DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

Analysis
of
"
Aged"
Telomer­
Based
Polymeric
Products
and
"
In
Use"
Telomer­
Treated
Articles
Draft
Work
Plan
The
members
of
the
Telomer
Research
Program
(
TRP)
1
submitted
a
Letter
of
Intent
(
LOI)
2
to
EPA
dated
March
14,
2003
that
outlined
our
voluntary
commitment
to
investigate
whether
and
how
telomer­
based
products
can
transform
or
break
down
into
perfluorooctanoic
acid
(
PFOA)
or
its
salts,
and
whether
articles
treated
with
such
products
contribute
to
significant
human
or
environmental
exposure
to
PFOA.
The
focus
of
the
LOI
is
on
research,
analysis
and
product
stewardship.

This
document
provides
an
overall
work
plan
as
a
follow­
up
to
the
LOI.
The
overall
work
plan
is
divided
into
four
sections
designed
to
assess
both
PFOA
presence
and
potential
generation
in
aged
telomer­
based
polymeric
products
and
in
"
in­
use"
treated
articles
to
which
the
telomer­
based
polymeric
products
have
been
applied.

Section
1
provides
summary
information.
Section
2
examines
the
potential
for
PFOA
generation
from
end­
use
products
over
time.
Additionally
the
issue
of
residual
monomers,
which
may
theoretically
transform
and
thereby
generate
PFOA,
will
be
addressed.
Twelve
(
12)
telomer­
based
polymeric
products
will
be
examined
covering
three
major
market
end­
use
segments:
carpet,
textile,
and
paper.

Section
3
examines
the
potential
in
"
in­
use"
treated
articles
for
PFOA
increases
or
decreases,
under
accelerated
storage
conditions
representative
of
approximately
one
year
of
ambient
storage.
PFOA
increases
or
decreases
due
to
photolysis
will
also
be
examined.
If
sufficiently
quantifiable
levels
of
PFOA
are
determined
in
"
in­
use"
treated
articles,
additional
experiments
to
determine
the
change
in
the
PFOA
level
under
typical
distribution
and
use
will
be
conducted.
These
tests
include:
abrasion,
washing/
laundering,
dry
cleaning,
hot
water
extraction
(
steam
cleaning)
and
if
appropriate,
PFOA
volatility.
Section
4
lays
out
a
schedule
for
the
proposed
work.

1.0
Summary
The
following
section
is
separated
into
two
sections
designed
to
assess
both
PFOA
presence
and
potential
generation
in
"
aged"
telomer­
based
polymeric
products
and
in
"
in­
use"
treated
articles
to
which
the
telomer­
based
polymeric
products
have
been
applied.
This
proposal
addresses
the
TRP
commitment
specific
in
the
"
Letter
of
Intent
for
the
Telomer
Research
Program"
(
TRP
to
Mr.
Stephen
L.
Johnson,
USEPA,
March
14,
2003,
Docket
#
OPPT­
2003­
0012).
This
proposal
also
accommodates
the
timing
given
in
the
Letter
of
Intent
as
far
as
possible.

1
The
companies
participating
in
the
TRP
include
Asahi
Glass,
Clariant
GmbH,
Daikin
Industries,
and
E.
I.
duPont
de
Nemours
&
Company.
These
companies
produce
or
import
fluorotelomer­
based
products,
which
are
used
as
fluorosurfactants
and
surface
protection
chemicals.
Telomers
are
not
made
from
PFOA,
nor
is
PFOA
added
during
the
manufacture
or
use
of
telomer
products.

2
TRP
Letter
of
Intent
 
EPA
Docket
#
OPPT­
2003­
0012­
0013.

Telomer
Research
Program
Page
1
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

The
draft
proposal
describes
eight
separate
pieces
of
work
that
were
considered.

