Charles
Auer
04/
23/
2003
01:
05
PM
To:
sneha.
satya@
nicnas.
gov.
au,
raimund.
quint@
bmu.
gv.
at,
robert.
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cec.
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int,
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iph.
fgov.
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robert.
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ec.
gc.
ca,
hasa@
env.
cz,
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mst.
dk,
Hty@
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dk,
jukka.
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fi,
esa.
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ymparisto.
fi,
laurence.
musset@
environnement.
gouv.
fr,
chemg@
baua.
bund.
de,
gxk­
environment@
ath.
forthnet.
gr,
Kozak@
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gov.
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iss.
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go.
jp,
oikawa­
shinichi@
meti.
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jp,
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me.
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kr,
dick.
sijm@
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nl,
arnold.
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gov.
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gov.
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aitio@
who.
ch,
urs.
staempfli@
buwal.
admin.
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chemical.
management@
defra.
gsi.
gov.
uk,
auer.
charles@
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gov,
hazen.
susan@
epa.
gov,
hernandez.
oscar@
epa.
gov,
esilberg@
jhsph.
edu
cc:
Mary
Dominiak/
DC/
USEPA/
US,
Jennifer
Seed/
DC/
USEPA/
US,
Chris
Blunck/
DC/
USEPA/
US,
Priscilla
Flattery/
DC/
USEPA/
US@
EPA,
Diane
Beal/
DC/
USEPA/
US@
EPA
Subject:
Preliminary
Risk
Assessment
on
Perfluorooctanoic
Acid
(
PFOA)

Dear
Members
of
the
OECD
Existing
Chemicals
Steering
Group,

On
Monday,
April
14,
2003,
the
U.
S.
Environmental
Protection
Agency
released
a
preliminary
risk
assessment
on
perfluorooctanoic
acid
(
PFOA),
a
chemical
which
is
structurally
similar
to
perfluorosulfonic
acid
(
PFOS).
As
you
may
recall
several
OECD
Member
countries
collaborated
in
the
preparation
of
an
OECD
hazard
assessment
of
PFOS.

This
information
is
being
provided
to
inform
you
about
the
current
state
of
EPA's
risk
assessment
efforts
on
PFOA,
which
is
focused
on
developmental
toxicity
as
described
in
the
material.
The
Agency
is
interested
in
collecting
additional
information
because
new
laboratory
studies
recently
evaluated
by
the
Agency
show
that
PFOA,
which
is
used
in
the
manufacture
of
fluoropolymers,
may
cause
developmental
toxicity
and
other
health
effects.
Further,
the
available
data
indicate
that
the
general
U.
S.
population
may
be
exposed
to
PFOA
at
very
low
levels.
The
potential
sources
and
exposure
pathways
of
PFOA
are
not
well
understood
at
this
time.
It
may
be
released
during
manufacturing
or
processing,
and
it
may
also
be
formed
during
the
environmental
breakdown
of
certain
other
fluorinated
compounds
known
as
telomers.
PFOA
may
also
have
been
a
contaminant
in
certain
other
fluorinated
products
(
e.
g.,
PFOS)
that
were
largely
discontinued
by
the
end
of
2002
in
the
U.
S.

Because
there
remains
considerable
scientific
uncertainty
regarding
the
potential
risks
from
PFOA,
EPA
considers
it
important
to
develop
additional
data
to
determine
whether
subsequent
steps
would
be
necessary
to
protect
public
health.
These
data
include
use
and
production
volume
data,
information
on
chemical
and
product
degradation,
and
additional
monitoring
of
PFOA
levels
in
the
environment.
The
additional
data
will
be
used
to
reduce
the
scientific
uncertainties
in
the
risk
assessment,
to
better
understand
the
potential
sources
in
the
environment,
and
to
identify
potential
exposure
pathways.
As
a
positive
step,
companies
that
manufacture
and
use
PFOA,
as
well
as
companies
that
manufacture
telomers,
are
taking
voluntary
product
stewardship
steps,
as
described
in
Letters
of
Intent
submitted
to
the
Agency.
Copies
of
these
Letters
of
Intent
are
attached
to
this
message.

