Document qdrZQQyag2qd7nqQE4jBw0mwR
AR226-2151
To:
cc: Subject:
Andrea Malinowski/DPL/DUP@DUP, Bernard J ReiHy/AE/DuPont@DuPont, Stephen H Korzeniowsld/DuPont@DuPont, Jim E Pesek/AE/DuPont@DuPont, Robert C Buck/DuPont@DuPont, Susan S Miteti/DuPont@DuPont. Robert F Pinchot/DEV/AE/DuPont<a>DuPont, Roger J 2ipteI/AE/DuPont@DuPont, Judy Stadler/AE/DuPont@DuPont, Robert W Rickard/AE/DuPont@DuPont, Gary W Jepson/AE/DuPont
request for information on perfluorochemlcals
E mail from EPA (which was also followed by a FAX) which needs immediate action. We need to identify a work group and a point person to get this accomplished. Thanks.
---------------------- Forwarded by Gerald L Kennedy/AE/DuPont on 04/19/2000 01 :SS PM ----------------------------
Auer.Charles@epamdl.epa.gov on 04/19/2000 08:42:54 AM
To: cc: Subject:
Gerald L Kennedy/AE/DuPont
Hemandez.0scar@iepamail.epa.gov, Patel.Neil@epamail.epa.oov. Leczynsld.Barbara@epamail.epa.gov request for information on perfluorochemicals
Dear Gerry,
As discussed on April 13 by phone, EPA needs to review complete copies of final reports and any other relevant information in your possession or control on
carboxylated and sulfonated perfluorocheniicals , with initial focus on PFOA
(perfluoro octanoic acid). The requested information includes health effects studies (including pharmacokinetics), environmental effects studies,
environmental fate studies and information, and human and environmental
exposure
If studies and information, including monitoring.
final reports are not
available, we request that you clarify the status of any ongoing studies with
regard to projected completion date and provide us with the latest and most
complete version of any preliminary reports in your possession or control.
We request that you provide us with the above information on PFOA by May 26,
2000. Regarding the sulfonated perfluorochemicals, our initial interest ig
-focused on perfluorooctyl sulfonic acid (PPOS) and we request that you provide
the above information on PFOS by April 28, 2000.
If you have any of the above information on other carboxylated or sulfonated perfluorochemicals, we request that, by April 28, 2000, you initially
identify the chemicals to allow us to confirm our interest, and then provide the requested information in your possession or control on other sulfonated perfluorochemicals by May 19, 2000 and on other carboxylated
EID081950
perfluorochemicals
by a week. later. May 26, 2000. The information
can
moBt usefully be provided in chemical specific
completed,
with completion of the full submissions by the
on these additional chemicals increments as they are dates requested.
A few points of clarification regarding this requests
>duPont need not resubmit copies of studies already provided to EPA (e.g.,
under
TSCA S8(e), as FYls, under PIFRA) although we do request that you provide a comprehensive bibliography of the studies already submitted so we can check this
against our holdings.
>copiea of acute systemic toxtcity studies can be limited to the key or critical studies as described in the Data Adequacy and robust emmnary guidance
developed
for the HPV Challenge Program. Under this approach all studies will be cited
in
a bibliographic listing although full copies can be limited to studies which
(1)
serve to identify lowest (i.e., most toxic) lethal dose values by different routes or (2) report observed effects which differ from those seen in studies
(using the same route) submitted under (1).
>skin and eye irritation studies can be handled in a manner consistent with
that
outlined for acute systemic toxicity (i.e., submit copies of the key or
critical studies which serve to set out the irritation potential of the chemical and other irritation studies which show effects which differ from those reported
in
submitted studies).
>the initial request is generally limited to studies conducted during or after 1976. For studies conducted prior to 1976, we ask for a bibliography listing all studies and for full copies of studies in the following endpoint areas: genetic toxicity; subchronic toxicity; reproductive toxicity; developmental
toxicity; immunotoxicity; uptake/metabolism; chronic toxicity/carcinogenicity; neurotoxicity.