1.
PFOA
only
in
aged
products
(
see
Section
2.2)
2.
Temperature
aging
on
treated
carpet,
textiles
and
paper
(
see
Section
3.4)
3.
Photolytic
aging
on
treated
carpet,
textiles
and
paper
(
see
Section
3.5)
4.
Abrasion
on
treated
carpet
and
textiles
(
see
Section
3.6)
5.
Washing
on
treated
textiles
(
see
Section
3.7)
6.
Dry
cleaning
on
treated
textiles
(
see
Section
3.8)
7.
Hot
water
extraction
cleaning
on
treated
carpet
(
see
Section
3.9)
8.
PFOA
Volatility
(
see
Section
3.10)

This
outline
separates
the
work
in
two
sections:
 
Telomer­
based
polymeric
product
aging
(
Item
1
listed
above)
is
described
in
Section
2,
 
Treated
article
"
in­
use"
(
Item
2,
3,
4,
5,
6,
7
and
8
listed
above)
is
described
in
Section
3.

For
these
analyses,
"
aged"
means
the
likely
conditions
our
products
will
see
under
normal
storage
and
distribution.
"
In­
use"
means
the
conditions
treated
articles
will
see
under
normal
distribution
and
use.

As
each
discrete
work
item
is
completed,
a
report
will
be
prepared
and
submitted
to
the
EPA.
In
addition,
as
part
of
the
on­
going
interactions
with
EPA,
interim
progress
of
this
workstream
will
be
reported
as
appropriate,
including
study
protocols,
analytical
methods
and
test
conditions.
The
entire
proposed
work
plan,
including
final
reports,
is
expected
to
be
complete
by
early
2004.

As
outlined
on
page
4
of
the
"
Letter
of
Intent
for
the
Telomer
Research
Program"
(
TRP
to
Mr.
Stephen
L.
Johnson,
USEPA,
March
14,
2003),
the
proposal
is
designed
to
achieve
expeditious
results
in
this
tiered
approach
to
determine
whether
or
not
PFOA
releases
arise
from
real­
world
conditions.
The
specific
issue
of
residual
telomer­
based
monomers
mentioned
on
page
12
of
the
Letter
of
Intent
will
be
addressed
in
Item
2.
The
issues
listed
on
page
12
of
the
Letter
of
Intent
(
i.
e.,
leaching,
degradation,
"
walk
off",
volatilization,
and
light
exposure)
are
addressed
for
treated
articles.
Study
outlines
or
rationale
are
presented
for
all
of
the
above
in
this
document.

All
the
attached
work
will
be
conducted
at
established
laboratories.
As
with
all
TRP
work,
the
proposed
studies
will
be
conducted
with
the
goal
of
meeting
EPA
data
quality
standards.

1.1
Telomer­
Based
Polymeric
Product
and
Telomer­
Treated
Article
Samples
Representative
major
telomer­
based
polymeric
products
in
commerce
and
articles
treated
with
those
telomer­
based
polymeric
products
will
be
tested.
The
work
outlined
for
this
"
aging/
in­
use"
proposal
follows
the
same
rationale
for
sampling
as
described
in
the
screening
study,
i.
e.,
investigations
will
be
conducted
in
the
three
major
end­
use
categories:
carpets,
textiles
and
paper.
The
primary
products
that
the
TRP
members
market
for
these
applications
are
polymers,
which
represent
approximately
85%
of
the
telomer­
based
products
that
the
TRP
members
manufacture
and
sell
globally.
The
telomer­
based
polymeric
product
classes
to
be
tested
are
those
that
the
respective
TRP
member
companies
manufacture
as
actual
items
of
commerce.

Telomer
Research
Program
Page
2
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

While
there
are
many
potential
telomer­
based
polymeric
products,
a
relatively
small
number
represent
the
primary
product
classes
in
commerce
(
12
products).
The
treated
articles
to
be
tested
are
actual
carpet,
textile,
and
paper
substrates
treated
under
representative
or
actual
mill
conditions
with
the
subject
telomer­
based
polymeric
products.

1.2
Sample
Handling
Procedures
for
Telomer­
Based
Polymeric
Products
and
Treated
Articles
At
the
respective
TRP
member
manufacturing
sites,
representative
telomer­
based
polymeric
product
samples
will
be
collected
and
sealed
immediately.
Prior
to
initiating
sample
collection,
the
vessels
used
for
sample
collection
will
be
tested
to
assure
no
contamination
with
PFOA
via
the
sampling
process.

