Document g2gKk1yeV33kz8qwXZagGqRV3

AR226-1914 DuPont Global PFOA Strategy Comprehensive Source Reduction Presentation to EPA January 31, 2005 Company Sanitized Contains No TSCA CBI Purpose Present a comprehensive risk management approach for PFOA based on source reduction - DuPont commitment - Global impact - Voluntary actions - Work in progress for some elements - Open dialogue with EPA on this approach Page 2 January 31, 2005 Company Sanitized Contains No TSCA CBI Topics for Discussion Comments on overall approach to mitigation? Should some or all of DuPont's voluntary commitments be made binding? If so, what are the options for making the commitments binding for all parties? Can this approach be used internationally? Page 3 January 31, 2005 Company Sanitized Contains No TSCA CBI Challenges Parts of society (customers, regulatory bodies globally, NGOs) are raising questions of safety. There is no nationally established "acceptable level of risk" today; may take years to establish. Routes of exposure not fully understood. TSCA is a challenging statute to achieve timely risk management. The global marketplace is complex. Fluorotelomer products and fluoropolymers present very different issues along the commercial chain. Page 4 January 31, 2005 Company Sanitized Contains No TSCA CBI Potential Sources of PFOA Consumer Products and Sales of APFO 1950's - 2002 APFO Manufacture 1950's - present ECF AFFF Agents PFOA-based 1960's-70's Olefin Byproduct of Fluorotelomer Product Manufacture 1970's - present Fluoropolymer Manufacture Fluoropolymer Dispersions APFN Manufacture 1960's - present PFOA in the Environment Potential Fluorotelomer Product Degradation? 1970's - present Fluorotelomer Product Manufacture, Industrial & Consumer Use 1970's - present 1950's - present AFFF agents PFOS-based 1970's - present DuPont and others Page 5 January 31, 2005 PFOA Impurities in POSF Materials 1950's - 2002 Company Sanitized Contains No TSCA CBI POSF Materials Potential Breakdown to PFOA 1950's - present DuPont PFOA Reductions APFO Manufacture Fluoropolymer Manufacture Fluoropolymer Dispersions >99% >98% >90% PFOA in the Environment Potential Fluorotelomer Product Degradation? ? >90% FluorotTeleolommererProduct MMaannuuffaaccttuurree,,IInndduussttrriiaall && CCoonnssuummeerr UUssee Pot1e9n7t0i'asl -Dperegsreandtation 1970's - present 1950's - present Page 6 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Page 7 January 31, 2005 Next generation dispersion (2005/06) Negligible exposure Company Sanitized Contains No TSCA CBI No known degradation DuPont Manufacturing Emissions Reduction U.S. Fluoropolymer/Fluorotelomer Manufacture (thousand lbs PFOA) Est Air WV H2O WV Air NJ H2O NJ '99 '00 31 31 56 49 0.3 0.3 24.9 24.4 '01 '02 26 15 14 6 0.2 0.1 17.6 14.8 '03 '04 YE %Red '06 6 0.2 99 0.2 5 1.5 97 0.2 0.2 0.1 67 0.1 14.5 2.7 89 1.0 Totals 112.2 104.7 57.8 35.9 25.7 4.5 96 1.5 U.S. APFO Manufacture (thousand lbs PFOA) 3M 50 50 0 0 0 0 0 DuPont 0 0 0 <0.1 <0.1 <0.1 <0.1 Total U.S. Emissions Reduction 99% (`99-'06); 97% (`99-'04YE) Data as of Dec `04 Page 8 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Manufacturing Emissions Reduction US Fluoropolymer/Fluorotelomer Manufacture (thousand lbs PFOA) '99 '00 '01 '02 '03 '04 YE %Red '06 Est Total 112.2 104.7 57.8 35 25.7 4.5 96 1.5 %Red 99 Global Fluoropolymer/Fluorotelomer Manufacture (thousand lbs PFOA) Total 142.6 140.9 78.7 51.3 42.0 15.6 89 7.7 95 DuPont commitment: >98% global emissions reduction by 2007 (vs 1999 base year) Data as of Dec `04 Page 9 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Page 10 January 31, 2005 Next generation dispersion (2005/06) Negligible exposure Company Sanitized Contains No TSCA CBI No known degradation Fluorotelomer Products: Definition Fluorotelomer derivatives are a family of compounds used as ingredients in making fire fighting foams and coatings because of their unique properties. They are also intermediates, or building blocks, used to manufacture stain, oil and water resistant additives for some textiles, paper coatings and other surfaces. These ingredients and additives are sometimes referred to as "telomers", or "telomer products". For clarity we have referred to them as "fluorotelomer products" throughout this discussion. Page 11 January 31, 2005 Company Sanitized Contains No TSCA CBI Fluorotelomer Products: Unique Materials Performance: - The lowest surface energy that can be achieved in a solution or on a surface to repel oil and water at relatively small use levels - Wetting and leveling at concentrations more than 100 times lower than conventional surfactants for smoother and easy-clean finishes - Protection from oil-based stains and soils - Inherent stability: thermal, chemical Page 12 January 31, 2005 Company Sanitized Contains No TSCA CBI Fluorotelomer Applications Industrial