U.
S.
Environmental
Protection
Agency
June
20,
2003
Draft
Agenda
Telomers
ECA
Technical
Workgroup
Meeting
Tuesday,
June
24,
2003
1:
00­
4:
00
PM
Mission
Statement:
The
Telomer
Workgroup
will
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
pchem
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
telomertreated
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.

Meeting
Objective:
Scoping
meeting
to:
1.
Identify,
with
respect
to
each
of
the
data
needs
enumerated
above
in
the
EPA
Preliminary
Framework,
what
specific
portions
of
the
work
are
included
in
the
LOI
(
OPPT­
2003­
0012­
0013)
to
allow
all
workgroup
participants
to
understand
fully
what
is
included,
how
many
and
what
chemicals/
types
of
chemicals
are
covered,
what
tests
will
be
conducted,
what
protocols
will
be
used,
when
information
will
be
reported,
etc.
2.
Identify
activities
within
the
EPA
Preliminary
Framework
and
beyond
the
scope
of
the
LOI
which
may
be
appropriate
for
consideration
in
the
ECA
process.
3.
Identify
workgroup
next
steps
and
assignments.

Workgroup
Participants:
3M;
CPSC;
EPA;
EWG;
Rich
Purdy;
TRP
Order
of
Meeting:
°
Introductions:
Chair,
Phil
Oshida,
Director,
Chemical
Control
Division
EPA
Technical
Lead:
David
Lynch,
Economics,
Exposure,
and
Technology
Division
°
Industry
presentation
on
the
scope
of
LOI
activities
°
Identification
and
discussion
of
activities
within
the
EPA
Preliminary
Framework
beyond
the
scope
of
the
LOIs
which
may
be
appropriate
for
consideration
in
the
ECA
process
°
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
for
workgroup
and
plenary
meetings
on
July
9
and
10,
2003
PFOA
ECA
Telomer
Technical
Workgroup
Meeting
June
24,
2003
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Telomer
Technical
Workgroup
Meeting
June
24,
2003
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ECA
Telomer
Technical
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Meeting
June
24,
2003
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TRP
Telomer
Research
Program
Letter
of
Intent
Commitments,

ECA
Framework
Discussion
and
ECA
Candidate
Additions
24
June
2003
2003­
06­
23/
24,
page
2
Telomer
Research
Program
TRP
Presentation
Outline

TRP
Background

Letter
of
Intent
(
LOI)
Perspectives,
Objectives
and
Approach

LOI
Commitments
Outline
and
ECA
Framework
Cross
Reference

LOI
Elements
Review

Next
Steps
2003­
06­
23/
24,
page
3
Telomer
Research
Program
The
Telomer
Research
Program
is
...


a
Science­
Focused
research
consortium
formed
in
August
2000
and
funded
under
a
contractual
agreement

Asahi
Glass
(
Japan),
Clariant
(
Germany),
Daikin
Industries
(
Japan),
and
DuPont
(
USA)


administered
by
the
RAND
Corporation
(
USA)
2003­
06­
23/
24,
page
4
Telomer
Research
Program
The
Telomer
Research
Program
 .


Was
founded
three
years
ago
in
response
to
the
need
to
develop
data
on
telomer
products

Developing
test
methods
and
protocols
that
can
be
used
by
member
companies
in
studies
on
their
own
products

Conducting
its
research
program
with
a
focus
on
three
parallel
workstreams
toxicology,
pharmacokinetics,
and
environmental
fate
and
effects
studies.


Developing
the
sophisticated
analytical
techniques
required
to
study
these
types
of
compounds
in
complex
matrices.


