3M
General
Offices
3M
Center
St.
Paul,
MN
551444000
651
733
1110
31V1
March
13,
2003
Stephen
L.
Johnson
Assistant
Administrator
Office
Of
Prevention,
Pesticides
And
Toxic
Substances
United
States
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20004
Re:
Environmental,
Health
And
Safety
Measures
Relating
To
Pertluorooctanoic
Acid
And
Its
Salts
(
PFOA)

Dear
Assistant
Administrator
Johnson:

3M
Company
(
3M)
understands
that
your
office
has
been
evaluating
perfluorooctanoic
acid
and
its
salts
(`
PFOA"),
which
are
perfluorinated,
8
carbon
carboxylate
surfactants
used
primarily
as
fluorinated
polymerization
aids
(
FPAs)
in
the
manufacture
of
fluoropolymers.'
This
letter
confirms
3M's
intent
to
continue
ongoing
environmental,
health
and
safety
(
EHS)
measures
relating
to
PFOA.
In
particular,
this
letter
documents
past
EHS
measures
by
3M
to
characterize
exposure
to
PFOA;
to
conduct
health
and
environmental
fate
and
effects
research
for
PFOA;
and
to
reduce
PFOA
exposure
through
a
production
phase­
out
and
other
measures.
This
letter
also
summarizes
3M's
plans
for
ongoing
and
future
EHS
measures
to
develop
additional
data
characterizing
exposure
to
PFOA;
to
continue
to
monitor
possible
PFOA
presence
in
the
environment
near
3M's
former
manufacturing
facilities;
to
characterize
possible
PFOA
exposure
pathways
from
3M's
former
manufacturing
and
commercial
activities;
and
to
fund
additional
health
and
environmental
fate
and
effects
research
for
PFOA.

I.
PERTINENT
BACKGROUND
3M
production
records
reflect
that
PFOA
was
produced
at
various
facilities
from
1969
to
2002
using
electrochemical
fluorination
(
ECF)
technology.
Between
1992
and
2002,
3M's
total
PFOA
production
averaged
250,000
pounds
per
year.

Chemical
Name:
Perfluorooctanoic
Acid
(
FFOA).
Molecular
formula:
C3
H
F15
02.
CAS
Number:
Various,
including:
335­
67­
1
(
free
acid);
3825­
26­
1
(
ammonium
salt);
335­
95­
5
(
sodium
salt);
and
2395­
00­
8
(
potassium
salt).
The
perfluorooctanoate
anion
has
no
specific
cAS
number.
Stephen
L.
Johnson
March
23,
2003
Page
2
Approximately
97
percent
of
the
PFOA
produced
by
3M
was
used
by
its
industrial
customers
and
in
its
own
processes
as
a
fluoropolymer
processing
aid.
The
remaining
3
percent
totaled
roughly
8,000
pounds
per
year
and
was
used
in
a
medical
film
coating
application
and
in
electronics
applications
involving
printed
circuit
boards
and
precision
bearings.

Between
1998
and
2002,
3M
submitted
to
EPA
serum
analyses
of
the
U.
S.
population
and
certain
U.
S.
population
subgroups.
These
analyses
indicated
the
presence
in
individual
and
pooled
human
serum
samples
of
the
PFOA
anion
at
very
low
mean
levels
of
4­
6
parts
per
billion
(
ppb).
Wildlife
sampling
also
occurred
during
this
period
and
indicated
the
presence
of
the
PFOA
anion
only
in
limited
circumstances.

Toxicological
and
epidemiology
studies
on
PFOA
have
been
sponsored
by
3M
as
well
as
other
members
of
industry
addressing
a
range
of
health
end­
points.
These
studies
are
available
to
the
public
along
with
other
information
through
a
public
docket
maintained
by
EPA
OPPTS
­­
AR­
226.

3M
does
not
believe
that
the
PFOA
levels
measured
in
workers,
the
U.
S.
population
or
the
environment
cause
adverse
effects
in
humans,
but
is
acting
on
a
voluntary
basis
to
develop
additional
PFOA
health
and
environmental
fate
and
effects
data;
to
provide
additional
characterization
of
potential
PFOA
routes
of
exposure;
and
to
agree
to
undertake
additional
measures
to
reduce
or
prevent
PFOA
exposure
whenever
practicable.
The
details
ofthese
EHS
commitments
by
3M
are
described
in
Section
II.
below.

