3M
General
Offices
3M
3M
Center
St.
Paul,
MN
55144­
1000
651733
1110
July
7,
2000
7
`8
+t~
a26­
0~
6~
70
+t~
a26­
0~
6~
70
Charles
Auer
(E403C)
Director,
Chemical
Control
Division
Office
of
Pollution
Prevention
and
Toxics
Office
of
Prevention,
Pesticides
and
Toxic
Substances
US
Environmental
Protection
Agency
401
M.
Street,
SW
Washington,
DC
Re:
Phase­
out
Plan
for
POSF­
Based
Products
Dear
Mr.
Auer:

As
you
know,
on
May
l&
2000
3M
announced
that
it
will
be
phasing
out
manufacture
of
products
based
on
perfluorooctanyl
chemistry.
In
that
announcement,
3M
indicated
that
production
of
these
materials
would
be
substantially
discontinued
by
the
end
of
2000
and
that
the
company
would
work
with
its
customers
to
implement
an
orderly
phase­
out.

EPA
has
asked
3M
to
submit
a
detailed
plan
explaining
how
it
intends
to
filtill
these
commitments.
This
letter
and
attachments
are
provided
in
response
to
EPA's
request.
As
discussed
with
the
Agency,
3M's
initial
plan
focuses
on
products
derived
from
perfluorooctanesulfonyl
fluoride
(POSF);
these
products
constitute
over
95
percent
of
3M's
total
production
of
perfluorooctanyl
chemistries.
Other
products
covered
by
3M's
May
16
announcement,
including
perfluorooctanoic
acid
(PFOA),
will
be
separately
discussed
with
EPA.

We
appreciated
the
opportunity
to
discuss
our
phase­
out
plan
with
EPA
staff
on
June
20.
The
Agency's
comments
at
the
meeting
and
in
subsequent
conversations
were
very
helpful
and
are
reflected
in
this
letter
and
attachments.
We
have
also
continued
to
refine
our
plan
on
the
basis
of
updated
information.
Because
of
these
modifications,
our
latest
submission
reflects
3M's
current
S
E
phase­
out
plan
and
therefore
supersedes
our
letters
of
June
16
and
23.

INTRODUCTION
AND
OVERVIEW
2
.
_1_.

i<

During
the
past
two
years,
3M
has
communicated
extensively
with
EPA
about
fluorochemical
2s
(FC)
issues.
We
informed
EPA
management
of
our
phase­
out
decision
before
it
was
announced
23
**
publicly
and
EPA
is
familiar
with
the
considerations
on
which
that
decision
was
based.
In
0
.r
summary,
3M
is
discontinuing
manufacture
of
perfluorooctanyl
materials
because
of
its
commitment
to
responsible
environmental
management
and
sound
business
principles.
3M
concluded
that,
in
light
of
the
persistence
of
certain
FCs
and
their
detection
at
extremely
low
levels
in
the
blood
of
the
general
population
and
wildlife,
other
business
opportunities
were
more
deserving
of
the
company's
energies
and
attention
than
perfluorooctanyl­
based
chemistries.
As
Page
2
July
7,
2000
3M
has
repeatedly
emphasized,
all
existing
knowledge
indicates
that
the
presence
of
these
chemistries
in
people
and
wildlife
at
the
low
levels
detected
does
not
pose
a
health
or
environmental
risk.

In
deciding
how
to
implement
its
phase­
out
decision,
3M
has
been
guided
by
two
objectives.
First,
we
wish
to
fulfill
our
commitment
to
accomplish
a
substantial
phase­
out
of
production
as
expeditiously
as
practicable.
Second,
we
want
to
minimize
marketplace
disruption
and
provide
for
an
orderly
transition
away
from
POSF­
based
products
by
the
business
sectors
that
depend
on
perfluorooctanyl
chemistries.
Balancing
these
considerations
is
extremely
challenging
because
our
POSF­
based
products
are
used
in
a
wide
range
of
applications
with
impacts
on
numerous
segments
of
the
economy.

