Barbara
Leczynski
06/
17/
2003
03:
37
PM
To:
Mary
Dominiak/
DC/
USEPA/
US@
EPA
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
PFOA
ECA
Public
Meeting
Summary,
June
6,
2003
You
are
receiving
this
message
because
you
have
expressed
an
interest
in
receiving
information
concerning
the
Agency's
enforceable
consent
agreement
(
ECA)
process
on
perfluorooctanoic
acid
(
PFOA)
and
the
fluorinated
telomers,
OPPT­
2003­
0012.
If
you
no
longer
wish
to
receive
this
information,
please
send
an
email
response
to
dominiak.
mary@
epa.
gov
requesting
that
you
be
removed
from
this
notification
list.

****************************************************************************************

Attached
for
your
information
is
a
brief
summary
of
the
public
meeting
held
at
EPA
Headquarters
from
noon
until
5:
00
PM
on
June
6,
2003,
in
Washington,
DC,
to
initiate
the
PFOA
ECA
process.
Copies
of
this
summary,
the
draft
meeting
agenda,
the
complete
attendance
list
for
the
meeting,
and
the
four
opening
statements
that
were
provided
at
the
meeting
in
writing
have
been
placed
in
the
online
electronic
docket
for
this
proceeding.
A
copy
of
the
verbatim
transcript
of
the
meeting
will
be
entered
into
the
docket
on
or
before
June
27,
2003.
You
can
access
the
docket
at
www.
epa.
gov/
edocket/
by
using
the
"
Quick
Search"
feature
to
locate
docket
OPPT­
2003­
0012.
Document
processing
requirements
may
delay
the
visibility
of
submitted
documents
in
the
public
docket
for
one
or
two
days.

If
you
have
any
questions
concerning
this
matter,
or
any
difficulty
in
accessing
the
electronic
docket,
please
contact
Mary
Dominiak
by
phone
at
202­
564­
8104,
or
by
email
at
dominiak.
mary@
epa.
gov.

Sincerely,

Barbara
Leczynski
Chief,
Existing
Chemicals
Branch
U.
S.
Environmental
Protection
Agency
EPA
East,
Room
4410­
A,
Mail
Code
7405M
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Phone:
202­
564­
8164
Fax:
202­
564­
4775
PFOA
Meeting
Summary,
June
6,
2003
U.
S.
Environmental
Protection
Agency
June
16,
2003
Enforceable
Consent
Agreement
Development
for
Perfluorooctanoic
Acid
(
PFOA)
and
Fluorinated
Telomers
Summary
of
June
6,
2003
Public
Meeting
One
hundred
and
ninety­
one
people
attended
the
initial
enforceable
consent
agreement
(
ECA)
meeting
on
PFOA
and
the
telomers
at
EPA
Headquarters
in
Washington,
DC
on
Friday,
June
6,
2003,
from
noon
to
5:
00
PM.
The
meeting
participants
represented
49
registered
interested
parties,
numerous
observers,
and
EPA
staff.
Groups
speaking
at
the
meeting
expressed
support
for
EPA's
actions
and
a
willingness
to
work
toward
agreements
on
the
data
needs
identified
in
EPA's
Preliminary
Framework
document.
Copies
of
the
attendance
list,
the
meeting
agenda,
and
the
four
opening
statements
submitted
in
writing
to
the
Agency
can
be
found
in
the
electronic
docket,
OPPT­
2003­
0012.
A
verbatim
transcript
of
the
proceedings
will
be
placed
in
the
docket
within
three
weeks
of
the
meeting.
The
next
Plenary
meeting
will
be
held
in
Washington,
DC
on
July
10,
2003.

Summary
of
Opening
Statements
EPA
and
six
interested
parties
made
opening
statements
at
the
meeting.

°
EPA
welcomed
the
meeting
participants,
provided
an
overview
of
the
ECA
process,
and
noted
that
the
goal
of
this
process
is
to
obtain
agreements
to
develop
data
to
clarify
the
sources
of
PFOA
in
the
environment
and
the
pathways
leading
to
exposure.
EPA
reiterated
statements
made
in
the
Federal
Register
notice
and
in
the
preparatory
materials
for
the
meeting
that
the
Agency
would
not
be
pursuing
additional
PFOA
toxicity
testing
or
blood
monitoring
through
this
ECA
process.
EPA
noted
that
pharmacokinetics
studies
are
already
underway
in
the
private
sector,
and
that
EPA
has
nominated
PFOA
and
related
chemicals
to
the
Centers
for
Disease
Control
and
Prevention
as
candidates
to
include
in
the
next
National
Health
and
Nutrition
Examination
Survey,
which
monitors
chemicals
in
human
blood.
EPA
stated
that
it
saw
no
need
to
duplicate
these
activities
in
the
ECA
process.
EPA
also
noted
that
it
is
continuing
its
efforts
to
refine
a
preliminary
risk
assessment
on
PFOA.
EPA
stated
that
a
further
developed,
revised
version
of
the
preliminary
risk
assessment
would
be
submitted
to
the
EPA's
Science
Advisory
Board
for
review
later
this
year,
in
a
public
process
that
will
allow
for
the
consideration
of
issues
specific
to
that
assessment,
and
that
the
preliminary
assessment
would
thus
not
be
discussed
in
the
context
of
these
ECA
proceedings.

