1
THE
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
PUBLIC
MEETING
ENFORCEABLE
CONSENT
AGREEMENT
DEVELOPMENT
FOR
PERFLUOROOCTANOIC
ACID
(
PFOA)
AND
FLUORINATED
TELOMERS
Friday,
June
6,
2003
[
12:
00
p.
m.]

ENVIRONMENTAL
PROTECTION
AGENCY
East
Building,
Room
1153
1201
Constitution
Avenue,
N.
W.

Washington,
D.
C.
20460
2
MEMBERS
OF
THE
PANEL
Oscar
Hernandez
Phil
Oshida
Charles
Auer
Ward
Penberthy
Mary
Ellen
Weber
Cathy
Fehrenbacher
3
1
P
R
O
C
E
E
D
I
N
G
S
2
3
MR.
OSHIDA:
Welcome
to
the
EPA's
public
4
meeting
concerning
data
development
through
5
enforceable
consent
agreements,
or
ECAs,
as
you
will
6
know,
to
identify
the
sources
of
perfluorooctanoic
7
acid
­­
PFOA,
also
known
as
C8
­­
in
the
environment,

8
and
the
pathways
leading
to
human
and
environmental
9
exposures.
I
would
like
to
thank
all
of
the
groups
10
and
individuals
who
have
registered
as
interested
11
parties
for
the
purpose
of
participating
in
these
12
negotiations.

13
I'm
Phil
Oshida,
Acting
Director
of
the
14
Chemical
Control
Division
in
the
EPA's
Office
of
15
Pollution
Prevention
and
Toxics,
and
I
will
be
16
chairing
this
meeting.

17
As
you
all
probably
realize,
this
meeting
is
18
being
recorded
and
transcribed
by
an
EPA
contractor.

19
The
verbatim
transcript
of
these
proceedings
will
be
20
placed
in
the
electronic
public
docket,
which
is
21
OPPT­
2003­
0012,
about
three
weeks
from
today.
We
will
22
also
prepare
a
short
summary
of
today's
discussions
to
4
1
place
in
the
public
record.
To
assist
in
ensuring
2
that
the
transcript
is
complete,
I'll
ask
that
all
3
speakers
use
the
microphone
that
our
staff
can
bring
4
to
you.

5
A
list
of
preregistered
attendees
is
available
6
now
at
the
registration
desk
area.
Please
make
7
certain
that
you
have
signed
in
at
the
registration
8
desk,
so
that
a
copy
of
the
complete
meeting
attendee
9
list
can
be
included
in
the
docket
next
week.
Because
10
we
have
so
many
people
in
attendance,
we
will
not
do
11
introductions
around
the
room
at
this
time.
A
couple
12
of
weeks
ago
we
had
intended
to
do
that,
but
with
the
13
large
number
here
we
decided
that
there
wouldn't
be
14
quite
enough
time.
When
we
enter
the
discussion
15
portions
of
the
meeting,
please
remember
to
introduce
16
yourself
with
your
name
and
your
affiliation.

17
Before
we
begin,
I
would
like
to
take
a
moment
18
to
offer
some
information
on
this
Toxic
Substances
19
Control
Act
Section
4
Enforceable
Consent
Agreement
20
process,
the
ECA
process
for
the
benefit
of
those
who
21
may
be
less
familiar
with
it,
and
to
put
things
in
22
context
for
the
record.
EPA
circulated
introductory
5
1
materials
in
two
email
messages
to
registered
parties
2
before
the
meeting,
including
a
short
background
3
document
on
the
ECA
process
and
one
example
of
a
4
simple
ECA
concluded
on
a
single
chemical.
Some
5
copies
of
these
materials
are
available
at
the
6
registration
desk
and
they
may
also
be
available
at
7
the
back
table.
If
there
aren't
enough
copies
8
available,
you
can
request
one
from
Annette
Washington
9
at
the
registration
desk,
and
we
will
send
it
to
you.

10
They
are
also
available
at
the
online
docket.

11
I
would
like
to
note
that
the
details
of
ECAs
12
that
will
be
developed
through
the
process
we
are
13
embarking
on
today
may
differ.
For
example,
as
an
14
initial
step
in
some
data
development,
we
may
need
to
15
adapt
existing
methods
to
meet
new
test
standards.

16
Such
an
ECA
would
likely
be
written
both
to
encompass
17
that
step
and
to
reflect
contingencies
based
on
the
18
results
of
those
tests.
EPA
anticipates
that
separate
19
ECAs
may
be
developed
to
cover
different
aspects
of
20
the
data
development
needs
that
the
Agency
has
21
identified
here,
and
multiple
ECAs
for
the
same
22
subject
may
be
needed
to
assure
no
breach
of
6
1
confidential
business
information,
or
CBI,
among
test
2
sponsors.
In
this
meeting
today,
we
hope
to
identify
3
opportunities
for
ECA
development,
to
identify
the
4
specific
parties
who
wish
to
actively
pursue
those
5
ECAs
and
set
the
schedule
and
format
for
future
6
meetings
as
may
be
needed
to
complete
this
work.

7
As
EPA
indicated
in
the
Federal
Register
notice
8
that
solicited
interested
parties
for
the
negotiation
9
of
ECAs,
the
goal
of
this
process
is
to
obtain
10
agreements
to
develop
data
to
clarify
the
sources
of
11
PFOA
in
the
environment
and
the
pathways
leading
to
12
exposure.
These
are
the
only
topics
which
will
be
13
addressed
in
this
meeting.

14
As
you
all
probably
know
there
are
activities
15
concerning
PFOA
currently
underway
in
other
forums.

16
Those
activities
including
private
lawsuits,
state
17
regulatory
actions,
independent
data
development
by
18
companies
and
industry
groups,
and
investigations
by
19
other
state
and
Federal
agencies.
Those
activities
20
are
not
the
subject
or
focus
of
this
meeting,
and
21
issues
that
properly
belong
in
those
other
forums
will
22
not
be
addressed
here.
For
example,
EPA
indicated
in
7
1
the
Federal
Register
notice
and
in
the
preparatory
2
materials
for
this
meeting
that
the
Agency
will
not
be
3
pursuing
additional
PFOA
toxicity
testing
or
blood
4
monitoring
through
the
ECA
process.
These
issues
are
5
beyond
the
scope
of
this
ECA
discussion.

6
Pharmacokinetics
studies
are
already
underway
7
in
the
private
sector,
and
EPA
has
nominated
PFOA
and
8
related
chemicals
to
the
Centers
for
Disease
Control
9
and
Prevention
as
candidates
to
include
in
the
next
10
National
Health
and
Nutrition
Examination
Survey,
the
11
NHANES
study.
One
criterion
that
CDC
uses
in
making
12
decisions
on
whether
to
include
a
chemical
in
NHANES
13
is
the
availability
of
validated
analytical
14
techniques.
CDC
has
adapted
published
3M
methods
for
15
high­
throughput
analyses,
as
required
by
NHANES,
and
16
CDC
is
currently
completing
their
validation
for
use
17
in
monitoring
human
serum
and
human
breast
milk.

18
Preliminary
results
of
this
work
will
be
submitted
for
19
presentation
to
the
Dioxin
2003
conference,
and
when
20
completed,
the
method
will
be
published
in
the
peer
21
reviewed
literature.
Independently
of
the
CDC
22
activity,
3M
and
DuPont
are
also
jointly
pursuing
8
1
validation
of
these
methods,
and
will
publish
their
2
work
in
peer
reviewed
journals.
EPA
sees
no
need
to
3
duplicate
any
of
these
activities
in
this
ECA
process.

4
CDC
will
be
making
a
decision
in
the
next
few
5
months
about
whether
to
add
perfluorinated
compounds
6
to
NHANES,
and
whether
it
may
be
able
to
screen
serum
7
bank
samples
from
the
1999­
2000
sampling
for
the
8
presence
of
selected
perfluorinated
chemicals.
When
9
CDC
announces
that
decision,
EPA
will
place
that
10
announcement
in
the
public
record
for
this
proceeding
11
to
ensure
that
interested
parties
are
informed.

12
Separate
from
this
ECA
process,
EPA
is
13
continuing
efforts
to
refine
a
preliminary
risk
14
assessment
on
PFOA,
as
indicated
in
the
Federal
15
Register
notice.
A
further
developed,
revised
version
16
of
the
preliminary
risk
assessment
will
be
submitted
17
to
the
EPA's
Science
Advisory
Board
for
review
later
18
this
year,
in
a
public
process
that
will
allow
for
the
19
consideration
of
issues
specific
to
that
assessment.

20
Accordingly,
EPA
will
not
discuss
its
preliminary
21
assessment
in
the
context
of
these
ECA
proceedings.

22
The
Agency
believes
that
as
a
general
matter,
9
1
when
we
engage
in
dialogue,
despite
differences,
the
2
ECA
process
benefits
government,
industry,
and
other
3
interested
parties
by
expediting
the
development
of
4
the
needed
information
and
by
guaranteeing
public
5
access
to
the
data.
However,
this
does
not
mean
that
6
this
negotiation
process
is
a
totally
open
forum.

7
There
are
a
few
important
considerations
to
keep
in
8
mind.

9
First,
information
which
is
claimed
as
10
confidential
business
information,
under
Toxic
11
Substances
Control
Act,
will
not
be
discussed
in
any
12
public
meeting.
Parties
are
reminded
to
observe
13
proper
procedures
in
submitting
any
CBI
information
to
14
the
Agency.
All
CBI
claims
concerning
information
15
submitted
as
part
of
this
ECA
process
may
require
16
formal
substantiation.

17
The
only
aspects
of
an
ECA
that
are
negotiable
18
relate
to
the
specifications
and
details
of
the
19
subject
testing
program.
Examples
of
this
would
be
20
the
Subject
Test
Substance,
the
Scope
of
the
Testing
21
Program,
and
the
Description
of
the
Testing
Program.

22
Mandatory
standard
language
which
establishes
10
1
enforceability
in
the
ECA
are
not
open
to
negotiation.

2
Examples
of
such
standard
language
include
the
3
sections
on
compliance
monitoring,
enforcement,

4
protocol
modifications,
compliance
with
Good
5
Laboratory
Practices,
export
notification,
and
6
disclosure
of
test
results.
Although
some
differences
7
may
exist
in
views
on
the
testing
needs
expressed
by
8
EPA,
I
am
confident
that
we
can
work
cooperatively
9
together
and
reach
a
successful
agreement
in
principle
10
on
the
framework
of
one
or
more
ECAs
within
a
period
11
of
four
months
from
today's
meeting.

12
We
requested
that
interested
parties
wishing
to
13
make
opening
statements
either
make
them
in
writing,

14
or
specifically
request
time
in
advance
for
a
brief
15
statement.
The
Telomer
Research
Program
and
the
16
Society
of
Plastics
Industry
have
provided
a
written
17
version.
Six
parties
requested
time
to
make
brief
3
18
to
5
minute
verbal
statements,
and
they
have
been
19
listed
on
the
agenda
in
the
order
in
which
their
20
requests
were
received.
The
Center
for
Regulatory
21
Effectiveness
will
begin.
Mr.
Slaughter?

22
MR.
SLAUGHTER:
Thank
you
for
the
opportunity
11
1
to
comment.
My
name
is
Scott
Slaughter
and
I
2
represent
The
Center
for
Regulatory
Effectiveness.

3
CRE
has
particular
interest
in
this
proceeding
in
that
4
we
think
the
greater
the
number
of
significant
issues
5
under
the
new
Data
Quality
Act
and
under
EPA
data
6
quality
guidelines.
We
agree
with
EPA
that
additions
7
in
the
current
data
base
inadequately
assess
the
risk
8
of
PFOA.
We
agree
that
additional
testing
is
9
necessary
in
order
to
produce
a
risk
assessment
and
10
disseminate
the
risk
assessment
that
complies
with
11
Data
Quality
Act
and
the
general
physical
(
inaudible).

12
And
we
won't
get
the
(
inaudible)
Data
Quality
Act
13
requires
that
any
data
assumed
about
EPA
in
context
be
14
based
on
tips
that
they
be
accurate,
reliable,
and
15
reproduceable,
and
we
also
want
data.
EPA
cannot
16
exhibit
any
original
assessment
that
meets
Data
17
Quality
Act
standards
unless
the
data
validly
18
demonstrates
to
be
accurate,
reliable,
reproduceable,

19
and
we
believe
based
upon
our
review
of
the
record
20
that
that
demonstrates
to
nothing
made
in
numerous
21
respects.
Thank
you.