We
are
still
receiving
and
evaluating
the
information
necessary
to
balance
these
complex
considerations.
However,
this
letter
and
attachments
provide
our
best
current
understanding
of
how
we
will
implement
our
phase­
out
plan
for
POSF­
based
products.
As
illustrated
in
Attachment
I,
3M's
plan
will
result
in
a
substantial
reduction
in
production
and
import
volumes
after
December
3
1,
2000.
Limited
further
production,
at
significantly
lower
levels,
will
continue
through
the
end
of
2002.
As
shown
in
Attachment
2,
production
of
POSF­
derived
materials
will
be
reduced
in
200
1
to
12.3
percent
of
the
projected
2000
baseline
and
would
decline
to
4.5
percent
of
the
baseline
in
2002.
3M
anticipates
that
manufacture
and
import
of
affected
products
will
cease
entirely
at
the
end
of
2002.
Thereafter,
3M
will
continue
to
distribute
small
volumes
of
certain
previously
manufactured
products
to
specific
customers.

After
the
end
of
the
year,
3M
manufacturing
capacity
will
be
committed
entirely
to
certain
proposed
"extended
phase­
out"
applications
for
POSF­
based
products
by
our
customers
or
other
3M
businesses.
These
applications
are
identified
in
Attachments
3,
4
and
5.
[These
attachments
are
CBI.]
They
were
selected
on
the
basis
of
a
careful
evaluation
process
within
3M.
We
understand
from
our
discussions
with
the
Agency
that
EPA
believes
that
3M's
initial
judgments
are
reasonable.
However,
we
urge
EPA
to
solicit
public
comment
on
extended
phaseout
applications
for
POSF­
based
chemistries
when
it
proposes
regulations
applicable
to
these
chemistries
later
this
summer
so
that
3M
customers
and
other
interested
parties
can
provide
input
to
EPA.

As
you
know,
3M
is
developing
substitutes
for
certain
products
that
will
require
Premanufacture
Notice
(PMN)
submissions
before
commercialization.
We
are
pleased
that
EPA
and
3M
have
begun
a
dialogue
on
these
substitute
chemistries.
This
ongoing
dialogue,
which
we
hope
will
continue
during
the
PMN
review
process,
will
help
3M
provide
informed
guidance
to
our
customers
on
substitution
options
at
the
earliest
possible
date
so
that
they
can
switch
to
acceptable
alternates
with
minimum
delay.

The
remainder
of
this
letter
addresses
five
aspects
of
3M's
phase­
out
plan:

+
Scope
of
the
plan
+
Details
of
production
scale­
down
+
Proposed
extended
phase­
out
applications
+
Proposed
substitutes
for
POSF­
based
products
2
Page
3
July
7,
2000
+
3M
stewardship
actions
during
the
phase­
out
period
SCOPE
OF
3M'S
PLAN
Global
Impacts.
3M's
phase­
out
plan
is
global
in
scope.
In
developing
the
plan,
we
have
applied
a
consistent
framework
to
production
and
use
activities
within
and
outside
the
US.
3M
recognizes
that
EPA
does
not
have
jurisdiction
over
manufacture
and
use
of
POSF­
based
products
outside
the
US,
but
we
want
the
Agency
to
be
informed
about
our
phase­
out
actions
on
a
worldwide
basis.

Attachment
2
provides
projected
Year
2000
production
volumes
for
POSF­
based
products
for
the
US
and
entire
world,
3M
management
is
in
the
process
of
determining
which
manufacturing
locations
in
the
US
and
Europe
will
be
used
for
production
during
2001
and
2002.
It
is
possible
that
all
production
will
be
consolidated
at
a
single
facility
in
order
to
reduce
costs
and
re­
deploy
manufacturing
resources
efficiently.
We
will
keep
EPA
informed
of
our
manufacturing
plans
as
they
evolve.

Status
ofFDA
Regulated
Products.
The
3M
phase­
out
plan
includes
products
used
in
food
packaging,
medical
devices
and
other
applications
regulated
by
the
Food
and
Drug
Administration
(FDA).
For
purposes
of
comparison,
we
have
provided
a
breakout
of
FDAregulated
applications
and
associated
production
volumes.
3M
will
be
informing
FDA
of
our
phase­
out
plans
for
products
within
that
agency's
jurisdiction.

