Document ppME3qg8Dyb3LD6B4612xmZMd

~ ~~ Katherine E . Reed, Ph .D . 3M Environmental, Health and Staff Vice President Safety Operations p. 1 900 Bush Avenue . Building 42-2E-26 PO Box 3333 1 St. Paul, MN 5513.3-333I 651 778 433 1 -3 -~-3?3 Certified Mail September 27, 2007 Document Processing Center EPA East - Room 6428 Attn : Section 8(e ) Office of Pollution Prevention and Toxics US EPA 1200 Pennsylvania Avenue Washington DC 20460-000 1 CON AW T NQ (;8 I N ~ ~ .I I ~I III I I!! i! I ;~ I NW 0 " (1 B O C I Re : TSCA 8(e) Substantial Risk Notice : Supplemental to Docket No . 8EHQ-0598-373 ; Sulfonate-based and Carboxylic-based Fluorochemical s To whom it may conce rn : 3M is submi tt ing this notice to supplement its previous submissions on sulfonate-based and carboxylic-based fluorochemicals . Enclosed is a final report detailing the results of a coho rt mortality study of workers at the former 3M ammonium perfluorooctanoate ( APFO) production facility in Cott age Grove, MN . While 3M does not believe that these data are repo rtable under the TSCA 8(e) repo rt ing criteria, a decision was made to provide this report to the EPA, recognizing the ongoing work to assess fluorochemical exposure pathways and potential risks . The purpose of cohort mortality study was to examine possible associations between working in jobs with vary ing exposure to APFO and speci fi c causes of death . Conclusions of the authors were as follows : "APFO exposed workers did not have an elevated risk of death when compared to the population of the state of Minnesota, however, within the coho rt risk of death from prostate cancer and cerebrovascular disease was elevated for workers with higher estimated exposure . Interpreting the somewhat contradicto ry results requires caution and consideration of several assumptions . A priori causes of death selected based on animal toxicology studies, liver, pancreatic and testicular cancer and cirrhosis of the liver, were not obse rv ed to be associated with APFO exposure . " If you have any questions, please contact Deanna Luebker at (651) 737-1374 or djluebker@mmm .com . Sincerely, Katherine E . Ree d Staff Vice President, Environmental, Health and Safety Operations Enclosure / ;. .. ~ 30 7,;~ 7 1