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: cpp or 7 C05r1a1t6e7s20v0e0r11:11 AM RECEIVED OPP HCIC W0SEP-6 PH 12: 57 ARQ26 -- 0629 To: `KLBoaavrmbeaorrnlaDDLCCe/cIUzUSySEnPEsAPkIiAU/USDS@CE@/PUESAPE,APWAa/rUdS@PEePnAb,erMtahryy/DDoCmIiUnSiEaPAkI/UDSC@/EUPSAE,PAK/aUrSe@nEPA, Frank Sutiect Phaseout of FOS He i e Foardby ChasAUHDGAUSoEnOPS1A62U00S0 117 AM rerrrerrrmrcs |; IT # C1o6a1r2es00A0uer11:06 AM To: CM5.hasCrhleeEshuAAnuge@rF/mDeACg/oXUrS,E.PtAh3e/rUe0Ss@aE0gPiAg1,alb4oinne@5ttcie@Eci+ssu2C.0niKt,oH,JnsoaAthadnneDtBkiunecIgc.inasIixs@+e,CSc.EgkHBc.AcZRaa3,+fISroErISe01@T8en6dI6t29oD6g8,I45EV" 20 @ocd.or `TgaeMmCosrtEg@AebnFasduAaoanX@ss.hfu3tet0lae0mdea1,x+bjnSoo,EmRIhaaiCnnseOernN@rjOrtcM.KOto,cUhh+aRsE2aI3@@GAeb2nrav3y.2+ecSr0zE-,Mamgaadirok.ahT+yhma3al0nL1@5ae6EaK4-.6nGg5aao1nv3cs.3yae0u@,5i3o,h gobo. aIaruit@enkceermmussos.emta@leknau@rbownanreemeinmtpoodu.,pl miams@jmosvLacka,naes@afonrkaufneesnnw@.guoyv.hsk, TH-TNG@ 9015. Geaxriaberc@eipniuImsaOrpyalarndd@Eeceuc, ouusis,iraaempi@bQuUwaIlRaEcDm.ucah. lnoaSgeanbtaaL-Ms@biiKcoGoo@g..mp. oVigcekrsriescg@uwnonroks@adleelgrovg.sa.ug.ovw.uikl. iHsy@@umnsce!hp,iy,ouungnueasrmy@@eulheoncdhe,rDhiuankTeUesRKvHanEILMe@oeecudworeg.n, ec: NroaboeyrutivaiYsAseSrU@DoeAcGaooercgaarbogrtLdeosnekyerOsN@YeeOcNe@uonet,cSrugs,anOsWcaayrlaHnedmDaCnIdUsS2E/PDACUNSI@SEEPPAA,SGWiElPlAan 5S2a3n2de0r0s1D@wCpI-UgSaEtePAoSmGEdeP,AP,risociplaFFaulelrryDCDICUS/EUPSAEIPJASI@SE@PAE,PmAiroybreck@epamai spa gov. Subject Phassoutof FOS I would like to draw your attention to an important development in the US which concerns a persistent, bioaccumulative, and toxic chemical. I will be approaching the OECD Secretariat about setting up a discussion opportunity at some point during the upcoming meeting of the Task Force on Existing Chemicals. Abrief summaryofthe information follows below and this is `accompanied by a number of documents which provide additional information (EPA's press. statement. 3M's press statement, and several reports submitted to EPA by 3M which provide more detailed background information). The reports from 3M will follow separately as.pdffiles and are not being sent to the cc's. Following negotiations with EPA, 3M Corporation today announced that it will voluntarily phase out perfluorooctanyl sulfonate (PFOS) chemistry, which is used to manufacture a wide range of products. This announcement is the result of a successful production stewardship effort between 3M and EPA. EPA supports this effort which began as a resultofdata 3M supplied to the Agency which indicated that these chemicals are very persistent in the environment, have a strong tendency to accumulate in human and animal tissures and, based on recent information, could potentially pose a risk to human health and the environment overthe long term. The `company plans to exit worldwide from productionof these chemicals by the endofthe year. PFOS (perfluorooctane sulfonic acid) is a memberof a large familyof sulfonated perfluoro-chemicals (total annual production < $ million kgs) which are used for a wide variety of industrial, commercial, and consumer applications (including use as a componentofsoil and stain-resistant coatings for fabrics, leather, furniture, and carpets (under the Scotchgard line), in fire-fighting foams, commercial and consumer floor polishes, cleaning products, and as a surfactant in other specialty applications); pesticidal and indirect food use products are also made from this technology. Final formulations for these uses contain less than 1%ofthe PFOS chemicals. All of these chemicals have the potential to degrade back to PFOS which does not appear to degrade further (it is thus highly persistent). 3M Corporation is the sole US. manufacturer of the PFOS familyof chemicals; 3M also has a production facility in Belgium. Available information suggests that there may be production facilities in Italy, Germany, Japan, and the Russian Federation, although 3M appears to be the dominant producer. PFOS has been found widely in human blood samples (ppm levels in manufacturing workers, ppb levels in non-exposed workers and in blood bank samples. PFOS has also been found in wildlife species across the US (especially in fish eating birds) and in the Baltic in Sweden. It was detected in naive (unexposed) laboratory rats (the PFOS contamination was traced back to fish meal used in the rat chow), PFOS caused postnatal deaths (and other developmental effects) in offspring in a 2-generation reproductive effects rat