Inclusion
of
Additional
Chemistries.
Following
our
initial
announcement,
3M
has
decided
to
discontinue
manufacture
of
products
based
on
C­
6
and
C­
10
homologs
of
POSF.
We
made
this
decision
because,
in
management's
judgment,
the
rationale
for
our
phase­
out
decision
applied
to
these
products
as
well
as
to
our
C­
8
sulfonated
materials.
The
C­
6
and
C­
10
products
represent
relatively
small
volumes
and
are
highlighted
in
the
attachments
to
this
letter.

DETAILS
OF
PRODUCTION
SCALE­
DOWN
Baseline
Inventory
ofAffected
Products.
To
establish
a
baseline
for
phase­
out
decisions,
3M
inventoried
all
POSF­
based
products
currently
manufactured
by
the
company.
This
inventory
is
presented
in
Attachment
6.
[Attachment
6
is
CBI]
The
Attachment
groups
these
products
by
use
category
and
then
lists
individual
products
in
each
category
by
3M
product
code,
CAS
Number,
chemical
name
and
the
percentage
of
fluorochemicals
(FCs)
present
in
the
product,
In
addition,
the
Attachment
provides
projected
Year
2000
production
totals
for
each
individual
product
and
use
category.

Since
six
months
remain
in
Year
2000,
3M
used
updated
business
forecasts
prepared
at
the
end
of
1999
to
estimate
production
volumes
for
the
remainder
of
the
year.
These
estimated
volumes
are
presented
for
both
the
FC
portion
of
the
product
and
the
entire
product
formulation
(FC
plus
other
components).
The
FC
poundages
represent
total
solids
(including
reactants
combined
with
the
FC
starting
material)
and
do
not
represent
the
POSF
molecule
itself.

3
Page
4
July
7,
2000
Year
2000
Ordering
Process.
3M
has
asked
customers
to
place
final
orders
by
October
1,200O.
We
are
informing
customers
that
final
order
amounts
cannot
exceed
50
percent
of
their
purchase
volumes
during
1999.
Our
intention
is
to
meet
customer
requirements
with
product
manufactured
during
this
calendar
year.
Depending
on
the
size
of
the
orders
we
receive,
total
production
volumes
for
2000
could
exceed
the
forecasted
levels
reflected
in
Attachment
6.

Production
of
Starting
Materials
and
Intermediates.
3M
has
previously
identified
to
EPA
the
different
raw
materials
and
intermediates
(including
POSF
itself)
used
in
the
manufacture
of
POSF­
based
products.
3M
was
required
to
provide
1997
production
volumes
for
several
of
these
chemicals
under
the
1998
TSCA
Inventory
Update
Rule
(RJR).
Attachment
7
provides
these
IUR
production
figures,
corrected
to
reflect
a
recent
reanalysis
of
1997
production
data.
The
Attachment
shows
1997
U.
S.
production
volumes
for
POSF
of
4,083,
OOO
lbs.
For
year
2000,
a
1.5%
decrease
is
anticipated
from
that
number,
which
would
be
4,022,
OOO
lbs.
Because
the
IUR
submissions
only
include
U.
S,
production
and
importation,
a
further
adjustment
is
needed
to
reflect
POSF
production
at
3M's
Antwerp
facility.
After
accounting
for
Antwerp
operations,
we
estimate
that
total
worldwide
POSF
production
in
2000
will
be
8,100,
OOO
lbs.

Production
of
starting
materials
and
intermediates
for
POSF­
based
products
will
necessarily
decline
very
significantly
in
200
1
and
2002
because
of
the
substantial
scale­
down
in
production
of
the
end­
products
themselves.
However,
the
precise
volumes
of
POSF
and
its
derivatives
produced
during
these
years
will
depend
on
the
chemical
compositions
and
quantities
of
the
extended
phase­
out
products
which
3M
continues
to
manufacture.
Once
the
mix
of
these
products
is
finalized,
3M
will
be
in
a
position
to
determine
anticipated
production
levels
for
the
corresponding
raw
materials.
3M
will
assemble
this
information
if
EPA
believes
it
is
needed
to
to
develop
regulations
applicable
to
POSF­
based
chemistries.