EPA
also
encourages
the
public
and
other
interested
parties
to
identify
and
generate
additional
information
on
PFOA
and
on
fluorinated
telomers
that
may
degrade
to
form
PFOA
in
order
to
allow
the
Agency
to
further
develop
its
risk
assessment
and
to
determine
whether
regulatory
action
may
be
appropriate.

EPA
published
the
announcement
of
these
activities
in
the
Federal
Register
on
Wednesday,
April
16,
2003.
Comments
on
the
notice
are
due
on
May
16,
2003.
A
copy
of
the
Federal
Register
notice
is
attached
to
this
message,
together
with
a
copy
of
the
preliminary
risk
assessment
and
the
letter
peer
review
of
the
assessment.
The
electronic
public
docket
for
this
action
can
be
accessed
through
the
Internet
at
www.
epa.
gov/
edocket/
by
using
the
"
Quick
Search"
feature
to
locate
docket
OPPT­
2003­
0012.
The
Agency
is
also
inviting
public
participation
in
the
development
of
enforceable
consent
agreements
(
ECAs),
which
will
be
used
to
direct
the
generation
of
new
scientific
information
critical
to
understanding
the
sources
and
pathways
of
potential
exposures
to
PFOA.
The
public
ECA
meeting
will
be
held
in
Washington,
DC
on
Friday,
June
6,
2003.
Following
receipt
of
additional
scientific
information,
EPA
expects
to
develop
a
more
comprehensive
risk
assessment
that
incorporates
new
information.
The
Agency
then
plans
to
seek
additional
public
comments
and
independent
peer
review
from
the
Agency's
Science
Advisory
Board
later
this
year.

EPA
prepared
a
press
statement
and
a
fact
sheet
concerning
these
activities,
and
copies
of
these
documents
are
also
attached
for
your
information.

If
you
have
questions
concerning
this
matter,
you
can
contact
Mary
Dominiak
(
dominiak.
mary@
epa.
gov
;
the
technical
contact
identified
in
the
published
notice)
or
Jennifer
Seed
(
seed.
jennifer@
epa.
gov
;
questions
relating
to
the
preliminary
risk
assessment).

The
attached
files
include:
Press
Release

Fact
Sheet
(
Q&
A)

FR
Notice

Preliminary
Risk
Assessment

Peer
review
on
Risk
Assessment

All
four
industry
Letters
of
Intent

Press
Release
on
PFOA.
p3­
14­
2003
FMG
LOI.
pd3­
14­
2003
TRP
LOI.
pd3­
31­
2003
Umbrella
LOI.
p
APFO
Prelim
RiskAssmt
4­
10­
2003Final
Coded
PFOA
FR
Notice.
PFOA
External
Letter
Peer
Review
pfoafcts.
pdf
3­
13­
2003
3M
LOI.
pd
Charles
M.
Auer,
Director
Office
of
Pollution
Prevention
&
Toxics
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Ave,
NW
(
7401M)
Washington,
DC
20460
Phone
(
202)
564­
3810
Fax
(
202)
564­
0575
Deliveries:
EPA­
East
Building
1201
Constitution
Avenue,
NW
Room
3166A
(
7401M)
Washington,
DC
20004
United
States
Office
of
Public
Affairs
Office
ph.
202­
564­
4355
Environmental
Protection
Washington
D.
C.
20460
www.
epa.
gov/
newsroom
Agency
(
1703A)

