March
3~,
2003
Regular
Mail
The
Honorable
Stephen
L.
Johnson
Assistant
Administrator
United
States
Environmental
Protection
Agency
Office
ofPrevention,
Pesticides
and
Toxic
Substances
1200
Pennsylvania
Avenue
N.
W.
(
Room
7101M)
Washington,
DC
20460
Dear
Mr.
Johnson:

This
letter
reaffirms
the
commitment
ofthe
companies
identified
below
to
assist
the
Environmental
Protection
Agency
(
EPA)
in
its
investigation
of
pcrfluorooctanoie
acid(
PEOA)
and
ammonium
perfluorooctanoate
(
APFO).
1
1)
APFO
Users:
Asahi
Glass
Fluoropolymers
USA,
Inc.,
Daikin
America,
inc..
Dyneon,
LLC,
and
El.
du
Pont
de
Nemours
and
Company.
These
companies
use
AFFO
as
a
polymerization
aid
to
manufacture
fluoropolymers
and
fluoroelastorners.
DuPont
aso
manufactures
APFO
in
the
United
States
for
use
in
Iluoropolymer
manufacturing.

2)
Telomer
Companies:
AGA
Chemicals,
Inc..
Clariant
GmbH,
Daikin
America,
Inc.,
and
E.
I.
du
Pont
de
Nemours
and
Company.
These
companies
produce
or
import
fluorotelomerbased
products,
which
are
used
as
fluorosurfactants
and
surfacc
protection
chemicals.

3)
The
3M
Company,
the
former
U.
S.
manufacturer
of
AFFO.

All
signatories
share
and
support
the
goals
ofsafeguarding
human
health
and
the
environment.
By
means
ofthis
letter
and
separate
Letters
ofIntent,
the
signatories
affirm
their
commitment
to
work
on
a
comprehensive
program
to
develop
additional
data
on
potentiaflicalth
or
environmental
effects
of
PFOA,
to
better
characterize
exposure
pathways,
to
reduce
or
prevent
such
exposure,
and
to
examine
and,
as
necessary,
strengthen
product
stewardship
and
ristc
communication
practices.

While
the
APFO
Users
utilize
APFO
as
a
polymerization
aid
to
manufacture
cen~
ntluoropolymcrs
and
fluoroelastomers,
PFOA
is
the
substance
that
has
been
found
in
some,
but
not
all,
the
environmental
and
blood
samples
that
have
been
tested.
PFOA
is
also
the
chemical
that
has
usually
been
tested
in
animal
studies,
because
APFO
dissociates
in
water
into
PFOA
and
ammonia.
EPAhas
assigned
Docket
Number
AR.
226
for
all
submissions
on
periluorinated
substances.
AR226
also
contains
documents
pertaining
to
other
periluorinated
chemical
substances.
The
APFO
Users
believe
that
the
matters
concerning
APFO
are
different
from
those
associated
with
the
other
chemicai
substances
included
in
EPA
Docket
Number
AR226.
Mr.
Stephen
L.
Johnson
March
31,
2003
Page2
of
10
The
APFO
Users
are
committed
to
reducing
emissions
of
APFO
from
fluoropolymer
manufacturing
facilitics.
The
APFO
Users
have
committed
to
developing
information
to
support
a
better
understanding
ofexposure
to
APFO
through
conducting
studies
on
finished
resins
and
finished
products,
and
on
emissions
and
discharges
from
fluoropolymer
processing
facilities.
They
are
also
committed
to
further
studies
ofthe
toxicology
of
APFO.
Through
the
Society
of
the
Plastics
Industry
(
SPI),
the
APFO
Users
will
submit
information
on
work
with
EPA
as
this
process
moves
forward.
SPI
is
signing
this
agreement
only
to
signify
its
willingness
to
act
as
a
facilitator
and
conduit
for
information
and
communications
between
EPA
and
the
fluoropolymer
manufacturers
and
other
members
ofthe
fluoropolymer
industry,
including
fluoropolymer
processors.
Its
participation
is
not
an
indication
that
SPI
has
any
obligations
addressed
by
separate
agreements
or
Letters
of
Intent
submitted
by
the
APFO
Users,
the
Telomer
Companies,
or
3M.

The
Telomer
Companies
do
not
use
PFOA
or
APFO
in
their
manufacturing
processes.
These
companies
have
committed
to
investigating
whether
and
how
telomer
products
can
transform
or
break
down
into
PFOA,
and
if
so,
to
support
a
better
understanding
of
those
processes.

The
3M
Company
has
I)
provided
a
summary
ofprevious
activity
taken
by
the
company
including
the
phase­
out
ofthe
production
for
sale
of
PFOA
at
the
end
of
2002,
and
2)
committed
to
a
plan
to
continue
a
monitoring
program
for
its
former
manufacturing
sites.

The
APFO
Users,
the
Telomer
Companies
and
3M
will
each
keep
the
EPA
apprised
of
progress
in
conducting
the
research
under
their
respective
Letters
of
Intent.
They
will
provide
status
reports
to
EPA
and
individually
share
the
results
from
all
studies,
surveys
or
other
investigations,
as
specified
in
the
Letters
ofIntent.

The
signatories
of
this
letter
appreciate
the
opportunity
to
work
with
EPA
on
this
matter
and
agree
that
close
coordination
of
our
efforts
and
sharing
ofinformation
is
important.
Accorthngly,
we
will
continue
to
communicate
with
EPA
as
information
becomes
available.

Respectfully
Submitted,

APFO
Users
Telomcr
Companies
The
3M
Company
Mr.
Stephen
L.
Johnson
March
31,
2003
Page
3
of
10
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