Document gbY91YeM5ko82RG8MX0VZNyke

with IY ONLINE MEETING 23 March 2021 - , 2965137 INTRODUCTION TO 3M RESPONSIBLE MANUFACTURING EMAS AEN ET g=TTae MOF-Tq o ToT BI =Ye [Vea ilo] a Re [oF:15 Upcycling of fluoropolymers UR] =8Ne)ill ddAWS) RMOA for PFAS : 3M Specialty Fluids N\ 3M Company 2021. All Rights Reserved. 3M Confidential. 2965137 Who We Are & What We Do Applying our science to improve every life Safety & Industrial Accelerating safety and industry performance by serving the industrial, electrical and safety markets. Transportation & Electronics Moving transportation and a connected world forward by serving automotive and electronic OEM customers. Health Care Connecting people, insights, science and technology to make better health possible around the world by serving the health care industry. 3M 2021. All Rights Reserved. 3M Confidential. 3M Consumer Innovating to simplify life and work by serving global consumers. 3 2965137 3M in Europe: 20,000 employees & 40 manufacturing sites 2965137 3M 2021. All Rights Reserved. 3M Confidential. Who We Are & What We Do 2 Fluorine materials manufacturing sites in Europe (out of 40) ZWIJNDRECHT; BELGIUM oe ag ~ GENDORF, GERMANY. 2965137 3M 2021. All Rights Reserved. 3M Confidential. 3M 5 New Carbon & Water commitments, building on 3M Sustainability Strategic Framework Science for Circular Our water goals will reduce water use by 25% in our facilities (10% by 2022, 20% by 2025 & 25% by 2030), and improve water quality when returned to the environment after use in our manufacturing operations 3M 2021. All Rights Reserved. 3M Confidential. Science for Climate Our carbon goal will make 3M achieve carbon neutrality in operations by 2050 while aiming for a 50% reduction of carbon emissions by 2030 and 80% by 2040 (note: 2019 is the baseline measure year) Science for Community Our social goals expand opportunities for underrepresented communities to participate and succeed in the future workplace, and make 3M lead in social equity and justice 2965137 Vision: The Fluorine Cycle Perfluorinated Fluoropolymer: ts 5 Partially Fluorinated Fluoropolymers = ~= | = * Circular technology Can be used for Fluoropolymers Manufacturing waste or post-use industrial material is decomposed back to key raw materials Raw materials can be used to produce new PTFE Pilot scale for perfluorinated Fluoropolymers demonstrated in Burgkirchen, D Reduced Environmental Impact for Perfluoropolymers per 1,000 t TEE produced: ) ( 5,000) Chlorine (10,0001) CO, (10,000 t) Acid byproduct (12,0001) Sulfuric acid ( 3,000t) Gipsum Pilot Plant development was supported by German Federal Ministry for Environment, Nature Conservation and Nuclear Safety 2965137 Our PFAS-enabled applications: Our fluorinated materials: Energy-efficient Window Films My Certain Medical devices I Certain Personal Protective Equipment I RE products (= Wind blade Protective coating) [I Road Safety products (= Pavement marking films, Traffic sign films) [W] Products used in electronics, automotive, aerospace and construction: automotive adhesive products coated masking paper adhesive transfer tapes double coated tapes foam tapes enhancing and shielding tapes 3M 2021. All Rights Reserved. 3M Confidential. UO Fluoropolymers OU Fluoroelastomers UO Fluoroplastics OQ Specialty chemicals (C1/CA4 additives) Q Specialty Fluids a 3MTM NovecTM Engineered Fluids a 3MTM FluorinertTM Electronic Liquids a 3MTM Performance Fluids ad 3MTM FA-188 Foam Additive 2965137 - "Sa ~~ Where our fluorinated materials are sold today Markets = Aerospace = Automotive = Construction = Data Centers = Electronics = Energy = Industrial * Medical = Personal Safety = Semiconductor Yes.| Select Applications = Coatings for aerospace wires that help prevent interference = High temp seals and hoses that help lower emission for autos = High transparency, long lived architectural films for stadiums = Immersion cooling of data center IT hardware = High temperature seals that enable modern electronics production = Conductive coatings that allow zero emission fuel cells = Corrosion resistant lining for industrial pipes Medical device packaging = Additives for flame retardant computer screens Heat transfer and testing fluids in semiconductor processing 3M sells broadly into non-consumer markets and supports hundreds of applications with high societal value 2965137 RMOA for PFAS RMOA should consider exempting both PFAS uses and manufacturing processes where emissions can be managed, controlled or minimized YETTedT]a g] oe) 3M 2021. All Rights Reserved. 