II.
EHS
COMMITMENTS
BY
3M
A.
Past
3M
EHS
Measures
For
PFOA
Over
the
years,
3M
has
undertaken
a
wide
range
of
measures
to
assess
the
exposure
and
toxicological
profile
of
PFOA.
The
elements
below
describe
3M's
major
past
actions,
but
are
not
an
exhaustive
list
of
3M's
past
EHS
measures.

1.
3M
has
monitored
the
health
of
fluorochemical
production
workers
dating
back
to
1978.
More
recently,
this
monitoring
program
has
involved
periodically
measuring
PFOA
levels
in
serum,
tracking
clinical
chemistries
and
communicating
with
workers
regarding
these
results;
undertaking
industrial
hygiene
measures
to
monitor
and
reduce
workplace
exposures;
and
conducting
medical
surveillance,
epidemiological
and
other
forms
of
pertinent
study.

2.
3M
has
both
engaged
in
and
supported
toxicological
research
to
address
whether
PFOA
has
the
potential
to
cause
any
health
effects
for
a
range
of
endpoints
including
developmental
toxicity,
mutagenicity,
chronic
toxicity,
reproductive
effects
and
cancer.
These
data
are
available
to
the
public,
along
with
other
information,
through
the
EPA­
maintained
OPPTS
AR­
226
docket.
Stephen
L.
Johnson
Merch
13,2003
Page
3
3.
3M
has
performed
extensive
analytical
work
to
determine
PFOA
exposure
levels
in
the
U.
S.
population
and
the
environment.
For
this
work,
3M
engaged
in
state­
of­
the
art
methods
development
and
refinement
to
lower
limits
of
detection
and
quantification.
3M
also
qualified
independent
laboratories
to
apply
these
methods.
Analyses
were
performed
of
pooled
blood
samples
from
U.
S.
blood
banks
as
well
as
of
individual
blood
samples
from
various
population
subgroups.
A
study
also
examined
liver
tissue.
With
respect
to
environmental
monitoring,
3M
conducted
monitoring
in
the
vicinity
of
its
now
former
PFOA
production
facilities;
analyzed
serum
and
liver
samples
from
fish,
birds
and
other
wildlife
for
the
presence
of
PFOA;
and
sponsored
a
Multi­
City
Study
in
which
a
variety
of
environmental
compartments
were
analyzed.
These
data
also
are
available
to
the
public
through
the
OPPTS
AR­
226
docket.

4.
Over
the
years,
3M
also
has
undertaken
steps
to
limit
PFOA
exposures
in
the
workplace.
These
steps
have
included
implementation
of
industrial
hygiene
controls
at
3M
fluorochemical
production
facilities,
including
adoption
of
exposure
guidelines.
3M
also
has
taken
various
actions
to
reduce
environmental
releases
of
PFOA
at
these
facilities,
including
capture
and
incineration
of
PFOAcontaining
waste
streams
and
the
implementation
in
1998
of
activated
carbon
systems
to
improve
the
removal
of
PFOA
from
wastewaters.

5.
In
1997,
3M
obtained
new
analytical
data
on
PFOA
and
periluorooctane
sulfonate
(
PFOS)
serum
levels
in
the
general
population
and
promptly
shared
these
data
with
EPA.
Thereafter,
3M
shared
additional
data
and
exposure
information
with
EPA
on
perfluorooctanyl
chemicals,
including
PFOA,
and
cooperated
with
EPA
in
evaluating
hazard
and
exposure
issues
associated
with
these
chemicals.

6.
Subsequent
to
obtaining
the
new
analytical
data
on
PFOA
and
PFOS
serum
levels
in
the
general
population,
3M
decided
to
phase­
out
its
perIluorooctanyl
chemistry
substantially
by
the
end
of
2000.
This
phase­
out
included
terminatin9
all
PFOA
production
for
commercial
sale
by
the
end
of
2002.
3M's
Dyneon
subsidiary2
continues
to
manufacture
small
quantities
of
PFOA
at
its
facility
in
Gendorf,
Germany
for
its
own
internal
use
as
a
fluoropolymer
manufacturing
aid
at
its
two
facilities.
In
this
connection,
Dyneon
has
made
process
changes
that
reduce
the
quantity
of
PFOA
required
and
has
developed
a
"
capture
for
recycle"
technology
that
reduces
the
need
for
new
PFOA.
As
described
in
Section
Il.
C.
6.
below,
Dyneon
will
be
engaging
in
its
own
EHS
measures
in
connection
with
this
limited
production
and
use,
including
further
reduction
of
PFOA
use.