°
The
Center
for
Regulatory
Effectiveness
indicated
that
all
information
disseminated
by
the
Agency
during
the
ECA
process
and
with
regard
to
the
Agency's
developing
risk
assessment
on
PFOA
must
meet
the
requirements
of
the
Agency's
information
quality
guidelines.
U.
S.
Environmental
Protection
Agency
June
16,
2003
2
°
The
Little
Hocking
Water
Association
commented
that
its
rural
water
system
contains
about
2
ppb
of
PFOA,
and
that
its
citizens
are
thus
exposed
to
PFOA
through
their
water
supply.
The
Association
requested
that,
during
this
ECA
process,
the
EPA
remember
this
local
community
and
provide
data
and
information
in
which
these
citizens
can
have
confidence.

°
The
Environmental
Working
Group
stated
that
any
CBI
claims
with
respect
to
PFOA
toxicity
or
exposure
data
must
be
denied;
that
companies
must
submit
to
EPA
all
existing
health
and
exposure
data
relating
to
PFOA
and
telomers;
that
the
ECA
process
must
include
blood
monitoring
studies;
and
that
the
ECA
process
should
include
PFOA
exposure
from
heated
non­
stick
appliances.

°
DuPont
recognized
that
many
questions
have
been
raised
by
EPA
and
others
about
the
potential
risks
associated
with
exposure
to
PFOA,
and
expressed
its
commitment
to
investigate
past
and
current
sources
of
exposure;
to
further
reduce
exposure
pathways;
and
to
provide
information
needed
to
allow
for
the
development
of
an
accurate,
science­
based
assessment
of
risks.
DuPont
stated
that
there
have
been
no
known
adverse
human
health
effects
associated
with
PFOA
in
the
more
than
50
years
of
PFOA
use
by
DuPont
and
others.

°
The
Telomer
Research
Program
(
TRP)
noted
that
questions
have
been
raised
about
the
potential
for
telomer
products
to
transform
to
PFOA.
TRP
stated
that
it
is
actively
working
to
identify
the
relevant
routes
by
which
telomer
products
may
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.
TRP
urged
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
would
include
PFOA
manufacture
and
use,
the
potential
contribution
by
discontinued
PFOS­
based
products,
and
telomers.

°
The
Fluoropolymer
Manufacturers
Group
(
FMG)
of
the
Society
of
the
Plastics
Industry
(
SPI)
stated
that
it
is
committed
to
working
with
the
EPA
to
define
the
routes
of
exposure
to
the
public
and
the
environment;
to
characterize
the
health
implications
of
that
exposure;
and
to
significantly
reduce
the
potential
exposure
sources
from
the
fluoropolymer
industry.
FMG
also
noted
that
fluoropolymers
have
many
important
uses
in
a
wide
variety
of
vital
industries,
and
that
PFOA
is
an
indispensable
polymerization
aid
in
the
manufacture
of
those
products.

Discussion
EPA
provided
a
brief
overview
of
the
Preliminary
Framework
document
that
was
circulated
to
interested
parties
and
placed
in
the
docket
on
May
21,
2003
(
OPPT­
2003­
0012­
U.
S.
Environmental
Protection
Agency
June
16,
2003
3
0056).
In
the
discussions
that
followed,
agreement
in
principle
was
reached
on
most
of
the
EPA
data
needs
described
in
the
Preliminary
Framework,
and
it
was
agreed
that
further
discussion
of
these
data
needs
should
occur
in
three
technical
workgroups.
The
technical
workgroups
were
tasked
to
work
out
the
technical
details
of
testing
and/
or
reporting
programs
for
the
agreed­
upon
data
needs
that
can
be
developed
into
ECAs.
The
initial
task
set
for
each
workgroup
was
to
receive
a
detailed
briefing
from
industry
on
the
specifics
of
the
commitments
covered
by
the
industry
Letters
of
Intent
(
LOIs),
and
to
determine
what
details
beyond
the
terms
of
the
LOIs
should
be
negotiated
through
the
workgroups
as
part
of
the
ECA
process.
A
fourth
workgroup
was
tasked
to
develop
a
roadmap
for
addressing
confidential
business
information
(
CBI)
and
proprietary
information
within
the
ECA
discussions
for
PFOA
and
the
telomers,
as
it
relates
to
market
information
(
data
need
number
1
in
Tables
I
and
II
of
the
EPA
Preliminary
Framework),
test
substances,
and
article
identity.
Draft
ECA
products
from
the
workgroups
will
be
brought
back
to
the
Plenary
Group
for
discussion
and
concurrence.