PROPOSED
EXTENDED
PHASE­
OUT
APPLICATIONS
Processfor
Selection.
To
identify
product
uses
for
which
production
would
continue
after
the
end
of
2000,
3M
screened
its
entire
product
line
using
three
criteria:

1.
Does
the
end­
use
product
provide
environmental,
health
or
safety
benefits
to
which
the
fluorochemical
component
makes
a
substantial
contribution?
2
.
Does
the
end­
use
product
perform
a
unique
or
important
function
which
is
lost
without
the
fluorochemical
component
and
is
there
either
no
technically
acceptable
substitute
available
for
the
fluorochemical
or
is
additional
time
needed
to
qualify
or
prove
out
such
a
substitute?
3.
Is
use
of
the
product
specified
by
a
federal
or
state
agency
or
would
governmental
activities
(such
as
national
defense)
be
affected
if
the
product
were
no
longer
available?

Products
meeting
one
or
more
of
these
criteria
were
assigned
to
the
extended
phase­
out
category
and
deemed
suitable
for
production
following
December
3
1,
2000.

Attachment
3
provides
background
on
extended
phase­
out
products
identified
during
3M's
screening
process.
The
Attachment
sorts
these
products
into
three
categories
based
on
3M's
4
Page
5
July
7,
2000
criteria
for
extending
production
beyond
2000.
Where
more
than
one
criterion
applies,
the
product
has
been
classified
on
the
basis
of
the
predominant
rationale
for
extended
phase­
out.
For
each
affected
product,
the
Attachment
also
provides
a
detailed
description
of
the
technological
complexities
or
other
factors
that
preclude
immediate
availability
of
an
acceptable
substitute.
Attachment
4
complements
this
information
by
providing
CAS
numbers,
chemical
compositions
and
projected
volumes
for
the
extended
phase­
out
products.
Finally,
Attachment
5
indicates
the
intended
distribution
of
the
extended
phase­
out
products
to
different
global
markets.

The
three
Attachments
should
be
reviewed
in
conjunction
with
the
more
detailed
use
profiles
for
POSF­
based
products
provided
in
3M's
May
26,
1999
white
paper
entitled
Fluorochemical
Use,
Distribution
and
Release
Overview.
EPA
should
also
note
that
the
CAS
names
that
appear
in
Attachment
4
are
those
that
are
specifically
tied
to
3M's
proposed
extended
phase­
out
products.
Additional
extended
phase­
out
products
that
are
identified
subsequent
to
the
date
of
this
submission
may
require
limited
production
of
chemicals
not
shown
in
the
CAS
names
column.

Attachments
I
and
2
indicate
the
small
volumes
that
3M
will
produce
for
extended
phase­
out
applications
during
2001
and
2002
in
the
aggregate
and
by
product
category.
Anticipated
production
volumes
in
2001
should
be
12.3
percent
of
the
projected
2000
baseline
on
a
global
basis.
In
2002,
global
production
should
decline
to
4.5percent
of
the
2000
baseline,
with
no
production
currently
anticipated
in
2003.

Needfor
Further
Input
on
Selection
of
Extended
Phase­
out
Products.
It
is
important
to
keep
in
mind
that
the
judgments
reflected
in
Attachment
3,
4
and
5
are
preliminary
and
were
based
on
information
currently
available
to
3M
regarding
the
applications
in
which
POSF­
based
products
are
used.
3M
necessarily
has
incomplete
knowledge
of
the
end­
use
products
and
processes
of
its
customers
and,
therefore,
cannot
make
definitive
judgments
about
the
availability
of
substitute
materials
or
the
precise
impacts
of
phasing
out
specific
products.
We
also
made
the
decision
not
to
consult
extensively
with
our
customer
base
until
we
had
reviewed
our
phase­
out
plan
with
EPA.
For
this
reason,
our
screening
process
has
not
fully
captured
customer
views
on
extended
phase­
out
applications.
To
permit
users
of
POSF­
based
products
or
other
interested
parties
to
address
this
subject,
we
would
encourage
EPA
to
solicit
public
comment
at
the
earliest
possible
date.