Samples
of
the
12
telomer­
treated
articles
will
be
collected
from
pilot
plant
facilities
or
from
commercial
manufacturing
facilities
Detailed
procedures
for
collection
of
treated
and
untreated
samples
as
well
as
for
sample
shipment
will
be
issued
as
part
of
the
detailed
protocol.
These
procedures
along
with
chain
of
custody
documentation
for
all
sample
shipments
will
be
maintained
in
the
study
records.
Any
deviations
from
these
procedures
will
be
noted
and
documented
in
the
study
records.

As
described
in
the
specific
sections
below,
this
document
proposes
triplicate
analyses
in
each
facet
of
telomer­
based
polymeric
product
and
treated­
article
testing.
The
number
of
replicates
may
change
as
method
development
and
validation
provides
further
information
on
variability.
Also,
duplicate
untreated
controls
and
fortifications
will
be
conducted
where
applicable.
Fortifi­
cations
are
untreated
control
samples
to
which
known
amounts
of
PFOA
standard
solutions
are
added
in
order
to
demonstrate
that
acceptable
recoveries
are
obtained.
The
analyses
of
fortifica­
tions
and
controls
will
confirm
the
method
accuracy
with
every
set
of
analyses.
As
no
control
materials
are
available
for
product
analyses,
the
method
accuracy
for
products
will
be
demonstrated
by
conducting
on
each
replicate
a
second
analysis
to
which
a
known
quantity
of
standard
will
be
added.

2.0
Analysis
of
"
Aged"
Telomer­
Based
Polymeric
Products
2.1
Goal
The
goal
of
the
product
aging
study
is
to
examine
the
transformation
of
end­
use
telomer­
based
polymeric
products
for
potential
PFOA
generation
that
might
occur
through
storage
and/
or
use
of
the
product
over
time.

2.2
PFOA
Analyses
The
only
compound
which
will
be
monitored
in
this
tier
is
PFOA.

The
12
telomer­
based
polymeric
products
cited
above
will
be
tested
to
determine
the
level
of
PFOA
formation
or
decline
over
conditions
representative
of
one­
year
of
shelf­
life.
The
products
Telomer
Research
Program
Page
3
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

will
be
stored
at
45
°
C
and
triplicate
samples
will
be
analyzed
at
the
following
time
intervals:
0
day,
2
weeks,
6
weeks,
and
12
weeks.

The
temperature
of
45
°
C
was
selected
to
accelerate
the
aging
process
by
simulating
12
months
of
room
temperature
shelf
conditions
using
higher
temperatures
for
a
shorter
period
of
time.
The
assumption
is
that
the
fairly
moderate
temperature
of
45
°
C
will
create
degradation
patterns
similar
to
those
typical
at
room
temperature.
Samples
of
each
product
will
be
held
at
ambient
temperature
and/
or
at
4
°
C
as
a
potential
reference
points
should
they
be
required.

3.0
Analysis
of
"
In­
Use"
Telomer­
Treated
Articles
3.1
Goal
To
examine
"
in­
use"
treated
articles
for
potential
PFOA
generation
that
might
occur
through
normal
use.

3.2
Assumptions
and
Study
Plans
1.
The
analyte
of
interest
is
PFOA.

2.
Accelerated
Aging
at
45
°
C
of
carpet,
textiles
and
paper
is
targeted
to
determine
if
PFOA
levels,
increase
or
decrease
relative
to
day
zero
levels,
in
a
closed
system.
Using
the
supposition
that
every
increase
of
10
°
C
doubles
the
rate
of
reaction,
the
use
of
45
°
C
over
12
weeks
simulates
about
1
year
of
storage
at
25
°
C.
This
temperature
accelerated
aging
approach
should
simulate
ambient
temperature
mechanistic
processes.
Additional
samples
will
be
maintained
at
ambient
temperature
and
may
be
analyzed
depending
upon
the
outcome
from
the
45
°
C
accelerated
sample
analyses.

3.
Photolysis
at
ambient
temperature
of
carpet,
textiles
and
paper
is
targeted
to
determine
whether
PFOA
levels,
increase
or
decrease
relative
to
day
zero
levels,
in
a
closed
system.