3M Confidential. End-of-Life 2965137 Na 2065137 2965137 l3aMm SSppeecciaiallttyy FluTidNs 3 7) 5 3M Specialty Fluids EY E Y - Sia =1 A Li FP He loa] ilas AVE |TEIT 6 [SREY from fire Ne 1 . Enabling semiconductor manufacturing Reducing climate impact in the energy sector Ny A =-- a aF = Addressing thermal management applications in EVs 3M NOVECTM ENGINEERED FLUIDS ARE OFTEN USED IN REPLACEMENT OF OZONE DEPLETING CHEMICALS, CHEMICALS WITH MUCH HIGHER GWP VALUES, HAZARDOUS CHEMICALS OR SUBSTANCES OF VERY HIGH CONCERN 1] \V IS oT-T=eLla RI[VITo ERC oli Taoo)gg 1]a a=TTae MUL[0a[UTW eT=Tg {el dnaboo ol-Nel sb: T=Yoa d= gE dex We) Vil Te (oR da =T ood a TT 0 a IE {TSTSRR= To To WoTfe30 i[2 [[aa]eTe ga NAVE |NT-MeY a =Ta RV1Id a WeT=Tg {eld na b= Ta[el- Ms Eo 1e1 x 1a [-eX lloI N=o T[SAoVZ=dYo VVd a Wel dp LoY Yo) [FHT] gE 3M 2021. All Rights Reserved. 3M Confidential. 2965137 3MTM NovecTM Engineered Fluids: Fluoroketones + 3MTM NovecTM 1230 Fire Protection Fluid + 3MTM NovecTM 5110 Insulating Gas + 3MTM NovecTM 612 Magnesium Protection Fluid + 3MTM NovecTM 649 Engineered Fluid v Global warming potential (GWP) <1 & non-ozone depleting v" Novec 1230 is a used as a clean agent in fire suppression systems to protect high value assets in applications such as electrical control rooms or underground substations, data centers, telecommunications switch rooms, computer control rooms, airport control towers, clean rooms, and computercontrolled manufacturing operations as well as in archives and museums with paper archives, historical documents, priceless works of art and antiquities where other fire protection fluids cannot be used. Used in replacement of Halons and HFCs with much higher GWP v' Novec 5110 is used in gas-insulated electrical equipment, existing installations using gas mixtures with Novec 5110 are demonstrating the potential to reduce greenhouse gas emissions of up to 99.99% compared to installations using SF6 v' Novec 612 is used as an alternative to SF6 as a cover gas to prevent molten magnesium from burning during casting processes, reductions in GHG emissions of more than 99% can be achieved compared to SF6 v Novec 649 is an advanced heat transfer fluid with ultralow GWP used in Organic Rankine Cycles (ORC) and electronics cooling applications v" Not considered to be bio-accumulative, not classified for human health hazards in the European Classification, Labeling and Packaging Regulation, not classified as CMR under CLP v" Novec 1230 fluid has the highest margin of safety for human occupancy among clean fire suppression agents, including inert gas. v' Short atmospheric lifetime (1-2 weeks or shorter)' v' These fluoroketones degrade through natural processes in the atmosphere and do not redistribute to soil or water to any meaningful degree v Expected degradation products of these fluoroketones have been studied. Some sources are listed below. 1) Taniguchi, et.al., J. Phys. Chem. A, 107 (2003), 2674-2679 SOURCES: 1) Taniguchi, et.al., J. Phys. Chem. A, 107 (2003), 2674-2679, 2) Jackson, et al. Environ Sci Tech, 45 (2011), 8030-8036. 3M 2021. All Rights Reserved. 3M Confidential. 3M 2965137 3MTM NovecTM Engineered Fluids: Segregated Hydrofluoroethers + 3MTM NovecTM Engineered Fluids 7000, 7100, 7100DL, 7200, 7200DL, 7300, 7500*, 7700, 8200 + 3MTM NovecTM Engineered Fluids 71DA, 71DE, 71IPA, 72DA, 72DE, 72FL, 73DE * 3MTM NovecTM Electronic Coatings 1700, 1702, 1710, 1720, 1908, 2202, 2704, 2708 v Lower GWP (57-530) & non-ozone depleting v' Novec engineered fluids are used in a variety of applications including: v" Cleaning and vapor degreasing of electronic components, medical device parts such as implants, metal components for automotive or aerospace and precision machine parts; these fluids are often used in replacement of substances of very high concern (SVHC) such as trichloroethylene (TCE), n-propyl bromide (nPB) and high GWP and/or ODP substances such as hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) v' Solvents in coating formulas and industrial cleaning solutions and for lubricant deposition and silicone deposition in applications in electronics, automotive and medical devices; they are often used in replacement of trichloroethylene (TCE), n-propyl bromide (nPB), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) v' Heat transfer fluids in semiconductor processing equipment, industrial and medical