA is of the opinion that such information is of paramount importance for this substance and that it should thus be taken into account during the process of potential identification of this substance as an SVHC. Therefore we have inserted an attachment in Section IV of the commenting form, which highlights the key points which shall be considered. In this document we do also refer to the comments filed for this substance by ILA, The International Lead Association, and which contains additional, more detailed information on specific topics which we did not repeat in the present attachment.
Note that the comments inserted for this substance are also applicable to 7 other lead compounds (collectively denominated “lead-based stabilisers”) and have been inserted  under each of the individual substances.
	Thank you for your comment.

Please refer to response to comment #7 in section “General comments on the SVHC proposal” (see above).	
			See also:
Comment 7 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-62229-08-7.pdf).pdf		
5	2012/10/16	Industry or trade association
International Lead Association
United Kingdom	THE LEAD REACH CONSORTIUM COMMENTS FOR THE PUBLIC CONSULTATION PROPOSAL TO IDENTIFY SULFUROUS ACID, LEAD SALT, DIBASIC (CAS# 62229-08-7) AS A SVHC
About the ILA The International Lead Association is a membership body that supports companies involved in the mining, smelting, refining and recycling of lead. The ILA represents the producers of about 3 million tons of lead and almost two thirds of lead production in the western world. As secretariat to the Lead (Pb) REACH Consortium, ILA Europe (a regional branch of the International Lead Association) is acting on behalf of the Lead Registrants for several lead substances.
These comments represent the view of the consortium member companies which are discussed in more detail in the attached document. A list of the consortium members has been provided in Appendix A of the attached document.
Further details on uses of sulfurous acid, lead salt, dibasic, workplace and environmental exposure, alternatives and socio-economic information can be found in the comments provided during this public consultation by the Industry Associations representing the predominant uses sulfurous acid, lead salt, dibasic in the EU:
European Lead Stabilizers Association (ELSA): Lead stabiliser producers
SUMMARY
We do not disagree that sulfurous acid, lead salt, dibasic could be identified as a substance meeting the criteria of Article 57 (c) of Regulation (EC) 1907/2006 (REACH owing to its CLP Annex VI classification toxic for reproduction category 1 A for lead compounds (INDEX no. 082-001-00-6), with the exception of those specified elsewhere.
The Pb REACH Consortium however believe that a detailed analysis of risk management options should be performed prior to candidate listing and only substances for which authorisation can be demonstrated to be the most appropriate risk management option should be proposed for the list. The fact that no such documentation has accompanied the current proposal is deeply regrettable. However in such circumstances it is crucial that the RMO analysis be conducted before a decision is made on whether to prioritise sulfurous acid, lead salt, dibasic for inclusion in Annex XIV. We believe that authorisation would prove to be an inefficient risk management option for this substance for the following reasons:
1. Lead based stabilisers are already subject to a voluntary phase out by end of 2015.
2. The major use of sulfurous acid, lead salt, dibasic is in the in PVC processing in the stabiliser sector. It has a non-dispersive and controlled use in that the sulfurous acid, lead salt, dibasic in the final article is bound into the matrix of plastics. It’s use in the workplace is already covered by existing Community legislation that imposes minimum requirements such as a binding occupational exposure limit and industry data indicates that the 90th percentile for exposure is below the blood lead DNEL of 40 μg/dL.
3. Sulfurous acid, lead salt, dibasic is not interchangeable with other lead compounds in any of its existing uses.
There are a number of additional points that should be considered when evaluating prioritisation for inclusion of sulfurous acid, lead salt, dibasic onto Annex XIV that are related to lead in general.
1. Extensive lead specific EU-wide Community legislation has been successfully implemented to control human and environmental exposures throughout its lifecycle from manufacturing to end of life and recycling.
2. This existing Community legislation has been successful in reducing human and environmental exposure to lead and compounds. Some examples of this include:
a. There have been significant reductions in the blood lead values of European children with, about 60% reduction between 1995 and 2007. This has predominantly been due to elimination of lead exposure from fuel (both in gasoline and energy production) which was the most significant contributor.
b. There has been a significant decrease in emissions from industry which is consistent across 26 of the EU Member States, with 22 reporting reductions of greater than 85% since 1990.
c. Occupational exposures in manufacturing and use of sulfurous acid, lead salt, dibasic are well controlled below the EU binding airborne lead limit of 0.15 mg/m3 and the biological exposure limit of 70 μg/dL and even stricter limits set by the different member states. The 90th percentile of occupational exposure is below the DNEL of 40 μg/dL.
3. Regulation introduced to limit the use of lead to only its more essential applications, particularly bans introduced on use in petrol and paint, has resulted in a marked and on-going fall in anthropogenic emissions and environmental levels globally. As a consequence of these marked reductions in industrial emissions, the relative importance of on-going natural emissions and re-circulation of pre-existing environmental deposits of lead arising from historical human activity, together with transboundary pollution from outside of Europe, are of growing significance when considering the extent of future European exposures and the impact of risk potential management measures in relation to REACH.
4. This would jeopardize the decade-long efforts and success of the VinylPlus consortium (formerly Vinyl 2010) in developing a significant recycling chain.	Thank you for the information provided. 

If the substance is identified as SVHC, this information, where relevant, will be taken into account at later stages of the authorisation process.

Even though information provided during public consultation is taken into account, we would like to stress that the registrations are the standard tool and route to communicate information on a substance and its uses to the authorities The registrations are the authorities’ principal source of information when assessing the need of further risk management for a substance or (some of) its uses. Therefore, it is of utmost importance that registrants keep the information provided in the registration dossiers up to date and adequately describing the current use and exposure situation, including the operational conditions and risk management measures in place.