Environmental
News
FOR
RELEASE:
MONDAY
APRIL
14,
2003
EPA
INTENSIFIES
SCIENTIFIC
INVESTIGATION
OF
A
CHEMICAL
PROCESSING
AID
Contact:
David
Deegan,
202­
564­
7839/
deegan.
dave@
epa.
gov
Today
EPA
is
releasing
a
preliminary
risk
assessment
for
the
chemical
PFOA
and
is
encouraging
the
public
and
other
interested
parties
to
participate
in
identifying
and
generating
additional
information
that
will
allow
the
Agency
to
further
develop
its
risk
assessment.
PFOA,
also
known
as
perfluorooctanoic
acid,
is
used
as
a
processing
aid
in
the
manufacture
of
a
wide
variety
of
consumer
and
industrial
products,
and
may
also
be
formed
during
the
environmental
breakdown
of
related
chemicals.
Studies
recently
evaluated
by
the
Agency
have
raised
a
number
of
potential
toxicity
concerns,
and
when
combined
with
information
that
the
general
U.
S.

population
may
be
exposed
to
very
low
levels
of
PFOA,
has
led
the
Agency
to
conclude
that
additional
scientific
information
is
needed
to
determine
if
new
regulatory
actions
are
necessary.

 
To
ensure
consumers
are
protected
from
any
potential
risks,
the
Agency
will
be
conducting
its
most
extensive
scientific
assessment
ever
undertaken
on
this
type
of
chemical, 
said
Stephen
L.
Johnson,
Assistant
Administrator
of
EPA s
Office
of
Prevention,
Pesticides,
and
Toxic
Substances.
 
Today s
announcement
puts
in
place
rigorous
regulatory
and
scientific
steps
that
will
lead
to
a
better
understanding
of
PFOA.
This
priority
scientific
review
will
guarantee
that
any
future
regulatory
action
on
PFOA
is
protective
of
public
health
and
supported
by
the
best
scientific
information. 

To
initiate
this
process,
the
Agency
is
releasing
its
preliminary
risk
assessment
on
PFOA
for
public
review.
A
public
docket
has
been
established
so
interested
parties
can
review
the
scientific
information
available
to
the
Agency.
Similarly,
through
public
meetings,
the
Agency
is
inviting
participation
in
the
development
of
enforceable
consent
agreements,
which
will
be
used
to
direct
the
generation
of
new
scientific
information
critical
to
understanding
the
sources
and
pathways
of
potential
exposures
to
PFOA.
By
using
enforceable
consent
agreements,
the
generation
of
new
data
can
be
accelerated
so
the
data
is
available
quickly.
Following
receipt
of
additional
scientific
information,
EPA
expects
to
develop
a
more
comprehensive
risk
assessment
that
incorporates
new
information.
The
Agency
then
plans
to
seek
additional
public
comments
and
independent
peer
review
from
the
Agency s
Science
Advisory
Board
later
this
year.

The
Agency
is
interested
in
collecting
additional
information
because
a
new
laboratory
studies
recently
evaluated
by
the
Agency
shows
that
PFOA
may
cause
developmental
toxicity
and
other
health
effects.
Further,
the
available
data
indicate
that
the
general
U.
S.
population
may
be
exposed
to
PFOA
at
very
low
levels.
The
potential
sources
and
exposure
pathways
of
PFOA
are
not
well
understood
at
this
time.
It
may
be
released
during
manufacturing
or
processing,
and
it
may
also
be
formed
during
the
environmental
breakdown
of
certain
other
fluorinated
compounds
known
as
telomers.
(
Telomers
are
small
fluorinated
polymers.)
PFOA
may
also
have
been
a
contaminant
in
certain
other
fluorinated
products
that
were
discontinued
by
the
end
of
2002.

R­
099
­
more
­
­
2­

Because
there
remains
considerable
scientific
uncertainty
regarding
the
potential
risks
from
PFOA,
it
is
important
to
develop
additional
data
to
determine
if
subsequent
steps
are
necessary
to
protect
public
health.
These
data
include
use
and
production
volume
data,
information
on
chemical
and
product
degradation,
and
additional
monitoring
of
PFOA
levels
in
the
environment.
The
additional
data
will
be
used
to
reduce
the
scientific
uncertainties
in
the
risk
assessment,
to
better
understand
the
potential
sources
in
the
environment,
and
to
identify
potential
exposure
pathways.

