Statement
By
Uma
Chowdhry,
Global
Vice
President
DuPont
Central
Research
&
Development
Before
The
United
States
Environmental
Protection
Agency
Public
Meeting
Enforceable
Consent
Agreement
Development
For
Perfluorooctanoic
Acid
(
PFOA)
and
Fluorinated
Telomers
Friday,
June
6,
2003
Good
aflernoon.
My
name
is
Uma
Chowdhry.
I
am
the
global
vice
president
ofDuPont
Central
Research
&
Development.
With
me
today
are
Mr.
Richard
Angiullo,
vice
president
of
DuPont
Fluoroproducts
and
Dr.
RobertRitchie,
technical
director
for
DuPont
Chemical
Solutions.

I
would
like
to
thank
the
Agency
forproviding
the
opportunity
for
DuPont
to
comment
on
the
Enforceable
Consent
Agreement
development
process
for
pefluorooctanoic
acid
(
PFOA).
I
would
note
that
in
addition
to
my
statement,
DuPont
also
responded
to
your
request
for
written
comments
and
submitted
those
to
you
for
consideration
on
May
16
th°

We
recognize
that
therehave
been
many
questions
raised
by
EPA
and
others
about
the
potential
risks
associated
with
exposure
to
PFOA.
And,
as
a
science
company,
DuPont
is
fully
conm­
iitted
to
work
with
industry
to
address
those
questions;
to
investigate
both
past
and
current
potential
sources
of
PFOA
exposure;
to
further
reduce
exposure
pathways;
and
to
provide
information
needed
to
allow
for
the
development
of
an
accurate,
science­
based
assessment
of
any
risks
posed
by
PFOA.

Our
knowledge
ofthe
compound
is
extensive
and
we
are
more
than
willing
to
continue
to
share
that
knowledge
with
the
agency
and
the
public
throughout
theECA
development
process.
And,
we
will
of
course
cooperate
with
its
final
conclusions.

DuPont
is
a
company
with
a
200­
year
heritage
based
on
core
values
of
safety,
health
and
environmental
stewardship;
high
ethical
standards;
and
a
commitment
to
treat
all
people
with
respect.
These
core
values
are
foremost
in
everything
that
we
do
as
a
company.
Consistent
with
these
values,
we
very
much
respect
the
rights
and
desires
of
consumers
around
the
world
to
know
that
the
products
they
purchase,
use
and
rely
on
are
safe.

Throughout
our
history,
safety
has
been
our
first
priority
of
business.
We
are
passionate
about
the
safety
of
our
operations
and
products.

In
more
than
50
years
of
use
by
DuPont
and
others,
there
have
beenno
known
adverse
human
health
effects
associated
withPFOA.
Extensive
scientific
studies
indicate
that
current
PFOA
exposure
does
not
present
a
risk
to
humans
or
the
environment.

There
are
more
than
100
laboratory
and
employee
health
studies
on
PFOA,
many
of
which
have
been
peer­
reviewed
andpublished
in
the
open
literature.
These
studies
support
our
2
conclusion
that
PFOA
does
not
pose
a
risk
to
humans.
This
is
especiallyimportant
given
the
potential
for
higher
levels
of
exposure
to
PFOA
that
may
result
in
an
occupational
setting.

We
believe,
and
are
confident,
that
PFOA
poses
no
danger
to
the
public
at
current
levels.

PFOA
is
a
biopersistent
compound.
It
does
not
bioaccumulate
in
the
environment
or
animals.
PFOA
is
not
a
genotoxin
and,
while
it
may
cause
cancer
in
laboratory
animals,
it
is
not
believed
to
be
a
human
carcinogen.
Based
on
the
scientific
data
available
to
us,
DuPont
does
not
consider
PFOA
to
be
a
developmental
toxin.

The
ECA
regulatory
process
should
be
based
on
high
quality,
credible
scientific
data,
and
should
include
a
complete
characterization
of
all
past
and
current
PFOA
exposure
routes.
We
are
confident
that
the
outcome
of
this
more
comprehensive
process
will
support
our
position
that
the
compounds
and
products
involved
are
safe
for
their
intended
uses.

In
2002,
DuPont
began
manufacturing
PFOA
in
the
U.
S.
after
3M,
our
domestic
supplier,
discontinued
production.
Today,
our
state­
of­
the­
art
manufacturing
facility
employs
emissions
control
technologythat
reduces
PFOA
emissions
by
more
than
99
percent
compared
to
emissions
from
previously
used
PFOA
manufacturing
technologies.
This
is
a
distinction
that
we
are
truly
proud
of
and
have
openly
shared
our
newly
developed
technology
on
emissions
reductions
throughout
the
industry.

Testing
is
conducted
to
ensure
that
DuPont
products
that
use
PFOA
in
their
manufacture
are
safe
for
their
intended
uses,
whether
they
are
sold
to
consumers
or
to
business­
to­
business
customers
who
fabricate
or
use
our
products
as
ingredients
in
their
products.

On
April
14
of
this
year,
your
agency
concluded
that
"
EPA
does
not
believe
there
is
any
reason
for
consumers
to
stop
using
any
consumer
or
industrial
products"
containing
fluoropolymers
or
telomers
as
ingredients,
because
of
questions
about
PFOA.

DuPont
agrees
and
supports
the
EPA
position.

Lastly,
I
would
like
to
reaffirm
that
DuPont
is
fully
supportive
ofthe
Agency's
leadership
to
conduct
a
scientifically
sound
risk
assessment
for
PFOA
and
we
are
fully
supportive
ofthe
Agency's
decision
to
convene
a
Scientific
Advisory
Board
to
review
and
comment
on
the
agency's
risk
assessment.

We
believe
that
EPA's
process
may
lead
to
regulation
that
will
assure
the
protection
of
the
public's
health
and
safety
while
allowing
the
continued
use
ofPFOA
and
the
benefits
it
brings
to
society.

We
remain
confident
that
society
is
not
being
exposed
to
healthor
environmental
risks
from
potential
exposure
to
PFOA.
We
will
work
with
the
Agency
to
provide
any
information
we
can
to
assist
with
your
investigation.

Thank
you.