Fire Fighting Architectural Coatings and Sealers Carpet & Textiles Page 13 January 31, 2005 Health Care Company Sanitized Contains No TSCA CBI Grease Resistant Packaging Fluorotelomers Global Economics Market Size z $700 Million at Fluorotelomer Producer Level Primary Manufacturers (by Size) : DuPont, Daikin, Asahi, Clariant Total 2004 sales of fluorotelomers from all producers estimated to be 160 million pounds of products, as sold, containing 25-30 million pounds of fluorotelomer active ingredient z $20 Billion: Industrial User Level Thousands of industrial customers and retailers worldwide Market Carpet and Paper Texiles Hard Surfaces Growth Rate < GDP > GDP > GDP Key Growth Region U.S., Europe U.S., Europe U.S., Europe Fluorotelomer Source U.S., Europe, Asia U.S., Europe, Asia U.S. Page 14 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Fluorotelomer Sales By Geography Europe Page 15 January 31, 2005 Asia Company Sanitized Contains No TSCA CBI Americas Fluorotelomer Products: Key Global Dynamics Fluorotelomer demand is growing globally due to - strong consumer demand for stain protection - end-use article manufacturer demand for the high value added to their products Fluorotelomer consumption is growing most rapidly in Asia due to low labor costs and proximity to textile mills. Fluorotelomer production is likely to follow suit. Page 16 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Market Segment Analysis Industry Emergency Response Healthcare Textiles Construction Construction Construction Food Packaging Application Fire Fighting Foams Medical Garments and Drapes Superior rain and stain protection Carpet soil and stain protection Architectural Coating and Sealers Benefit Saves lives and property. Superior resistance to petrochemical and solvent based fires Provides barrier protection from bodily fluids and pathogens Protection from the elements, keeps articles looking newer, longer Newness retention, adds to product life cycle Stain Protection - newness retention, adds to product life cycle. Surface active agents for leveling of coatings, reduce use of solvents Potential Alternatives Hydrocarbon based surfactants Silicone and Hydrocarbon based extenders, plastic laminates Silicones Silicones Silicones Challenges to Alt. Adoption Greater consumption, potential for greater loss of property and life Reduced level of protection and comfort for health care providers Does not provide oil based stain protection Inferior stain and soil protection will result in increased in cleanings and a reduced life cycle Inferior stain and soil protection will result in increased cleanings and a reduced life cycle. Additional surfactant need (10x) and solvent use Institutional Maintenance Reduce use of solvents to obtain quick drying and leveling of coatings Silicones Additional surfactant need (10x) and solvent use Paper Board and wrap Cost effective, breathable package with grease protection from food contact Plastic Higher cost. Cannot be recycled in paper mills. Page 17 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Next generation dispersion (2005/06) Negligible exposure Page 18 January 31, 2005 Company Sanitized Contains No TSCA CBI No known degradation Next Generation Fluorotelomer Products We recognize that some trace by-products can be a potential source of PFOA. We have taken a broad and conservative approach to potential PFOA precursors. Our next generation fluorotelomers will dramatically reduce PFOA and these trace by-products and thus reduce the potential for emissions. Page 19 January 31, 2005 Company Sanitized Contains No TSCA CBI Next Generation Fluorotelomer Product Technologies Page 20 January 31, 2005 Company Sanitized Contains No TSCA CBI Next Generation Fluorotelomer Product Technologies Page 21 January 31, 2005 Company Sanitized Contains No TSCA CBI Next Generation Fluorotelomer Products Significant Reduction of PFOA and Precursors Page 22 January 31, 2005 Company Sanitized Contains No TSCA CBI Next Generation Fluorotelomer Product Technologies Page 23 January 31, 2005 Company Sanitized Contains No TSCA CBI Next Generation Fluorotelomer Product Technologies Page 24 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Page 25 January 31, 2005 Next generation dispersion (2005/06) Negligible exposure Company Sanitized Contains No TSCA CBI No known degradation Fluoropolymer Global Economics Global Fluoropolymers Market Size (excluding Fluoroelastomers) Producer Level Revenues : $2.2B Industrial User Level Revenues : >> $10B Growth : In aggregate, products and markets are growing at, or slightly above GDP Some cyclical, but growing applications and markets (e.g., semiconductors in electronics) Some regions/countries are growing faster, such as China (but from a small base) Page 26 January 31, 2005 Company Sanitized Contains No TSCA CBI Fluoropolymer