Comments
of
Donald
K.
Duncan,
President
The
Society
of
the
Plastics
Industry,
Inc.

EPA
Public
Meeting
Enforceable
Consent
Agreement
Development
For
PFOA
and
Fluorinated
Telomers
June
6,
2003
Good
afternoon.
I
am
Don
Duncan,
president
of
The
Society
of
the
Plastics
Industry,
or
SPI,
the
Washington,
DC­
based
trade
association
representing
the
$
320­
billion
U.
S.
plastics
industry.
I
am
a
chemical
engineer
by
training
and
have
been
involved
in
the
plastics
industry
for
more
than
30
years.

In
2000,
Ijoined
SPI,
an
organization
that
has
served
the
industry
for
more
than
65
years
and
has
created
a
strong
record
of
working
openly
and
effectively
with
federal
agencies
to
address
their
concerns.
These
discussions
continue
that
tradition.

I
am
here
today
to
speak
on
behalf
of
S
PT's
Fluoropolymers
Manufacturing
Group,
or
FMG,
which
includes
those
global
companies
that
use
PFOA
as
a
surfactant
to
produce
their
polymer
products.
The
FMG
appreciates
the
opportunity
to
participate
in
the
EPA's
public
meeting
and
continue
a
process
begun
more
than
two
years
ago.

The
issue
that
brings
us
together
involves
data
that
has
been
submitted
suggesting
that
PFOA
has
been
found
in
U.
S.
blood
samples
and
appears
to
be
persistent
in
the
environment.
While
extensive
research
done
to
date
has
indicated
no
adverse
effects
on
human
health
or
the
environment
at
the
levels
indicated,
these
matters,
of
course,
are
of
concern
to
our
industry,
and
we
are
committed
to
working
with
the
EPA
to:

°
define
the
routes
of
exposure
to
the
public
and
the
environment,
°
characterize
the
health
implications
of
that
exposure,
and
°
significantly
reduce
the
potential
exposure
sources
from
the
fluoropolymer
industry.

Today's
meeting
is
an
important
part
of
that
process,
whose
outcome,
we
believe,
will
produce
the
mutually
beneficial
result
ofensuring
continued
protection
ofhuman
health
and
the
environment
without
disrupting
the
supply
ofessential
materials
or
causing
undue
adverse
impact
on
an
important
segment
of
U.
S.
industry.

This
issue
is
extremely
significant
to
the
FMG,
because
PFOA
is
an
indispensable
polymerization
aid
in
the
manufacture
of
its
products.
In
previous
meetings
with
the
EPA,
the
FMG
has
defined
its
considerable
efforts
to
find
a
substitute
for
PFOA.
While
there
has
been
some
very
limited
success
in
finding
alternatives
for
niche
products,
to
date
there
has
been
no
discovery
of
a
universal
replacement
for
PFOA
in
the
production
of
fluoropolymers.

Considering
the
complexity
and
importance
of
this
issue,
and
its
overwhelming
impact
on
the
fluoropolymer
industry,
we
think
it
is
important
to
understand
the
value
of
the
fluoropolymer
industry
and
the
contributions
it
makes
to
both
the
economy
and
our
quality
of
life.
While
fluoropolymers
are
a
small
part
ofthe
plastics
industry,
they
are
a
key
material
for
industries
that
make
up
the
core
of
our
country's
economy
and
serve
many
critical
uses.
Hence,
the
issues
being
discussed
today
are
highly
relevant
to
all
of
us,
and
it
is
appropriate
that
they
are
being
considered
with
great
thought
and
care.

Recent
media
coverage
related
to
PFOA
has
associated
fluoropolymers
primarily
with
non­
stick
cookware
 
no
question
one
of
the
best­
known
commercial
applications
of
fluoropolymers.
However,
it
is
important
to
note
that
the
overwhelming
majority
of
fluoropolymers
are
used
in
areas
where,
unseen
to
the
consumer,
they
support
and
enable
vital
industries
such
as
defense
and
aerospace,
telecommunications,
chemical
processing,
semiconductor
manufacturing,
automotive
and
power
generation.