4.
It
should
be
noted
that
accelerated
aging
at
45
°
C
and
photolysis
experiments
are
designed
to
determine
if
PFOA
increases
or
decreases
over
time
in
"
in­
use"
articles
in
closed
systems.
Other
proposed
testing
such
as
abrasion,
washing,
dry­
cleaning
and
hot
water
extraction
cleaning
are
targeted
to
determine
changes
in
PFOA
levels
on
the
initial­
treated
article.
Abrasion,
washing,
dry
cleaning
and
hot
water
extraction
cleaning
will
only
be
evaluated
if
sufficiently
quantifiable
levels
of
PFOA
are
detected
in
the
treated
article.

5.
Two­
Tiered
Study
Plan
The
first
tier
of
this
study
plan
is
to
determine
the
level
of
PFOA
at
day
zero
in
treated
carpet,
textiles
and
paper
and
if
these
levels
increase
or
decrease
under
accelerated
storage
conditions
equivalent
to
about
one
year
of
ambient
storage
(
see
Section
3.4),
and
photolytic
conditions
(
See
Section
3.5).
The
second
tier
will
be
initiated
if
significant
levels
of
PFOA
are
determined
to
be
present
in
treated
articles
previously
analyzed
or
day
zero
samples
employed
in
the
elevated
temperature
or
photolysis
experiments.
The
purpose
of
the
second
tier
is
to
determine
if
PFOA
increases
or
decreases
under
expected
use
conditions
exemplified
by
Telomer
Research
Program
Page
4
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

abrasion,
washing
dry
cleaning,
dry
cleaning
and
hot
water
extraction
cleaning
(
sometimes
referred
to
as
"
steam
cleaning").

6.
Below
is
a
summary
of
the
planned
testing
by
treated
article
type.
It
is
currently
planned
that
representative
"
in
use"
treated
articles
representative
of
the
twelve
telomer­
based
polymeric
products
will
be
initially
evaluated
at
elevated
temperature
(
45
°
C)
and
by
photolysis.
The
plan
consists
of
twelve
different
treated
articles:
carpet
(
4
articles),
textiles
(
6
articles)
and
paper
(
2
articles).
Additionally,
if
sufficiently
quantifiable
levels
of
PFOA
are
present
in
the
"
in
use"
treated
articles,
then
the
studies
to
determine
if
PFOA
levels
increase
or
decrease
in
treated
articles
under
the
proposed
in­
use
conditions
will
be
initiated.
If
insufficient
levels
of
PFOA
are
found
in
the
"
in­
use"
treated
articles,
no
additional
testing
will
be
conducted.

3.3
Summary
of
Treated
Article
Testing
by
Specimen
Carpet
Textile
Paper
Elevated
Temperature
Elevated
Temperature
Elevated
Temperature
Light
(
Photolysis)
Light
(
Photolysis)
Light
(
Photolysis)
Abrasion
(
walk
off)
*
Abrasion
(
walk­
off)
*
n/
a
n/
a
Washing
*
n/
a
n/
a
Drycleaning*
n/
a
Hot
water
extraction
*
n/
a
n/
a
PFOA
volatility
**
PFOA
volatility
**
PFOA
volatility**
*
Only
conducted
if
significant
PFOA
levels
are
found
in
"
in­
use"
treated
articles
n/
a
not
applicable.
**
Rationale
attached
in
3.10.

3.4
Accelerated
Aging
of
Treated
Articles
at
Elevated
Temperature
Study
Rationale:
This
test
will
determine
if
PFOA
levels
increase
or
decrease
in
treated
articles
over
time
at
elevated
temperature.

Summary
of
Test:
Treated
samples
of
carpet,
textiles
and
paper
will
be
analyzed
for
detectable
levels
of
PFOA.
Samples
will
then
be
subject
to
accelerated
aging
in
closed
containers
at
45
°
C
with
periodic
"
whole
container"
analysis
for
PFOA
over
a
time
period
of
12
weeks
(
equivalent
to
approximately
1
year
at
25
°
C).
Additional
samples
will
be
maintained
at
ambient
temperature
in
parallel
for
analysis
depending
upon
the
results
from
the
elevated
temperature
work.
The
use
of
closed,
whole
container
analysis
should
represent
the
cumulative
effect
of
aging
over
time.
At
each
sampling
interval,
control
samples
stored
at
ambient
temperature
and
fortifications
will
be
analyzed.

