Document NGObjGoekVdoVxojv89dJOLww

.^ E0sr> UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 JAN 2 5 2006 Mr. Charles O. Holliday, Jr. Chairman and Chief Executive Officer Dupont 1007 Market Street Wilmington, DE 19898 THE ADMINISTRATOR Dear Mr. Holliday: As you are aware, Dupont and other proactive companies have been working collaboratively with the Environmental Protection Agency (EPA) to better understand the sources and pathways of exposure to perfluorooctanoic acid (PFOA) and related chemicals. Considerable progress has been made by putting in place a comprehensive testing and research program that will fill in many of the critical information gaps that exist around our understanding of potential exposures and risks. We all recognize that PFOA is persistent in the environment, that it.has been detected in human blood, and that animal studies indicate effects of concern. The data from the research and testing programs will allow the Agency and others to make informed decisions about any potential risk management actions that are warranted. In the meantime, absent the certainty that these data will provide, I am asking you to join with EPA and other stakeholders to commit to a global stewardship program whose goal is to work toward essentially eliminating emissions and product content levels o f PFOA and related chemicals. Participation in the stewardship program requires voluntary corporate commitment to two goals: 1) To commit to achieve, no later than 2010, a 95% reduction, measured from a year 2000 baseline, in both: facility emissions to all media of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals, and product content levels o f PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals. 2) To commit to working toward the elimination of PFOA, PFOA precursors, and related higher homologue chemicals from emissions and products by five years thereafter, or no later than 2015. Printed on Recycled Paper US00001915 2 While these program goals are ambitious, some participating companies may attain or even surpass some aspects o f the goals before achieving others, some companies may have achieved portions of these goals already, and some may wish to commit to a more aggressive timeline. I encourage participating companies to identify specific individual commitments that go beyond the overall program goals, such as achieving the emissions and/or product content reductions before the 2010/15 goal years. The Agency also recognizes that technological and cost issues may preclude eliminating PFOA and related chemicals entirely from emissions and products by 2015. Annual reporting should help to identify and focus attention on these areas to encourage progress toward that ultimate goal. Many activities are underway concerning PFOA and related chemicals, including additional research by companies, government agencies, and universities. Participation in the stewardship program will be in addition to a company's existing commitments to the Agency which may include research efforts, enforceable consent agreements, and memoranda of understanding. These ongoing efforts will combine with the 2010/15 PFOA Stewardship Program to further our understanding o f this family of persistent, bioaccumulative, and toxic chemicals, and to achieve true long-term environmental and public health benefits. Although our risk assessment activities are not yet complete and new data may change the current picture, to date EPA is not aware of any studies specifically relating current levels o f PFOA exposure to human health effects. This may offer us a window o f opportunity now to ensure, through the 2010/15 PFOA Stewardship Program and other related efforts, that potential concern levels are never reached. I hope that you will accept this invitation to step forward into environmental leadership. Please respond by letter with your commitment to the 2010/15 PFOA Stewardship Program by March 1, 2006. Additional information on the details of program commitments is enclosed with this letter. If you have questions concerning this program and your participation in it, please contact Mary Dominiak in the U.S. EPA Office of Pollution Prevention and Toxics, Chemical Control Division, by telephone at 202-564-8104, or by email at dominiak.mary@epa.gov. I look forward to working with you and achieving these goals. Enclosure cc: S. Hazen C. Auer US00001916 3 2010/15 PFOA Stewardship Program Commitments Corporate commitment letters should include commitments to both goals of the Stewardship Program: 1) To commit to achieve, no later than 2010, a 95% reduction, measured from a year 2000 baseline, in both: facility emissions to all media of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals, and product content levels o f PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals. 2) To commit to working toward the elimination of PFOA, PFOA precursors, and related higher homologue chemicals from emissions and products by five years thereafter, or no later than 2015. Companies participating in this 2010/15 PFOA Stewardship Program will be asked to submit their year 2000 baseline numbers for emissions and product content to EPA by October 31, 2006. To ensure transparency, companies will submit annual public reports on their progress toward the goals in October of each successive year, expressing their progress in terms of company-wide percentage achievements both for U.S. operations and for the company's global business. Companies will also provide to EPA detailed information on their progress in support of their public reports. By participating in the Program, companies grant permission to EPA to share information submitted under the Program with its contractors, including information contained within detailed progress reports that may be claimed as confidential. These chemicals present considerable scientific challenges in ensuring accurate and reproducible results in chemical analyses. To ensure that the results reported under the 2010/15 PFOA Stewardship Program are both comparable and reliable, each participating company will also commit to work with EPA, other PFOA Stewardship Program participants, and others in order to establish scientifically credible analytical standards and laboratory methods for measuring the chemicals in the program by 2010, the first goal attainment year. Participants will also make a general commitment to continue research to better understand the sources, pathways of exposure, and potential risks of these chemicals. Corporate commitment letters should be submitted by March 1, 2006, and should be addressed to: Stephen L. Johnson, Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. (1101 A) Washington, DC 20460 With a courtesy copy to: Charles M. Auer, Director U.S. EPA Office of Pollution Prevention and Toxics 1200 Pennsylvania Avenue, N.W. (7401M) Washington, DC 20460 US00001917