22
MR.
OSHIDA:
Thank
you,
Mr.
Slaughter.
Little
12
1
Hocking
Water
Association,
Robert
L.
Griffon.

2
MR.
GRIFFON:
Good
afternoon,
everyone.
My
3
name
is
Bob
Griffon.
I
am
the
General
Manager
of
the
4
Little
Hocking
Water
Association.
I
would
like
to
5
thank
the
EPA
for
the
opportunity
to
comment
this
6
afternoon.
What
I
would
like
to
do
is
share
our
7
perspective
on
C8
contamination
as
proved
in
our
water
8
supply.
To
the
best
of
my
knowledge,
our
water
system
9
has
the
highest
C8
levels
of
any
other
water
system
in
10
this
country,
if
not
in
the
world.
Currently
on
a
11
daily
basis
we're
supplying
water
to
our
customers
12
that
has
a
C8
level
of
two
parts
per
billion
­­

13
MR.
AUER:
Could
you
pull
the
microphone
closer
14
to
you?

15
MR.
GRIFFON:
Basically
we
have
a
C8
level
of
16
two
parts
per
billion,
this
is
twice
the
historic
17
DuPont
community
special
guideline
of
one
part
per
18
billion.
We're
located
in
Washington
County,
Ohio,

19
our
well
field
is
along
the
Ohio
River,
it
is
directly
20
across
from
the
DuPont
Plant,
Washington
Works,
in
21
Washington
County,
West
Virginia.
For
those
who
­­

22
AUDIENCE
MEMBER:
We
still
can't
hear
you.
13
1
MR.
GRIFFON:
Basically
we're
located
in
2
Washington
County,
Ohio.
We
are
(
inaudible)
to
about
3
12,000
people.
Our
water
wells
are
located
along
the
4
Ohio
River
in
Washington
County,
Ohio.
On
the
other
5
side
of
the
river
directly
across
from
us
is
the
6
DuPont
Washington
Works
Plant
in
Wood
County,
West
7
Virginia.
The
way
the
wind
blows
from
the
plant
8
basically
is
toward
our
well
field.
Last
year
DuPont
9
discharged
a
total
of
about
20,000
pounds
of
C8
into
10
the
air
and
water.
We're
not
the
only
Ohio
water
11
system
that's
affected,
we
have
water
systems
upstream
12
and
downstream
from
our
location
that
have
C8
13
contaminating
their
water
supplies.
For
example,
the
14
Tuppers
Plains­
Chester
Water
District,
they're
located
15
about
15
miles
downstream
from
us
and
they're
also
16
contaminated
with
C8
as
well.
One
of
the
goals
of
17
this
C8
investigation
is
to
understand
how
the
general
18
public
is
being
exposed
to
C8.
Unfortunately
in
our
19
case
we
already
know
some
of
the
pathways
of
how
20
people
in
our
community
are
being
exposed.
Twenty
21
years
ago
DuPont
knew
C8
contaminated
our
water,
we
22
didn't
find
out
until
about
a
year
and
a
half
ago.
14
1
Since
then
we've
learned
that
C8
not
only
contaminates
2
our
water,
it
contaminates
our
air
and
our
soil
as
3
well.
I
was
taking
water
samples
from
our
well
field,

4
we
found
C8
levels
as
high
as
8.6
parts
per
billion
in
5
one
of
our
production
wells.
This
number
goes
up
in
6
the
test
scoring.
We
found
78
parts
per
billion
in
7
the
test
scoring
that
was
done
in
our
well
field.

8
Also
the
soil
sample
we
found
levels
as
high
as
170
9
micrograms
per
kilogram.
It
is
now
apparent
to
us
10
that
our
community
has
probably
been
at
a
normal
11
exposure
to
this
chemical
for
more
than
50
years.

12
It
is
my
understanding
that
the
EPA
will
not
13
pursue
human
biomonitoring
through
the
ECAs
that
we're
14
discussing
today.
Even
so,
the
EPA
recognizes
that
15
the
population
living
near
industrial
sites
may
have
16
­­
there's
a
possibility
that
the
C8
in
their
blood
17
level
is
higher
than
the
general
population.
Based
on
18
a
chart
developed
by
DuPont
there
have
been
newspaper
19
articles
suggesting
that
people
in
our
community
have
20
higher
C8
levels
in
their
blood
than
even
DuPont's
own
21
workers.

22
Therefore
I
recommend
that
in
the
future
our
15
1
community
should
be
a
part
of
the
sampling
group,
not
2
only
are
we
exposed
to
the
products
that
the
general
3
population
uses
nationwide,
but
we're
also
exposed
4
through
the
very
water
we
drink,
our
air,
our
soil.

5
Unfortunately
we're
a
ready­
made
study
group.
We
6
probably
have
the
most
exposure
of
anybody
in
the
7
country.

8
Under
the
West
Virginia
Consent
Order
the
C8
9
screening
level
are
150
parts
per
billion
in
water
was
10
established,
however
the
very
industry
that
11
contaminated
our
water,
our
air,
our
soil
was
heavily
12
involved
in
this
consent
order
process.
As
a
result,

13
based
on
newspaper
polls
the
majority
in
our
community
14
do
not
have
faith
in
a
150
parts
per
billion
number.

15
Because
of
the
controversy
surrounding
this
issue
we
16
feel
there's
a
need
for
a
study
of
the
problem
that
is
17
truly
independent
of
industries
that
have
interest
in
18
the
outcome,
so
the
residents
of
our
community
have
19
assurance
of
the
quality
of
their
air
and
water.

20
Therefore
we
are
requesting
that
we
not
be
21
forgotten
in
this
investigative
process
with
the
EPA's
22
undertakers.
People
in
our
community
and
other
16
1
communities
along
the
Ohio
River
are
drinking
water
2
every
day
that
has
C8
in
it.
They're
drinking
it
3
without
truly
knowing
what
the
health
effects
are
to
4
them,
their
children,
their
grandchildren
are,
so
5
please
do
not
forget
us,
please
give
us
data
and
6
information
that
we
can
have
confidence
in.
Thank
7
you.

8
MR.
OSHIDA:
The
Environmental
Working
Group
9
represented
by
Kristina
Thayer.

10
MS.
THAYER:
Hi,
good
afternoon,
my
name
is
11
Kristina
Thayer
from
Environmental
Working
Group.
The
12
Environmental
Working
Group
appreciates
the
13
opportunity
to
participate
as
an
interested
party
in
14
these
deliberations.
We
commend
the
EPA
for
15
initiating
this
process
and
for
pursuing
an
16
enforceable
consent
agreement
or
ECA
to
obtain
basic
17
environmental
data
about
perfluorooctanoic
acid,
PFOA,

18
and
fluorinated
telomers.
It
is
a
testament
the
to
19
feebleness
of
America's
regulatory
safety
net
for
20
toxic
chemicals
that
the
Federal
government
has
had
to
21
resort
to
a
negotiated
consent
agreement
in
order
to
22
obtain
rudimentary
scientific
information
that
should
17
1
have
been
available
decades
ago
with
DuPont,
3M,
and
2
other
companies
that
have
managed
to
permanently
3
pollute
the
entire
biosphere
with
PFOA
and
other
4
fluorinated
chemicals.
These
are
chemicals
that
last
5
forever
in
the
environment
having
disturbing
raised
6
toxic
effects
in
numerous
species
of
laboratory
7
animals,
and
contaminate
virtually
all
human
blood
8
tested
in
recent
years
including
the
blood
of
infants
9
and
children.

10
Most
Americans
would
and
certainly
should
11
wonder
why
is
on
earth
it
took
almost
50
years
to
12
learn
that
popular,
heavily
advertised
brand
names
13
like
Teflon,
Scotchgard,
and
Stain
Master
are
14
synonymous
not
only
to
stain­
free
carpets,
non­
stick
15
pans,
and
water
repellant
furniture,
but
with
severe
16
essentially
permanent
pollution
on
a
planetary
scale.

17
We
hope
that
these
proceedings
will
lead
to
a
18
ban
on
PFOA
and
other
problematic
chemicals
in
the
19
family.
The
available
science
more
than
justifies
20
that
step.
But
we
also
hope
this
process
will
help
21
the
public
understand
why
the
government
doesn't
have
22
a
clue
about
these
problems
until
just
a
few
years
18
1
ago.
We
hope
these
proceedings
help
explain
why
2
DuPont,
3M,
and
other
science
companies
that
make
3
billions
of
dollars
selling
Teflon,
Scotchgard,
or
4
other
fluoro
chemicals
have
been
so
irresponsible
or
5
incompetent
in
assessing
and
acknowledging
their
6
impact
on
the
environment
and
human
health.

7
We
have
been
shocked
in
particular
by
recent
8
public
statements
from
DuPont
claiming
that
the
9
company
welcomes
regulatory
scrutiny
of
PFOA,
has
10
cooperated
eagerly,
and
fully
and
looks
with
favor
on
11
the
prospect
that
PFOA
might
at
last
be
regulated.

12
But
DuPont
was
neither
transparent
nor
cooperative
13
when
it
performed
secret
tests
20
years
ago
that
found
14
PFOA
contaminated
the
tap
water
of
communities
near
15
its
Parkersburg
Teflon
plant,
and
didn't
say
a
word
to
16
its
neighbors
or
regulators.
Internal
company
17
documents
show
that
DuPont
executives
were
so
18
concerned
about
corporate
liability
and
credibility
19
arising
from
PFOA
pollution
that
they
consider
an
20
in­
house
plan
to
eliminate
it
in
1984,
but
instead
of
21
eliminating
PFOA
pollution,
DuPont
more
than
doubled
22
it
by
1989.
Only
now
with
regulations
opting
is
19
1
DuPont
volunteering
to
curb
a
contaminate
that
will
2
constrict
the
environment
and
the
people
forever.

3
This
is
the
same
company
that
fearing
publicity
filed
4
a
secret
motion
in
a
West
Virginia
court
to
secretly
5
impose
a
temporary
restraining
order
that
would
6
prevent
a
lawyer
from
speaking
about
PFOA
at
a
7
previous
public
meeting
convened
by
EPA
three
years
8
ago.
In
fact,
DuPont
asked
that
the
attorney
not
even
9
be
allowed
to
respond
to
the
gag
order
before
it
was
10
secretly
imposed.
The
court
wisely
denied
the
11
restraining
order,
but
just
last
month
DuPont
was
12
sanctioned
by
the
same
court
after
acknowledging
that
13
its
lead
toxicologist
of
PFOA,
Gerry
Kennedy,
had
14
destroyed
documents
sought
by
2,000
plaintiffs
in
a
15
class
action
suit
alleged
from
tap
water
pollution.

16
DuPont's
efforts
at
corporate
damage
control
17
and
the
pollution
problems
they
were
meant
to
hide
or
18
minimize
are
a
shameful
chapter
in
the
history
of
19
America's
oldest
and
foremost
chemical
company.
3M's
20
behavior
was
only
marginally
better.
For
decades
the
21
company
ignored
clear
scientific
warning
signs
about
22
both
PFOA
and
PFA,
signs
of
persistence,
toxicity,
and
20
1
contamination
of
the
environment
and
people.
Just
2
recently
3M
said
it
will
replace
PFOs
with
another
3
persistent
chemical
in
the
same
family.
The
company
4
has
said
that
it
is
almost
nontoxic
reportedly
on
the
5
basis
of
some
40
health
studies
that
3M
is
hiding
6
under
the
shield
of
confidential
business
information.

7
We
agree
with
EPA's
emphasis
on
identifying
8
sources
of
exposure
and
not
further
defining
9
toxicological
properties
as
the
next
essential
step
in
10
characterizing
the
potentials
of
PFOA.
This
decision
11
reflects
the
Agency's
conclusion
that
current
levels
12
of
PFOA
in
human
blood
present
a
potential
major
13
public
health
risk.
We
agree
that
the
next
task
is
to
14
identify
the
sources
of
this
contamination.

15
Although
EPA
is
to
be
commended
for
quickly
16
initiating
the
ECA
process
and
expanding
the
focus
17
from
PFOA
to
include
both
PFOA
and
fluorotelomers,

18
several
points
present
in
the
preliminary
framework
19
document
concern
us.
First,
all
claims
that
PFOA
20
toxicity
or
exposure
data
are
confidential
business
21
information
must
be
denied.
If
sources
of
PFOA
are
22
kept
secret
then
the
public
will
lose
its
inherent
21
1
right
to
reduce
PFOA
voluntarily.
While
we
respect
2
legitimate
CBI,
we
urge
highly
judicious
use
of
CBI
3
privilege
and
a
great
respect
for
the
public's
right
4
to
know
the
sources
of
the
human
blood
pollutant.

5
Second,
DuPont
and
other
companies
must
submit
to
6
EPA
all
existing
health
and
exposure
data
relating
to
7
PFOA
and
the
telomers.
It
is
outrageous
that
in
8
important
worker
studies
such
as
finding
the
birth
9
defects
in
2
of
7
female
workers
exposed
to
PFOA
and
10
drinking
water
contamination
in
Little
Hocking,
Ohio,

11
were
not
submitted
to
EPA
by
DuPont,
but
only
became
12
public
through
litigation.

13
Third,
the
ECA
must
include
blood
monitoring
14
studies.
As
it
stands,
the
Agency
proposes
to
test
15
PFOA
levels
in
air,
water,
soil,
and
biota
near
16
manufacture
and
use
facilities
as
well
as
control
17
sites,
but
specifically
state
it
will
not
sample
blood
18
at
other
sites.

19
This
omission
will
seriously
undermine
the
20
entire
ECA
process
and
is
equivalent
to
entering
all
21
the
numbers
in
the
calculator
and
then
not
adding
them
22
up.
22
1
Finally,
we
urge
EPA
to
include
PFOA
exposures
2
from
heated
non­
stick
appliances
such
as
pans,
ovens,

3
microwave
parts,
and
irons
in
the
ECA
process.
There
4
are
literally
billions
of
non­
stick
pans
in
use
across
5
the
globe.
Temperatures
where
PTFE,
which
is
the
6
chemistry
underlining
nonstick
pans,
degrade
into
PFOA
7
can
easily
be
reached
in
the
kitchen,
for
example,
if
8
an
empty
pan
is
preheated
on
high
or
if
someone
pours
9
hot
water
in
the
pan.
The
widespread
use
of
non­
stick
10
cookware
and
the
degree
to
which
people
can
misuse
it
11
suggest
consumer
use
of
PTFE
can
be
a
source
of
PFOA
12
on
the
people
in
the
environment.

13
MR.
OSHIDA:
DuPont,
Dr.
Uma
Chowdhry.

14
DR.
CHOWDHRY:
Good
afternoon.
I'm
Dr.
Uma
15
Chowdhry
for
DuPont
Corporate
Research
and
Development
16
Laboratory
and
with
me
are
Mr.
Rich
Anguillo,
he
is
17
the
Vice­
President
and
General
Manager
of
our
fluoro
18
product
business,
and
Dr.
Robert
Ritchie,
he
is
our
19
Technical
Director
for
DuPont
Chemical
Solutions.
I
20
would
like
to
begin
by
thanking
the
Agency
for
21
providing
the
opportunity
for
DuPont
to
comment
on
the
22
enforceable
consent
agreement
development
process
for
23
1
perfluorooctanoic
acid
or
PFOA.