Treated
Articles
representing
the
12
telomer­
based
polymeric
products
will
be
tested:
Treated
Articles
tested:
Carpet
(
4
articles),
Textiles
(
6
articles),
and
Paper
(
2
articles).
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval.

An
identical
set
of
samples
will
be
maintained
at
ambient
temperature.

Telomer
Research
Program
Page
5
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

Treated
Samples
Weeks
at
45
°
C
Sampling
Intervals
(
days)
0
day
6
weeks
12
weeks
Total
Analyses
Total
Analyses
­
Carpet
*
28
28
28
84
Total
Analyses
­
Textile*
42
42
42
126
Total
Analyses
­
Paper*
14
14
14
42
Sum
of
all
analyses
84
84
84
252
*
Includes
two
controls
and
fortifications
per
article
3.5
Accelerated
Aging
of
Treated
Articles
via
Photolysis
Study
Rationale:
This
test
will
determine
if
PFOA
levels
increase
or
decrease
in
treated
articles
over
time
by
exposure
to
light.

Summary
of
Test:
Treated
samples
of
carpet,
textiles
and
paper
will
be
analyzed
for
detectable
levels
of
PFOA.
Samples
will
then
be
subject
to
Xenon
lamp
irradiation
in
closed
containers
at
25
°
C
with
whole
container
analysis
for
PFOA.
Non­
irradiated
untreated
samples
will
be
fortified
with
PFOA;
these
fortifications
along
with
the
non­
irradiated,
untreated
controls
will
be
analyzed
simultaneously
with
the
samples
(
both
non­
irradiated
and
irradiated)
to
demonstrate
that
acceptable
recoveries
are
obtained.
The
"
ASTM's
Paper
Aging
Research
Program"
(
report
March
12,
2002
version)
found
that
natural
sunlight
paper
brightness
loss
(
yellowing)
could
be
correlated
with
that
of
the
Xenon
lamp
when
the
Xenon
lamp
time
scale
was
multiplied
by
300.
Therefore
one
Xenon
lamp
irradiation
day
is
equivalent
to
about
1
year
of
natural
sunlight.

Analysis
Design:
For
each
treated
article
sub­
type,
each
set
of
analyses
will
include
the
following:
3
replicates
of
the
treated
article
without
any
additional
treatment
(
day
0)
3
replicates
of
the
treated
article
irradiated
for
about
24
hours
2
non­
treated,
non­
irradiated
control
samples
2
non­
treated,
non­
irradiated
control
samples
fortified
at
two
levels
Twelve
Treated
Articles
representing
the
12
telomer­
based
polymeric
products
will
be
tested:
Articles
tested:
Carpet
(
4
articles),
Textiles
(
6
articles),
and
Paper
(
2
articles).
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval.

Treated
Samples
Hours
of
Xenon
Lamp
Irradiation
Sampling
Interval
(
hours)
0
+
24
hours
Total
Analyses
­
Carpet
*
40
Total
Analyses
­
Textile*
60
Total
Analyses
­
Paper*
20
Sum
of
all
analyses
120
*
Includes
two
controls
and
fortifications
per
article.

Telomer
Research
Program
Page
6
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

Based
on
the
information
generated
on
the
above­
mentioned
samples,
TRP
may
elect
to
conduct
additional
testing
on
irradiated
untreated
articles.

3.6
Abrasion
Carpet
and
Textiles
are
appropriate
treated
articles.
This
test
is
not
appropriate
for
paper.
The
purpose
of
this
test
is
to
determine
if
PFOA
residues
in
the
"
in­
use"
treated
article
would
be
changed
as
a
result
of
abrasion.
This
test
will
only
be
conducted
if
sufficiently
quantifiable
PFOA
is
present
in
the
treated
article.