If certain uses are not covered by the provided exposure scenarios, downstream users can either communicate this through supply chain communication (via their suppliers) to the registrants, who then need to update their registrations accordingly, or prepare their specific chemical safety report and submit a downstream user report to ECHA.

Topics such as the availability and suitability of alternatives, socio-economic considerations regarding the benefits of a use or the (adverse) impacts of ceasing a use as well as information on the low level of risk associated to a use are important. Information regarding these topics should be provided as part of the application for authorisation (e.g. in the analysis of alternatives, the chemical safety report or the socio-economic analysis). This information will be taken into account by the Risk Assessment and Socio-Economic Analysis Committees when forming their opinions and by the Commission when taking the final decision. It may impact the decision on granting the applied for authorisation and the conditions applicable to the authorisation, such as e.g. the length of the time limited review period of the authorisation.

The current proposal for identifying the substance as a substance of very high concern (SVHC) is in accordance with REACH Article 59(2) based on its harmonised classification in Annex VI of Regulation (EC) No 1272/2008 (CLP Regulation). The additional mentioned information is not relevant for determining whether the substance meets the criteria for identification as SVHC. However, when examining whether the substance should be recommended for inclusion in Annex XIV, ECHA will indeed have to assess available information on uses and exposures. In addition, information on work already done by industry to identify and assess potential alternatives is used in defining transitional arrangements in the draft Annex XIV entries for the recommended substances. This information will be collected by ECHA before prioritising the substances and defining the transitional arrangements for its recommendation. The generic approaches for prioritisation and defining the draft Annex XIV entries are available at: http://echa.europa.eu/documents/10162/13640/axiv_prioritysetting_general_approach_20100701_en.pdf and http://echa.europa.eu/documents/10162/13640/draft_axiv_entries_gen_approach_4th_en.pdf.
If ECHA intends to recommend the substance for Annex XIV inclusion, interested parties can provide comments on ECHA’s recommendation, including the suggested transitional arrangements in accordance with Article 58 of REACH.

Regarding your comment on the preparation of risk management options analysis (RMOA) before proposing the identification of a substance as SVHC, we note that this is a voluntary step in the co-ordination of risk management activities among the Competent Authorities for REACH but not a requirement of REACH. 

Nevertheless, ECHA agrees on the importance of identifying the most appropriate route(s) for risk management and on the co-operation and co-ordination of the regulatory risk management activities between the authorities. 

Finally, regarding the information provided on controls for this substance under other legislation note that the current proposal only concerns identifying the substance as a substance of very high concern (SVHC) in accordance with REACH Article 59(2). However, if the substance is identified as SVHC, information in relation to controls under other legislation will be taken into account at later stages of the authorisation process.	
			See also:
Comment 5 attachment (Public consultation document Sulfurous acid, lead salt, dibasic CAS 62229-08-7.pdf).pdf		
4	2012/10/15	Company
REHAU AG + Co.
Germany	page 10:
The inclusion of this substance in the candidate list 2 years  before effective date of the voluntary phase out of the use of lead-containing additives would not lead to an essential reduction of risk. From REHAU’s point of view it would cause severe problems for articles produced from post-consumer PVC-recycling-material, because most of recycled material contains more than 0.1% of lead compounds. The obligation to inform customers about lead compounds would apply to articles containing recycled material although we wouldn’t know which of the 30 listed lead compounds are contained. It is analytical impossible to identify the exact lead compounds and due to this the given information will be speculative to some extent. The information will presumably make our customers insecure to buy articles produced from recycled post consumer PVC although the lead compounds are included the matrix. The bureaucracy connected with the obligation to inform customers will jeopardize the rates for recycling of post consumer PVC aspired by association Vinyl Plus because this obligation applies along the whole supply chain and especially wholesale-companies try to avoid any bureaucracy related to substances listed in candidate list.According to our opinion it would be the better way to issue a restriction for all lead compounds effective from beginning 2016 and to allow  per derogation lead compounds introduced per recycling material up to a content of 3% (measured as metal). In return for this restriction the suggested inclusion of the 30 single lead containing substances in the candidate list should be waived.
	Thank you for your opinion.

It may indeed be difficult to know which of the Candidate List’s lead substances used in the production of PVC articles - and at which exact concentration – are contained in articles made of recycled PVC. Therefore in those cases the substance’s name information, which is among the information that needs to be provided where Articles 7(2) and 33 of REACH apply, may, as you mention, to some extent be speculative. If companies cannot draw and document a conclusion that the articles contain less than 0.1% (w/w) of any of  Candidate List substances, companies should strive to fulfil the obligations in Articles 7(2) and 33 of REACH. Information on the lead content could be given in case there is uncertainty regarding which exact substances give rise to the presence of lead. It is up to the companies to assess whether the obligations foreseen in Articles 7(2) and 33 REACH may apply; ECHA suggests to document the procedures followed during such assessment in case of enforcement.

Regarding your reference to the impact of the inclusion of lead substances in the Candidate List, on PVC recycling rates, ECHA would like to highlight that one of the purposes of Art. 33 of REACH is to enable customers to make more informed choices. Article 33 sets that for articles containing substances of very high concern (included in the Candidate List) information should be provided to allow safe use by customers. One way of doing this in practice could be to inform about the lead content of the articles. 

Finally, regarding alternative risk management options, please refer to the response to comment #3 in section “General comments on SVHC identification”.	

Attachments

Comment number	Public attachment	
5	
Comment 5 attachment (Public consultation document Sulfurous acid, lead salt, dibasic CAS 62229-08-7.pdf).pdf	
7	
Comment 7 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-62229-08-7.pdf).pdf