Has
this
year
refocused
on
creating
and
carrying
out
the
commitments
of
the
TRP
LOI
2003­
06­
23/
24,
page
5
Telomer
Research
Program
TRP
Perspectives

TRP
member
companies
do
not
add
or
use
PFOA
in
their
Telomer­
based
products
and
processes

Exposure
to
PFOA
in
the
workplace
from
Telomer­
based
products
is
therefore
expected
to
be
extremely
small

Environmental
releases
from
Telomer­
based
processes
are
also
expected
to
be
extremely
small

Therefore
the
focus
for
the
Telomer
LOI
efforts
is
on
potential
transformation
in
the
environment
2003­
06­
23/
24,
page
6
Telomer
Research
Program
TRP
LOI
Overall
Program
Objectives

Investigate
the
potential
formation
and/
or
release
of
perfluorooctanoic
acid
(
PFOA)
from
Fluorotelomer­
based
polymeric
products
and
consumer
articles
treated
with
such
products
and
from
manufacturing
operations
making
or
using
these
products

Better
understand
telomer­
based
polymeric
product
environmental
fate
and
disposal
2003­
06­
23/
24,
page
7
Telomer
Research
Program
TRP
Approach
to
the
LOI
and
ECA
Processes

Focuses
on
relevant
releases
and
exposures
during
the
life­
cyle
of
telomer­
based
products
and
articles

Focuses
on
fate
and
monitoring
studies
based
on
release
and
exposure
analyses
and
considerations

Considers
testing
and
measurements
in
an
iterative
step­
wise
approach
triggered
by
improved
knowledge
gained
2003­
06­
23/
24,
page
8
Telomer
Research
Program
TRP
Overall
Meeting
Objectives
for
23­
24
June
`
03

Insure
that
EPA
and
Other
Interested
Parties
have
a
clear
idea
of
what
is
covered
and
planned
in
each
LOI
item,
status
of
each
item,
and
next
steps

Seeking
public
input
on
the
scope
of
the
TRP
LOI
and
potential
additions

Items
we
can
identify
to
define
as
part
of
the
ECA
and
not
compromise
our
LOI
efforts
2003­
06­
23/
24,
page
9
Telomer
Research
Program
TRP
LOI
Commitments
Outline:

Potential
Future
Sources
of
PFOA*

Product
and
Article
Analysis
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles
Commercial
Items
Commercial
Manufacture
Potential
PFOA
Release
from
Article
Manufacture
Potential
PFOA
Release
from
Product
Manufacture
+
Biodegradation
Analysis
of
Polymeric
Products
Fate
Incineration
Analysis
+

and
*
Analyses
on
Polymeric
Products
for
Carpet,
Textile,
and
Paper
Segments
Most
of
these
analyses
will
be
done
in
parallel,
not
sequential
2003­
06­
23/
24,
page
10
Telomer
Research
Program
Telomer
ECA
Item
Number
Description
­
Brief
Captured
in
LOI;
Location
1
Market
Information
Yes;
Item
#
1
2
P­
chem
Properties
Yes;
In
Related
Activities
3
Degradation
Pathways
and
Products
Yes;
Items
#
5
&
In
Related
Activities
4
P­
chem
of
Degradation
Products
TBD
5
Incineration
Byproducts
Yes;
Item
#
6
6
P­
chem
of
Incineration
Byproducts
TBD
7
Presence
of
PFOA
and
precursors
in
Telomer
Products
Yes;
Item
#
1
8
Presence
of
PFOA
and
precursors
in
Telomer
Articles
Yes;
Item
#
1
9
Product
"
Aging"
and
"
In­
use"
Articles
Yes;
Item
#
2
10
Release
and
Exposure
in
Telomer
Products
Yes;
Items
#
3&
4
11
Release
and
Exposure
in
Fire
Fighting
Foams
No;
FFFC
12
Product
Stewardship
Yes;
In
Related
Activities
TRP
LOI
vs.
ECA
Framework
Table
1
Cross
Reference
2003­
06­
23/
24,
page
11
Telomer
Research
Program
ECA
Framework
Item
#
1,
LOI
#
1
Comprehensive
Telomer
market
information:
CAS
Numbers;
Chemical
Names;