Surfactant
Properties
of
POSF­
Based
Materials.
As
Attachment
3
illustrates,
the
great
majority
of
the
proposed
extended
phase­
out
products
identified
by
3M
are
in
the
industrial
surfactant
category,
which
represents
roughly
10
percent
of
projected
Y2000
production
of
POSF­
based
materials.
Surfactants
are
crucial
additives
in
many
formulator
applications
used
widely
in
transportation,
construction,
electronic,
oil
and
other
market
segments.
They
provide
value
through
two
basic
modes
of
operation.
First
is
their
ability
to
lower
surface
tension
of
liquids
and/
or
solids.
Second
is
their
ability
to
emulsify
and
disperse
a
host
of
materials.
These
surfactant
characteristics
are
typically
achieved
at
very
low
concentrations
within
a
formulation
due
to
the
surfactant's
ability
to
migrate
to
interfaces
and
surfaces.

The
scientific
literature
documents
that
the
lowest
surface
tensions
attainable
are
derived
from
the
use
of
fluorosurfactants
(perfluoro­
containing
surfactants).
This
is
because
the
unique
physicochemical
characteristics
of
perfluorinated
compounds
give
them
greater
surface
tension
5
Page
6
July
7,
2000
reduction
capability
than
other
surfactants,
such
as
silicone
or
hydrocarbon
oils.
Accordingly,
while
fluorosurfactants
may
not
be
essential
in
some
applications,
they
are
irreplaceable
in
many
others.
For
these
applications,
3M
is
proposing
to
continue
production
through
2002
while
3M
works
[CBQ
While
Attachments
3
and
4
list
extended
phase­
out
applications
known
to
3M
at
this
time,
we
expect
that
more
will
be
identified
as
3M's
customer
base
focuses
on
the
implications
of
our
phase­
out
announcement.
To
address
this
possibility,
we
urge
that
any
regulation
developed
by
EPA
allow
additional
extended
phase­
out
uses
during
2001­
2002
if
such
uses
are
identified
by
3M
or
its
customers.
To
place
limits
on
such
uses,
this
regulation
might
include
an
annual
cap
on
total
production
of
POSF­
based
products
during
2001
and
2002.
Assuming
that
production
does
not
exceed
this
cap,
3M
could
market
these
products
for
additional
uses
first
identified
after
December
3
1,
2000
if
3M
or
its
customer
files
a
notice
with
EPA
confirming
that
the
use
meets
the
criteria
for
extended
phase­
out.

INTRODUCTION
OF
SUBSTITUTES
FOR
POSF­
BASED
PRODUCTS
At
the
current
time,
3M
is
planning
[CBI.]

3M
STEWARDSHIP
ACTIONS
DURING
THE
PHASE­
OUT
PERIOD
Environmental
Controls.
Since
1997,
manufacturing
releases
of
perfluorooctanyl
chemistries
at
3M's
Decatur
facility
have
been
reduced
by
50
percent
for
wastewater
discharges
and
40
percent
for
air
emissions.
During
the
phase
out
of
POSF­
based
products,
3M
will
continue
to
implement
these
emission
reduction
programs,
These
include
source
reduction
and
recycle,
off­
site
disposal
of
designated
waste
streams,
and
end­
of­
pipe
treatment.
Drying
systems
have
been
installed
and
are
operating
at
all
3M
manufacturing
facilities
to
recover
and
reuse
POSF.
Designated
wastewater
streams
are
being
collected
and
transported
off­
site
for
disposal
at
permitted
hazardous
waste
thermal
treatment
facilities.
These
practices
will
continue
during
production
phase­
out
and
additional
waste
streams
continue
to
be
included
in
this
program.
3M
will
also
be
utilizing
carbon
adsorption
systems
to
recover
POSF
from
more
dilute
wastewater
streams.
Systems
have
been
installed
and
are
operating
in
both
Antwerp,
Belgium
and
Decatur,
Alabama.
Carbon
adsorption
has
been
shown
to
be
effective
in
the
removal
of
POSF
and
POSF
based
compounds.