equipment, freeze drying applications in the manufacture of pharmaceuticals and as testing fluids in semiconductor, electronics and electrical applications v' Reaction media or inert media and in microfluidics applications for medical testing applications v' Novec electronic coatings are used for electronic device component protection and for easy-clean and anti-smudge properties on device screens and glass v' Not considered to be bio-accumulative, not classified for human health hazards in the European Classification, Labeling and Packaging Regulation, not classified as CMR under CLP v These segregated hydrofluoroethers degrade over time through natural processes in the atmosphere and do not redistribute to soil or water to any meaningful degree v Expected degradation products of these segregated hydrofluoroethers have been studied. Some sources are listed below. * *NOTE: Due to the use of the OECD305 bioconcentration factor (BCF) test as indication of bioaccumulation, 3M expects that Novec 7500 will be labeled as vPvB. 3M does not agree that the results of this test are relevant in the determination of the risk of bioaccumulation for these chemistries. 3M is currently working on potential modifications to the protocol that will be proposed to reduce the uncertainty in the measured result. SOURCES: 1) Ninomiya, et.al., Environ. Sci. Technol 34, (2000), 2973-2978, 2) Wallington, et. al., Journal of Physical Chemistry A, 101 (1997) 8264-8274, 3) Christensen, et. al., Journal of Physical Chemistry A, 102 (1998) 4839-4845, 4) Rodriguez, et.al., Atm Environ, 96 (2014) 145-153, 5) Goto, et. al., Env Sci Tech, 36 (2002) 2395-2402 3M 2021. All Rights Reserved. 3M Confidential. 3M 14 2965137 3MTM NovecTM Engineered Fluids: Fluoronitrile + 3MTM NovecTM 4710 Insulating Gas v" GWP = 2100 & non-ozone depleting v Used in medium-voltage and high voltage gas insulated power generation and distribution equipment including gas insulated switchgear and gas insulated lines v Used in gas mixtures with other gases (CO,, CO,/0,) in place of sulfur hexafluoride, SF4, a potent greenhouse gas with GWP of 23,500 v' Existing installations using gas mixtures with Novec 4710 are demonstrating the potential to reduce GHG emissions by more than 99% compared to installations using SFg v' Not considered to be bio-accumulative, classified at the lowest level category for human health hazards in the European Classification, Labeling and Packaging Regulation, not classified as CMR under CLP v The fluoronitrile degrades over time through natural processes in the atmosphere and does not redistribute to soil or water to any meaningful degree v Expected degradation products of this fluoronitrile have been studied. Sources are listed below. SOURCE: 1) Sulbaek Andersen, et.al., Environ Sci Tech, 51 (2017) 1321-1329. 3M 2021. All Rights Reserved. 3M Confidential. 3M 2965137 Highlighted applications and comparison to alternatives \L Fire suppression application with 3MTM NovecTM 1230 Fire Protection Fluid Non-PFAS fire protection agents include water, carbon dioxide, dry chemical and inert gases. These non-PFAS fire protection agents can cause corrosion, can damage equipment or valuable artifacts, can be electrically conductive, are slower drying, can leave a residue, may have higher toxicity, may require high operating pressures and may result in higher maintenance costs. Inert gas systems work through a different extinguishing mechanism than HFCs and Novec 1230 fluid by displacing oxygen in an enclosure rather than cooling the fire. As a result, the volume of gas necessary for extinguishment and the pressure at which inert gas systems operate are far greater. As a result, there are extra costs associated with storing the additional volume of gas needed and extra costs required to make the system safe including extra ventilation and extra structural strength to support the weight of the system as well as more expensive testing and checkout costs. )\ Cleaning applications with 3MTM NovecTM Engineered Fluids Non-PFAS cleaning solvents include water, alcohol, n-propyl bromide (nPB), trichloroethylene (TCE) and hydrocarbons. These non-PFAS cleaning solvents and solvents can cause corrosion, have longer drying and processing times and thus use more energy, may be flammable, can have higher levels of toxicity, may have lower material compatibility and/or may be ozone-depleting substances. Unlike aqueous solutions, Novec fluids do not support