2
Dyneon
engages
in
the
manufacture
of
fluoropolymers
and
fluoroelastomers
and
operatestwo
facilities
­­
one
in
the
United
States
and
one
in
Germany.
Formerly
a
joint
venture
between
3M
and
Hoechst
AG,
Dyneon
now
is
a
wholly­
owned
subsidiary
of
3M.
Stephen
L.
Johnson
March
13,
2003
Page
4
B.
Characterization
Of
Other
Potential
Routes
Of
Exposure
A
qualitative
discussion
more
fully
characterizing
possible
exposure
routes
related
to
non­
fluoropolymer
PFOA
uses
and
discontinued
perfluorooctanesulfonyl
fluoride
(
POSF)­
based
products
follows
below.
This
discussion
reflects
two
key
points:
(
i)
3M's
commercial
PFOA
production
for
non­
fluoropolymer
uses
occurred
on
a
limited
basis
at
a
level
of
only
8000
pounds
per
year
for
medical
film
and
electronics
applications
with
low
exposure
potential;
and
(
ii)
POSF­
based
products
did
not
likely
pcov~
dea
route
of
measurab~
ePFOA
exposure.

1.
Production
Of
PFOA
For
Non­
Fluoropolvmer
Uses
3M
produced
limited
quantities
of
PFOA
­­
approximately
8,000
pounds
per
year
in
recent
years
­­
for
non­
fluoropolymer
uses.
The
principal
non­
fluoropolymer
use
occurred
in
a
medical
film
application
where
PFOA
served
as
an
antistatic
additive
in
coatings
sandwiched
between
multi­
layer
medical
films.
No
consumer
or
medical
patient
exposure
would
be
expected
from
this
application.
Worker
exposure
should
have
been
minimal
given
that
the
PFOA
sold
for
this
application
in
recent
years
was
in
a
30
percent
aqueous
solution
and
the
MSDS
advised
protective
measures
during
handling
and
use.

A
small
amount
of
PFOA
­­
less
than
500
pounds
per
year­­
was
derivatized
as
an
ester
to
form
a
methacrylate
co­
polymer
coating
used
in
electronics
applications
to
provide
a
humidity
barrier
on
printed
circuit
boards
and
to
secure
silicone
oil
on
precision
bearings,
for
example,
in
gyroscopes
and
telecommunications
switching
stations.
These
applications
involved
PFOA
derivatized
into
a
stable
polymer,
making
PFOA
exposure
to
workers,
the
consumer
or
the
environment
highly
unlikely.

2.
Transformation
Of
POSF­
Based
Substances
3M
has
submitted
two
biodegradation
studies
to
EPA
on
N­
Et
FOSE
alcohol.
3
N­
Et
FOSE
alcohol
was
both
a
building
block
intermediate
used
in
the
production
of
many
POSF­
based
products
and
one
of
the
prevalent
fluorochemical
residuals
found
in
POSF­
based
products.
The
biodegredation
studies
were
performed
in
accordance
with
EPA
OPPTS
Guidelines
at
40
C.
F.
R.
835.3200
 
3210
&
­
5045.
Both
studies
indicate
that
PFOS
would
be
generated
through
the
biotic
degradation
of
N­
Et­
FOSE
alcohol,
but
that
PFOA
could
be
formed
instead
of
PFOS
only
under
an
abiotic
or
hydrolytic
condition
during
the
last
step
of
the
degradation
pathway.
The
diagram
below
depicts
the
degradation
pathway
indicated
by
these
studies.

3M
E01­
0415
dated
February
23,
2001;
3M
E0O­
2252
dated
October
1,2000,
available
in
OPPTS
AR­
226
docket.
Stephen
L.
Johnson
March
13,
2003
Page
5
N­
Et
FOSE
Alcohol
Biodegradation
Pathway
N­
ETFOSE
ALCOHOL
(
STARTING
SUBSTANCE)