Continuation
of
Research
Program.
As
previously
discussed
with
EPA,
3M
is
committed
to
continuing
its
ongoing
research
program
on
the
environmental
fate
and
distribution,
ecotoxicity
and
human
health
effects.
We
plan
to
share
new
data
when
it
becomes
available
and
to
continue
our
scientific
dialogue
with
EPA
on
the
interpretation
of
key
studies.

*
*
*
*
J
*

6
Page
7
July
7,
2000
We
look
forward
to
continuing
dialogue
with
EPA
on
our
phase­
out
plan.
We
expect
to
be
refining
the
information
in
the
attachments
based
on
further
feedback
from
our
own
organization
and
customers
and
will
submit
updated
attachments
to
EPA
as
appropriate.

We
appreciate
EPA's
cooperation
on
this
matter.

William
A.
Weppner,
Ph.
D.
Director
Environmental,
Health,
Safety
and
Regulatory
Affairs
Specialty
Materials
Markets
Group
3M
Center,
Bldg.
236­
lB­
10
St.
Paul,
MN
55144
M
1
.
d
POSF­
Containing
Chemistry
Production
Phase­
Out
I
3000
=
2500
%
of
2000
Baseline
2000
)
1500
1000
500
0
60%

40%

VY,
20%
3n7
3n7
136
136
88
88
0
4th
Qtr
1st
Qtr
2000
2001
2nd
Qtr
2001
3rd
Qtr
2001
4th
Qtr
2001
1st
Qtr
2002
2nd
Qtr
2002
3rd
Qtr
2002
4th
Qtr
2002
1st
Qtr
2003
f
`
Summary
of
the
Phase­
Out
Plan
for
the
production
of
POSFContaining
Chemistry
Attachment
2
This
summary
presents
total
estimated
production
for
2000,
which
is
useful
as
a
baseline
for
comparing
production
levels
in
subsequent
plan
years.
The
summary
also
presents
projected
production
levels
for
2001
and
2002.
Extended
transition
period
uses
requiring
production
in
2001
and
2002
are
included
on
Attachment
3.

Total
3M
POSF
Containiw
Chemistrv
manufactured
Y2000
Baseline
Y2000'
POSF
containing
chemistry­
pounds
produced
globally:
9,895,500
Y2000
POSF
containing
chemistry­
pounds
produced
in
US:
6,490,
OOO
Other
Information
for
Baseline
comparison
1999
POSF
containing
chemistry­
pounds
imported
into
the
US:
239,900
Y2000
POSF
containing
chemistry­
pounds
used
for
FDA
applications
are
3,532,
OOO
Y2001
Y2001
POSF
containing
chemistry­
pounds
to
be
produced
globally:
1,215,300
or
12.3%
of
2000
base­
line.
See
categories
below
for
US
production
numbers.
Y2001
POSF
containing
chemistry­
pounds
used
for
FDA
applications
will
be
300,000.

Y2002
Y2002
POSF
containing
chemistry­
pounds
to
be
produced
globally:
447,900
or
4.5%
of
2000
base­
line.
See
categories
below
for
US
production
numbers.
Y2002
POSF
containing
chemistry­
pounds
used
for
FDA
applications
will
be
zero.

SORTED
BY
CATEGORY
Paper
&
Packaeing
Categom
Global
Y2000
POSF
containing
chemistry­
pounds
produced:
Y2001
POSF
containing
chemistry­
pounds
to
be
produced:

US
Onlv
3,297,200
zero
Y2000
POSF
containing
chemistry­
pounds
produced:
2,670,700
Y2001
POSF
containing
chemistry­
pounds
to
be
produced:
zero
'
Estimation
based
on
Y2000
forecasts
from
customers
before
phase­
out
plan
announcement.
*
This
estimate
includes
total
solid
pounds
of
fluorochemical
containing
compound
and
has
not
been
broken
down
to
the
POSF
molecule.
3
Imports
are
not
included
in
2000
production
totals.
3M
is
presenting
1999
import
figures
because
projections
for
2000
are
not
available.

