Document 441v84X9yLdkw5meeNBeo4joN

5M General Offices 3M Center St. Paul. M N SJ144-1000 612 733 1110 May 15, 1998 BY CERTIFIED MAIL Document Processing Center (7407) Attn: Section 8(e) Coordinator Office OfToxic Substances United States Environmental Protection Agency 40 1 M Street, Southwest Washington, D. C. 20460 . Re: TSCA Section 8(e) --Perfluorooctane Sulfonate -- Docket Numbers 8EHQ-1180-373; 8EHQ-1180-374; 8EHQ-0381-0394 _______________________________ Dear Sir/Madam: . With this letter, 3M Company is submitting information to the EPA Administrator pursuant to Section 8(e) o f the Toxic Substances Control Act ("TSCA"). As detailed below, this information relates to fluorochemicals --specifically, perfluorooctane sulfonate (``PFOS") [CAS No. 2795-39 3] --and consists o f analysis o f blood sera samples showing PFOS at very low (/.*., parts per billion ("ppb")) levels. The presence o f organic fluorochemicals in the blood o f the general population and subpopulations, such as workers, has been known dating back to the 1970's,1and 31^3 epidemiological study o f its own workers indicates no adverse effects at parts per million levels. 3M does not believe that any reasonable basis exists to conclude that PFOS "presents a substantial ride o f injury to health or the environment." Nevertheless, as a precautionary measure, 3M is submitting this information to the TSCA Section 8(e) docket at this time. See. e.o,, Taves, D.R.; Comparison o f 'Organic" Fluoride in Human and Nonhuman Serums, SO J. Dent. Res. 783 (1971); Guy, W.S., et al.; Biochemistry Involving Carbon Fluorine Bonds, American Chemical Society, 117-34 (1976); Ubel, FA .etal.; Health Status O f Plant Workers Exposed to Fluorochemicals - A Preliminary Report, 4 American Indus. Hygiene J. 584 (Aug. 1980). 3M has submitted PFOS-related medical surveillance and epidemiological information on its own production workers as well as animal toxicology data previously to the TSCA Section 8(e) docket ee Docket Numbers 8EHQ-1180-373; 8EHQ-1180-374; 8EHQ-0381-0394 2602.0001 Tab 355 Exhibit 2602 State of M innesota v. 3M Co., C o urt File No. 27-CV-10-28862 3M M N02456909 Document Processing Center (7407) May 14. 1998 Page 2 ` In the process o f validating analytical methodology for measuring PFOS, a product o f the electrochemical fluorination process, an outside laboratory detected PFOS at ppb levels in blood samples from individuals-with no known occupational exposure to fluorochemicals. Subsequent analyses o f commercially pooled sera from human blood bank samples in different regions o f the United States measured PFOS levels between 9 ppb-and 56 ppb.3 Analyses o f limited historical blood samples from 1969 and 1976 showed mean PFOS levels o f 28 ppb and 33 ppb, respectively. Analyses o f limited animal sera samples found comparable PFOS levels. 3M also has conducted qualitative in v itro and in v iv o metabolism studies, which suggest the possibility that non-occupational presence ofPFOS could result from the metabolic conversion o f other fluorochemicals to PFOS. 3M would welcome the opportunity to discuss our findings and our plans. We are sending a copy o f this letter to Charles Auer, Director ofthe Chemical Control Division, and will be contacting him shortly to arrange a meeting for this purpose. In the meantime, please do not hesitate to contact Wiliam Weppner at (612) 733-6374 with any questions. * Sincerely, I ;h Group Vice President Chemical Markets Group 3M also analyzed these sera samples for another fluorochemical --perfluorooctanoate ("PFOA") [CAS No. 3825-26-1] - but detected the presence of PFOA at quantifiable levels of 12 and 22 ppb In only two of the samples. 2602.0002 Tab 355 3M M N02456910