+

N­
ETFOSE
ALDEHYDE
+
N­
ETFOSAA
4
N­
ETFOSA
N­(
2)
HYDROXYETHYL
PERFLU
ROOCTANE
SULFONAMIDE
4
PERFLUOR000TANE
SULFONAMIDE
ACETALDEHYDE
4
M556
+
FOSA
4
PFOSulfinate
Biotic
Mechanism/
PFOS
Only
Under
\~
iot1c
Conditions
PFOA
Stephen
L.
Johnson
March
13,
2003
Page
6
As
the
diagram
depicts,
these
studies
indicate
that
under
biotic
conditions,
the
N­
Et
FOSE
alcohol
will
follow
a
stepwise
degradation
pathway
that
results
in
PFOS
as
the
ultimate
degradation
product.
Prior
to
the
final
degradation
step
to
PFOS,
the
penultimate
intermediate
degradation
step
involves
degradation
to
a
compound
known
as
periluorooctane
sulfinate.
The
protocol
for
these
studies
requires
a
degradation
control
test
to
be
run
under
abiotic
conditions
for
each
step
in
the
pathway.
In
this
control
test,
the
perfluorooctane
sulfinate
did
show
some
degradation
to
PFOA.
My
such
degradation
to
PFOA,
however,
did
not
occur
under
biotic
conditions,
but
instead
only
in
the
abiotic
control
test
mode
and
only
during
the
last
step.

Several
factors
indicate
that
PFOA
is
not
the
expected
biological
degradation
end­
product
of
the
other
fluorochemical
residuals
present
in
POSF­
based
products.
First,
while
some
degree
of
abiotic
degradation
can
occur
in
a
biotic
system,
the
particular
biodegradation
pathway
described
above
suggests
that
PFOS
formation
would
be
the
expected
degradation
route.
Hence,
even
if
the
other
fluorochemical
residuals
present
in
POSF­
based
products
were
absorbed
by
humans
or
wildlife,
PFOA
is
unlikely
to
be
formed
as
a
metabolite.
Second,
to
the
extent
PFOA
could
be
formed
in
an
abiotic
environmental
compartment,
no
PFOA
uptake
from
that
compartmentwould
be
expected
because,
as
studies
have
shown,
PFOA
does
not
bioconcentrate.
4
Third,
in
the
highly
specialized
and
limited
circumstances
where
PFOA
could
form
and
transfer
from
an
abiotic
environmental
compartment
to
water,
the
PFOA
should
be
immediately
diluted
due
to
its
water
solubility
(>
100,000
mg/
L
or
10
percent
by
weight
for
ammoniurn
perfluorooctanoate),
5
and
hence,
should
remain
present
in
the
water,
if
at
all,
at
miniscule
levels.
Finally,
although
studies
have
been
done
only
on
the
N­
Et
FOSE
alcohol,
this
degradation
pathway
should
be
representative
of
the
other
major
building
blocks
for
POSF­
based
products.
6
3.
PFOA
As
An
Impurity
In
POSF­
Based
Products
3M
analytical
studies
of
eight
POSF­
based
product
samples
have
identified
the
presence
of
PFOA
at
very
low
concentrations
ranging
from
200­
1600
ppm
as
a
manufacturing
impurity.
Based
on
1997
production
information,
the
estimated
See
Kurume
Laboratory,
2001.
Bioaccumulation
Test
of
Perfluoroalkylcarboxylic
acid
(
c=
7­
1
3),
Test
No.
51519.,
chemicals
Evaluation
and
Research
Institute,
Japan
(
Dec.
18,
2001),
at
1­
26
(
the
carp
exposed
to
5
*
gIL
resulted
in
a
BCF
of
3.1,
while
carp
exposed
to
50
*
gIL
showed
a
BCF
of
<
5.1­
9.1);
see
also
Revised
Draft
Hazard
Assessment
Of
Perfluorooctanoic
Acid
And
Its
Salts,
U.
S.
EPA
(
Nov.
4,2002),
at
1,
14.

See
characterization
Study
of
PFOA(
Lot
#
332)
Primary
Standard
 
Test
control
Reference
#
TCR­
99030­
030
Phase:
Solubility
Determination,
available
in
OPPTS
Docket
AR­
226.