2
I
will
note
that
in
addition
to
my
statement
3
DuPont
also
responded
to
your
request
for
written
4
comments
and
submitted
those
to
you
for
consideration
5
on
the
16th
of
May.
We
do
recognize
that
there
have
6
been
many
questions
raised
by
EPA
and
others
about
the
7
potential
risks
associated
with
exposure
of
PFOA.
As
8
a
science
company,
DuPont
is
fully
committed
to
work
9
with
industry
to
address
those
questions,
to
10
investigate
both
past
and
current
potential
sources
of
11
PFOA
exposure,
to
further
reduce
exposure
(
inaudible),

12
and
to
provide
information
needed
to
allow
for
the
13
development
of
an
accurate
science­
based
assessment
of
14
any
of
this
exposed
by
PFOA.
Our
knowledge
of
the
15
compound
is
extensive
and
we
are
more
than
willing
to
16
continue
to
share
that
knowledge
with
the
Agency
and
17
the
public
throughout
the
ECA
development
process.

18
And
of
course
we
will
cooperate
with
the
Agency's
19
final
conclusion.

20
DuPont
is
a
company
with
a
200­
year
heritage
21
based
on
values
of
safety,
health,
and
environmental
22
stewardship,
very
high
ethical
standings,
and
a
24
1
commitment
to
treat
all
people
with
fairness
and
2
respect.
These
core
values
are
foremost
in
everything
3
we
do
as
a
company.
Consistent
with
these
values
we
4
very
much
respect
the
rights
and
desires
of
consumers
5
around
the
world
to
know
that
the
products
they
rely
6
on
and
use
are
safe.
Throughout
our
history
safety
7
has
been
our
first
priority
of
business.
We
are
8
passionate
about
the
safety
of
our
operations
and
our
9
products.
In
more
than
50
years
of
use
by
DuPont
and
10
others
there
have
been
no
known
adverse
human
health
11
effects
associated
with
PFOA.

12
Extensive
scientific
studies
indicate
that
13
current
PFOA
exposure
does
not
present
a
risk
to
14
humans
or
to
the
environment.
There
are
more
than
100
15
laboratory
and
employee
health
studies
on
PFOA,
many
16
of
which
have
been
peer
reviewed
and
published
in
the
17
open
literature.
These
studies
support
our
conclusion
18
that
PFOA
does
not
pose
a
risk
to
humans.
This
is
19
especially
important
given
the
potential
for
higher
20
levels
of
exposure
to
PFOA
that
may
result
in
an
21
occupational
setting.

22
We
believe
and
we
are
confident
that
PFOA
poses
25
1
no
danger
to
the
public
at
current
levels.
PFOA
is
a
2
biopersistent
compound,
it
does
not
bioaccumulate
in
3
the
environment
or
man.
PFOA
is
not
a
genotoxin
and
4
while
it
may
cause
cancer
in
laboratory
animals,
it
is
5
not
believed
to
be
a
human
carcinogen.
Based
on
the
6
scientific
evidence
that
is
available
to
us,
DuPont
7
does
not
consider
PFOA
to
be
a
developmental
toxin.

8
The
ECA
regulatory
process
should
be
based
on
9
high
quality
credible
scientific
data
and
should
10
include
a
complete
characterization
of
all
past
and
11
current
PFOA
exposure
levels.
We
are
confident
that
12
the
outcome
of
this
(
inaudible)
process
will
support
13
our
conclusion
that
the
compounds
and
products
14
involved
are
safe
for
their
intended
use.
In
2002,

15
DuPont
began
manufacturing
PFOA
in
the
U.
S.
after
3M,

16
our
domestic
supplier,
discontinued
production.

17
Today,
our
state­
of­
the
art
manufacturing
18
facility
employee
emissions
PFOA
technology
that
19
reduces
PFOA
emissions
by
more
than
99
percent
20
compared
to
emissions
from
previously
used
PFOA
21
manufacturing
technology.
This
is
the
distinction
we
22
are
truly
proud
of
and
have
openly
shared
the
new
26
1
technology
with
all
our
industry
colleagues.

2
Testing
is
conducted
to
insure
that
DuPont
3
products
that
use
PFOA
in
their
manufacture
are
safe
4
for
their
intended
use.
We
ensure
their
safety
to
5
consumers,
as
well
as
to
industry
customers
who
6
fabricate
or
use
our
products
and
the
ingredients
in
7
their
products.

8
On
April
14th
of
this
year
your
Agency
9
concluded
that
quote
"
EPA
does
not
believe
there
is
10
any
reason
for
consumers
to
stop
using
any
consumer
or
11
industrial
products"
unquote
containing
fluoropolymers
12
or
telomers
as
ingredients
because
of
questions
about
13
PFOA.
DuPont
agrees
and
supports
the
EPA's
position.

14
Lastly,
I
would
like
to
reaffirm
that
DuPont
is
15
fully
supportive
of
the
Agency's
leadership
to
conduct
16
a
scientifically
sound
risk
assessment
for
PFOA.
We
17
are
fully
supportive
of
the
Agency's
decision
to
18
convene
a
scientific
advisory
board
to
review
and
19
comment
on
the
Agency's
risk
assessment.
We
believe
20
that
EPA's
process
may
lead
to
regulation
that
will
21
assure
the
protection
of
the
public's
health
and
22
safety
while
allowing
the
continuing
use
of
PFOA
and
27
1
the
benefits
that
it
brings
to
society.

2
We
remain
confident
that
society
is
not
being
3
exposed
to
health
or
environmental
risks
from
4
potential
exposure
to
PFOA.
We
will
work
with
the
5
Agency
to
provide
any
information
we
can
to
assist
6
with
your
investigation.

7
Thank
you
for
your
attention.

8
MR.
OSHIDA:
The
Telomer
Research
Group,
Katie
9
Smythe.

10
MS.
SMYTHE:
Good
afternoon.
My
name
is
Katie
11
Smythe.
I
work
for
the
RAND
Corporation
and
serve
as
12
the
administrator
of
the
Telomer
Research
Program,

13
also
known
as
the
TRP.
As
the
TRP
administrator,
I
14
have
been
asked
by
the
member
companies
to
present
the
15
TRP's
opening
statement
summarizing
their
views.
The
16
TRP
members
would
like
to
thank
the
Agency
for
the
17
opportunity
to
comment
on
the
Enforceable
Consent
18
Agreement
development
process
for
PFOA.
TRP
is
a
19
science­
focused
research
consortium
funded
by
the
20
primary
global
fluorotelomer
manufacturers:
Asahi
21
Glass,
Clariant,
Daikin
Industries,
and
DuPont.
The
22
TRP
companies
produce
or
import
telomer­
based
products
28
1
into
the
United
States,
which
are
used
as
surface
2
protection
chemicals
and
specialty
fluoro­
additives
in
3
many
markets.

4
Individually,
the
member
companies
have
studied
5
fluorotelomer
products
for
more
than
40
years
and
are
6
firmly
committed
to
the
safe
manufacture
and
use
of
7
telomer­
based
products.
In
addition,
TRP
members
8
continue
to
affirm
that
these
products
are
indeed
safe
9
for
the
markets
in
which
they
are
used.
The
TRP
has
10
initiated
an
ambitious
program
to
develop
additional
11
data
on
the
environmental
fate
of
telomer­
based
12
products,
better
characterize
the
routes
of
13
environmental
release
and
human
exposure,
strengthen
14
product
stewardship,
and
take
additional
measures
to
15
reduce
or
prevent
exposure
wherever
new
data
suggest
16
that
such
changes
are
needed.

17
Telomer
products
are
not
made
from
PFOA,
nor
is
18
PFOA
added
during
the
manufacture
or
use
of
telomer
19
products.
However,
questions
have
been
raised
about
20
the
potential
for
telomer
products
to
transform
to
21
PFOA.
The
TRP
is
actively
working
to
address
these
22
questions
and
identify
the
relevant
routes
by
which
29
1
telomer
products
may,
in
fact,
transform
to
PFOA,
and
2
if
they
do,
to
what
extent
these
transformations
take
3
place
and
if
there
may
be
human
or
environmental
4
exposure
of
consequence.
The
TRP
is
committed
to
5
answer
EPA's
questions
and
participate
in
the
ECA
6
process.

7
Telomer­
based
products
and
articles
treated
8
with
these
products
provide
many
unique
and
9
irreplaceable
benefits
to
people
and
society.
The
10
telomer
products
provide
protection
that
significantly
11
extends
the
useful
lifetime
and
lessens
the
need
to
12
clean
textile
articles,
including
apparel,
upholstery,

13
and
carpeting.
In
specific
applications,
garments
14
treated
with
telomer
products
protect
military
and
15
healthcare
workers
from
chemical
agents
and
diseases
16
transmitted
through
blood,
such
as
HIV
and
hepatitis.

17
Telomer­
based
products
are
also
key
ingredients
in
18
fire
fighting
foam
formulations
and
are
unparalleled
19
in
their
ability
to
knock
down,
resist
burnback,
and
20
secure
an
enflamed
area
quickly
and
safely.

21
In
a
Letter
of
Intent
to
EPA,
the
TRP
members
22
outlined
a
voluntary
commitment
to
investigate
the
30
1
potential
association
between
PFOA
and
telomers,
and
2
continue
to
generate
data
in
a
timely
manner.
The
3
TRP
has
developed
a
staged
scientific
study
approach
4
focused
on
articles
treated
with
telomers
and
telomer
5
products
in
order
to
determine
their
potential
to
6
transform
or
break
down
into
PFOA.
The
TRP
is
7
utilizing
the
best
testing
and
methodology
practices
8
available.
The
members
believe
it
is
important
to
9
provide
the
EPA,
their
customers
and
the
public
with
10
scientific
data
on
the
products
that
they
purchase.

11
The
TRP
work
is
focused
on
three
major
end­
use
12
applications,
carpets,
textiles
and
paper.

13
For
the
work
underway,
analytical
method
14
development
has
been
a
substantial
challenge
due
to
15
the
unique
properties
of
the
telomer
substances
and
16
the
lack
of
methods
to
determine
low
levels
of
PFOA.

17
Current
experience
with
method
development
has
shown
18
us
that
standard
test
guidelines
are
not
always
19
suitable
and
need
significant
adaptations
to
develop
20
sound
data
and
methods.
TRP
is
now
sponsoring
work
at
21
several
contract
labs
to
develop
and
validate
22
analytical
methods
to
conduct
these
studies
on
31
1
products
and
articles.

2
The
TRP
members
fully
understand
that
EPA
has
3
questions
regarding
potential
exposure
pathways
of
4
PFOA.
The
member
companies
support
EPA's
efforts
to
5
assure
the
regulatory
process
is
based
on
high
6
quality,
credible
scientific
data
and
they
are
7
committed
to
providing
their
part
of
this
data
8
collection
in
a
timely,
efficient
and
responsible
9
manner.

10
Current
contributions
to
environmental
loadings
11
of
PFOA
provide
on
part
of
the
answer
to
EPA's
12
questions.
A
full
characterization
of
potential
13
routes
of
environmental
and
human
exposure
for
PFOA
14
should
include
all
past
and
current
sources
of
PFOA.

15
The
TRP
members
believe
that
the
ECA
process
should
16
include
products
that
have
been
discontinued,
but
are
17
still
in
commercial
use
and
available
in
the
18
environment
for
human
exposure.
Discontinued
19
PFOA­
based
products
and
past
PFOA
production
and
use
20
must
be
included
to
fully
and
accurately
reflect
21
current
environmental
and
human
exposure
potential.

22
TRP
member
companies
urge
EPA
to
take
a
comprehensive
32
1
and
holistic
approach
to
understanding
environmental
2
and
human
exposure
to
develop
a
risk
assessment
on
3
PFOA
and
its
salts
that
includes
PFOA
manufacture
and
4
use,
PFOS­
based
products,
and
telomers.

5
The
world
is
ever
evolving
and
so
are
science
6
and
our
understanding
of
it.
The
research
being
7
conducted
by
the
TRP
is
no
exception.
The
research
8
being
undertaken
requires
the
development
of
new
9
testing
standards
and
new
methodologies
that
will
10
result
in
further
understanding,
increased
awareness
11
and
the
continued
responsible
stewardship
of
12
telomer­
based
products.

13
The
member
companies
stand
by
their
substantial
14
and
aggressive
commitments
to
EPA,
described
in
our
15
Letter
of
Intent
and
in
the
comments
made
today.
The
16
TRP
members
are
committed
to
safe
handling
and
use
of
17
their
products
and
to
continue
their
comprehensive
18
research
program.
The
TRP
members
strongly
believe
19
the
end
result
of
this
research
program
will
be
new
20
knowledge
on
telomer­
based
products
and
chemistry
that
21
will
reaffirm
to
the
EPA,
customers
and
consumers
the
22
value
and
safety
of
telomer
products.
33
1
Thank
you
for
the
opportunity
to
comment.

2
MR.
OSHIDA:
The
Society
for
the
Plastics
3
Industry
Fluoropolymer
Manufacturers
Group,
Don
4
Duncan.

5
MR.
DUNCAN:
Good
afternoon.
I'm
Don
Duncan,

6
President
of
The
Society
of
the
Plastics
Industry
or
7
SPI,
the
Washington,
D.
C.­
based
trade
association
8
representing
the
U.
S.
Plastics
Industry.
I'm
here
9
today
to
speak
on
behalf
of
SPI's
Fluoropolymers
10
Manufacturing
Group
or
FMG,
which
includes
those
11
global
companies
that
use
PFOA
as
a
surfactant
to
12
produce
their
polymer
products.
The
FMG
appreciates
13
the
opportunity
to
participate
in
the
EPA
public
14
meeting
which
for
us
represents
a
continuation
of
a
15
process
begun
more
than
two
years
ago.