Synthetic
Sequences;
Production/
Import
Volumes;
Uses/
Applications
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
Provide
above
information
to
EPA
by
each
member
company
under
CBI
via
documents
and
presentations
LOI
All
detailed
and
comprehensive
information
already
provided
to
EPA
under
LOI
2003­
06­
23/
24,
page
12
Telomer
Research
Program
ECA
Framework
Item
#
2,
LOI
­
In
Related
Activities
P­
chem
properties
to
inform
fate
testing
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
Telomer
8­
2
alcohol
is
studied
under
all
the
suggested
test
methods.
LOI
pH
dependent
hydrolysis
work
submitted
and
TRP
will
provide
specific
gravity
data
2003­
06­
23/
24,
page
13
Telomer
Research
Program
ECA
Framework
Items
#
3/
4,
LOI
#
5
and
In
Related
Activities
Elucidation
of
degradation
pathways
and
identification
of
degradation
products
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
TRP
has
committed
to
analyze
degradation
of
12
representative
polymer
products
used
prevalently
in
carpet,
textile,
and
paper
enduse
markets.
Inherent
biodegradation
studies
looking
for
PFOA.
LOI
None
at
this
time.
Re­
evaluate
based
on
results
from
degradation,
release
estimate,

and
mill
pilot
study
work
TRP
is
conducting
biodegradation
studies
of
the
Telomer
8­
2
alcohol
to
determine
the
potential
for
PFOA
formation
LOI
None
at
this
time.
Re­
evaluate
based
on
results
from
degradation,
release
estimate,

and
mill
pilot
study
work
Framework
Item
#
4
is
not
addressed
in
the
LOI.
TBD.
Focus
is
PFOA
None
at
this
time.
Re­
evaluate
based
on
results
from
degradation,
release
estimate,

and
mill
pilot
study
work
2003­
06­
23/
24,
page
14
Telomer
Research
Program
ECA
Framework
Items
#
5/
6,
LOI
#
6
Determination
of
incineration
byproducts
of
telomers
and
telomer
treated
products
and
articles
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
TRP
has
agreed
to
study
the
applicability
of
incineration
to
its
Telomer­
treated
products
and
related
articles
in
the
US
in
a
"
desk
study"

­
Initial
steps
will
be
to
first
understand
the
US
disposal
methods
and
in
what
markets
incineration
is
applicable
­
Second
review
the
US
incinerator
conditions
to
understand
permitted
temperatures
and
compare
with
known
Telomer
degradation
temperatures
ECA
The
"
desk
study"
will
define
the
scope.
The
design
of
the
study
and
nature
of
the
methodology
needs
to
be
discussed
to
measure
PFOA
emissions
from
incineration
of
treated
articles
Framework
Item
#
6
is
not
addressed
in
the
LOI.
TBD
2003­
06­
23/
24,
page
15
Telomer
Research
Program
ECA
Framework
Items
#
7/
8,
LOI
#
1
Presence
of
PFOA,
Telomer
8­
2
alcohol,
and
other
precursors
in
telomer­
based
products
and
treated
articles
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
Analyze
for
PFOA
in
each
of
the
12
polymeric
products.
Method
development
underway.
LOI
Analyze
for
Telomer
8­
2
alcohol
in
the
cited
products.
A
validated
method
for
alcohol
analysis
will
need
to
be
developed.

Analyze
for
PFOA
in
each
of
the
treated
articles
­
carpet,
textile,

paper
­
using
the
12
polymeric
products.
Method
development
underway.
LOI
None
at
this
time.
Re­
evaluate
based
on
results
from
degradation,

release
estimate,
and
mill
pilot
study
work.