Global Economics (Cont'd.) DuPont Fluoropolymers (Resins and Dispersions) Telecomm Transportation Chem Processing Electronics Cookware Construction Market GDP > GDP GDP Cyclical, Growth > GDP GDP Key Growth Region US, AP Global Global AP, US Global, China Global, China DuPont Sources US, Europe US, Europe US, Europe, AP US, AP US, AP US, Europe, AP Page 27 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Fluoropolymers Sales by Geography Europe Americas Key Industries Resins Telecommunications Transportation Aerospace/Aircraft Automotive Chemical Processing Military Electronics Asia/Pacific Page 28 January 31, 2005 Dispersions Construction Cookware Company Sanitized Contains No TSCA CBI DuPont Fluoropolymers Materials with unique electrical properties, temperature performance, flame resistance, chemical stability and surface release. Sold as resin pellets and in aqueous dispersion form to industrial fabricators. - Resin pellets contain <25 pounds/year PFOA content; > 90% PFOA destroyed in thermal processing into fabricated articles - Aqueous dispersion products contain ~ 23,000 pounds/year PFOA content; ~75% PFOA destroyed in processing dispersion to final products Page 29 January 31, 2005 Company Sanitized Contains No TSCA CBI Fluoropolymers Applications - Resins Semiconductor Manufacture High Purity Liquid Handling Telecomm Wire & Cabling Chemical Processing Valves, Lined Piping, Tanks Page 30 January 31, 2005 Low Permeable Automotive Fuel Hose Company Sanitized Contains No TSCA CBI Aerospace Materials Hydraulic tubing Wire & Cabling Flares Fluoropolymer Applications - Dispersions Non-stick Coatings for Cookware and Small Electrical Appliances Page 31 January 31, 2005 Construction Architectural Fabric Company Sanitized Contains No TSCA CBI DuPont Fluoropolymer Market Segment Analysis Industry Sub-industry Transportation Automotive Aerospace Construction Buildings/Bridges Page 32 January 31, 2005 Application Fuel Hose Seals & O-Rings Hydraulic Tubing W&C control & power W&C in flight entertainment W&C spacecraft/satellite Architectural Fabric Thread Sealant Tape (TST) Bearing Pads Benefit Reduced Emissions, Improved Reliability & Fire Safety Reduced Emissions & Improved Reliability Improved Safety & Reliability Weight savings Weight savings and performance Fire Safety & Reduced Weight Radiation Resistance Structural Design Flexibility and Integrity, Weatherability & Fire Safety Leak Prevention & Industrial Gas Applications Structural Integrity during freeze/thaw cycles, earthquakes Potential Alternatives/ Switching Challenges No known polymer substitutes for same functionality. Metal tubing without same benefits & functionality. Other Polymers w/o equal performance(leakage) Metal tubing without same benefits & functionality Polyolefin with metal conduit Polyolefins with increase fire risk Other Polymers with poorer performance Glass fabric (poor structural properties) Hard Construction (weight) Organic fabric (low functionality & fire risk) Pipe dope compound with increased leak rate Engineering redesign with reduced productivity & safety Company Sanitized Contains No TSCA CBI DuPont Fluoropolymer Market Segment Analysis(Cont'd) Industry Telecommunications Consumer Products Apparel Sub-industry Application Benefit Potential Alternatives/ Switching Challenges Datacomm/Plenum W&C Computers - W&C Fire Safety Bandwidth/Hi Speed Data Security Systems & Mission Critical Fail-safe Performance Data Facilities Cell Phone Tower W&C Wireless Enabler Cookware & SE Convenience, Low Fat Cooking Dental Floss Hygiene Install cable in conduit with increased cost & fire hazard No known polymer substitutes for same functionality. No known polymer substitutes for same functionality. Polyolefins (unacceptable thermal performance) Metal, Ceramic or Glass cookware w/o easy clean Silicone glaze for bakeware with marginal durability Polyester thread Breathable Protective Fabric Simultaneous external protection Other durable textile fabrics with with flexibility for heavy activity decreased functionality Emergency Response Military Flares for Decoys for Heat-Seeking Safety of Military Assets & Missiles personnel None known for current or future technologies Page 33 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Fluoropolymer Market Segment Analysis(Cont'd) Industry Sub-industry Application Chemical Processing Tanks, Valves, Lined Pipe Benefit Handling of hazardous materials in aggressive environments Potential Alternatives/ Switching Challenges Exotic metals and glass with higher costs and reduced containment/safety Industrial Food Preparation Electronics Conveyor belts for ovens Coated glass cloth for cooking surfaces Semiconductor Fabrication Fluid handling for silicon wafer processing Office Automation Fuser Rolls for Copiers Easy Clean leading to better Health/Hygiene