The
four
technical
workgroups
and
their
participants
and
focus
are:

°
Confidential
Business
Information
(
CBI)
Workgroup
Participants:
EPA,
the
Consumer
Product
Safety
Commission
(
CPSC),
3M,
the
Environmental
Working
Group
(
EWG),
the
Fluoropolymer
Manufacturers
Group
(
FMG),
the
Telomer
Research
Program
(
TRP),
and
the
Tuppers
Plains­
Chester
Water
District.

Objective:
Develop
a
roadmap
to
meaningfully
communicate,
within
the
PFOA
ECA
process,
information
regarding
marketing
data,
test
substance(
s),
and
article
identity
in
a
way
that
preserves
proprietary
information
and
satisfies
the
needs
of
EPA
and
the
interested
parties.

°
Environmental
Monitoring
Workgroup
Participants
:
EPA,
3M,
EWG,
FMG,
TRP,
the
Little
Hocking
Water
Association,
environmental
consultants
Bennett
&
Williams,
the
WV
Class
Action
Plaintiffs
group,
the
National
Center
for
Policy
Research
for
Women
and
Families,
consulting
toxicologist
Rich
Purdy,
and
the
Tuppers
Plains­
Chester
Water
District.

Objective:
To
develop
ECA
proposal(
s)
for
screening­
level
environmental
monitoring
of
PFOA
and
PFOA
precursors
as
identified
by
the
Plenary
Group.
The
initial
focus
will
be
for
data
needs
identified
in
item
10
of
Table
I
and
item
10
of
Table
II
of
the
EPA
Preliminary
Framework
document,
specifically
addressing
environmental
sampling
and
monitoring
in
the
vicinity
of
telomer
and
fluoropolymer
manufacturing
and
use
facilities.
The
interested
parties
were
U.
S.
Environmental
Protection
Agency
June
16,
2003
4
supportive
of
using
the
existing
3M
and
DuPont
analytical
protocols
and
sampling
methods
as
a
starting
place
to
develop
analytical
protocols
and
sampling
methods
specifically
addressing
PFOA
data
needs
under
the
ECA.
In
addition,
the
Workgroup
will
develop
considerations
for
site
selection
in
monitoring
studies.

°
Fluoropolymer
Workgroup
Participants:
EPA,
CPSC,
3M,
FMG,
EWG,
and
Bennett
&
Williams.

Objective:
To
develop
ECA
proposal(
s)
for
data
needs
identified
in
items
2,
7,
8,
9
and
11
of
Table
II
in
the
EPA
Preliminary
Framework
document,
specifically
addressing:
(
a)
the
physical/
chemical
(
p­
chem)
properties
of
the
fluoropolymers;
(
b)
the
presence
of
PFOA
emitted
from
fluoropolymer­
treated
products
and
articles
as
they
age
during
use
for
those
products
and
articles
not
included
in
the
LOI
commitments;
(
c)
determining
the
incineration
byproducts
of
fluoropolymers
and
fluoropolymer­
treated
articles
and
determining
the
p­
chem,
fate,
and
transport
properties
of
those
byproducts;
and
(
d)
product
stewardship
information.

°
Telomer
Workgroup
Participants:
EPA,
CPSC,
3M,
EWG,
TRP,
and
Rich
Purdy.

Objective:
To
develop
ECA
proposal(
s)
for
telomers
and
telomer­
treated
products
as
identified
by
the
Plenary
Group.
The
initial
focus
will
be
for
the
data
needs
identified
in
items
2,
3,
4,
5,
6,
7,
8,
9,
and
12
of
Table
I
of
the
Preliminary
Framework
document
prepared
by
EPA,
specifically
addressing:
(
a)
P­
chem
properties
to
inform
fate
testing
for
telomer
chemicals
not
included
in
the
industry­
sponsored
LOI;
(
b)
elucidation
of
degradation
pathways
and
identification
of
degradation
products;
(
c)
determination
of
p­
chem,
fate
and
transport
properties
of
major
degradation
products;
(
d)
determination
of
incineration
byproducts
of
telomers
and
telomer­
treated
products
and
articles;
(
e)
determination
of
p­
chem,
fate
and
transport
properties
of
major
incineration
byproducts;
(
f)
presence/
quantification
of
PFOA
precursors
in
telomer
chemical
products
and
in
telomer­
treated
or
telomer­
containing
products
and
articles;
(
g)
presence
of
PFOA
precursors
emitted
from
telomer­
treated
products
and
articles
as
they
age
during
use;
and
(
h)
product
stewardship
information.