biological growth and are less equipment and energy intensive and dry quickly with less chance for corrosion. Heat transfer & testing applications with 3MTM NovecTM Engineered Fluids Non-PFAS heat transfer agents include water, ethylene glycol and alcohols, these non-PFAS heat transfer agents can be electrically conductive, can create corrosion, use more energy to reach low temperatures, can be flammable and/or explosive and can have higher levels of toxicity Non-PFAS testing fluids include mineral oil and silicone oils, these other testing fluids may have less efficient heat transfer properties, may be flammable and/or / combustible, may have limited operating temperature ranges and can use more energy to reach the required low temperatures and/or high temperatures Insulating gases with 3MTM NovecTM Insulating Gases 4710 & 5110 Non-PFAS electrical insulation includes vacuum, interrupter/air-based technology. However, it unclear if the full voltage range can be covered by this technology. Furthermore, the increased space requirements of this technology when used in high voltage applications results in an overall worse life cycle management assessment compared to equipment using Novec insulating gas mixtures. Novec gases remain in place for the useful life of the equipment. / 3M 3M 2021. All Rights Reserved. 3M Confidential. 16 2965137 RMOA for 3M Novec fluids 3M Novec fluids, which are enabling the European Green Deal, should not fall under the scope of the proposed PFAS restriction. i \ a NO TM\ oF lh. Ff MA 3MTM NovecTM1230 Fire Protection Fluid will be produced at our EMAS-certified site in Belgium (as of 2021). 3M Novec fluids are used in applications of high societal value. They are helping to achieve EU climate objectives and digital agenda. 3M Novec fluids are typically used in closed applications or in applications in which users manage and minimize emissions. In many applications, the fluids are filtered in situ and can be recycled and reused. Any non-PFAS alternative is expected to exhibit inferior performance and added cost. A life cycle assessment (LCA) would need to demonstrate whether use of non-PFAS alternatives would result in a lower potential impact on the environment. N JAN A JL py 3M 2021. All Rights Reserved. 3M Confidential. 2965137 3M Position on the upcoming PFAS restriction . Restriction based on grouping of 4000+ substances with different chemical structure, physiochemical properties and an extremely wide range of applications across industrial sectors is not appropriate and will be highly difficult to implement. + Instead of a blanket approach, we believe PFAS should be grouped according to their structures and properties: v" PFAS that do not present bioaccumulative or toxic characteristics should be treated separately, and not be grouped together with other PFAS. v" Products such as Novec fluids, which are enabling the European Green Deal, should not fall under the scope of the upcoming PFAS restriction. 3M has invested in the development of Novec fluids as potential replacements for ozone depleting substances, products with higher GWP, hazardous substances and substances of very high concern (SVHC). v" High molecular weight fluoropolymers (`polymers of low concern') should be excluded from restriction in view of their lack of risk, importance to many key sectors and to be aligned with the exclusion of polymers from REACH. . Persistence on its own is not enough to assess or demonstrate an unacceptable risk to human health and environment and therefore to ban or restrict substances being manufactured, imported, or used in products, particularly in such a broad fashion. + Essential use concept cannot replace the proper impact-assessment process. Applying the essential/non-essential use concept in the absence of a demonstrated unacceptable risk would mean that products would be banned on the basis of unnecessarily intrusive judgements of what is good or bad for society, which is by nature relative and must remain evolutionary. . Applying the essential/non-essential use concept should allow the use of substances when the benefits to society, including socio economic benefits, outweigh the demonstrated unacceptable risk, if any, and for which there are no equally performing, technically and economically feasible alternatives available. Such an analysis should also account for a life cycle assessment point of view. 3M 2021. All Rights Reserved. 3M Confidential. aM 2965137 2965137 f=