The
properties
of
fluoropolymers
are
unique
in
the
level
ofperformance
they
provide,
including
temperature
and
flame
resistance,
inertness
to
chemical
attack
and
electrical
insulating
properties.

In
many
cases,
the
use
of
fluoropolymers
helps
protect
both
people
and
theenvironment
in
ways
not
possible
with
other
materials.

Let
me
offer
some
examples:

°
The
defense
industry
is
highly
dependent
on
fluoropolymer
components
ranging
from
seals
for
hydraulic
aircraft
systems
to
sophisticated
films
that
protect
liquid
crystal
displays.
°
The
chemical
processing
and
power
generation
industries
employ
fluoropolymer
devices
that
help
to
prevent
pollution
and
the
release
of
hazardous
chemicals.
°
The
telecommunications
and
semiconductor
industries
use
fluoropolymer
products
to
reduce
risk
of
fire
in
commercial
buildings
and
enable
the
manufacture
of
semiconductor
chips
by
processes
that
require
the
ultra
high
purity
that
only
fluoropolymers
provide.
°
The
automotive
industry
is
a
significant
consumer
of
fluoropolymers
in
fuel
and
lubrication
systems,
enabling
reductions
in
air
pollution
from
fuel
evaporation
and
improvements
in
fuel
economy.
°
The
U.
S.
space
program,
while
not
a
large
consumer
of
fluoropolymers,
is
very
dependent
on
these
products
for
critical
applications
in
vehicle
components
and
protective
clothing
for
the
astronauts.

It
should
be
pointed
out
that
these
applications
involve
state­
of­
the­
art
or
best­
available
technology.
Manufacturers
in
these
areas
use
fluoropolymers
 
which
are
considerably
more
expensive
than
other
plastics
 
because
they
are
the
only
materials
that
meet
their
demanding
performance
requirements.

I
stress
this
because,
without
an
understanding
of
how
fluoropolymers
have
helped
bring
technology
to
where
it
is
today,
it
would
be
tempting
for
some
to
view
fluoropolymers
as
simply
a
type
of
plastic
that
could
be
easily
replaced
if
taken
offthe
market.

Thus
one
of
SPI's
goals
today
is
for
the
EPA
and
the
American
public
to
understand
that
fluoropolymers
provide
far
more
than
the
convenience
for
which
they
are
so
well
known.

Since
their
invention
more
than
60
years
ago,
fluoropolymers
have
served
to
raise
the
bar
on
the
technological
capabilities
of
the
many
key
industries
we
have
discussed.
These
materials
play
a
discrete
but
critical
role
in
protecting
both
the
public
and
the
environment,
and
they
are
essential
to
the
productive
and
competitive
operations
of
the
important
American
and
global
industries
they
serve.

Another
SPI
goal
today
is
to
reemphasize
the
FMG's
commitment
to
reduce
exposures
to
PFOA
that
may
be
due
to
the
activities
of
the
fluoropolymer
industry.
As
you
know,
FMG
members
already
have
implemented
programs
that
will
reduce
emissions
from
PFOA
manufacturing
facilities
by
99
percent
and
are
ahead
of
schedule
to
meet
the
voluntary
target
ofreducing
PFOA
emissions
from
fluoropolymer
manufacturing
facilities
by
50
percent
by
2006.

Because
there
is
so
much
at
stake
with
respect
to
the
PFOA
issue
and
because
ofthe
complexity
ofthe
science
surrounding
the
understanding
of
this
material,
SPI
and
the
FMG
look
forward
to
continuing
our
working
relationship
with
the
EPA
to
expand
the
knowledge
base
around
PFOA
and
reduce
potential
exposures
from
activities
of
the
fluoropolymer
industry.

This
concludes
my
remarks.
Thank
you.