Agreement
in
principle
was
not
reached
on
several
data
needs
identified
in
the
EPA
Preliminary
Framework,
and
these
will
receive
additional
discussion
in
the
Plenary.
These
include
the
need
for
data
assessing
the
potential
biodegradation
products
and
pathways
of
fluoropolymers,
and
conducting
a
release
and
exposure
assessment
for
PFOA
and
PFOA
precursors
from
telomer­
based
fire
fighting
foams.
With
respect
to
the
first
set
of
issues,
the
U.
S.
Environmental
Protection
Agency
June
16,
2003
5
FMG
indicated
that
fluoropolymers
are
not
expected
to
biodegrade.
The
Fire
Fighting
Foam
Coalition
(
FFFC)
indicated
that
it
is
in
the
process
of
collecting
information
concerning
fire
fighting
foam
releases,
principally
from
sites
managed
by
the
Department
of
Defense,
and
will
submit
that
information
to
the
Agency
as
it
becomes
available.
These
data
needs
will
be
the
subject
of
further
discussions
at
the
July
plenary
session.

Summary
of
Public
Comments
One
private
citizen
and
one
organization
made
oral
statements
during
the
public
comment
portion
of
the
meeting.
Della
Tennant,
a
West
Virginia
resident
owning
property
close
to
the
DuPont
Dry
Run
landfill
and
a
plaintiff
in
an
earlier
lawsuit
against
DuPont,
spoke
about
her
own
experiences
and
described
health
problems
recounted
to
her
by
other
members
of
the
community.
She
asked
EPA
to
take
action
to
resolve
the
PFOA
water
contamination
issues.
Diana
Zuckerman
of
the
National
Center
for
Policy
Research
for
Women
and
Families
encouraged
EPA
to
look
for
patterns
in
the
problems
that
people
were
reporting
and
to
make
certain
that
the
ECA
process
would
balance
all
customer
needs
and
apply
scrutiny
to
all
sides
of
the
issues.
The
Center,
which
had
not
previously
registered
as
an
interested
party,
expressed
the
desire
to
participate
on
the
Monitoring
Workgroup,
and
was
accorded
interested
party
status.

EPA
indicated
that
anyone
who
wished
to
augment
an
opening
statement
or
other
comments
could
submit
their
additional
materials
to
the
docket
within
ten
days
of
the
meeting,
preferably
through
direct
electronic
submission
to
the
online
docket.

Next
Steps
EPA
noted
that
the
urgency
of
the
PFOA
ECA
process
to
develop
PFOA
source
and
environmental
fate
and
exposure
pathway
data
will
require
a
tight
schedule
for
follow­
up
meetings.
EPA
pledged
to
make
every
effort
to
keep
the
interested
parties
informed
through
meeting
summaries
submitted
to
the
electronic
docket
for
this
action,
and
by
scheduling
meetings
with
an
eye
to
reducing
travel
and
making
teleconferencing
available
whenever
possible.
The
Plenary
Group
developed
a
schedule
for
the
next
meetings
under
the
ECA
process.

Initial
Technical
Workgroup
meetings
will
be
scheduled
at
EPA
Headquarters
in
Washington,
DC
during
the
weeks
of
June
16
or
June
23,
2003.
Teleconference
facilities
will
be
available
for
those
who
cannot
attend
the
meeting
in
person.
The
workgroups
will
have
another
opportunity
to
meet
in
person
in
Washington,
DC
on
Wednesday,
July
9,
2003.
The
next
plenary
session
will
be
held
on
Thursday,
July
10,
2003.
Topics
to
be
discussed
at
the
July
Plenary
session
will
include:
(
1)
reports
from
the
Workgroups;
(
2)
data
needs
identified
in
the
EPA
Preliminary
Framework
document
which
were
not
tasked
to
the
Workgroups
at
the
June
meeting;
and
(
3)
other
topics
as
appropriate.
Additional
workgroup
meetings
and
another
plenary
session
are
tentatively
scheduled
for
September,
2003.
