Document bae3325n1bm8kgzNOy9J9opn3

"uapfd 3M Specialty' Materials W S3M17Ce3nta eor o n. FULgOBOD- 137 : am / HERAT FY1-00-001378 Arse ? June 14,2000 Dr. Charles Auer Director Chemical Control Division OfficeofPollution Prevention and Toxics United States Environmental Protection Agency 401 M Street, Southwest RWaosohmin4g0t3onE,asDt.CT.ow2e0r46(M0ail Code 7405) MR2T[07 85000000019 - 180 ON urejucy Dear Charlie: "This letter responds to the May 25, 2000 letter received from Richard H. Hefter, Chief of the High Production Volume Chemicals Branchof EPA, requesting certain information from 3M. The May 25 letter requests copiesofcertain studies ~ highlighted on an attachment to the letter that were "not included with other listed studies" provided in 3M's May 4, 2000 submittal. All of the highlighted studies on the attachment to the letter are studies in progress for which 3M does pnroottyoectolhsavaendansytufdiynapllarnespo,rtwsh.erAesavianidliacbaltee,d fionr 3tMhe'sse Mstauydi4esTMisnupbrmoigtrteasls.covWeer lheattveer,rweevideiwdedproouvride files and determined that the May 4" submittal did, in fact, contain copies of these protocols and study plans, where available. `The summary study planforthe "Biodegradation Studies" (referenced as 2a on the attached sheet by Mr. Hefter) was provided. It is the same summary plan that is entitled "3M Microbial Metabolism Program." There are not two different study plans. We provided the study plan because the study is not yet complete. 3 9 `The protocol for phytotoxicity (referenced as 7 on the attached sheet by Mr. Hefter) is stilts 5 in the development stage and was not provided in the May 4" submittal. So `The summary sheet for the Global Environmental Sampling Plan (referenced as 8 on the , + attached sheet by Mr. Hefter) was provided. It is the one page summary sheet that was attached to the files discussing studies on environmental monitoring. It has also been & subsequently provided as partof the May 15, 2000 follow-up submittal to you. Contain NO CBI Page2 Dr. Charles Auer Mr. Hefter's letterofMay 25, 2000 also makes reference to aNew York Times article that indicated that some Scotchgard products -- Scotchgard Cleaner for Rugs and Carpet, Scotchgard Cleaner for Fabric & Upholstery, and Scotchgard Heavy Duty Water Repellent -- would remain in production. The letter requests confirmation that these products will remain in production and requests complete chemical compositions for these products and for any other Scotchgard products that will remain in commerce. As 3M indicated when we first informed EPA of the plan to phase out production of perfluorooctanyl chemistry substantially by the end of the year, this phase out would cover some ~ but not all -- of 3M's Scotchgard products for the reason that not allof3M' Scotehgard products are based on perfluooctanyl chemistry. With what we have already told EPA in mind, 3M can cheosniftianrtm, thhoawtetvheerp,rotdoupcrtosvmideenttihoencehdemiinctahle cMoamypo2s5itTMiolenttfeorrwtohuelsde prreomdauicntsindpureodtouctthieons.ensWiteivaere confidentiality issues and the lack of relevanceof these compositions given that the products are not based on the perfluorooctanyl chemistry being phased out by 3M, but instead, are comprised of non-perfluorochemical formulations. We would be pleased to discuss our position with the Agency further and to answer any questions. Please let me know ifyou or Mr. Hefher has questions regarding this response. Very truly yours, Atlas Q. Hepp William Weppner, Ph.D. Director Environmental, Health, Safety and Regulatory Affairs 3M Specialty Material Markets Group 3M Center, Building 236-1B-10 St. Paul, MN 55144-1000 651/733-6374 6w5a1v/e7p3p3e-r1@9m58mm(.facxo)m