6
The
N­
Et
FOSE
alcohol
served
as
the
key
building
block
for
the
vast
majority
of
3M's
POSFbased
products.
The
other
key
alcohol
building
block,
N­
Me
FOSE
alcohol,
would
be
expected
to
have
a
comparable
degradation
pathway
due
to
its
structural
similarity
to
the
N­
Et
FOSEalcohol.
Moreover,
N­
Et
FOSE
alcohol
was
a
precursor
to
the
other
key
building
block
compounds
for
3M's
POSF­
based
products,
and
hence,
degradation
pathways
for
these
building
blocks
already
are
captured
by
the
N­
Et
FOSE
alcohol
degradation
studies.
Stephen
L.
Johnson
March
13,2003
page
1
annual
levels
of
PFOA
residual
present
in
POSF­
based
products
would
not
have
exceeded
6000
pounds.
Nearly
95
percent
of
POSF­
based
products
­­
and
hence
nearly
all
of
the
6000
annual
pounds
of
PFOA
residual
present
in
such
products
 
were
commercialized
into
industrial
applications.
7
A
number
of
these
applications
involved
use
of
high
molecular
weight
polymers
or
other
formulated
POSF­
based
products
for
surface
treatment
of
carpets
and
fabrics
or
for
coating
on
paper
and
packaging.
Due
to
the
nature
of
these
applications,
only
a
minute
amount
of
the
PFOA
residual,
at
most,
would
have
ended
up
in
the
finished
article.
Moreover,
a
number
of
the
industrial
applications
br
POSF­
based
products
involved
the
use
of
aqueous
washing
or
finishing
steps.
In
view
of
PFOA's
water
solubility,
a
washing
or
finishing
step
most
likely
removed
the
very
small
amount
of
PFOA
residual
present
in
such
product.
Any
industrial
release
of
PFOA
residual
into
the
environment
from
these
sources
would
likely
have
resulted
in
extremely
low
concentrations
in
localized
aquatic
systems
and
would
not
have
provided
a
source
of
measurable
PFOA
exposure.

C.
Future
EElS
Measures
In
addition
to
the
PFOA
production
phase­
out
and
the
numerous
other
measures
undertaken
to
date
as
detailed
above,
3M
plans
to
engage
in
ongoing
and
future
EHS
measures
itemized
below.
3M
plans
to
undertake
these
measures
in
an
expeditious
manner
and
may
undertake
additional
EHS
measures
not
described
in
this
letter,
as
warranted,
under
3M's
existing
safety,
health
and
environmental
programs.

1.
3M
will
not
resume
the
manufacture
of
PFOP..
for
comiwerdat
sale.

2.
3M
will
continue
with
its
medical
monitoring
efforts
for
fluorochemical
production
workers
and
will
provide
reports
to
EPA
on
a
bi­
annual
basis
on
the
results
of
this
program.
These
efforts
will
continue
to
include
monitoring
for
the
presence
of
PFOA.
In
addition,
3M
will
continue
to
track
the
mortality
experience
of
the
fluorochemical
production
worker
cohort
and
will
submit
updated
epidemiologicâl
study
reports
to
EPA
every
five
years.

3.
3M
will
continue
to
monitor
in
the
vicinity
of
its
former
PFOA
production
facilities.
This
monitoring
will
include
groundwater,
surface
water
and
other
environmental
media
and
will
be
part
of
ongoing
requirements
and/
or
voluntary
commitments
established
with
local
regulatory
agencies.
3M
will
provide
an
initial
summary
report
to
EPA
for
this
monitoring
within
two
years
of
the
date
ofthis
letter
and
periodic
additional
reports
at
appropriate
intervals
thereafter.

4.
3M
will
work
with
other
members
of
industry
to
conduct
additional
validation
of
the
PFOA
serum
analytical
method
and
sampling
protocol;
publish
the
analytical
method
in
a
peer
reviewed
journal;
and
continue
to
qualify
independent
See
Fluorochemical
Use,
Distribution
Arid
Release
Overview
(
May
26,
1999),
available
in
OPPTS
Docket
AR­
226.
Stephen
L.
Johnson
March
13,
2003
Page
8
laboratories
to
perform
the
validated
method.
3M
will
support
the
efforts
of
the
Centers
For
Disease
Control
(
CDC)
and
EPA
to
develop
a
more
complete
understanding
of
the
PFOA
levels
present
in
the
general
population
and
the
environment.
3M
will
continue
to
assess
the
appropriateness
of
undertaking
additional
research
and
other
actions
in
coordination
with
CDC
and
EPA.