16
The
issue
that
brings
us
together
involves
data
17
that
has
been
submitted
suggesting
that
PFOA
has
been
18
found
in
the
U.
S.
blood
samples
and
appears
to
be
19
persistent
in
the
environment.
While
extensive
20
research
done
to
date
has
indicated
no
adverse
effects
21
on
human
health
or
the
environment
at
the
levels
22
indicated,
these
matters
of
course
are
of
concern
to
34
1
the
industry.

2
Consequently,
the
FMG
is
committed
to
working
3
with
the
EPA
to
define
the
routes
of
exposure
to
the
4
public
and
the
environment,
characterize
the
health
5
implications
of
that
exposure,
and
significantly
6
reduce
the
potential
exposure
sources
from
the
7
fluoropolymer
industry.

8
Today's
meeting
is
an
important
part
of
that
9
process
whose
outcome
we
believe
will
produce
the
10
mutually
beneficial
result
of
ensuring
continued
11
protection
of
human
health
and
the
environment,

12
without
disrupting
the
supply
of
essential
materials
13
or
causing
undue
adverse
impact
on
an
important
14
segment
of
the
U.
S.
industry.

15
This
issue
is
extremely
important
and
16
significant
to
the
FMG
because
PFOA
is
an
17
indispensable
polymerization
aid
in
the
manufacture
of
18
its
products.
In
previous
meetings
with
the
EPA,
FMG
19
has
defined
its
considerable
efforts
to
find
a
20
substitute
for
PFOA.
While
there
has
been
some
21
limited
success
in
finding
alternatives
for
niche
22
products,
to
date
there
has
been
no
discovery
of
a
35
1
universal
replacement
for
PFOA
in
the
manufacture
of
2
fluoropolymers.

3
Considering
the
complexity
and
importance
of
4
this
issue
and
its
overwhelming
impact
on
the
5
fluoropolymer
industry,
we
think
it
is
important
to
6
understand
the
value
of
the
fluoropolymer
industry
and
7
the
contributions
it
makes
to
both
the
economy
and
8
serve
our
quality
of
life.
While
fluoropolymers
are
a
9
small
part
of
the
total
plastics
industry,
they
are
a
10
key
material
that
make
up
the
core
­­
excuse
me
­­

11
they
are
a
key
material
for
industries
that
make
up
12
the
core
of
our
country's
economy
and
serve
many
13
critical
uses.
Hence,
the
issues
being
discussed
14
today
are
highly
relevant
to
all
of
us,
and
it
is
15
appropriate
that
they
are
being
considered
with
great
16
thought
and
care.

17
Recent
media
coverage
related
to
PFOA
has
18
associated
fluoropolymers
primarily
with
non­
stick
19
cookware
­­
no
question
one
of
the
best­
known
20
commercial
applications
of
fluoropolymers.
However,

21
it
is
important
to
note
the
overwhelming
majority
of
22
fluoropolymers
are
used
in
areas
where,
unseen
to
the
36
1
consumer,
they
support
and
enable
vital
industries
2
such
as
defense
and
aerospace,
telecommunications,

3
chemical
processing,
semiconductor
manufacturing,

4
automotive
and
power
generation.

5
The
properties
of
fluoropolymers
are
unique
in
6
the
level
of
performance
they
provide,
including
7
temperature
and
flame
resistance,
inertness
to
8
chemical
attack
and
electrical
insulating
properties.

9
In
many
cases,
the
use
of
fluoropolymers
helps
10
protect
both
people
and
the
environment
in
ways
not
11
possible
with
other
materials.

12
Let
me
offer
some
examples:
The
defense
13
industry
is
highly
dependent
on
fluoropolymer
14
components
ranging
from
seals
for
hydraulic
systems
15
for
aircraft
to
sophisticated
films
that
protect
16
liquid
crystal
displays.
The
chemical
processing
and
17
power
generation
industries
employ
fluoropolymer
18
devices
that
help
to
prevent
pollution
and
the
release
19
of
hazardous
chemicals.
The
telecommunications
and
20
semiconductor
industries
use
fluoropolymer
products
to
21
reduce
risk
of
fire
in
commercial
buildings
and
enable
22
the
manufacture
of
semiconductor
chips
by
processes
37
1
that
require
the
ultra­
high
purity
that
only
2
fluoropolymers
provide.
The
automotive
industry
is
a
3
significant
consumer
of
fluoropolymers
in
fuel
and
4
lubrication
systems,
enabling
reductions
in
air
5
pollution
from
fuel
evaporation
and
improvements
in
6
fuel
economy.
And
lastly,
the
U.
S.
space
program,

7
while
not
a
large
consumer
of
fluoropolymers,
is
very
8
dependent
on
products
for
critical
applications
in
9
vehicle
components
and
protective
clothing
for
10
astronauts.

11
It
should
be
pointed
out
that
these
12
applications
involve
state­
of­
the­
art
or
best
13
available
technology.
Manufacturers
in
these
areas
14
use
fluoropolymers,
which
are
considerably
more
15
expensive
than
other
plastics
because
they
are
the
16
only
materials
that
meet
their
demanding
performance
17
requirements.

18
I
stress
this
because
without
an
underlying
19
understanding
of
how
fluoropolymers
have
helped
bring
20
technology
to
where
it
is
today,
it
would
be
tempting
21
to
view
fluoropolymers
as
simply
a
typical
plastic
22
that
could
be
easily
replaced
if
taken
off
the
market.
38
1
Thus,
one
of
SPI's
goals
today
is
for
the
EPA
and
the
2
American
public
to
understand
that
fluoropolymers
3
provide
far
more
than
the
convenience
for
which
they
4
are
so
well
known.

5
Since
their
invention
over
60
years
ago,

6
fluoropolymers
have
served
to
raise
the
bar
on
the
7
technological
capabilities
of
the
many
key
industries
8
we
have
discussed.
These
materials
play
a
discreet,

9
but
critical
role,
in
protecting
both
the
public
and
10
the
environment,
that
they
are
essential
to
the
11
production
and
competitive
operations
of
the
important
12
American
and
global
industries
they
serve.

13
Another
SPI
goal
today
is
to
reemphasize
the
14
FMG's
commitment
to
reduce
exposures
to
PFOA
that
may
15
be
due
to
the
activities
of
the
fluoropolymers
16
industry.
As
you
know,
FMG
members
already
have
17
implemented
programs,
as
Dr.
Chowdhry
had
said,
that
18
will
reduce
PFOA
manufacturing
emissions
by
99
19
percent,
and
in
addition
to
that,
we've
also
made
a
20
commitment,
which
we're
ahead
of
schedule
on,
which
is
21
to
reduce
emissions
for
our
polymerization
plants
by
22
over
50
percent
by
year
2006.
39
1
Because
there
is
so
much
at
stake
with
respect
2
to
the
PFOA
issue
and
because
of
the
complexity
of
the
3
science
surrounding
the
understanding
of
material,
SPI
4
and
the
FMG
look
forward
to
continuing
our
working
5
relationship
with
the
EPA
to
expand
the
knowledge
6
based
around
PFOA
and
reduce
potential
exposures
from
7
activities
of
the
fluoropolymers
industry.

8
This
concludes
my
remarks.
Thank
you.

9
MR.
OSHIDA:
Thank
you
very
much
from
all
of
10
speakers.
At
this
time,
I
want
to
make
you
aware
of
11
something
you've
probably
already
seen
on
your
agenda,

12
there
will
be
a
30­
minute
public
comment
period
13
towards
the
close
of
this
meeting
and
for
those
14
members
of
the
public
who
have
not
registered
as
15
interested
parties,
but
who
wish
to
make
a
statement
16
at
this
meeting,
please
sign
up
at
the
registration
17
table
and
we
will
be
glad
to
hear
you
at
that
time.

18
All
the
statements
during
that
period
of
time
19
will
be
limited
to
three
minutes.
Also,
anybody
20
wishing
to
follow
up
today's
meeting
with
a
written
21
statement
may
do
so,
providing
that
it
is
done
within
22
ten
days
of
this
meeting
and
all
the
statements
will
40
1
be
placed
in
the
EPA's
docket
for
this
action.
And
we
2
prefer
that
direct
submission
to
EPA's
electronic
3
docket
website,
well
we
would
certainly
prefer
that
4
and
it
is
the
fastest
method
for
submission.

5
At
this
point,
I
would
like
to
introduce
6
somebody
that
most
of
you
are
probably
very
familiar
7
with,
it's
Charlie
Auer.
Charlie's
the
Director
of
8
the
Office
of
Pollution
Prevention
and
Toxics,
and
9
he'll
present
an
overview
of
the
EPA's
preliminary
10
framework
for
data
development.

11
MR.
AUER:
Thank
you,
Phil.
I
note
there
are
a
12
small
number
of
seats
that
are
available
down
here,
so
13
if
anyone
would
like
a
seat,
if
the
people
who
have
a
14
seat
that's
open
next
to
them,
put
up
your
hand,
and
15
if
you
want
to
just
go
to
those
seats
as
I
start
16
talking
that's
fine
by
me.

17
I
would
like
to
open
by
noting
the
EPA's
18
appreciation
for
the
support
voiced
by
a
number
of
the
19
opening
talks
for
the
ECA
process
and
the
interest
and
20
support
that
diverse
group
of
speakers
brought
to
this
21
activity,
the
importance
of
this
activity,
and
the
22
need
for
us
to
make
progress
in
finding
sources
and
41
1
pathways
for
exposure
to
PFOA,
so
I
am
somewhat
2
heartened
at
least
by
the
opening
discussions.

3
The
Preliminary
Framework
document,
which
was
4
circulated
by
email
to
the
interested
parties
and
5
placed
in
the
electronic
docket
May
21st,
should
be
6
viewed
as
a
discussion
guide
,
not
as
a
predetermined
7
list
defining
the
outcome
of
this
ECA
process.
Some
8
elements
referenced
in
the
Framework
may
be
provided
9
voluntarily
by
industry
under
the
programs
they
10
describe
in
their
Letters
of
Intent.
It
is
also
11
possible
that
interested
parties
may
identify
other
12
data
needs,
or
suggest
alternative
means
of
obtaining
13
information
to
those
mentioned
by
EPA
in
the
14
Framework.
The
Framework
focuses
on
the
needs
that
15
EPA
defined
in
the
Federal
Register
notice
of
April
16
16th,
these
are
identifying
the
sources
of
PFOA
found
17
in
the
environment
and
the
pathways
leading
to
18
exposures
to
PFOA.

19
As
Phil
mentioned
earlier,
we
will
not
be
20
addressing
additional
toxicity
studies
or
human
blood
21
monitoring
in
this
ECA
process.
We
think
these
issues
22
are
being
adequately
addressed
elsewhere,
at
this
42
1
point
in
the
process.
In
addition,
we
will
not
be
2
addressing
as
part
of
this
ECA
process
chemicals
that
3
are
no
longer
being
manufactured
or
imported,
the
4
reason
for
that
is
the
basic
thrust
of
section
4
is
5
directed
towards
chemicals
that
are
now
or
will
be
in
6
commerce.

7
The
Preliminary
Framework
separates
EPA's
8
perceived
data
needs
into
two
principal
areas.
The
9
first
is
needs
related
to
telomer
chemicals
and
the
10
second
is
needs
related
to
fluoropolymers.
EPA's
main
11
concern
with
the
telomers
is
the
potential
for
these
12
chemicals
to
degrade
to
form
PFOA
in
the
environment,

13
even
though
the
telomers
do
not
themselves
contain
14
PFOA
and
are
not
made
using
PFOA.
The
focus
of
EPA's
15
data
needs
on
telomers
thus
involves
determining
how
16
and
to
what
extent
telomer
chemicals
and
articles
17
treated
with
telomer
chemicals
may
be
a
source
of
PFOA
18
in
the
environment
over
time
and
may
release
PFOA
into
19
media
that
could
contribute
to
human
and
environmental
20
exposures.

21
EPA's
principal
concerns
with
respect
to
the
22
fluoropolymers,
on
the
other
hand,
are
the
potential
43
1
for
PFOA
to
be
released
during
the
manufacture
or
2
processing
of
fluoropolymers,
and
the
extent
to
which
3
PFOA
may
remain
in
and
be
released
over
time
from
4
fluoropolymers
made
with
PFOA.
Both
of
these
5
industries
have
initiated
voluntary
research
programs
6
which
they
described
in
their
Letters
of
Intent,
or
7
LOIs,
which
are
available
in
the
docket,
and
have
been
8
noted
in
their
opening
statements
to
this
meeting.
It
9
is
not
our
intent
in
this
ECA
process
to
delay
any
of
10
the
voluntary
actions
to
which
industry
groups
have
11
already
committed.
At
the
same
time,
we
note
that
the
12
Agency's
data
quality
requirements
will
apply
to
any
13
information
from
these
programs
that
the
companies
14
would
submit
to
the
Agency
for
consideration
during
15
its
investigation
of
PFOA
and
the
telomers.

16
Our
goal
in
this
ECA
process
is
to
go
beyond
17
the
elements
covered
in
the
LOIs
to
address
additional
18
chemicals
or
tests
not
covered
in
the
LOIs,
and
to
19
identify
and
pursue
additional
steps
that
may
be
20
necessary
pending
the
results
of
screening­
level
LOI
21
data
development.