>regarding exposure information, we are most interested in receiving information and data of the types found in the Use and Exposure Information Profile (UEIP; the UEIP has been used to support SIDS assessments in the US) and information
on
results of exposure or monitoring studies (human and environmental), including
full copies of studies where available and including details on procedures and
methods used for sampling and analysis. We are also interested in studies relating to the ultimate environmental fate and distribution of these
chemicals.
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In order to maintain the integrity of your submissions, please submit all
information on a given chemical as a separate "for Tour Information" (FYI) BubitLiBBion. Xou may also submit the information ae Bupplemente to any prior Bubiniaaions by your coiapany under TSCA S8(e) relating to these chemicals. As always, any CBI must be submitted in accordance with applicable procedures.
Ifyou have any questions with regard to the submission procedures, or you wish
to work out the arrangements in advance, please contact Terry 0?Bryan (202-260-3483).
If you have any general questions regarding this request, please contact me by
email or phone (202-260-3749). I thank you in advance for your cooperation. Charles H. Auer, Director Chemical Control Division Office of Pollution Prevention and ToxicB/OPPTS/EPA
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Robwt F Pirohot 05/11/200007:31 AM
To:
cc: Subject:
David M Hurak/AE/DuPont@DuPont, Michael E McCord/Ate/DiiPont@DuPont, Robert J Cavanaugh/DuPont@DuPont, Luk D'Haenens/EUR/DuPontfBDuPont, Roger J 2i(rfel/AE/DuPoot@DuPont. Anthony J Playtis/CL/DuPort^DuPont, Arie J Venneulen/EUR/DuPont@>DuPont, Gerald L Kennedy/AE/DuPorrt@DuPont, William R Berti/AE/DuPont@DuPorrt, John Gawon/AE/DuPontODuPorrt. Robert L Ritehey/CL/DuPorrtODuPont, Andrew S Hartten/AE/DuPont@DuPont. Susan S Mlleti/DuPont@DuPont Andrea V Malinowski/AE/DuPont@lDuPoiTt, Maurice AstorBa/AE/DuPont@DuPont, Richard J Anaidlo/AE/DuPorrt@OuPont, Bernard J Heilty/AE/DuPont^DuPorrt, Gary W Jepson/AE/DuPDnt@DuPont
PFOA EPA Request
As many of you know, -the Office of Pollution Prevention and Toxics In the US EPA has requested that DuPorrt supply a large amount of information on Peffluorooctanoate (PPOA or C-8). This
information includes toxicity (human and environmental) data, environmental fate data, human exposure data, use data, and emission data. Some of this data needs to be submitted to the EPA by May 26th while the rest of the data will need to be in EPA's hands by June 23. To be able to collect all this data and get it Into a form so that EPA can use it, I will need significant help from all of you. Specifically, I will need the following information:
Purchase/Import history of C-8 in the US (Rurak, McCord) Sales History of dispersions in the US (McCord)
Fate of C-8 in dispersions (Cavanaugh) Quantity of C-8 in dispersions (Cavanaugh)
Fate of C-8 in finishes products (D'Haenens)
Emissions history at WW by media including 1999 data (Zipfel) C-8 destruction and recycle rate at WW (Zipfel) Further reduction plans at WW (Zipfel)
C-8 Air monitoring data (Playtis, Vermeulen)
Blood sampling data analysis (Playtis, Vermeulen) Blood data from other DuPont sites, as available (Kennedy, Miteti) Soil/sediment absorption study report IBertil
Bioconcentration factor and Bioaccumulation factor modeling/tests FS-62 tests/modeling for my information only].
WW emission data reported to state/EPA (Ritchey)
Groundwater information reported to EPA and state (Hartten)
(Gannon)
(Include
Zonyl8
Gerry Kennedy wfll be collecting the toxicity information that the EPA is requesting.
I will be contacting each of you either individually or in small groups to gather this data. Roger, Tony. Bob, I will plan to travel to WW during the week of May 22 to discuss the information that I
need from you.
Best Regards, Rob
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