5.
3M
will
participate
in
certain
human
health
and
environmental
fate
and
effects
studies
of
PFOA.
These
studies
will
occur
under
the
auspices
of
the
Association
of
Plastics
Manufacturers
of
Europe
(
APME)
and
will
include
the
following:
(
i)
chronic
toxicity
in
daphnia;
(
ii)
chronic
toxicity
in
trout;
(
iii)
ADE
mass
balance
in
rats;
(
iv)
protein
binding
­­
rat/
human;
(
v)
physiologically
based
kinetic
modeling;
(
vi)
adsorption/
desorption
studies;
(
vii)
acute
toxicity
in
daphnia;
(
viii)
acute
toxicity
in
trout;
(
ix)
algal
growth;
and
(
x)
mechanistic
studies
of
pancreatic
tumor
induction
in
rats.
The
results
of
these
studies,
and
any
additional
studies,
will
be
promptly
communicated
to
EPA
in
the
form
of
final
reports.
The
industry
participants
will
consult
with
EPA
on
what
additional
studies
would
be
beneficial.

6.
As
discussed
above,
Dyneon
will
continue
to
produce
small
amounts
of
PFOA
for
internal
use
and
will
continue
to
use
PFOA
in
fluoropolymer
production.
In
connection
with
this
production
and
use,
Dyneon
will
engage
in
various
EHS
measures,
including:

a.
Dyneon
will
continue
to
reduce
further
the
now
small
use
at
its
facility
in
the
United
States
of
PFOA
imported
from
Dyneon's
Gendorf,
Germany
facility.

b.
Dyneon
has
developed
and
is
using
a
"
capture
for
recycle'
technology
for
PFOA
and
has
made
that
technology
available
for
license
by
other
PFOA
users.
This
technology,
which
allows
for
a
recapture
and
reuse
of
PFOA,
has
and
will
continue
to
result
in
a
significant
reduction
of
PFOA
emissions
and
production
demands
for
Dyneon.

c.
Dyneon's
employees
in
the
United
States
will
continue
to
be
part
of
the
3M
program
for
medical
monitoring
of
fluorochemical
production
workers
and
will
be
included
in
the
above­
referenced
reports
to
be
submitted
by
3M
on
the
results
of
this
program.
This
program
will
continue
to
include
monitoring
for
the
presence
of
PFOA.
Dyneon's
employees
at
the
Gendorf,
Germany
facility
have
been
and
will
continue
to
be
subject
to
an
equivalent
program
that
follows
3M's
monitoring
protocols.

d.
Dyneon's
fluoropolymer
manufacturing
facility
in
the
United
States
will
continue
to
be
part
of
the
above­
referenced
3M
environmental
monitoring
program.
This
monitoring
will
include
groundwater,
surface
water
and
other
environmental
media
and
will
be
part
of
ongoing
requirements
and/
or
voluntary
commitments
established
with
local
regulatory
agencies.
Periodic
reporting
of
the
results
of
this
monitoring
program
will
begin
within
two
years
from
the
date
of
this
letter
and
occur
at
appropriate
intervals
thereafter.
Stephen
L.
Johnson
March
13,
2003
Page
9
e.
Dyneon
will
commit,
as
a
signatory
to
the
separate
letter
of
intent
among
PFOA
users
in
the
fluoropolymer
industry,
to
perform
the
exposure
assessment
and
testing
specified
therein.

In
connection
with
the
foregoing
EHS
measures,
3M
recognizes
the
importance
of
EPA's
recently­
issued
guidelines
pursuant
to
the
Data
Quality
Act.
8
We
will
continue
­­
as
we
have
in
the
past
­­
to
employ
scientific
practices,
protocols
and
procedures
designed
to
ensure
that
data
meeting
reasonably
appropriatwbenctimarksfor
objectivity,
utility
and
integrity
are
developed
and
provided
to
the
Agency.

*
*
*

3M
appreciates
this
opportunity
to
memorialize
our
prior,
ongoing
and
future
EHS
measures
for
PFOA.
We
look
forward
tp
dialogue
with
EPA
regarding
the
content
of
this
letter.

Very
truly
yours,

Dr.
Larry
Wbndling
Vice
President
Performance
Materials
Division
3M
Company
cc:
Charles
Auer,
Director
Office
Of
Pollution
Prevention
And
Toxics
DC\
571981.4
See
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
Information
Disseminated
by
the
Environmental
Protection
Agency;
Public
Law
106.554itR.
5658,
§
515(
a)
(
2001);
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
Information
Disseminated
by
Federal
Agencies,
0MB,
67
Fed.
Reg.
8452°
f2­
002);­­
sse
also
EPA
Order
5360.1A2
`
Policy
And
Program
Requirements
For
Agency­
Wide
Quality
System"
(
May
5,
2000);
EPA
Quality
Manual
For
Environmental
Programs,
5360A1
(
May
5,
2000).