Currently
AATCC
Test
Method
119­
1994,
"
Color
Change
Due
to
Flat
Abrasion
(
Frosting):
Screen
Wire
Method
is
the
intended
method
to
evaluate
abrasion
on
textiles.
Levels
of
PFOA
before
and
after
abrasion
will
be
measured.
AATCC
=
American
Association
of
Textile
Chemists
and
Colorists
The
Vetterman
Drum
test
(
ISO/
TR
10361)
is
currently
proposed
for
carpet.
ISO
=
International
Standards
Organization
Analysis
Design:
For
each
treated
article
sub­
type,
each
set
of
analyses
will
include
the
following:
3
replicates
of
the
treated
article
without
any
additional
treatment
(
day
0)
3
replicates
of
the
treated
article
after
abrasion
2
non­
treated,
non­
abraded
control
samples
2
non­
treated,
non­
abraded
control
samples
fortified
at
two
levels
Ten
Treated
Articles
representing
the
10
telomer­
based
polymeric
product
will
be
tested:
Treated
Articles
tested:
Carpet
(
4
articles),
Textiles
(
6
articles)
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval
Article
Before
and
After
Abrasion
Total
Carpet
analyses*
40
Total
Textile
analyses*
60
Total
analyses
100
*
Two
controls
and
two
fortifications
per
article
tested,
includes
controls
and
fortifications
3.7
Washing/
Laundering
Textile
is
a
representative
sample
for
washing/
laundering
evaluation.
If
there
is
sufficient
PFOA
residues
in
the
six
treated
textile
articles,
then
washing
three
treated
articles
per
textile
will
be
considered.
Treated
articles
will
be
analyzed
before
and
after
washing.
This
test
will
only
be
conducted
if
sufficiently
quantifiable
PFOA
is
present
in
the
treated
article.

AATCC
Test
Method
135­
1995,
"
Dimensional
Changes
in
Automatic
Home
Laundering
of
Woven
and
Knit
Fabrics"
is
the
intended
method
to
evaluate
textile
washing.
Although
this
method
recommends
the
use
of
four
temperatures,
three
agitation
cycles,
and
four
drying
procedures,
one
representative
set
of
conditions
will
be
chosen
initially
for
use
in
this
test.
AATCC
=
American
Association
of
Textile
Chemists
and
Colorists
Telomer
Research
Program
Page
7
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

Analysis
Design:
For
each
treated
article
sub­
type,
each
set
of
analyses
will
include
the
following:
3
replicates
of
the
treated
article
without
any
additional
treatment
(
before)
3
replicates
of
the
treated
article
after
washing
2
non­
treated,
non­
washed
control
samples
2
non­
treated,
non­
washed
control
samples
fortified
at
two
levels
Six
Treated
Articles
representing
the
6
telomer­
based
polymeric
products
will
be
tested:
Treated
Articles
tested:
Textiles
(
6
articles)
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval
Article
Before
and
After
Washing
Total
Textile
analyses*
60
*
Two
controls
and
two
fortifications
per
article
tested,
includes
controls
and
fortifications
3.8
Dry
Cleaning
Textiles
are
the
appropriate
treated
articles
for
this
evaluation.
The
purpose
of
this
test
is
to
determine
if
PFOA
residues
in
the
article
would
be
changed
as
a
result
of
dry
cleaning.
This
test
will
only
be
conducted
if
sufficiently
quantifiable
PFOA
is
present
in
the
treated
article.

AATCC
Test
Method
132­
1998,
"
Colorfastness
to
Drycleaning",
is
the
intended
method
to
evaluate
drycleaning.
Levels
of
PFOA
before
and
after
dry
cleaning
will
be
measured.
AATCC
=
American
Association
of
Textile
Chemists
and
Colorists
Analysis
Design:
For
each
treated
article
sub­
type,
each
set
of
analyses
will
include
the
following:
3
replicates
of
the
treated
article
without
any
additional
treatment
3
replicates
of
the
treated
article
after
dry
cleaning
2
non­
treated,
non­
dry
cleaned
control
samples
2
non­
treated,
non­
dry
cleaned
control
samples
fortified
at
two
levels
Six
Treated
Articles
representing
the
6
telomer­
based
polymeric
products
will
be
tested:
Treated
Articles
tested:
Textiles
(
6
articles)
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval
Article
Before
and
After
Drycleaning
Total
Textile
analyses*
60
*
Two
controls
and
two
fortifications
per
article
tested,
includes
controls
and
fortifications
3.9
Hot
Water
Extraction
Method
Carpet
is
the
appropriate
treated
article
for
evaluation.
This
test
will
only
be
conducted
if
sufficiently
quantifiable
PFOA
is
present
in
the
treated
article.

