EPA
Public
Meeting
on
Enforceable
Consent
Agreement
Development
for
Perfluorooctanoic
Acid
(
PFOA)
and
Fluorinated
Telomers
June
6,
2003
Opening
Statement
for
the
Telomer
Research
Program
On
Behalf
of
the
TRP
Participating
Companies
~
Asahi
Glass
Co.,
Clariant
GmbH,
Daikin
Industries
and
E.
I.
duPont
de
Nemours
&
Company
~

Good
afternoon.
My
name
is
Katie
Smythe.
I
work
for
the
RAND
Corporation1
and
serve
as
the
administrator
of
the
Telomer
Research
Program,
also
known
as
the
TRP.
As
the
TRP
administrator,
I
have
been
asked
by
the
member
companies
to
present
the
TRP's
opening
statement
summarizing
their
views.
The
TRP
members
would
like
to
thank
the
Agency
for
the
opportunity
to
comment
on
the
Enforceable
Consent
Agreement
(
ECA)
development
process
for
PFOA.

The
TRP
is
a
science­
focused
research
consortium
funded
by
the
primary
global
fluorotelomer
manufacturers:
Asahi
Glass
(
Japan),
Clariant
(
Germany),
Daikin
Industries
(
Japan),
and
DuPont
(
USA).
The
TRP
companies
produce
in
or
import
telomer­
based
products
into
the
United
States,
which
are
used
as
surface
protection
chemicals
and
specialty
fluoro­

addditives
in
many
markets.

Individually,
the
member
companies
have
studied
fluorotelomer
products
for
more
than
40
years
and
are
firmly
committed
to
the
safe
manufacture
and
use
of
telomer­
based
products.
In
addition,
TRP
members
continue
to
affirm
that
these
products
are
indeed
safe
for
the
markets
in
which
they
are
used.
The
TRP
has
initiated
an
ambitious
program
to
develop
additional
data
on
the
environmental
fate
of
telomer­
based
products,
better
characterize
routes
of
environmental
release
and
human
exposure,
strengthen
product
stewardship,
and
take
additional
measures
to
reduce
or
prevent
exposure
wherever
new
data
suggest
that
such
changes
are
needed.

1
RAND
is
not
engaged
in
research,
technical
analysis
or
policy
considerations
for
the
TRP
and
takes
no
position
on
PFOA
issues.

Page
1
of
4
Telomer
products
are
not
made
from
PFOA,
nor
is
PFOA
added
during
the
manufacture
or
use
of
telomer
products.
However,
questions
have
been
raised
about
the
potential
for
telomer
products
to
transform
to
PFOA.
The
TRP
is
actively
working
to
address
these
questions
and
identify
the
relevant
routes
by
which
telomer
products
may,
in
fact,
transform
to
PFOA
and,
if
they
do,
to
what
degree
these
transformations
take
place
and
if
there
may
be
human
or
environmental
exposure
of
consequence.
The
TRP
is
committed
to
answer
EPA's
questions
and
participate
in
the
ECA
process.

Telomer­
based
products
and
articles
treated
with
these
products
provide
many
unique
and
irreplaceable
benefits
to
people
and
society.
The
telomer
products
provide
protection
that
significantly
extends
the
useful
lifetime
and
lessens
the
need
to
clean
textile
articles,
including
apparel,
upholstery,
and
carpeting.
In
specific
applications,
garments
treated
with
telomer
products
protect
military
and
healthcare
workers
from
chemical
agents
and
diseases
transmitted
through
blood,
such
as
HIV
and
hepatitis.
Telomer­
based
products
are
also
key
ingredients
in
fire
fighting
foam
formulations
and
are
unparalleled
in
their
ability
to
knock
down,
resist
burnback,
and
secure
an
enflamed
area
quickly
and
safely.