22
The
Telomer
Data
Needs
table
begins
on
page
6
44
1
of
the
Framework.
The
first
six
items
address
telomer
2
market
information
and
fate,
biodegradation,
and
3
incineration
testing.
Companies
have
provided
the
EPA
4
much
of
the
market
information,
which
is
largely
5
protected
from
public
disclosure
as
confidential
6
business
information,
or
CBI.
The
companies
have
also
7
committed
through
the
Telomer
Research
Program
LOI,
to
8
providing
the
tests
marked
by
asterisks
on
certain
of
9
the
telomer
chemicals
that
they
produce.

10
The
TRP
has
committed
to
test
12
chemicals
and
11
various
products
treated
with
these
chemicals
under
12
the
LOI.
On
the
basis
of
CBI
regarding
the
overall
13
market
of
all
telomer
chemicals
produced
by
TRP
member
14
companies,
the
Agency
believes
that
these
12
chemicals
15
represent
a
substantial
portion
of
the
markets
for
the
16
carpet,
textile,
and
paper
industries,
which
are
the
17
major
market
sectors
associated
with
telomer
use.
The
18
12
chemicals
also
structurally
represent
a
diverse
19
mixture
of
the
chemicals
that
are
currently
used
in
20
commerce.

21
In
this
ECA
process,
EPA
is
suggesting
that
22
additional
chemicals
may
need
to
be
considered
to
45
1
fully
characterize
the
scope
of
the
telomer
family
and
2
to
address
all
market
sectors.
For
example,
although
3
telomer
alcohol,
acrylates,
urethanes,
and
sulfonates
4
are
represented
among
the
test
substances
covered
by
5
the
TRP
LOI,
none
of
the
companies
have
committed
to
6
testing
any
of
the
telomer
phosphates
or
telomer
7
iodides.
EPA
is
also
suggesting
the
need
for
8
additional
fate
tests
not
currently
included
in
the
9
TRP
LOI,
including
photolysis
tests,
aerobic
and
10
anaerobic
transformations
in
soil
and
aquatic
11
sediment,
aerobic
sewage
treatment,
and
anaerobic
12
biodegradability
in
digested
sludge.
In
addition,

13
because
telomer
chemicals
and
articles
treated
with
14
telomer
chemicals
are
likely
to
be
disposed
of
in
15
municipal
incinerators,
EPA
has
suggested
tests
to
16
identify
incineration
breakdown
products.
Through
17
these
tests,
EPA
proposes
to
identify
the
potential
18
for
telomer
degradation
and
incineration
to
contribute
19
to
the
presence
of
PFOA
in
the
environment.

20
EPA
believes
that
longer­
term
biodegradation
21
studies,
conducted
under
environmentally
realistic
22
conditions,
may
be
necessary
to
provide
confirmation
46
1
that
data
from
the
shorter
term
studies
conducted
2
under
the
LOIs
and
through
screening
level
phases
in
3
this
ECA
process
accurately
characterize
the
true
4
long­
term
degradation
potential
of
these
chemicals.

5
This
ECA
process
through
our
discussions
should
6
provide
a
forum
for
us
to
develop
the
decision
7
guidance
that
would
indicate
the
circumstances
under
8
which
such
longer­
term
testing
should
be
done,
as
well
9
as
to
adopt
methods
and
develop
standards
for
such
10
testing.

11
Item
7
through
9
of
the
table
propose
to
test
12
for
the
presence
PFOA,
residual
telomer
alcohol,
or
13
other
PFOA
precursors
in
telomer
chemical
products,
in
14
new
products
and
articles
treated
with
telomers,
and
15
in
telomer­
treated
products
and
articles
as
they
age
16
and
are
used.
The
TRP
LOI
includes
proposals
to
test
17
these
items
for
the
presence
of
PFOA.
Because
there
18
is
some
evidence
to
suggest
that
the
degradation
of
19
telomers
to
PFOA
in
the
environment
proceeds
via
a
20
stepwise
process,
EPA
is
suggesting
that
such
testing
21
look
not
only
for
the
presence
of
PFOA,
but
for
the
22
presence
of
precursors
to
PFOA
formation,
including
47
1
residual
telomer
alcohols
and
other
potential
2
precursors
that
may
be
identified
through
3
biodegradation
and
fate
testing
performed
under
the
4
LOI
and
through
this
ECA
process.
The
test
standards
5
for
these
studies
may
be
developed
by
technical
6
working
groups
of
interested
parties
during
this
ECA
7
process.

8
Items
10
and
11
in
the
table
propose
9
environmental
sampling
and
monitoring
for
the
presence
10
of
PFOA
and
PFOA
precursors
in
the
vicinity
of
telomer
11
manufacturing
and
use
facilities,
including
areas
12
where
telomer­
based
fire
fighting
foams
are
discharged
13
directly
into
the
environment,
in
order
to
14
characterize
exposures
to
and
releases
of
PFOA
from
15
these
locations
and
activities.
The
TRP
LOI
did
not
16
include
any
environmental
sampling
or
monitoring
17
activities.
This
ECA
process
may
provide
a
forum
for
18
the
adaptation
of
methods
and
the
development
of
test
19
standards
for
this
sampling
and
monitoring
by
20
technical
work
groups
drawn
from
the
interested
21
parties,
using
the
protocols
already
developed
by
3M
22
and
DuPont
as
a
starting
point
for
those
discussions.
48
1
Item
12
in
the
table,
concerning
product
2
stewardship
information,
does
not
involve
testing,
but
3
reflects
our
interest
and
need
to
understand
on
a
4
continuing
basis
the
steps
that
the
industry
is
taking
5
to
oversee
its
products
throughout
their
life
cycle.

6
Many
of
the
elements
in
the
Fluoropolymer
Data
7
Needs
table,
which
begins
on
page
11
of
the
Framework,

8
are
very
similar
to
their
counterparts
in
the
Telomer
9
Data
Needs
table.
The
companies
have
already
provided
10
to
EPA
much
of
the
market
information
identified
in
11
item
1
of
the
table.

12
The
Fluoropolymer
Manufacturers
Group
LOI
does
13
not
include
any
fluoropolymer
biodegradation
testing.

14
High
molecular
weight
fluoropolymers
are
not
generally
15
expected
to
degrade
significantly,
but
EPA
considers
16
that
it
would
be
useful
to
confirm
the
degradation
17
potential
particularly
of
some
of
the
lower
molecular
18
weight
polymers.
This
testing
appears
in
the
table
at
19
items
2
through
4.

20
Because
the
fluoropolymer
manufacturing
process
21
uses
PFOA
as
a
polymerization
aid,
it
is
possible
that
22
fluoropolymers
and
fluoropolymer­
treated
products
and
49
1
articles
might
contain
residual
PFOA
as
a
component
of
2
the
final
product
and
release
PFOA
to
the
environment
3
over
time
and
under
typical
conditions
of
use
and
4
disposal.
The
FMG
LOI
includes
commitments
to
test
5
for
the
presence
of
PFOA
and
fluoropolymer
products.

6
In
items
5
through
7
of
the
table,
EPA
has
suggested
7
that
such
testing
may
need
to
be
expanded
to
include
8
the
presence
of
PFOA
in
fluoropolymer­
treated
articles
9
and
to
address
the
potential
release
of
PFOA
over
time
10
and
under
use
conditions.
In
items
8
and
9
of
the
11
table,
EPA
also
suggests
incineration
testing
and
the
12
determination
of
incineration
byproducts
which
were
13
not
contemplated
in
the
FMG
LOI.

14
The
fluoropolymer
industry
has
taken
steps
15
voluntarily
to
reduce
emissions
and
releases
of
PFOA
16
from
the
manufacturing
process,
but
characterizing
17
those
releases
and
the
presence
of
PFOA
in
the
18
environment
in
the
vicinity
of
facilities
that
19
manufacturer
PFOA
or
fluoropolymers,
or
that
process
20
or
use
fluoropolymers
to
treat
other
products
and
21
articles,
will
help
to
complete
the
picture
of
the
22
sources
and
exposure
pathways
for
PFOA.
The
FMG
50
1
LOI
includes
commitments
to
monitor
for
PFOA
in
water
2
at
PFOA
manufacturing
facilities,
and
to
some
extent
3
at
fluoropolymer
manufacturing
facilities,
and
to
4
perform
some
air
modeling.
In
items
9
and
10
of
the
5
table,
EPA
suggests
that
additional
sampling
and
6
monitoring
may
be
necessary
including
stack
or
air
7
monitoring
rather
than
the
modeling,
as
well
as
8
sampling
from
soil,
sediments,
and
biota,
and
that
9
additional
sites
may
need
to
be
considered
including
10
processing
and
use
facilities
as
well
as
manufacturing
11
facilities.

12
Item
11
in
the
table
concerning
product
13
stewardship
information
does
not
involve
testing,
but
14
reflects,
as
with
the
telomers,
our
need
to
understand
15
on
a
continuing
basis
the
steps
the
industry
is
taking
16
to
oversee
its
products
throughout
their
life
cycle.

17
Through
this
point,
I
provided
a
very
brief
18
overview
of
the
elements
contained
in
the
Framework.

19
Again,
to
reemphasize
the
Framework
presents
EPA's
20
thoughts
concerning
data
needs
and
approaches
to
be
21
addressed
through
this
ECA
process.
We
think
these
22
are
important
to
undertake
to
meet
the
goal
of
51
1
identifying
the
sources
of
PFOA
in
the
environment
and
2
the
pathways
of
human
and
environmental
exposure
to
3
PFOA.

4
Throughout
the
rest
of
this
portion
of
the
5
meeting,
I
would
like
to
discuss
with
the
interested
6
parties
additional
data
needs
that
EPA
may
have
7
missed,
receive
initial
feedback
describing
why
8
particular
aspects
of
EPA's
data
needs
may
not
be
9
needed
or
are
not
relevant,
and
pursue
approaches
to
10
developing
ECAs
that
will
help
us
to
reach
our
goal
of
11
understanding
PFOA
source
and
exposure
as
12
expeditiously
as
possible.
In
this
regard,
I
ask
13
interested
parties
to
consider
any
elements
that
may
14
be
candidates
for
early
technical
discussion
and
15
possible
consensus,
and
other
areas
which
will
require
16
plenary
discussion
to
reach
agreement
in
principle
17
regarding
the
need
such
that
technical
discussions
can
18
begin.
Examples
of
what
we
might
term
"
low
hanging
19
fruit"
areas
where
we'd
like
to
be
able
to
move
more
20
quickly
towards
agreement
in
principle
could
include
21
certain
fate
testing
whereas
the
monitoring
efforts
22
may
require
additional
plenary
discussions,
such
that
52
1
we
can
adequately
scope
that
and
begin
moving
towards
2
an
agreement
in
principle.
And
I
think
that
concludes
3
my
part.

4
MR.
OSHIDA:
We
would
like
to
open
the
floor
at
5
this
time
for
discussion
among
the
interested
parties
6
about
the
data
needs
identified
by
EPA,
and
the
7
approaches
the
Agency
has
suggested
to
for
addressing
8
these
needs
through
ECAs.
Please
raise
your
9
identification
card,
so
that
our
spotters
can
see
you
10
and
identify
you,
and
wait
until
you
have
the
11
microphone
before
you
speak.
Please
remember
to
start
12
by
identifying
yourself
and
your
affiliation.

13
Who
would
like
to
start
us
off?

14
MR.
PURDY:
My
name
is
Rich
Purdy.
I
am
a
15
freelance
toxicologist.
I
noticed
that
the
focus
of
16
the
information
around
the
telomers
has
to
do
with
17
PFOA
and
not
the
other
fluorinated
acid
degradation
18
products.
Are
you
interested
in
the
other
polymers
of
19
PFOA?

20
MR.
AUER:
I
think
I
as
described
in
the
21
Federal
Register
Notice
we're
interested
in
materials
22
that
could
contribute
to
the
formation
of
PFOA
and
the
53
1
environment,
which
we
note
could
include
C8
materials,

2
but
it
could
also
include
higher
carbon
number
of
3
materials,
which
might
have
the
potential
to
4
biodegrade
or
otherwise
degrade
to
form
PFOA.

5
MR.
PURDY:
Well,
the
other
(
inaudible)
since
6
they
have
been
shown
they
have
similar
modes
with
the
7
same
modes
of
toxicity
and
the
same
tissues
of
action
8
fit
into
accumulative
(
inaudible)
of
PFOA,
so
the
9
level
of
PFOA
in
the
environment,
the
total
load
of
10
the
class
is
greater
than
just
PFOA,
so
as
one,
you
11
know,
and
in
addition
we
seen
data
the
indicates
a
12
higher
(
inaudible)
like
PFDA,
PFUA,
(
inaudible)
acid
13
occur
in
water
samples,
and
in
precipitation
samples,

14
in
wild
life
samples
a
higher
concentration
than
PFOA,

15
so
since
they
can
occur
at
higher
concentrations
they
16
may
have
a
larger
impact
than
PFOA
for
the
cumulative
17
toxicity
for
the
class.

18
MR.
AUER:
Well,
we
appreciate
that.
I
think
19
that
our
approach
at
this
point
is
to
focus
20
principally
on
PFOA
and
things
that
can
degrade
PFOA.

21
I
just
don't
know
that
it
can
be
possible
for
us
to
22
deal
with
all
of
the
issues
that
are
going
to
come
54
1
forward.
That's
not
to
say
that
we
might
decide
that
2
these
issues
are
important
for
us
to
deal
with
as
3
follow­
on
activity
in
the
future,
but
at
least
EPA's
4
going
into
this
discussion
is
to
focus
in
the
areas
5
that
I've
indicated,
at
the
same
time
if
there
are
6
views
by
the
interested
parties
we
can
certainly
take
7
that
under
advisement.

8
MR.
PURDY:
So
as
part
of
the
ECA
process
we
9
could
discuss
the
cumulative
approaches
that
are
10
important
to
proceed
with?