Given
these
considerable
scientific
uncertainties,
EPA
has
not
made
a
determination
as
to
whether
PFOA
poses
an
unreasonable
risk
to
the
public.
This
determination
will
be
better
informed
as
new
exposure
data
are
factored
into
the
risk
assessment.
EPA
does
not
believe
there
is
any
reason
for
consumers
to
stop
using
any
consumer
or
industrial
related
products.

As
a
positive
step,
companies
that
manufacture
and
use
PFOA,
as
well
as
companies
that
manufacture
telomers,
are
taking
voluntary
product
stewardship
steps,
as
described
in
Letters
of
Intent
submitted
to
the
Agency.
These
letters
are
available
in
the
public
docket.
For
example,
3M
will
not
resume
the
manufacture
of
PFOA,
and
they
will
continue
medical
monitoring
efforts
for
workers
and
continue
monitoring
groundwater,
surface
water,
and
other
environmental
media
and
provide
reports
to
EPA.
The
members
of
the
Fluoropolymer
Manufacturers
Group
have
committed
to
reduce
emissions,
to
study
their
products
to
determine
whether
they
may
be
a
source
of
PFOA,
and
to
take
steps
to
reduce
exposures
to
workers
and
the
environment.
The
members
of
the
Telomer
Research
Program
have
committed
to
evaluating
products
sold
in
the
U.
S.
to
determine
whether
they
contribute
to
significant
human
or
environmental
exposure
to
PFOA.

By
way
of
background,
PFOA
is
used
as
an
essential
processing
aid
in
the
manufacture
of
fluoropolymers.
Fluoropolymers
are
used
in
a
wide
variety
of
consumer
and
industrial
applications,
including
non­
stick
surfaces
on
cookware,
but
finished
products
are
not
expected
to
contain
PFOA.
PFOA
may
also
be
a
degradation
product
of
small
polymers
called
telomers,
which
are
used
in
a
range
of
commercial
products
including
fire
fighting
foams,
as
well
as
soil,
stain
and
grease
resistant
coatings
on
carpets,
textiles,
paper,
and
leather.

For
further
information
on
EPA
preliminary
risk
assessment
of
PFOA,
including
the
Federal
Register
notice,
Fact
Sheet
and
Questions
&
Answers,
please
visit
http://
www.
epa.
gov/
oppt/.

R­
099
#
#
#
FACT
SHEET
Public
Q s
&
A s
on
PFOA
In
a
Federal
Register
notice
signed
on
April
14,
2003,
EPA
is
releasing
a
preliminary
risk
assessment
for
the
chemical
PFOA,
and
is
starting
a
public
process
to
identify
and
generate
additional
information
to
strengthen
the
risk
assessment.
EPA
is
also
inviting
interested
parties
to
monitor
or
participate
in
negotiations
on
one
or
more
enforceable
consent
agreements
to
obtain
additional
data
concerning
PFOA
and
fluorinated
telomers
which
may
metabolize
or
degrade
to
PFOA.
The
first
public
meeting
will
take
place
on
June
6,
2003.

1.
What
is
PFOA?
PFOA
is
perfluorooctanoic
acid.
It
is
a
synthetic
(
man­
made)
chemical
and
does
not
occur
naturally
in
the
environment.
The
"
PFOA"
acronym
is
used
to
indicate
not
only
perfluorooctanoic
acid
itself,
but
also
its
principal
salts.
The
most
commonly
used
chemical
in
this
grouping
is
the
ammonium
salt,
ammonium
perfluorooctanoate,
or
APFO,
which
is
sometimes
called
"
C8."

2.
What
is
PFOA
used
for?
PFOA
is
used
as
an
essential
processing
aid
in
the
manufacture
of
fluoropolymers.
Fluoropolymers
impart
valuable
properties,
including
fire
resistance
and
oil,
stain,
grease,
and
water
repellency.
For
example,
they
can
be
used
to
provide
non­
stick
surfaces
on
cookware
and
protective
finishes
on
carpets
and
clothing.
They
are
employed
in
hundreds
of
uses
in
almost
all
industry
segments,
including
the
aerospace,
automotive,
building/
construction,
chemical
processing,
electrical
and
electronics,
semiconductor,
and
carpet
and
textile
industries.
Although
fluoropolymers
are
made
using
PFOA,
the
finished
products
themselves
are
not
expected
to
contain
PFOA.