Telomer
Research
Program
Page
8
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

If
there
is
sufficient
PFOA
in
the
four
carpet
articles
then
hot
water
extraction
of
carpets
in
triplicate
will
be
considered
for
those
articles.
Carpet
will
be
analyzed
for
PFOA
residues
before
and
after
treatment.

AATCC
Test
Method
171­
1995,
"
Carpets:
Cleaning
of;
Hot
Water
Extraction
Method"
is
the
intended
method
to
evaluate
carpet
cleaning.

Analysis
Design:
For
each
treated
article
sub­
type,
each
set
of
analyses
will
include
the
following:
3
replicates
of
the
treated
article
without
any
additional
treatment
(
before)
3
replicates
of
the
treated
article
after
hot
water
extraction
2
non­
treated,
non­
extracted
control
samples
2
non­
treated,
non­
extracted
control
samples
fortified
at
two
levels
Four
Treated
Articles
representing
the
4
telomer­
based
polymeric
products
will
be
tested:
Treated
Articles
tested:
Carpet
(
4
articles)
Replicates:
Each
article
will
be
run
in
triplicate
at
each
sampling
interval
Article
Before
and
After
Cleaning
Total
Carpet
analyses*
40
*
Two
controls
and
two
fortifications
per
article
tested,
includes
controls
and
fortifications
3.10
PFOA
Volatility
The
results
of
the
report,
"
Impinger
Studies
of
Volatility
of
FC­
95
and
FC­
143"
(
EPA
reference
docket
number
3M
AR226,
June
28,
2001),
state
that
solid
PFOA"
is
not
volatile
or
has
a
very
low
vapor
pressure
as
a
solid".
The
report
concludes
that
the
vapor
pressure
must
be
below
1
x
10­
7
torr
based
on
method
sensitivity.
Therefore,
one
could
argue
that
PFOA
is
not
volatile.

PFOA
volatility
from
aqueous
solutions
containing
low
levels
of
quaternary
ammonium
salts
was
determined
in
the
report
titled,
"
Impinger
Studies
of
Volatility
of
FC­
95
and
FC­
143".
FC­
95
is
PFOA.
Bubbling
air
through
10
ppm
(
mg/
kg)
PFOA
aqueous
solutions
over
280
minutes
at
flow
rate
of
1
liter/
min
for
a
total
volume
of
280
liters
showed
that
on
average
about
92%
of
the
sample
was
accounted
for
in
solution.

In
addition,
the
TRP
is
currently
conducting
an
on­
going
screening
study
in
products
and
articles
and
other
work
on
the
potential
release
of
PFOA
from
telomer­
treated
article
manufacture
will
be
conducted
by
the
TRP
as
described
in
the
Letter
of
Intent.
If
unexplained
dramatic
reductions
in
PFOA
levels
occur
in
these
tests,
the
issue
of
volatility
may
be
investigated
further.

4.0
Schedule
April
 
May
2003
 
Developed
draft
work
plan
for
telomer­
based
polymeric
product
aging
and
treated
article
"
in­
use"
simulation
Telomer
Research
Program
Page
9
of
10
DRAFT
 
For
EPA
Review
and
Comment
TRP
(
9­
May­
03)

Telomer
Research
Program
Page
10
of
10
May
 
June
2003
 
Prepare
individual
draft
protocols
for
PFOA
analysis
on
aged
telomer­
based
polymeric
products
and
treated
article
"
in­
use"
and
locate
suitable
laboratories
July
 
August
2003
 
Initiate
elevated­
temperature
studies
on
telomer­
based
polymeric
products
and
treated
articles
 
Review
data
on
PFOA
in
treated
articles
prior
to
in­
use
simulation
and
assess
the
need
and
viability
of
conducting
abrasion,
dry
cleaning,
washing,
steam
cleaning,
and
volatility
studies,
 
Initiate
article
"
in­
use"
studies
if
appropriate
September
2003
 
Initiate
photolysis
study
on
treated
articles.
 
Complete
validation
of
procedures
to
be
used
at
the
"
in­
use"
laboratories
November
2003
 
Submit
Photolysis
report
January
2004
 
Submit
Elevated­
Temperature
reports
 
Submit
"
in­
use"
reports
