Document a1aVBxoZB3qg6KkgKoQy4XmLX

* 3M ftKIK-OSItO Dr. Charles Reich 3M Specialty Material 3M Center, Building 220 Group Vice President Markets Group St. Paul, M N 55144-1000 May 26, 1999 dm -o o w - 373 651 733 0439 651 575 8001 Fax A EPA -O .I?,,, 000811772Q Vv-jO> 0 - O^rC0nO CERTIFIED MAIL Document Processing Center (7407) 000011772(2 -- =. oea<rcn po o o ATTN: Section 8(e) Coordinator t 70000 Office of Pollution Prevention and Toxics US Environmental Protection Agency-. I r \ ,s i ? W 401 M Street, SW 0 (f -QP-373 Washington, DC 20460 \ Re: TSCA 8(e) SUPPLEMENTAL NOTICE: Sulfonate-based and Carboxylic-based Fluorochemicals - Docket Nos. 8EHQ-1180-373; 8EHQ-1180-374; 8EHQ-0381- 0394; 8EHQ-0598-373 *-- Dear Sir: 3M Company is submitting this notice to supplement its previous submissions on cn sulfonyl and carboxylic-based fluorochemicals (FCs). ^ On May 15, 1998, 3M submitted a TSCA Section 8(e) notice summarizing analyses of77 blood sera samples from the general population which demonstrated the presence of r, perfluorooctane sulfonate (PFOS) at very low levels (under 100 ppb). Further details on these sera analyses were provided in a paper entitled Perfluorooctane Sulfonate: Current Summary o f Human Sera, Health and Toxicology Data which 3M submitted to EPA in January of this year. Since that time, 3M has refined its analytical methodologies for detecting and measuring PFOS and other FCs and has collected and analyzed additional sera samples. u io' i --Hi The results of these analyses are summarized in the attached table. Over 35 lots of individual or pooled human sera samples were purchased from chemical or biological supply companies and screened for both perfluorinated sulfonates (PFS) and perfluorinated carboxylic acids (PFCAs). Instrument detection limits are estimated to be about 200 ppt in the sera. In addition to confirming the presence of PFOS, the sample analyses resulted in the detection of several additional PFSs and PFCAs in human sera. The PFSs include a number of 3M products, as well as certain newly-identified compounds that are believed to be metabolites of other functionally derivitized PFSs and/or residuals in PFS manufacturing processes. The PFSs detected in the sera analyses were present at lower average levels (typically 0.5-5 ppb) than PFOS. The PFCAs identified include perfluorooctanoate (PFOA), which was found at average levels of 3 ppb. Five other PFCAs were also detected at levels of 500 ppt or less. The source of these five compounds is uncertain, but it is unlikely that 3M is the only source. OOOOOl US Environmental Protection Agency May 26, 1999 Page 2 As indicated in the attached table, standard material is not yet available to confirm the quantity of some of the analytes. Pending synthesis of standard material, concentration information for these compounds should be considered preliminary. As previously discussed with EPA, 3M's epidemiological studies of its own workers indicate no adverse effects at part per million (ppm) levels of PFOS and other FCs. Accordingly, 3M does not believe that PFOS or other FCs found in human sera present a substantial risk of injury to human health. If you would like additional information, please contact Dr. William Weppner at (651) 733-6374. Sincerely, I :ich Group Vice President Specialty Material Markets Group Attachment 000002 000003 Attachment Sulfonate-based Fluorochemicals identified in Human Sera Formula Estimated Range in Sera (Average)* identity Confirmed?** C8F17S03C8F17S02NH2 C8F17S02N((CH2CH3)(CH2C00))C8F17S02N((H)(CH2C00))C8F17S02N((CH3 )(CH2C00))C5F11S03C6F13S03C7F15S03C9F19S03C10F21SO3- 5-85 ppb (35 ppb) 500 ppt -2 ppb (0.8 ppb) 500 ppt -5 ppb (3 ppb) 500 ppt -5 ppb (2 ppb) 500 ppt -5 ppb (2 ppb) estimated at 500 ppt 1-13 ppb (4 ppb) estimated at 1 ppb estimated at 1 ppb estimated at 5 ppb Y Y Y Y Y No standard material Y No standard material No standard material No standard material Carboxylic acid-based Fluorochemicals identified in Human Sera Formula C7F15COOC6F13COOC8F17COOC9F19COOC10F21COO- Estimated Range in Sera (Average)* 1-13 ppb (3 ppb) estimated at 500 ppt estimated at 500 ppt estimated at 100 ppt estimated at 100 ppt Identity Confirmed?** Y No standard material No standard material Y No standard material * All concentrations are best estimates, based on standard material, if available ** Identity confirmed by HPLCESM SM S data comparison with standard material Where no`standard material is available, identification is based on reasonable interpretation of HPLC-ESMSMS data HPLC-ESMSMS = High Performance Liquid Chromotography-Electrospray Tandem Mass Spectrometry *-o g p ia T -VS mf ) ^ -h ni t> < ~ P ii r\3 0 0 -j