3.
What
action
is
EPA
taking?
EPA
is
issuing
a
preliminary
risk
assessment
of
PFOA,
requesting
public
comment
on
its
scientific
findings,
and
seeking
additional
data
concerning
these
chemicals.
EPA
is
also
inviting
interested
parties
to
monitor
or
participate
in
negotiations
on
one
or
more
enforceable
consent
agreements
(
ECAs)
under
section
4
of
the
Toxic
Substances
Control
Act
(
TSCA)
concerning
PFOA
and
fluorinated
telomers
which
may
metabolize
or
degrade
to
PFOA.
EPA
is
also
announcing
the
first
public
meeting
for
these
ECA
negotiations,
which
will
be
held
on
June
6,
2003.
EPA
is
taking
these
steps
to
better
understand
the
sources
and
exposure
pathways
leading
to
the
presence
of
PFOA
in
human
blood.
Further
information
will
help
EPA
determine
whether
and
what
additional
actions
are
appropriate.

4.
Why
is
this
action
necessary?
The
Agency
is
interested
in
collecting
additional
information
because
studies
have
indicated
that
PFOA
causes
developmental
toxicity
and
other
effects
in
animals.
EPA's
preliminary
assessment
indicates
potential
exposure
of
the
U.
S.
general
population
to
PFOA
at
very
low
levels.
However,
this
assessment
also
reflects
considerable
scientific
uncertainty
regarding
the
potential
risks.
EPA
has
identified
areas
where
additional
information
could
be
very
helpful
in
allowing
the
Agency
to
develop
a
more
accurate
assessment
of
the
potential
risks
posed
by
PFOA
and
by
chemicals
that
may
degrade
to
form
PFOA,
and
to
identify
what
voluntary
or
regulatory
actions,
if
any,
would
be
appropriate.

5.
Are
there
steps
consumers
could
take
to
reduce
exposures
to
PFOA?
At
present,
there
aren't
any
steps
that
EPA
recommends
that
consumers
take
to
reduce
exposures
to
PFOA,
because
the
sources
of
PFOA
in
the
environment
and
the
pathways
by
which
people
are
exposed
are
not
known.
Given
the
considerable
scientific
uncertainties,
EPA
has
not
made
a
determination
as
to
whether
PFOA
poses
an
unreasonable
risk
to
the
public.
This
determination
will
be
better
informed
as
new
exposure
data
are
factored
into
the
risk
assessment.
EPA
does
not
believe
there
is
any
reason
for
consumers
to
stop
using
any
consumer
or
industrial
related
products.

6.
How
are
people
exposed
to
PFOA?
Current
information
indicates
that
the
general
U.
S.
population
may
be
exposed
to
very
low
levels
of
PFOA,
but
the
available
scientific
information
cannot
determine
how
people
are
being
exposed.
The
limited
geographic
locations
of
fluorochemical
plants
making
or
using
the
chemical
suggest
that
there
may
be
additional
sources
of
PFOA
in
the
environment,
and
exposures
beyond
those
attributable
to
direct
releases
from
industrial
facilities.
The
degradation
of
telomer
chemicals
may
be
one
of
these
additional
sources.
But
whether
human
exposures
are
due
to
PFOA
in
the
air,
the
water,
on
dusts
or
sediments,
in
dietary
sources,
or
through
some
combination
of
routes
is
currently
unknown.