11
MR.
AUER:
Well,
what
I
would
do
for
that,

12
Rich,
I
think
is
I
would
cue
these
items
up
and
focus
13
on
the
initial
areas
first
and
then
to
the
extent
that
14
there
are
areas
which
would
be
new
areas
or
where
15
there's
less
agreement
going
into
that
discussion,
I
16
would
look
to
defer
those
to
­­

17
MR.
PURDY:
And
what
you
mean
by
defer,
do
you
18
mean
further
in
this
process
or
something
following
19
this
process?

20
MR.
AUER:
Well,
I
think
I
would
probably
need
21
to
consult
with
others
at
EPA
as
to
the
best
way
of
22
considering
those
additional
aspects
that
you
have
55
1
brought
out.

2
MR.
PURDY:
Thank
you.

3
MR.
AUER:
Thank
you.
Environmental
Working
4
Group.

5
MS.
THAYER:
Hi,
Kris
Thayer
for
Environmental
6
Working
Group.
I
was
wondering
why
there
weren't
any
7
additional
proposed
studies
to
look
at
PFOA
in
food,

8
both
market
basket­
type
analysis
and
also
food
9
migration
study
cells,
for
example
food
that's
in
a
10
paper
product
treated
with
telomers,
for
example,
and
11
also
if
there
are
any
­­
if
it
is
also
possible
to
12
extend
the
drinking
water
studies
beyond
the
original
13
six
studies
or
six
of
the
studies
that
was
originally
14
done
by
3M?

15
MR.
AUER:
On
the
question
of
the
food
16
monitoring,
I
think
I
would
want
to
think
about
that
17
before
responding.
As
far
as
the
drinking
water
18
monitoring,
we
suggested
the
need
to
do
monitoring
19
around
the
production
and
use
facilities
and
that
20
would
include
appropriate
media
in
those
areas.
And
21
if
there
is
a
need
to
consider
drinking
water
22
concentrations
in
those
locales,
I
would
think
that's
56
1
something
that
we
would
consider
for
discussion
within
2
the
room.

3
MS.
THAYER:
And
what
about
the
food
migration?

4
Again,
is
that
something
you
think
more
about?

5
MR.
AUER:
Well,
the
reason
I'm
hesitating
is
I
6
don't
have
authority
for
food
or
food
migration
per
7
se,
and
so
I
would
need
to
consider
whether
that's
8
appropriate
area
for
me
to
get
into
and
that's
why
I
9
am
deferring
a
response
to
you.

10
MR.
SPEAKER:
The
Center
for
Regulatory
11
Effectiveness.
We
agree
with
you
completely
with
the
12
Agency's
statement
that
the
Data
Quality
Act
under
13
very
good
guidelines
that
EPA
issued
pursuant
to
that
14
Act
will
govern
those
proceedings
in
their
entirety.

15
As
you
know,
an
integral
part
of
the
EPA's
guidelines
16
are
predissemination
review
provision,
which
would
17
mean
the
data
that
the
Agency
collects
is
subject
to
18
review
by
the
Agency
to
see
if
it
conforms
with
the
19
guidelines
you
set
out.

20
The
question
I
have
to
you
and
other
members
of
21
the
panel,
have
you
set
up
a
process
for
22
predissemination
review
and
release
by
the
Agency
of
57
1
the
very
large
substantial
amount
of
data
we
would
2
expect
you
to
receive
from
this
proceeding?

3
MR.
AUER:
I
think
it
would
be
helpful
to
us
if
4
we
had
a
better
understanding
of
the
issue
that
you're
5
presenting,
perhaps
you
could
submit
a
written
comment
6
to
that
effect.

7
MS.
TENNANT:
I'm
Della
Tennant
of
Tennant
8
Rentals
in
Parkersburg,
West
Virginia.
Along
with
my
9
husband,
we
own
Tennant
Rentals
Box
3117,
in
10
Parkersburg,
West
Virginia.
I
come
to
you
today
as
a
11
very
concerned
­­
a
very
concerned
person
of
God,
as
a
12
mother,
a
grandmother,
a
sister,
a
sister­
in­
law,
a
13
landlord,
a
friend,
and
a
neighbor
in
the
Middle
Ohio
14
Valley.
We
own
property
next
to
the
DuPont
landfill
15
on
Route
68
south
of
Lubeck,
Virginia
and
our
property
16
is
at
that
the
end
of
that
fifteen
hundred
feet
of
the
17
DuPont
landfill.

18
Although
I
understand
we
are
not
here
today
to
19
discuss
the
landfill,
but
we
are
here
today
to
talk
20
about
the
PFOA
or
in
my
­­
I
will
just
say
the
Teflon
21
chemical
because
it
is
easier
for
me
to
do
that
­­
and
22
the
contamination
that
is
being
done
in
the
Middle
58
1
Ohio
Valley.
We
at
one
point
used
to
own
about
68
2
acres
of
property
that
is
the
DuPont
landfill
now
and
3
I
would
like
at
this
time
to
be
assured
and
assure
4
everybody
to
understand
that
this
property
was
not
5
sold
in
any
way
ever
sold
to
become
a
chemical
6
unregulated
or
regulated
chemical
dump
in
any
way.

7
A
few
years
back
we
sued
DuPont.
Going
up
8
against
DuPont
was
hard
for
us
to
do,
but
it
was
9
something
that
needed
to
be
done
because
our
family
10
was
sick,
my
family
was
sick,
Earl
and
Sandy
Tennant's
11
family
was
sick,
Jack
and
his
wife,
their
family
was
12
all
sick,
my
mother­
in­
law
being
in
good
health,
and
13
this
was
before
we
sued
DuPont,
passed
away
recently
14
with
getting
sick
very
sudden
coming
into
lung
and
15
heart
problems.

16
During
this
time,
we
was
represented
by
the
17
best
law
firm
there
is
in
the
United
States
of
America
18
and
two
of
the
best
lawyers
on
the
face
of
the
earth
19
that
I
could
ask
that
any
of
God's
people
could
have.

20
And
I
think
they
are
to
be
commended
for
a
job
well
21
done,
for
it
was
in
that
time
of
our
lawsuit
that
they
22
discovered
this
Teflon­
related
chemical
that
has
59
1
contaminated
the
Middle
Ohio
Valley.

2
The
problems
with
the
contamination
in
and
3
around
the
landfill
with
the
deers
dying,
the
cattle
4
dying
by
the
hundreds,
is
the
contamination
in
the
5
environment
is
why
we
are
here
today.
If
they
hadn't
6
discovered
that
the
Teflon
chemical
had
contaminated
7
our
Middle
Ohio
Valley,
it
would
not
have
been
8
overturned
because
DuPont
(
inaudible)
for
50
years.

9
In
March
I
put
a
article
on
a
medical
chart
and
put
it
10
in
a
medical
directory
opposing
the
DuPont
landfill
11
renewal.

12
MR.
AUER:
Excuse
me.
We're
trying
to
focus
13
the
discussion
here
on
the
Framework
document,
if
you
14
could
attempt
to
direct
your
comments
in
that
way,
if
15
you
have
other
more
general
points
that
you
would
like
16
to
make
which
perhaps
might
fit
more
as
an
opening
17
statement
we
would
be
very
pleased
to
receive
that,

18
but
the
time
is
limited
here
and
I
would
like
to
try
19
to
focus
on
the
goals
of
this
discussion.

20
MS.
TENNANT:
Can
I
talk
about
the
health
21
problems
in
the
Middle
Ohio
Valley
at
this
time
or
22
will
I
get
an
opportunity
to
do
so
later?
60
1
MR.
AUER:
How
about
if
we
give
you
a
slot
in
2
the
public
comments
section.

3
MS.
TENNANT:
Okay.
Thank
You.

4
MR.
AUER:
Thank
you.
I
appreciate
your
5
assistance.
Okay.
Well,
so
far
we've
got
a
couple
of
6
areas
where
people
think
we
need
to
do
more
work.
I
7
am
also
interested
in
beginning
discussion
of
areas
8
where
interested
parties
might
think
that
there's
9
perhaps
more
agreement
at
the
outset
and
we
might
be
10
able
to
move
towards
closure.
Don,
please
help
me.

11
MR.
DUNCAN:
I
hope
I
can.
As
the
spokesperson
12
for
SPI's
Fluoropolymer
Manufacturers
Group,
I
would
13
like
to
make
a
couple
of
comments.
If
I
can
impose
on
14
you,
I'd
like
to
read
them.
Trying
to
speak
for
many,

15
many
companies
becomes
important
that
what
we
say
is
16
precise
and
to
the
point.

17
After
receiving
the
information
involved
in
18
your
Framework
over
a
week
ago,
the
FMG
assembled
a
19
team
of
technical
professionals
from
all
the
member
20
companies
to
evaluate
and
comment
on
the
information
21
and
concepts
that
were
presented
by
the
EPA.
The
22
detailed
results
of
that
effort
have
been
submitted
to
61
1
the
EPA
in
written
form.

2
For
the
purposes
of
this
meeting,
I
would
like
3
to
summarize
our
findings
and
the
commitment
that
we
4
made.
First,
I
think
it's
important
to
say
that
we
5
believe
we
understand
the
content,
specifics
and
6
reasoning
behind
the
11
items
that
were
requested
of
7
the
fluoropolymer
industry
in
that
area.
Second,
the
8
FMG
supports
the
need
for
data
in
each
of
the
broad
9
categories
in
the
Framework
document.
Third,
there
10
are
no
issues
raised
in
the
Framework
that
the
FMG
11
categorically
rejects.
Fourth,
the
FMG
is
encouraged
12
by
its
belief
that
much
of
what
is
being
is
either
13
already
available
within
the
tremendous
amounts
of
14
existing
information
developed
around
PFOA,
or
will
be
15
provided
as
a
result
of
the
commitments
made
in
the
16
LOI
assigned
by
the
FMG.
And
fifth,
the
FMG
believes
17
that
the
key
to
meeting
the
data
needs
of
all
18
interested
parties
is
identical
to
the
process
used
19
earlier
this
year
to
develop
the
LOIs
specifically,

20
close
cooperation
between
the
senior
technical
21
professionals
in
the
EPA
and
the
fluoropolymer
22
industries,
and
other
stakeholder
groups.
62
1
In
summary,
the
FMG
supports
ECA
process
for
2
completing
the
development
and
analysis
of
critical
3
data
needed
to
assess
the
regulatory
implications
for
4
PFOA.
The
FMG
is
committed
to
cooperating
with
the
5
EPA
and
other
stakeholders
in
creating
ECAs
that
help
6
understand
the
routes
of
exposure
to
PFOA.

7
Thank
you
very
much.

8
MS.
THAYER:
Hi,
Kris
Thayer
again
from
the
9
Environmental
Working
Group.
Just
looking
at
the
10
blood
monitoring
data
where
certain
PFA­
related
11
chemicals
that
were
used
in
carpet
treatments
seem
to
12
be
higher
in
children
and
the
highest
(
inaudible)
PFOA
13
in
the
general
population
as
far
as
from
coming
from
a
14
child.

15
We
were
wondering
if
you
were
going
to
have
any
16
sort
of
specific
exposure
change
directed
toward
17
infants
and
children.
For
example,
levels
of
telomers
18
in
the
air
that
might
off
gas
from
carpets
in
an
19
infants
breathing
zone,
or
also
maybe
secondary
users
20
who
might
have
sprayed
Stain
Master
on
furniture
or
21
carpets
in
the
back
room?

22
MR.
AUER:
I
think
that
those
kinds
of
studies
63
1
would
fit
within
proposal
to
include
tests
to
2
understand
release
of
PFOA
over
time
from
products
and
3
articles,
and
so
to
the
extent
there
are
specific
4
issues
that
you
might
wish
to
suggest
be
focused
on
5
and
discuss,
I
think
that
would
be
the
place
to
fit
6
that
data.

7
DR.
ZUCKERMAN:
I'm
Dr.
Diana
Zuckerman,

8
President
of
the
National
Center
for
Policy
Research
9
for
Women
and
Families.
I
would
like
to
thank
you
for
10
allowing
us
in
the
audience
to
speak.

11
I
had
a
question,
it's
come
to
our
attention
12
that
Gore­
Tex,
a
Teflon­
related
product,
has
been
used
13
for
implants
inside
the
human
body
for
about
20
years,

14
for
vascular
surgery,
and
more
recently
for
facelifts
15
and
other
plastic
surgery
on
the
face.
And
I
don't
16
believe
that
the
FDA
has
data
on
any
health
effects
of
17
these
implants,
but
I
thought
it
might
be
relevant
to
18
your
work
and
I'm
wondering
if
you
checked
to
see
if
19
there
data
available,
and
if
not,
I
would
certainly
20
want
the
FDA
to
know
about
the
work
that
you're
doing
21
in
order
to
know
about
communication
between
the
two
22
agencies.
64
1
MR.
AUER:
Let
me
start
with
the
last
bit
of
2
your
intervention.
We
have
been
communicating
with
3
the
FDA
for
some
time
on
PFO
and
PFOA
and
they're
4
fully
informed
as
to
the
understanding
that
we
have
5
and
the
issues
that
we're
looking
at,
we've
been
6
involved
in
a
number
of
discussions
with
them
over
7
this
time.
As
far
as
any
work
that
might
be
8
contemplated
under
the
Enforceable
Consent
Agreement
9
dealing
with
medical
devices,
that's
an
area
where
10
we're
moving
beyond
the
authority
that
we
have,
so
we
11
would
not
be
able
to
consider
that
data
in
this
12
content.

13
DR.
ZUCKERMAN:
No,
I
understood
that.
I
just
14
wanted
to
make
sure
that
there
is
communication
15
between
you
because
obviously
there
are
risks,

16
reproductive
risk,
people
want
to
know
­­
I
think
you
17
would
want
the
FDA
to
know
about
that
because
they're
18
placing
these
products
inside
the
human
body.

