Document 0kRmzd3y2mpZpj5rqXrrgb2J

AR226-2553 To: oo: Subject: Andraw S Hartten/AE/DuPont@DuPont request for information on pBrfluorochemicals can you mate a meeting this afternoon at 3:15 at chestnut run 711 ..------...------ Forwarded by Isidores J Zanikos/AE/OuPont on 04/20/2000 08:05 AM - Robert F_Pinc;hot_04^p^Op008,p4_AH4 ___________ To: Isidores J Zanlkos/AE/DuPontQDuPont cc: Subject: request for information on perfluorocriemicals See attached. Rob Forwarded by Robert P Pinchot/DEV/AE/DuPont on (M/20/2000 08:04 AM --- Robert F Pinchot 04/18/2000 03:24 PM To: cc: Subject: Richard J Anglullo/AE/DuPont@DuPont, Timothy P Mccann/DuPont@DuPont, Maurice A8toraa/AE/OuPont@DuPont, Michael 6 McCord/AE/DuPont@DuPont Robbin Baneriee/AE/DuPont@DuPont, Oscar T Garza/AE/DuPont@OuPont, Gerald L Kannedy/AE/DuPont@DuPont request for information on pertluorochemlcals Please see the attached. Charlie is the Director for EPA's Office of Pollution Prevention and Toxics (the office that administers TSCA) and he is requesting a lot of data on PFOA (C-8), PFOS (which we don't handle in FLPR or DC8E) and other "carboxylated or sulfonated perfluorochemicals." Gerry was given a heads up by Chariie that this was coming but we were unaware of the magnitude of the request until Gerry received the letter today. Charlie told Gerry last week that the persistent functionalized fluorochemicals are a concern due to 3M's recent TSCA 8(e) submission of reproductive effects at doses of <1mg/kg/day of PFOS. Though we haven't had a chance to have a group of knowledgable people look at this request In detail, the work to fulfill the request is enormous. Not only are toxleity studies required but also data on emissions to the environment, and human monitoring and exposure data are required. A group is meeting tomorrow afternoon to discuss our plan of action. Though there are specific dates for submission in the letter, we may have some negotiation room If we put in a good faith effort to get the data to the EPA in a timely manner. More to come. Rob -- Forwarded by Robert P PInchot/DEWAE/DuPent on 04/19/2000 02:24 PM Gerald L Kennedy 04/19/2000 02:06 PM EID156168 To: ec: Subject: Andrea Malinowskl/DPUDUPQDUP, Bernard J Reitty/AE/DuPont@DuPont, Stephen H Ko(2eniowski/DuPont@DuPont, Jim E Pesek/AEyDuPontQDuPont, Roben C Buck/DuPontigDuPont, Susan 8 Mileti/DuPont@DuPont, Robert F PinchoVDEWAE/DuPont@DuPont, Roger J Zlpfel/AE/DuPont@DuPont, Judy Stadler/AE/DuPontQDuPont, Robert W Rtekard/AE/DuPontQDuPont, Gary W Jepson/AE/DuPont request for information on perfluorochemicals 6 mall from EPA (which was also followed by a FAX) which needs immediate action. We need to identify a work group and a point person to get this accomplished. Thanks. Foiwanjed by Garald t. Kwinedy/AE/OuPont on (Wl 9/2000 01 -58 PM -"--------------------- Auar.Charl9s@epamall.epa.gov m 04/19/2000 08:42:54 AM To: co; Subject: Gerald L Kennedy/AE/DuPont Mernandez.OsoarQepamalI.epa.gov, Patel.NeilQepamaiI.epa.gov, Leczynskf.Barbara@epamail.epa.gov request for information on perfluorochemicafs Dear Gerry, If As discussed on April 13 by phone, SPA needs to review complete copies of final reports and any other relevant information in your possession or control on caeboxylated and sulfonated perfluorochemicals, with initial focus on PFOA (perfluoro octanoic acid). The requested information includes health effects studies (including phannacolcinetics), environmental effects studies, environmental fate studies and information, and human and environmental exposure studies and information, including monitoring. final reports are not available, we request that you clarify the status of any ongoing studies with regard to projected completion date and provide us with the latest and most complete version of any preliminary reports in your possession or control. We request that you provide us with the above information on PFOA by May 26, 2000. Regarding the aulfonated perfluorochendcals, our initial interest ia focused on perfluorooctyl sulfonic acid (PFOS) and we request that you provide the above information on PFOS by April 28, 2000. If you have any of the perfiuoroehemicals, Me above information on other request that, by April 28, carboxylated or aulfonated 2000, you initially identify the chemicals to allow us co confirm our interest, and then provide the requested information in your possession or control on other sulfonated , perfluorochemicals by May 19, 2000 and on other carboxylated pecfluorochenu.eals by a week later. May 26, 2000. The information on these additional chemicals can moat usefully be provided in chemical specific increments as they ara completed,^ with completion of the full submissions by the datag requested. A faw points of clarification regarding this request; >duPont need not resubmit copies of studies already provided to EPA (e.g., under TSCA S8(e), as FYls, under FIPRA) although we do request that you provide a comprehensive bibliography of the studies already submitted so w can check this against our holdings. >copies of acute systemic toxicity studies can be limited to the key or critical studies as described in the Data Adequacy and robust summary guidance developed for the HPV Challenge Program. Under this approach all studies will be cited in a bibliographic listing although full copies'can be limited to studies which (1) serve to identify lowest (i.e., most toxic) routes or (2) report observed effects which lethal differ dose from values by different those seen in studies (using the same route) submitted under (I). >3kin and eye irritation studies can be handled in a manner consistent with that EID15616& &&^e&^s&w^:sssssiiSiSsi outlined for acute systemic toxicity (i.e., submit copies of the key or critical studies Mhieh sarvs to sat out the irritation potential of the chemical and other irritation studies which show affects which differ from those reported in submitted studies) . >the initial request is generally limited to studies conducted during or after 1&76. FOE studies conducted prior to 1976, we ask foe a bibliography listing all studies and for full copies of studies in the following endpoint areas: genetic toxicity; subchconic toxicity; reproductive toxicity; developmental toxicity; immunotoxicity; uptake/metabolism; chronic toxicity/earcinogenicity; neurotoxicity. >regarding exposure information, we are most interested in receiving information and data of the types found in the Use and Exposure Information Profile (UEIP; the UEIP has been used to support SIDS assessments in the US) and information on results of exposure or monitoring studies (human and environmental), including full copies of studies where available and including details on procedures and methods used for sampling and analysis. We are also interested in studies relating to the ultimate environaien.tal fate and distribution of these chemicals. Xn order to maintain tha integrity of your submissions, pleaaa submit all information on a given chemical as a separate "For Your Information" (F?X) submission. You may also submit the information as supplements to any prior submissions by your company under T3CA S(e) relating to these chemicals. As always, any CBI must be submitted in accordance with applicable procedures. If you have any questions with regard to the submission procedures?, or you wish to work out the arrangements in advance, please contact Terry 0?Bryan (202-260-3483), If you have any general questions regarding this request, please contact me by email or phone (202-260-3749). I thank you in advance for your cooperation. Charles H. Auer, Director Chemical Control Division Office of Pollution Prevention and Toxics/OPPTS/EPA E1D156170