In
a
Letter
of
Intent
(
LOI)
2
to
EPA,
the
TRP
members
outlined
a
voluntary
commitment
to
investigate
the
potential
association
between
PFOA
and
telomers,
and
continue
to
generate
data
in
a
timely
manner.
The
TRP
has
developed
a
staged
scientific
study
approach
focused
on
articles
treated
with
telomers
and
telomer
products
in
order
to
determine
their
potential
to
transform
or
break
down
into
PFOA.
The
TRP
is
utilizing
the
best
testing
and
methodology
practices
available.
The
members
believe
it
is
important
to
provide
the
EPA,
their
customers
and
the
public
with
scientific
data
on
the
products
that
they
purchase.
The
TRP
work
is
focused
on
three
major
end­
use
applications:
carpets,
textiles
and
paper.

For
the
work
underway,
analytical
method
development
has
been
a
substantial
challenge
due
to
the
unique
properties
of
the
telomer
substances
and
the
lack
of
methods
to
determine
low
2
TRP
Letter
of
Intent
 
EPA
Docket
#
OPPT­
2003­
0012­
0013;
TRP's
response
to
EPA
follow­
up
questions
(
Docket
#
OPPT­
2003­
0012­
0049)
provides
additional
information.

Page
2
of
4
levels
of
PFOA.
Current
experience
with
method
development
has
shown
us
that
standard
test
guidelines
are
not
always
suitable
and
need
significant
adaptations
to
develop
sound
data
and
methods.
TRP
is
now
sponsoring
work
at
several
contract
labs
to
develop
and
validate
analytical
methods
to
conduct
these
studies
on
products
and
articles.

The
TRP
members
fully
understand
that
EPA
has
questions
regarding
potential
exposure
pathways
of
PFOA.
The
member
companies
support
EPA's
efforts
to
assure
the
regulatory
process
is
based
on
high
quality,
credible
scientific
data
and
they
are
committed
to
providing
their
part
of
this
data
collection
in
a
timely,
efficient
and
responsible
manner.

Current
contributions
to
environmental
loadings
of
PFOA
provide
only
part
of
the
answer
to
EPA's
questions.
A
full
characterization
of
potential
routes
of
environmental
and
human
exposure
for
PFOA
should
include
all
past
and
current
sources
of
PFOA.
The
TRP
members
believe
that
the
ECA
process
should
include
products
that
have
been
discontinued
but
are
still
in
commercial
use
and
available
in
the
environment
for
human
exposure.
Discontinued
PFOS­

based
products
and
past
PFOA
production
and
use
must
be
included
to
fully
and
accurately
reflect
current
environmental
and
human
exposure
potential.
TRP
member
companies
urge
EPA
to
take
a
comprehensive
and
holistic
approach
to
understanding
environmental
and
human
exposure
to
develop
a
risk
assessment
on
PFOA
and
its
salts
that
includes
PFOA
manufacture
and
use,
PFOS­
based
products,
and
telomers.

The
world
is
ever
evolving,
and
so
are
science
and
our
understanding
of
it.
The
research
being
conducted
by
the
TRP
is
no
exception.
The
research
being
undertaken
requires
the
development
of
new
testing
standards
and
new
methodologies
that
will
result
in
further
understanding,
increased
awareness
and
the
continued
responsible
stewardship
of
telomer­
based
products.

The
member
companies
stand
by
their
substantial
and
aggressive
commitments
to
EPA,

described
in
the
TRP
LOI
and
in
the
comments
made
today.
The
TRP
members
are
committed
to
safe
handling
and
use
of
their
products
and
to
continue
their
comprehensive
research
program
to
identify
potential
PFOA
exposure
pathways
that
may
be
associated
with
telomer­
based
Page
3
of
4
Page
4
of
4
products.
The
TRP
members
strongly
believe
the
end
result
of
this
research
program
will
be
new
knowledge
on
telomer­
based
products
and
chemistry
that
will
reaffirm
to
the
EPA,
customers
and
consumers
the
value
and
safety
of
telomer
products.

Thank
you
for
the
opportunity
to
provide
these
comments
today.

#
#
#