Page
1
of2
9
L
Global
Y2000
POSF
containing
chemistry­
pounds
produced:
Y2001
POSF
containing
chemistry­
pounds
to
be
produced:
Y2002
POSF
containing
chemistry­
pounds
to
be
produced:
Textile,
Leather,
and
Carpet
Treatment
Cateporv
This
category
includes
Apparel
h
Leather,
Aftermarket
(sold
as
part
of
commercial
warranty
packages),
Carpet,
Fabric
&
Upholstery,
and
Commercial
Care
(consumer
andprofessional)
Fabric
Protectors.
Global
Y2000
POSF
containing
chemistry­
pounds
produced:
4,762,900
Y2001
POSF
containing
chemistry­
pounds
to
be
produced:
zero
US
Only
Y2000
POSF
containing
chemistry­
pounds
produced:
Y200
1
POSF
containing
chemistry­
pounds
to
be
produced:
2,356,700
zero
Industrial
Surfactants,
Additives
and
Coatiws
CatePory
This
category
includes
the
External
sales
of
Coatings,
Electroplating
&
Etching
Surfactants,
Household
Additives,
Insecticides,
Intermediates,
and
Mining
&
Oil
and
Internal
3M
Applications
Global
Y2000
POSF
containing
chemistry­
pounds
produced:
1,501,800
Y2001
POSF
containing
chemistry­
pounds
to
be
produced:
881,700
Y2002
POSF
containing
chemistry­
pounds
to
be
produced:
432,600
US
Only
Y2000
POSF
containing
chemistry­
pounds
produced:
Y200
1
POSF
containing
chemistry­
pounds
to
be
produced:
Y2002
POSF
containing
chemistry­
pounds
to
be
produced:
I
,259,
OOO
808,400
428,400
Fire
Fbhtiw
Foams
Cateeorv
333,600
333,600
15,300
US
Onlv
Y2000
POSF
containing
chemistry­
pounds
produced:
203,500
Y200
1
POSF
containing
chemistry­
pounds
to
be
produced:
203,500
Y2002
POSF
containing
chemistry­
pounds
to
be
produced:
15,300
Page
2
of
2
/D
CAS#

307­
35­
7
754­
91­
6
2991­
51­
7
4151­
50­
2
31506­
32­
8
1691­
99­
2
24448­
09­
7
423­
82­
5
25268­
77­
3
376­
l
4­
7
`I
4650­
24­
g
423­
50­
7
I­
Hexanesulfonyl
fluoride,
1,1,2,2,3,3,4,4,5,5,6,6,6­
tridecafluoro­
501,634
307­
51­
7
Attachment
7
POSF
and
Core
Reactant
Product
Volumes
7991
us
Production
as
1997
us
Reported
in
Production
1998
IUR
based
on
May
Submission
2000
rework
CAS
Name
I­
Octanesulfonyl
fluoride,
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­
heptadecafluoro
(Ibs)
(Ibs)

3,492,
ooo
4,083,
OOt
I­
Octanesulfonamide,
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­

heptadecafluoroGlycine
N­
ethyl­
N­[(
heptadecafluorooctyl)
sulfonyl]­,
potassium
salt
I­
Octanesulfonamide,
N­
ethyl­
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­

heptadecafluoroI
Octanesulfonamide,
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­
heptadecafluoro­
N­
methyl
0
12,180
31,081
48,300
I­
Octanesulfonamide,
N­
ethyl­
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­
heptadecafluoro­
N­(
2­
hydroxyethyl)

I
Octanesulfonamide,
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8­
heptadecafluoro­
N­(
2­
hydroxyethyl)­
N­
methyl
2,149,
ooo
1,861,000
2­
Propenoic
acid,
2­
[ethyl[(
heptadecafluorooctyl)
sulfonyl]
amino]
ethyl
ester
2­
Propenoic
acid,
2­
[[(
heptadecafluorooctyl)
sulfonyl]
methylamino]
ethyl
ester
2­
Propenoic
acid,
2­
methyl­,
2­
[ethyl[(
heptadecafluorooctyl)
sulfonyl]
amino]
ethyl
ester
2­
Propenoic
acid,
2­
methyl­,
2­
[[(
heptadecafluorooctyl)
sulfonyl]
methylaminoJethyl
ester
7,678
777,765
53,507
36,327
I­
Decanesulfonyl
fluoride,
1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,1O­
heneicosafluoro­
24,171
07/
07/
2000
//
Page
1