study (NOAELof0.1 mg/kg/day and LOAELof 0.4 mg/kg/day). At higher doses in this study, all progeny in first generation died while a the LOAEL manyofthe progeny from the second generation died. It is very unusual to see such second generation effects. PFOS accumulates to a high degree in humans and animals. It has an estimated half-life of4 years in humans. It thus appears to combine Persistence, Bioaccumulation, and Toxicity properties to an extraordinary degree. Several years ago, in response to the blood findings, 3M launched a major research effort on PFOS to characterize its environmental presence, environmental and human effects, and environmental fate EPA REVIEW Preliminary data indicated to EPA that PFOS isof significant concern on the basisof evidence of widespread human exposure and indications of toxicity in a 2 generation rat study. In addition, EPA's preliminary risk assessment indicated potentially unacceptable marginsofexposure (MOES) for workers and possibly the general population. There are many assumptions and considerable uncertainty in these arguments and analyses. It is not possible at present to judge the adequacy or accuracyof the MOE analyses or whether the exposure levels used in the above estimations may be considered representativeofthe affected populations a large. EPA requested detailed information from 3M and a large bodyof information has been received but 2 not reviewed. 3M hasraised questions regarding the possible relevance to humans ofa proposed mechanism (effects on cholesterol biosynthesis) for PFOS's lethal effect in the 2-generation study. The proposed mechanism, the company argues, affects reproductive outcomes in litter bearing. animals dueto its inhibitory effect on a burstofcholesterol biosynthesis in the critical periodjust before birth. The proposed mechanism would, if demonstrated, have broad implications for and present significant potential concerns for humans and environmental organisms. RECENT DEVELOPMENTS Following a seriesofdiscussions with EPA, and based on concerns about the widespread presence and longer term risks presented by PFOS, 3M decided that it would exit worldwide from this market by about the end of the year, although it may need to extend the time period for some critical uses (.g., fire fighting foam). The company had previously launched a major research efforts on PFOS to provide an in-depth understandingofthe problem and its human and environmental consequences; this research effort would be continued despite the commercial decision. 3M has expressed interest in collaborative efforts with EPA as they withdraw from the market and in the development of safer substitutes. NEXT STEPS FOR EPA EPA is preparinag communications strategy for conveying clear messages in response to 3M's announcement. We will be alerting other US Agencies (FDA, CPSC, OSHA, NIOSH), OECD governments, and international agencies (UNEP, IPCS). We do not believe that PFOS presents an imminent harm from use in consumer products during the phaseout (it is used in high molecular weight polymers which do not appear to result in exposure to PFOS during normal use; residual PFOS contamination occurs at very low levels). At the same time, we agree that continued manufacture and use of PFOS represents an unacceptable technology that should be eliminated to protect human health and the environment from potentially severe long term consequences. Regulatory action would have been difficult and time consuming at best and, given EPA's view thata rapid phase out is necessary and appropriate, EPA believes that 3M has taken a responsible corporate decision in quickly moving away from this technology. EPA is currently examining appropriate regulatory steps necessary to ensure protectionof human health and the environment. PFOA PFOA (perfluorooctanoic acid) is closely related structurally to PFOS and is used as a solvent for certain polymerization reactions. EPA has requested information from producers and will be preparing an assessment. Based on preliminary information, PFOA presents a different hazard, exposure, and risk picture compared to PFOS. 3M has also committed to ending production of PFOA. There are other producers in the US and EPA is examining its options regarding action on PFOA. 3 EPA Press Statement May 16,2000 Following negotiations between EPA and 3M, the company today announced that it will voluntarily phase out and find substitutes for perfluorooctanyl sulfonate (PFOS) chemistry used 10 produce a rangeofproducts, including some of their Scotchgard lines. 