7.
What
types
of
industrial
and
consumer
products
contain
PFOA?
Currently,
consumer
products
are
not
believed
to
contain
PFOA,
although
some
products
might
contain
other
chemicals,
called
telomers,
that
might
degrade
over
time
in
the
environment
to
form
PFOA.
Some
industrial
fluoropolymer
dispersion
products
contain
PFOA,
but
these
products
are
typically
used
in
heattreated
applications
that
would
remove
the
PFOA
from
final
products
before
they
leave
the
manufacturing
plants.

8.
What
are
fluorinated
telomers,
and
how
do
they
relate
to
PFOA?
Fluorinated
telomers,
commonly
called
"
telomers,"
are
small
fluorine­
containing
polymers,
man­
made
chemicals
produced
by
a
specific
process
that
utilizes
the
ability
of
certain
chemicals
to
link
together
into
chains
of
a
defined
length.
Although
telomers
aren't
made
using
PFOA,
some
data
indicate
that
certain
telomers
may
break
down
or
degrade
to
form
PFOA
in
the
environment,
and
may
be
metabolized
to
form
PFOA
if
they
get
inside
living
organisms.

9.
What
are
telomers
used
for?
Telomers
are
used
in
many
products,
including
fire
fighting
foams;
personal
care
and
cleaning
products;
and
oil,
stain,
grease,
and
water
repellent
coatings
on
carpet,
textiles,
leather,
and
paper.
10.
Are
there
reasonable
and
cost
effective
alternatives
to
PFOA
and
telomers?
PFOA
is
an
essential
processing
aid
in
the
manufacture
of
fluoropolymers.
Fluoropolymer
manufacturers
have
indicated
that
there
are
no
known
alternatives
to
PFOA.
Some
manufacturing
processes
can
use
different
technologies
that
don't
employ
PFOA,
but
these
processes
could
not
currently
be
used
to
produce
most
fluoropolymer
products.

EPA
does
not
know
all
of
the
uses
of
the
telomer
chemicals,
and
thus
does
not
have
readily
available
information
concerning
alternatives
for
those
uses.
The
industry
has
committed
to
provide
additional
information
as
part
of
its
ongoing
voluntary
activities
with
respect
to
these
chemicals.

11.
What
companies
manufacture
PFOA
and
telomers?
3M
Company
formerly
manufactured
PFOA
in
the
United
States,
but
discontinued
manufacturing
the
chemical
during
the
period
2000­
2002.
Currently,
DuPont
is
the
only
domestic
manufacturer
of
PFOA.
Other
companies
may
manufacture
PFOA
elsewhere
in
the
world.

DuPont,
Clariant
GmbH,
Daikin
Industries,
and
Asahi
Glass
all
manufacture
telomers
at
various
facilities
worldwide.
There
may
be
additional
producers
of
telomer
chemicals.

12.
What
exactly
is
an
ECA?
An
enforceable
consent
agreement
(
ECA)
is
a
publicly
negotiated
agreement
among
EPA,
industry,
and
interested
parties
that
requires
certain
signing
parties
to
generate
data
and
submit
those
data
to
EPA
on
a
specified
schedule.
EPA
has
found
that,
in
instances
where
there
is
substantial
agreement
that
particular
data
are
necessary
or
important,
ECAs
can
be
a
much
quicker
way
to
obtain
data
than
pursuing
a
test
rule
under
section
4
of
the
Toxic
Substances
Control
Act.
Test
rules
can
take
up
to
two
years
to
complete,
while
ECA's
can
often
be
concluded
in
less
than
a
year.
ECAs
are
enforceable,
meaning
that
EPA
can
compel
the
submission
of
information
agreed
to
under
the
ECA.
Because
they
are
negotiated
in
public,
all
parties
who
are
interested
in
the
data
have
the
opportunity
to
participate.
13.
Is
PFOA
more
toxic
to
children
than
to
adults?
EPA
is
not
aware
of
any
studies
that
would
provide
evidence
that
PFOA
is
either
more
or
less
toxic
to
children
than
to
adults.