19
MR.
AUER:
We
have
given
them
a
set
of
all
the
20
CD's
that
we
have
accumulated
in
the
administrative
21
record
on
this
action.

22
MR.
SLAUGHTER:
Once
again,
this
is
Scott
65
1
Slaughter
for
The
Center
for
Regulatory
Effectiveness.

2
I
just
wanted
to
make
sure
that
I
understand
the
3
process
here.
As
I
understand
it,
efforts
to
validate
4
human
and
animal
serum
tests
are
currently
not
in
the
5
context
ongoing
now
and
they
are
not
part
of
this
ECA
6
process;
am
I
correct?

7
MR.
AUER:
The
validation
work
for
human
serum
8
is
otherwise
occurring
and,
yes,
it
is
not
considered
9
to
be
part
of
this
ECA
process,
principally
because
we
10
are
not
contemplating
any
data
development
regarding
11
human
serum.
To
the
extent
we
get
into
analytical
12
protocols
in
other
media
where
there
is
inadequate
13
validation
available,
the
development
of
that
14
understanding
would
as
appropriate
be
part
of
this
15
proceeding
to
ensure
that
when
results
are
obtained
we
16
understand
the
confidence
that
should
be
given
to
them
17
and
so
forth.

18
MR.
SLAUGHTER:
And
in
regards
to
serum
test
19
validation
that's
being
conducted
in
(
inaudible)

20
content;
am
I
correct?

21
MR.
AUER:
I'm
sorry?

22
MR.
SLAUGHTER:
The
CDC?
66
1
MR.
AUER:
Well,
CDC
has
done
­­
is
doing
work
2
in
that
area,
but
3M
and
DuPont
are
also
pursuing
work
3
in
this
area
to
validate
those
measurements
in
human
4
blood,
as
well
as
in
rodent
blood.

5
MR.
SLAUGHTER:
Thank
you
very
much.

6
MR.
AUER:
So
we
are
looking
forward
to
having
7
that
work
done,
so
that
we
can
fully
appreciate
the
8
values
to
be
attributed
to
those
data.

9
MR.
SLAUGHTER:
But
the
work
is
ongoing
now
and
10
not
complete;
is
that
right?

11
MR.
AUER:
To
my
knowledge
it's
not
complete,

12
but
I'm
not
necessarily
the
best
one
to
answer
the
13
question.

14
MR.
SLAUGHTER:
Thank
you
very
much.

15
MR.
AUER:
You
know
when
you
are
in
consensus
16
discussions
you
can
take
the
view
that
silence
is
an
17
agreement,
and
I
haven't
heard
anyone
speak
against
18
any
of
the
data
needs
that
are
included
in
EPA's
19
Framework.
There
has
been
some
discussion
in
the
20
opening
remarks
about
testing
that
might
of
more
or
21
less
interest
or
more
or
less
accommodated
under
the
22
LOIs.
67
1
It
would
be
really
useful
in
this
section
of
2
the
meeting
if
we
can
begin
to
identify
those
areas
3
where
there's
more
versus
potentially
less
agreement.

4
I
suggested
in
my
remarks
that
the
fate
area
might
be
5
one
that
perhaps
is
more
ready
for
moving
into
6
technical
discussions
as
opposed
to
the
monitoring
7
area
where
because
of
the
complexity
of
those
studies
8
the
absence
of
standard
protocols
and
whatnot
you
9
might
need
more
discussions.

10
If
we
could
get
comments
along
these
lines
I
11
think
it
could
be
very
helpful
in
structuring
the
12
discussions
that
would
occur
after
2
o'clock,
which
is
13
really
the
heart
of
the
meeting
where
we
begin
to
14
consider
areas
that
might
be
ripe
for
going
directly
15
into
technical
consultations
where
experts
from
16
amongst
the
interested
parties
would
go
off
and
talk
17
about
the
specifics
of
the
biodegradation
protocol
or
18
hydrolysis
protocol,
whatever
the
case
might
be,
and
19
then
other
issues
that
would
be
most
appropriately
20
retained
in
the
plenary
forum,
where
we
can
have
21
continued
discussion
until
we
can
get
to
the
point
of
22
arriving
at
the
agreement
in
principle,
which
is
the
68
1
way
that
the
ECA
procedural
language
has
us
working,

2
to
try
to
come
to
an
agreement
in
principle
on
a
given
3
data
need
and
then
recognizing
that
you
get
into
a
lot
4
of
technical
details,
shifting
to
get
out
of
a
larger
5
forum
into
a
smaller,
more
expert­
oriented
forum
where
6
the
goal
there
is
to
elaborate
the
specifics
of
the
7
test
standard
that
would
then
emerge
and
be
included
8
in
the
written
Enforceable
Consent
Agreement.

9
So
I
hope
that
helps
explain
what
we're
trying
10
to
do
here
and
what
I
hope
to
do
in
the
next
section,

11
so
comments,
discussions?

12
MS.
SMYTHE:
The
TRP
has
reviewed
the
data
13
needs
that
were
outlined
in
EPA's
Framework
document
14
in
order
to
identify
potential
candidates
for
ECA
15
discussions.
In
doing
so,
the
TRP
has
identified
work
16
that
qualifies
as
the
next
logical
step
contained
in
17
the
LOI
commitments.
Another
important
consideration
18
for
our
comments
today
which
is
to
focus
on
activities
19
not
in
the
LOIs
to
assure
that
the
ECA
negotiations
do
20
not
impede
ongoing
work.

21
Based
on
this
review,
the
TRP
has
identified
22
additional
areas
that
are
fruitful
subjects
for
ECA
69
1
discussions.
TRP
proposes
to
analyze
the
telomer
2
alcohol
raw
material
in
telomer
products
in
eight
3
products
and
to
release
and
exposure
assessments.
It
4
should
be
noted
that
validated
analytical
methods
do
5
not
yet
exist,
but
will
be
developed
carrying
out
its
6
work.

7
The
TRP
will
conduct
analyses
using
real
8
simulations
rather
than
at
customer
sites
due
to
the
9
potential
for
PFOA
contamination
from
historical
use
10
of
other
supplier
products.
If
PFOA
is
generated
from
11
telomer
product
degradation
it
will
be
12
indistinguishable
from
PFOA
that
is
present
or
is
13
released
resulted
from
other
sources.

14
TRP
further
proposes
to
augment
its
LOI
15
commitment
in
the
area
of
incineration
by
conducting
16
initial
incineration
studies
on
representative
telomer
17
products,
but
will
also
focus
on
developing
an
18
understanding
of
decomposition,
temperature
profile,

19
and
the
temperature
at
which
complete
combustion
20
occurs.

21
The
TRP
companies
(
inaudible)
commitment
by
22
these
additional
commitments
is
the
best
overall
70
1
approach
to
understand
the
potential
contribution
2
telomer
products
may
have
to
PFOA
levels
in
the
3
environment.
The
data
generated
by
TRP
will
resolve
4
most
issues
and
will
inform
future
discussions
about
5
additional
data
development
efforts
that
TRP
is
6
prepared
to
discuss
with
the
Agency
and
other
7
stakeholders
for
the
scope
of
such
work.

8
Any
reasonable
attempt
to
address
these
issues
9
in
a
scientifically
sound
timely
manner
must
proceed
10
in
a
stepwise
fashion.
TRP's
current
research
program
11
as
outlined
in
the
LOI,
plus
the
additional
work
12
proposed
today
largely
fulfills
EPA's
data
needs
cited
13
in
the
preliminary
PFOA
ECA
Framework.
The
TRP
member
14
companies
stand
by
the
substantial
and
scientifically
15
sound
commitments
to
EPA
as
described
in
our
Letter
of
16
Intent
and
in
our
main
response
to
EPA
questions
and
17
its
proposals
made
today.

18
MR.
AUER:
Thank
you
for
that.
I
think
the
19
general
comment
that
has
been
made
is
that
we
20
understand
the
LOI
commitments
at
a
general
level,
and
21
have
been
working
with
the
companies
to
better
22
understand
the
specifics
of
what
is
intended
to
be
71
1
done
under
the
LOIs.
As
I've
indicated,
we're
2
interested
in
obtaining
what
information
we
can
3
through
the
LOI
process
to
provide
framework
for
or
4
foundation
for
discussions
focused
on
testing
beyond
5
that
level.

6
I
certainly
welcome
the
TRP
comments
as
to
your
7
intention
to
expand
the
work
that
you're
including
8
within
your
LOI.
I
would
ask
that
you
submit
that
in
9
writing
to
the
Agency
with
as
much
specificity
as
10
possible
as
to
chemicals,
materials,
you
know,
what
11
products
and
whatnot,
what
methods
would
you
be
using,

12
things
like
that,
so
that
we
and
other
interested
13
parties
would
be
in
a
position
of
fully
understanding
14
what
is
intended
to
be
done
in
that
regard
and
then
15
can
consider
what
work,
if
any,
is
appropriate
for
16
consideration
here
in
a
given
area.

17
MS.
THAYER:
I
was
wondering
if
data
need
18
number
7
under
fluoropolymers
presence
of
PFOA,

19
emitted
from
fluoropolymer
treated
products
and
20
articles
as
they
age
during
use,
if
that
includes
21
Teflon
and
other
non­
stick
cookware
or
appliances?

22
MR.
AUER:
Yes,
it
would.
72
1
MS.
THAYER:
Okay.
I
guess
I
have
a
few
other
2
questions
to
ask.
What
is
sort
of
the
process
for
3
maybe
dealing
with
some
of
concerns
about
CBI
for
4
specific
products,
is
there
any
(
inaudible)
on
blood
5
monitoring.
I
mean,
we
think
it's
important
that
if
6
you
have
gone
through
the
process
of
selecting
7
manufacturing
or
use
facilities
and
also
control
sites
8
it
seems
important
to
have
that
final
integration
9
measure
of
human
blood
to
confirm
the
monitoring
or
10
modeling
data.

11
MR.
AUER:
On
the
human
monitoring,
as
we
noted
12
in
our
Framework
document
we're
not
proposing
to
go
13
into
that
area
at
this
juncture,
but
once
additional
14
information
of
the
types
discussed
here
as
well,
as
15
other
information
becomes
available,
we
would
be
open
16
to
revisiting
that
issue
in
the
future.
I
think
we
17
also
want
to
take
advantage
of
whatever
work
the
CDC
18
might
be
able
to
do
in
the
near
term
such
that
we
19
could
be
fully
informed
as
we
go
into
that,
and
then
20
frame
an
understanding
and
hopefully
move
to
consensus
21
as
to
what
additional
work
would
be
needed
and
how
to
22
most
effectively
orient
that
work.
73
1
MS.
THAYER:
Any
thoughts
on
the
CBI
concerns?

2
MR.
AUER:
Well,
the
CBI
areas,
as
a
general
3
matter
we
are
encouraging
the
industry
to
be
as
4
forthcoming
as
they
can
in
providing
information.
I
5
think
it
is
helpful
to
assure
other
interested
parties
6
if
there
is
understanding
at
some
level
as
to
the,
you
7
know,
the
significance
of
a
given
set
of
actions,
that
8
was
why
I
attempted
in
my
opening
remarks
to
9
characterize
the
12
chemicals
that
TRP
is
proposing
to
10
test
in
general
terms
to
give
interested
parties
some
11
sense
of
the
extent
of
coverage
which
is
afforded
by
12
those
materials,
while
at
the
same
time
there
will
be
13
some
areas
where
coverage
may
be
less
than
fully
14
adequate.

15
I
think
this
is
going
to
be
an
area
where
it's
16
going
to
be
difficult
to
go
very
far
toward
specifics,

17
but
I
think
the
challenge
is
to
figure
out
ways
where
18
we
can
be
working
with
the
industry
and
other
19
interested
parties,
convey
an
understanding
that
can
20
provide
a
measure
of
confidence
as
to
what's
covered
21
and
not
covered
in
the
work,
while
at
the
same
time
22
protecting
a
legitimate
CBI.
74
1
MR.
DUNCAN:
Just
as
kind
of
a
process
check
to
2
see
if
you're
getting
what
you
need
and
it's
kind
of
a
3
follow­
up
of
what
the
Telomer
people
just
said.
One
4
of
the
things
that
we
will
like
to
do
is
to
make
sure
5
we're
kind
of
assisting
in
this
process,
as
you
had
6
suggested
the
telomers
group
that
the
fluoropolymer
7
group
cast
its
responses
in
writing,
but
if
we
can
8
look
back
in
the
past
it
looks
as
though
our
most
9
effective
method
resolving
issues
that
are
of
great
10
concern
to
you
is
to
work
closely
to
make
sure
that
we
11
understand
what
we're
looking
for,
make
sure
we
get
12
that
data
available.

13
Our
understanding
was
that
while
we
try
to
14
identify
these
things
and
have
an
initial
response
15
today
to
those
11
items
that
the
best
and
forward
16
would
include
then
in
continuing
interactive
sessions
17
with
you
to
make
sure
we
understand
precisely
what
it
18
is
that
you're
looking
for.
Specificity
seems
to
be
19
the
most
important
characteristic
here.

20
We're
very
heartened
to
develop
in
a
relatively
21
short
period
of
time
to
come
up
with
some
statements,

22
but
what
we
really
look
forward
to
do
is
to
make
sure
75
1
that
we've
understood
what
you're
looking
for
both
in
2
terms
of
specifics
and
intensity,
so
all
I
wanted
to
3
do
is
follow­
up
of
my
original
comments
to
make
sure,

4
if
you
would
like
for
us
to
go
into
more
details
on
5
each
of
those
11
items
today
we
can,
but
we
thought
6
really
this
was
a
mechanism
that
would
take
a
of
time
7
to
make
sure
that
we
have
all
the
technical
people
in
8
place
to
elaborate
in
the
most
appropriate
manner,
as
9
to
what
those
issues
involve,
how
much
information
is
10
really
available,
how
much
information
in
your
opinion
11
needs
to
be
added
to
that,
and
that
kind
of
thing;
so
12
are
we
on
the
right
track
here,
Charlie?