3M data supplied to EPA indicated that these chemicals are very persistent in the environment, have a strong, tendency to accumulate in human and animal tissues and could potentially posea risk to human health and the environment over the long term. EPA supports the company's plans to phase out and develop substitutes by year's end for the productionof their involved products. "Today's phaseout announcement by 3M will ensure that future exposure to these: chemicals will be eliminated, and public health and the environment will be protected." said EPA Administrator Carol M. Browner. "EPA will work with the company on the development of substitutes to ensure that those chemicals are safe for the environment. 3M deserves great credit for identifying this problem and coming forward voluntarily." PFOS chemicals are used to produce a range of products from fire fighting foams, coatings for fabrics, leather, and some paper products, o industrial uses such as mist suppressants in acid baths. The company is continuing a major research effort on these chemicals to enhance the understandingofany potential risks that may be associated with this class of chemicals. EPA will also be evaluating the chemicals to determine how individuals and the environment are exposed and what potential adverse effects may exist. Iffuture regulatory actions are required, EPA will take them. At present, 3M is the only US manufacturer of PFOS. EPA will be contacting foreign governments and other chemical manufacturers, both domestically and internationally, to sek their support fora voluntary. phaseout of PFOS and related chemicals. A May 18.2000 7:28 PRBS I o 3M Ne ews FORIMMEDIATERELEASE Investor Contact: JonGreer 651-736-1915 J Media Contact:JoinCorawell 651-733-7698 3MPhasing OutSomeofitsSpecialty Materials ST. PAUL,Minn. ~May 16,2000 - 3M todayannounced tisphasingout ofthe perfiuorooctanylchemistry usd to producecetain repellents and srfctantproducts. Thoaffectedproductlinesrepresent about twoporoeatof M'snearly S16billilionon in anonduuacltsaslceos.nihnegsseiunscdluodremianaynSdcortecahsgraersdisTMtparnocdeuocntps,apseucphassaoic,oiklfarneadwiaggtheirinrefpneolalmgesn;t;xd specialty components fo other products. 3M eidit lastosbtatally phasecut groducion bytheendoftheyearaad willworkwith customers 10accomplish smoothtrangifion urdosisionanticipatesincreasing attention tothespproprite use andmanagementof Mikes,"Whilethis chemistryhasbeen sedeffctvelyformorothan40yearsandour products ae safe our decison phase ut productionsbasedon ou principlesofresponsible covironmetal management." sudtechneoleogeierse.aTtlioacadteicnigsrieosnouricnesofopslcyiclaetraetpsunbolviaitnitorensitn,io'rsesuhsetabiensatbaleropeporstuonfituilels ourconstituencies .. ouremployees,customers, communitiesandinvestors"Reichsid. Sophisticscd testing capable some developed only tho astfew years~ show 31 {ehxitsrpeemresliystleonwtlceovrealpsouinndt,heikavitrhoenrmmeaattnedsiinnptehopelea.viArlolumexeiastti,ngasnibocdaalkcnoewblreodugdley 4 dicate thatthepresence of thesematerialsat thseverylowlovelsdossnotpose umen Tnealthorenvironmenrtiaskl | Wap 16.2000 7:20 PRS IS 15 Rodos P33 3MPhasingOutSomeofisSpecialtyMaterials- PageTwo About1,500outof 3M'sglobalwork force of 7,000employeeshave jobsassociated `wilhtheseproducts. "Innovationat 3Misatanall-timehigh,andtherearemanygreat opportunitiesfor cmployeesacrossthecompany,"Reichssid. 3Mexpectstomeetconsensuscamingsestimatesforthe res of2000.Thisexcludesa. one-timechargeon theorderof$200millon, thatwil be taken sometimethisyear, "Our growthenginesare morepowerfulthaneverandwe'reconfidentinourabilityto continuedeliovneexperctiatinonsg," said LD. DeSimone, chaiarndmCaEOn. "Manyofour newtechnologyplatformsdiceyaddres thefstest-growingsegmentsofthe ew economy suchaselectronics, telocommaundnfaitpcantelidisoplnayss." "Weexpe thepositivemomentum inourfinancialpecformance tocontinu into2001 withcamingssomewhat abovecurratanalyst esimate,"DeSimonesaid. 3Mit leadingmanufictureofinnovativeproductsforindustial,consuner,tans. portation, safety,healthcareandothermarkets, withoperationsinmorethan 60countics worldwide.Thecompany iswellknownforts"PollutionPrevention Pays"environmental initiative, and its anission reduction programs including water-based replacementofsolvents in `manufacturing andreplacementforozone-depleting chlorofluarocarbans (CFCs). 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