and increased Productivity Easy Clean leading to better Health/Hygiene and increased Productivity Ability to handle very aggressive, high-purity chemicals for wafer processing without introducing any impurities Metal belts with poor cleanability Metal or ceramic cooking surfaces with poor cleanability None known for current or future technologies Improved Copy Quality and Extended Service Lifetime and Reliability Rubber rollers if internal temperatures reduced requiring redesign. Reduced quality, reliability, and Copy speed Page 34 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Page 35 January 31, 2005 Next generation dispersion (2005/06) Negligible exposure Company Sanitized Contains No TSCA CBI No known degradation Next Generation Dispersion Products Reduce PFOA content by >90% Program on track to meet 2005 milestones - Pilot plant started up in January 2005 - Basic data development in progress - Customer sampling underway Interim manufacturing facilities to be installed in February 2005 for large samples and interim supply Commercial facilities to be authorized 2Q 2005 and expected to be started up 2H 2005 Significant customer conversions planned for 4Q 2005 and 2006 Page 36 January 31, 2005 Company Sanitized Contains No TSCA CBI Product Stewardship: Cookware Manufacturing Audit Program Ensure that downstream applicators are following proper manufacturing protocols so that: Product Quality is maintained Point Source Emissions are minimized Page 37 January 31, 2005 Company Sanitized Contains No TSCA CBI Product Stewardship: Expand Existing Cookware Licensee Program Page 38 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction Manufacturing Industrial Use Consumer Env. Fate Fluorotelomer Products Historically 100's lbs emissions >85% reduction by 2007 Next generation fluorotelomer products (2005/06) Negligible exposure DuPont degradation approach Fluoropolymers Historically 10,000's lbs emissions >98% reduction by 2007 Page 39 January 31, 2005 Next generation dispersion (2005/06) Negligible exposure Company Sanitized Contains No TSCA CBI No known degradation DuPont Proposed Approach on Biodegradation of Fluorotelomer Products Work in Progress It is important to determine if fluorotelomer products contribute to PFOA exposure through environmental biodegradation. DuPont is committed to: - Peer reviewed studies to determine if our new or existing fluorotelomer products biodegrade. - Concurrently, develop and validate exposure models. - If potential for degradation exists, use these exposure models to assess whether degradation contributes to detectable levels of PFOA in the general population. If these models show our new or existing product applications measurably contribute (0.5 ppb or above) detectable human blood levels, DuPont will take mitigation steps such as: - Changing formulation or how product is applied, - Introducing new technologies and products, and/or - Other steps to reduce the impact of continuing sales into these applications. Page 40 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Commitment MANUFACTURING Reduce global fluoropolymer manufacturing emissions by >98% (vs 1999) Reduce global fluorotelomer manufacturing emissions by >85% (vs 1999) FLUOROPOLYMER DISPERSION Reformulate fluoropolymer dispersion products to reduce PFOA content by >90% (vs current products) Test the value of the expanded cookware manufacturing audit program FLUOROTELOMER PRODUCTS Implement new fluorotelomer manufacturing technology to reduce PFOA and PFOA-precursors in our products by >85% Determine whether biodegradation of fluorotelomer products is a significant route of human exposure to PFOA and take defined actions if it is. Page 41 January 31, 2005 Company Sanitized Contains No TSCA CBI DuPont Global PFOA Strategy Comprehensive Source Reduction (lbs PFOA) Manufacturing Emissions Fluoropolymer Mfr Fluorotelomer Mfr 1999 142,400 (192,400*) 200 2005 <15,500 100 2007 <2,850 <100 Product Content Fluoropolymer Dispersion Fluorotelomer Uses*** Fluoropolymer Resin 1999 21,500** 5,830 <25 2005 Transitioning downward 3,640 <25 2007 <2,000** <1,100 <25 Fluorotelomer Degradation ? * Including emissions from PFOA production by previous manufacturer ** ~75% destroyed during downstream processing *** Also includes fluorotelomer alcohol, iodide and ester potential precursors Page 42 January 31, 2005 Company Sanitized Contains No TSCA CBI ? DuPont approach Discussion Comments on overall approach to mitigation? Should some or all of DuPont's voluntary commitment be made binding? If so, what are the options for making the commitment binding? What are mechanisms to drive similar reductions by other parties so that the total environmental load is reduced? Can this approach be used internationally? Next steps? Page 43 January 31, 2005 Company Sanitized Contains No TSCA CBI