Document Oz903V1D4jED0xNbq7yMMg2bM

PF mm _ 1 - USER ~6 py 5: 5 AR 86 _ 06.26 3/7/2000 EPA/3M Meeting Objectives 1. Update EPA OPPT management on 3M FC initiative - product understanding - product stewardship - communications - product/process re-engineering - product reinvention - human health risk assessment . - environmental risk assessment 2. Define a "path forward" for future EPA/3M communications on the 3M FC initiative - feedback on EPA management's perspective - risk assessment - new chemicals regulatory strategy 1 | Flectro-Chemicl Fluor Co fitmT Ie 00 ilyctBu ee 5 ml zauiaad SRE OR ess Sie Sais Fluorination Cells Boornu Se D (OEcrtaenE esulE f E 1flur oride++ He lHF +electrical energyW)feies Hfuseaug Le fonyl fluorid Galton] E AeeRlaSeharfaonRS IS a CTh loCS k ora a e Ga HGiEeS LnSl ECNBa arsa g aa es faS SSue isksae ened eCloee ea B ]E e Secy ondTaarly RR e--l--EES1 sae at Pertuorooedne iee 0 EEov Co a Semmes, ea ee > Hey os en Th Sy igreTeo o ! mi pierTJuce rogoctasin emi wga e e a E ee 0 emphohtierie., [LU ms). ethylperfiuorgoctarie: Goiae aes; Fa ire Figh fghFaoa e aa de sthanol a C HE y e CE Commercialized Uses of POSFBasedChemistries + Paper and Packaging Protection Carpet Protection + Home Textiles Protection Apparel Protection Fire Fighting Foams + Performance Chemical Sales -fire fighting foams -mining and oil -metal plating and electronic etching baths -household additives -coatings and coating additives -carpet spot cleaners -insecticides -intermediates 3 POTENTIAL SOURCES OF EXPOSURE + Products - Manufacturing residuals in products - Degradation of high molecular weight FC products . + 3M Manufacturing Operations - Minimize/eliminate waste streams and emissions as potential exposure sources - Industrial hygiene + Customer's Manufacturing Operations - Help to identify and minimize waste streams and emissions as potential exposure sources - Industrial hygiene surveys - Education & Training - Screen new customers BN B He REGULATORY COMMUNICATIONS | US.EPA Initial meeting December 14, 1998 Maintain regular verbal dialogue with EPA counterparts on FC program * Recent TSCA 8(e) submissions 4 submissions Perfluorooctane Sulfonate 1 submission on Perfluorooctanoate + White paper submissions ` 1) PFOS: Current summary of Human Sera, Health and Toxicology Data (January 21 1999) 2) The Science of Organic Fluorochemistry (February 5, 1999) 3) Fluorochemical Use, Distribution and Release Overview (May 26, 1999) . 4) Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects (March 7, 2000) All submitted information reference directly to 8(e) file oan REGULATORY COMMUNICATIONS US. FDA Initial meeting April 24, 1998 * Updated Safety Assessment submitted February 9, 1999 * No further information/communication desired by FDA at this time pending completed review of safety assessment. Third generation safety assessment involving real food migration studies nearing completion. Co 6 REGULATORY COMMUNICATIONS Europe BgVV - Initial visit June 25, 1998 on Scotchban products Updated data package sent September, 1999 Expert toxicology committee review November, 1999 Canada ; Health Canada - Initial meeting September 23, 1998 Followed up with updated FDA safety assessment Environment Canada - Initial meeting November, 1998 MHW-Initial meeting February, 1999 Recent meeting October 19, 1999 MITI - Initial meeting February, 1999 Recent meeting October 19, 1999 man 7 CUSTOMER COMMUNICATIONS * Inform them of our findings and understanding * Reinforce the appropriate use, handling, and disposal of our products * Share with them an overview of our science and stewardship programs * Provide Industrial Hygiene assessments and share experience learned from our own operations g FLUOROCHEMICAL RE-ENGINEERING INITIATIVE Overall Goal: Reduce Potential for Exposure Reengineering Process Goals Reduce Manufacturing Residuals by >90% via continuous process improvement Past -- Present =p Future Average 1% Estimate 0.5% <0.1% q FLUOROCHEMICAL REINVENTION INITIATIVE Overall Goal: Reduce Potential for Exposure Reinvention Process Goals Identify New Product Chemistries with theFollowing Criteria for Human Health, Environment: * Very Low Toxicity * Minimize Accumulation Properties * Equal / Improved Product Performance * Cost Effective + Initial Screen Identified Candidates That Show Promise to Meet These Criteria. * Envision Transformation of Some Product Lines by 2001. * Will Require New PMN Filings. 0 PROPOSED FUTURE MEETINGS 1. Regulatory strategy meeting with New Chemicals Notice Management Branch to discuss transition from POSB-based chemistries to PBSF-based chemistry (within 90 days). Suggested EPA participants: - Flora Chow - Rebecca Cools - Vince Nabholz - Gary Thom 2. Meeting with Risk Assessment Division to begin discussing details of study plans and existing data on POSF-based chemistries (within 60 days). Suggested EPA participants: - Oscar Hernandez - Appropriate Scientific Staff I