Fire
Fighting
Foams
are
not
part
of
the
TRP
LOI
2003­
06­
23/
24,
page
16
Telomer
Research
Program
ECA
Framework
Item
#
9,
LOI
#
2
Presence
of
PFOA,
Telomer
8­
2
alcohol,
or
other
potential
PFOA
precursors
emitted
from
"
aged"
products
and
"
in­
use"
telomer­
treated
articles
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
TRP
will
analyze
for
PFOA
in
"
aged"

products
initially
using
elevated
temperature
studies
LOI
Analyze
for
Telomer
8­
2
alcohol
in
the
cited
products.
A
validated
method
for
alcohol
analysis
will
need
to
be
developed.

TRP
will
analyze
for
PFOA
for
"
in­
use"

articles.
Studies
simulating
real
world
conditions
will
be
conducted.
LOI
Re­
evaluate
based
on
results
from
degradation,
release
estimate,
and
mill
pilot
study
work.

For
this
analysis,
"
aged"
means
the
storage
and
distribution
of
products
and
"
in­
use"
means
the
distribution
and
use
of
the
treated
articles
2003­
06­
23/
24,
page
17
Telomer
Research
Program
ECA
Framework
Item
#
11,
LOI
#
­
NA
Release
and
exposure
assessment
for
PFOA
and
PFOA
precursors
from
use
of
fire­
fighting
foams
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
Not
included
in
LOI.
Will
be
addressed
separately
by
Fire
Fighting
Foam
Coalition
in
next
Plenary
Session
on
10
July
`
03
NA
FFF
Fluoro­
additives
are
a
very
small
part
of
the
overall
global
manufacture
(
kgs),
are
largely
C­
6
based,

and
are
used
in
critical
life
saving
applications
2003­
06­
23/
24,
page
18
Telomer
Research
Program
ECA
Framework
Item
#
12,
LOI
In
Related
Activities
Product
Stewardship
information
concerning
telomer
products
and
articles
Summary
of
LOI
Commitments
LOI
or
ECA
for
Additional
Work?
Nature
of
Additional
Work
TRP
member
companies
have
agreed
to
confirm
compliance
of
their
stewardship
programs
with
SOCMA
guidelines.
NA
Documentation
of
Product
Stewardship
Programs
Develop
TRP
Safe
Handling
and
Use
Handbook
for
customer
review
 
by
August
/
September
2003
NA
2003­
06­
23/
24,
page
19
Telomer
Research
Program
TRP
LOI
vs.
ECA
Framework
Table
1
Review
Telomer
ECA
Item
Number
Description
­
Brief
Captured
in
LOI;
Location
1
Market
Information
Yes;
Item
#
1
2
P­
chem
Properties
Yes;
In
Related
Activities
3
Degradation
Pathways
and
Products
Yes;
Items
#
5
&
In
Related
Activities
4
P­
chem
of
Degradation
Products
TBD
5
Incineration
Byproducts
Yes;
Item
#
6
6
P­
chem
of
Incineration
Byproducts
TBD
7
Presence
of
PFOA
and
precursors
in
Telomer
Products
Yes;
Item
#
1
8
Presence
of
PFOA
and
precursors
in
Telomer
Articles
Yes;
Item
#
1
9
Product
"
Aging"
and
"
In­
use"
Articles
Yes;
Item
#
2
10
Release
and
Exposure
in
Telomer
Products
Yes;
Items
#
3&
4
11
Release
and
Exposure
in
Fire
Fighting
Foams
No;
FFFC
12
Product
Stewardship
Yes;
In
Related
Activities
2003­
06­
23/
24,
page
20
Telomer
Research
Program
Conclusions

TRP's
LOI
is
a
comprehensive
document
which
addresses
a
majority
of
the
specified
ECA
Framework's
Telomer
needs

The
most
expeditious
method
to
conduct
work
is
through
the
current
LOI

By
employing
a
technically
sound,
step­
wise
testing
approach,
all
parties'
interests
are
better
served
2003­
06­
23/
24,
page
21
Telomer
Research
Program
Next
Steps