14.
Is
PFOA
present
in
my
food,
drinking
water
and
indoor
air?
EPA
does
not
know
the
source
of
PFOA
in
the
environment,
or
the
pathways
by
which
it
is
getting
into
humans.
There
are
only
very
limited
data
on
the
general
environmental
presence
of
PFOA.
Additional
studies
are
attempting
to
determine
answers
to
these
questions.

15.
What
are
the
health
benefits
from
EPA
taking
this
action?
EPA's
preliminary
assessment
indicates
that
the
general
U.
S.
population
may
be
exposed
to
PFOA
at
very
low
levels.
Receiving
the
information
that
EPA
has
requested
will
allow
the
Agency
to
better
characterize
the
exposure,
refine
its
risk
assessment,
and
determine
what
additional
actions,
if
any,
would
be
appropriate
to
protect
human
health
and
the
environment.

16.
What
additional
data
is
the
Agency
requesting
and
why?
EPA
is
asking
for
use
and
production
volume
data,
to
better
define
the
universe
of
chemicals
which
may
contribute
to
the
presence
of
PFOA
in
the
environment
and
in
people,
and
additional
data
on
chemical
and
product
biodegradation
to
help
explain
the
sources
of
PFOA.
EPA
is
also
requesting
any
additional
information
that
would
help
in
the
development
of
an
understanding
about
the
pathways
by
which
people
may
be
exposed
to
PFOA.

17.
What
are
the
next
steps
to
evaluate
PFOA?
EPA
has
requested
additional
information
that
would
help
to
reduce
the
uncertainties
in
its
scientific
risk
assessment
and
improve
the
understanding
of
the
presence
of
the
chemical
in
the
environment.
EPA
expects
to
submit
a
more
comprehensive
risk
analysis
incorporating
some
of
this
additional
information
to
the
Agency's
Science
Advisory
Board
for
independent
peer
review
and
comment
in
Fall
2003.
EPA
has
also
solicited
interested
parties
to
participate
in
the
negotiation
of
enforceable
consent
agreements
to
produce
additional
data.
Industry
has
already
committed
to
providing
some
additional
information
through
letters
of
intent
submitted
to
the
Agency
in
March
2003.

18.
What
is
a
Letter
of
Intent?
A
Letter
of
Intent
is
a
unilateral
statement
by
a
company,
group,
or
individual
describing
activities
they
are
undertaking,
and
making
voluntary
commitments
to
perform
those
activities
as
described.
Because
the
commitments
in
such
a
letter
are
voluntary,
the
letters
are
not
binding
or
enforceable.

19.
What
has
industry
committed
to
do
in
their
letters
of
intent
on
PFOA
and
telomers?
In
brief,
the
companies
have
committed
to
providing
additional
data
that
should
help
to
develop
the
understanding
of
PFOA
sources
and
exposures.
3M
Company
has
indicated
that
it
will
not
resume
the
manufacture
of
PFOA,
and
it
will
continue
its
medical
monitoring
efforts
for
workers
and
continue
monitoring
groundwater,
surface
water,
and
other
environmental
media
and
provide
reports
to
EPA.
The
members
of
the
Fluoropolymer
Manufacturing
Group
have
committed
to
reduce
emissions,
to
study
their
products
to
determine
whether
they
may
be
a
source
of
PFOA,
and
to
follow
principles
of
product
stewardship
in
their
efforts
to
support
toxicological
research,
control
occupational
exposures
in
their
own
facilities,
monitor
employee
health,
assist
customers
in
protecting
their
employees,
and
meet
the
general
commitment
to
reduce
emissions
to
the
environment.
The
members
of
the
Telomer
Research
Program
have
committed
to
evaluating
telomer
products
sold
in
the
U.
S.
to
determine
whether
they
contribute
to
significant
human
or
environmental
exposure
to
PFOA.
All
of
the
Letters
of
Intent
are
available
in
the
public
docket.

FOR
MORE
INFORMATION:
For
general
information
about
PFOA,
or
about
these
standards,
contact:

*
TSCA
Hotline
202­
5541404
*
EPA s
web
site
at
www.
epa.
gov/
oppt/
