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3M General Offices
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August 18, 2004
3M Center St. Paul, MN 55144-1000 651 733 1110
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VIA EXPRESS MAIL
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Document Processing Center (7407M)
EPA East - Room 6428 Attention: Section 8(e) Docket
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Re: TSCA Section 8(e) Supplemental Notice on Perfluorooctanesulfonate Docket Nos. 8EHO-1180-374
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Dear Sir and Madam: 3M has received final reports for reproductive avian toxicity studies on
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perfluorooctanesulfonate (PFOS) in northern bobwhite quail and mallard duck. In a previous
submission dated February 1, 2002, 3M described draft reports for these studies which
indicated certain early post-reproductive phase regression effects. Although such effects are
part of a normal physiological process in birds, these studies suggest that PFOS may have
accelerated this process as compared to untreated birds. As also described in our previous
submission, pilot studies preceded these studies and were inconclusive.
We are now providing the final reports for these studies, along with the analytical reports of serum, liver, and egg concentrations, as well as the reports for the pilot studies. In addition, we are submitting recently-received revised final reports for acute PFOS dietary studies in northern bobwhite and mallard. These reports were revised to reflect reporting changes after sample purity was refined. 3M also has prepared toxicological summaries for all studies being submitted today and is providing those summaries as a reference tool and to place the study results in context.
Please contact Susan Beach (651-778-7452) if you have any technical questions or if we can provide additional information. For any other assistance, please do not hesitate to contact the undersigned (651-778-4331).
Sincerely,
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Katherine E. Reed
Staff Vice President, Environmental Health and Safety Operations
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