13
MR.
AUER:
Yeah.
One
thing
to
note
that
if
you
14
turn
to
appendix
A
in
our
Framework
document,
there
we
15
provide
rationales
for
the
proposed
testing
and
in
a
16
number
of
these
areas
we
provide
specific
references
17
to
test
procedures,
either
EPA
test
guidelines
or
OECD
18
test
guidelines
or
ASTM
or
as
appropriate
and
19
available
in
these
areas.
Ultimately,
within
the
ECA
20
that's
the
level
of
specificity
that
we
need
to
21
provide,
which
would
include
chemicals
to
which
these
22
test
that
are
to
be
conducted
and
then
the
specific
76
1
tests
which
are
to
be
conducted,
and
recognizing
the
2
unusual
properties
of
perfluorinated
materials
and
the
3
appropriate
modifications
to
those
standard
test
4
procedures
to
allow
you
to
adequately
deal
with
the
5
specifics
of
the
material
that
would
be
the
test
6
substance.

7
So
to
the
extent
we
can
get
that
kind
of
8
specificity
either
here
or
in
follow­
up
correspondence
9
that
would
be
very
good,
knowing
the
test
protocol
10
that
is
intended
to
be
used
in
any
of
the
LOI
testing
11
of
a
given
type,
for
example,
we
have
some
of
that
12
understanding,
but
from
talking
with
my
staff
I
think
13
it's
not
clear
in
all
cases
what
is
contemplated.
It
14
may
be
that
there
are
choices
and
you
haven't
made
15
that
choice
yet,
but
to
get
that
information
to
us
so
16
that
we
can
understand
as
quickly
as
possible
what's
17
covered
and
not
covered
within
the
LOIs.

18
MS.
BITTNER:
I'm
Patte
Bittner
with
the
U.
S.

19
Consumer
Products
Safety
Commission,
and
if
you
are
20
looking
for
points
of
agreement
we
can
certainly
agree
21
that
marketing
product
information
would
be
useful
to
22
us,
identifying
which
products
contain
these
chemicals
77
1
is
very
difficult
for
us
at
this
time.
Also
we
are
in
2
agreement
that
information
would
be
useful
on
the
3
presence
of
PFOA
and
the
precursors
and
particular
4
products,
carpets
and
textiles
have
been
mentioned
5
today,
and
those
data
would
be
particularly
of
6
interest
to
us
and
products
as
they
age.

7
And
one
thing
that
perhaps
I
missed,
but
if
8
it's
not
there
that
we
would
be
interested
in
is
data
9
on
direct
photolysis
data
on
these
products,
carpets
10
and
textiles.

11
MR.
CORTINA:
I'm
Tom
Cortina.
I'm
here
on
12
behalf
of
the
Fire
Fighting
Foam
Coalition
which
is
an
13
organization
of
manufacturers
of
fire
fighting
foams
14
and
fluorosurfactants
that
are
used
in
them.
I
wanted
15
to
address
item
number
11,
but
first
I
want
to
point
16
out
that
fire
fighting
foams
are
an
extremely
small
17
use
of
telomer­
based
products,
but
a
highly
critical
18
use
in
that
they're
used
for
life
safety.
Also
fire
19
fighting
foam
fluorosurfactants
that
are
used
in
them
20
are
mostly
C6­
based
fluorosurfactant,
so
that
kind
of
21
indirectly
involves
the
issue,
but
we
did
see
item
22
number
11
of
the
telomer
item
needs
and
we
have
78
1
already
begun
to
collect
some
existing
data
in
which
2
we
just
found
out
about
some
ground
water
sampling
in
3
places
where
the
DOD
facilities
where
fire
fighting
4
foams
have
been
used,
so
we
would
like
to
collect
all
5
of
that
information
and
come
to
the
Agency
with
it
and
6
go
from
there
discussing
whether
there
is
any
7
additional
monitoring
whether
you
need
to
or
not.

8
MR.
AUER:
That
would
be
very
helpful.

9
Regarding
that
use
while
the
volume
may
not
be
great
10
of
course,
it
gets
released
into
the
environment,

11
which
is
the
reason
why
we're
focused
on
that.
As
our
12
understanding
of
this
industry
has
grown
we
have
come
13
to
appreciate
that
that's
predominantly
the
C6
14
material.
It
is
an
area
where
I
would
like
to
pursue
15
work
in
this
forum,
principally
because
of
the
direct
16
release
situation
that's
operating
there.

17
I
think
your
offer
to
collect
available
18
information
and
to
make
that
available
to
us
as
part
19
of
this
process
is
certainly
very
welcome
and
we
look
20
forward
to
receiving
that,
but
as
I've
indicated
21
because
of
the
specific
issues
which
are
presented
22
there,
we
think
it
is
important
for
us
to
consider
79
1
that.

2
I
would
also
note
that
the
Toxic
Substances
3
Control
Act
as
a
statute
is
considered
to
require
a
4
balancing
of
risks
and
benefits
and
any
control
5
actions
that
are
taken
at
the
end
of
the
day,
so
in
6
that
regard
the
nature
of
a
use
critically
used,
as
in
7
fire
fighting
foams,
is
part
of
the
important
factor
8
to
consider
in
any
such
undertaking
and
as
a
matter
of
9
the
statutory
framework
under
which
we
operate
that
10
would
be
a
part
of
that
approach.

11
I
have
obtained
information
that
the
suggestion
12
from
CPSC
for
photolysis
work
on
products
seems
to
be
13
a
new
need
that
has
been
identified.
There
is
the
14
need
identified
in
our
Framework
as
well
as
in
perhaps
15
some
of
the
LOIs,
photolysis
studies
on
the
neat
16
material,
but
evidently
the
product
of
photolysis
is
a
17
new
area,
so
I
bring
that
to
your
attention.

18
MR.
BILOTT:
Rob
Bilott
from
Taft,
Stettinius
&

19
Hollister
on
behalf
of
the
Ohio
and
West
Virginia
20
Class
Action
Claims.
I
had
a
question
giving
to
the
21
form
to
what
extent
is
there
agreement
of
certain
22
issues.
You
had
mentioned
identifying
various
80
1
manufacturing
processing
use
facilities
and
other
2
spill
locations
for
testing,
and
I
was
curious
as
to
3
where
that
stands
right
now
as
far
as
identifying
4
which
particular
facilities
would
fit
within
that
list
5
and
the
extent
to
which
there
is
agreement
on
which
of
6
those
sites
would
be
included
on
the
list.

7
MR.
AUER:
We
have
received
some
information
8
from
the
industry,
some
of
it
preceded
the
LOIs,
other
9
information
is
coming
to
us
in
the
course
of
the
LOI
10
proceeding
and
that
information
to
the
extent
we
could
11
make
it
available
will
be
in
a
record
of
this
12
proceeding,
as
well
there
is
additional
information
13
that
could
be
found
in
the
administrative
record
for
14
the
general
proceeding,
but
that
would
form
important
15
information
in
informing
us
as
to
the
possibly
for
16
monitoring
studies
that
given
are
at
different
kinds
17
of
facilities
as
part
of
this
undertaking.

18
MR.
PURDY:
Richard
Purdy.
I
was
wondering
if
19
we
could
consider
in
the
biodegradation
studies
and
20
the
other
studies
with
telomers
also
looking
at
the
21
other
telomer
products
that
wouldn't
necessarily
22
breakdown
in
PFOA.
The
reason
most
of
those
aren't
on
81
1
the
radar
screen
is
that
they
haven't
been
monitored
2
for
before
and
the
few
monitorings
that
had
been
done
3
in
terms
of
higher
concentrations
of
PFOA,
so
it
is
4
possible
that
are
going
to
be
as
important
or
more
5
important
if
we
consider
an
accumulative
class
later
6
and
as
PFOA.

7
So
I
would
like
to
suggest
that
we
look
for
8
those
products
also
in
the
studies
of
degradation
of
9
telomers.
It's
not
that
much
more
cost
to
look
at
10
those
along
with
PFOA
(
inaudible)
and
look
at
several
11
compounds
in
a
single
run
and
that
would
be
just
a
12
matter
of
standards
and
standard
terms.

13
MR.
AUER:
Rich,
is
your
proposal
directed
to
14
what
you're
attempting
to
detect
being
formed
through
15
the
degradation
product
or
is
it
the
starting
material
16
for
the
degradation?

17
MR.
PURDY:
I
don't
understand
your
question.

18
MR.
AUER:
Are
you
proposing
that
we
do
19
biodegradation
studies
on
­­

20
MR.
PURDY:
There
are
proposals
to
do
it
on
21
telomers
and
telomer
products
and
telomers
containing
22
other
compounds
that
will
break
down
to
PFOA,
and
you
82
1
will
find
those
if
you
look
for
them,
if
you
don't
2
look
for
them
then
you
won't
have
that
information,

3
they'll
be
there
in
the
matrix,
but
you
won't
4
necessarily
analyze
for
them
unless
you
decide
to
up
5
front.
Like
photo
degradation
studies
of
a
6
degradation
of
a
polymer
that's
used
for
carpet
7
treatments,
you
possibly
can
get
PFOA
out
there,
but
8
also
PFDA
and
so
forth.

9
MR.
AUER:
Okay.
Well,
we're
interested
in
10
identifying
PFOA
precursors,
so
to
the
extent
­­

11
MR.
PURDY:
Well,
PFDA
shouldn't
be
a
precursor
12
of
PFOA,
but
PFDA
is
found
in
higher
concentrations
in
13
the
environment
than
most
(
inaudible)
than
PFOA
and
14
they
obviously,
where
can
they
come
from
but
telomers.

15
MR.
AUER:
I
think
one
way
to
try
to
handle
16
this
is
to
­­
I
mean
this
is
really
a
questions
of
17
what
you're
looking
for
as
the
biodegradation
products
18
from
a
given
material,
and
depending
on
what
the
19
starting
material
is
for
that
is
kind
of
an
issue
that
20
could
be
presented,
and
I
would
suggest
that
we
take
21
it
up
when
we
get
to
that
point
in
the
process,
so
it
22
would
be
in
the
more
technical
discussions
as
to
the
83
1
specifics
of
what
you're
looking
for
in
those
studies.

2
MR.
PURDY:
Thank
you.

3
MS.
ALLER:
I'm
Linda
Aller
from
Bennett
&

4
Williams
we
work
for
a
consultant
company.
I
noticed
5
as
part
of
appendix
A
that
you
were
listing
specific
6
chemical
properties
that
you
wanted
to
make
sure
you
7
had
information
for,
and
I
just
wanted
to
encourage
8
you
not
to
think
that
this
is
an
inclusive
list
of
9
everything
that
might
be
needed.
I
know
in
hunting
10
for
specific
chemical
properties
they
might
be
11
available
to
the
companies,
but
they're
not
12
necessarily
available
publicly,
so
when
the
chemical
13
process
is
done
you
have
a
complete
list
of
things
14
including
density
and
effects
of
PFOA
and
some
of
15
chemicals
it
would
be
helpful.

16
MR.
AUER:
If
there
are
specific
areas
that
you
17
would
like
to
suggest
in
that
regard,
that's
the
kind
18
of
additional
data
need,
so
I
encourage
you
to
either
19
enumerate
them
now
or
it
would
be
better
to
submit
20
them
as
written
comment.

21
MS.
ALLER:
Well,
one
in
particular
would
be
22
density,
it
has
a
lot
to
do
with
what
you
would
84
1
collect
for
samples,
particularly
ground
water,
in
the
2
environments,
some
of
other
things
that
we've
noticed
3
is
a
correlation
between
PFOA
and
levels
of
C8
found
4
specifically
in
ground
water
that
may
also
go
to
soil
5
as
well,
so
those
would
be
two
specific
ones
off
the
6
top
of
my
head
that
should
be
included
somewhere
along
7
the
line,
and
I
could
provide
additional
comments
8
later.

9
MR.
AUER:
That
would
be
great.

10
MS.
ALLER:
Thank
you.

11
MR.
AUER:
Well,
I
don't
see
any
more
hands.

12
We
are
scheduled
to
take
a
break
right
about
at
this
13
point
in
the
meeting.
Why
don't
we
come
back
at
2:
20
14
and
give
ourselves
a
little
bit
more
time.
What
I
15
would
like
people
to
do
is
to
talk
amongst
yourselves
16
as
interested
parties
want
to
talk
about
certain
17
things
and
what
I'm
looking
to
get
in
the
next
18
discussion
is
to
develop
opportunities
and
approaches
19
for
how
we
might
go
forward,
this
is
where
I
would
try
20
to
identify
those
areas
that
might
be
appropriate
for
21
spinning
them
off
into
technical
discussions
at
an
22
earlier
point,
other
things
that
might
be
more
85
1
appropriate
for
additional
plenary
discussions,
how
we
2
might
approach
it
in
the
plenary,
basically
how
we
3
work
the
process
to
help
us
move
along
the
path
4
towards
consensus
on
specific
issues.
So
why
don't
we
5
take
a
break
now
and
come
back
at
2:
20.
Thank
you.

6
(
Short
break.)

7
MR.
AUER:
We're
now
at
the
point
in
the
agenda
8
where
I
want
to
identify
and
discuss
opportunities
and
9
approaches
for
moving
towards
agreement
in
principle
10
in
specific
areas
where
we
might
be
able
to
spin
the
11
work
into
technical
subgroups
and
then
other
areas,

12
issues
where
there's
still
issues
that
would
benefit
13
from
plenary
discussions
in
order
to
reach
the
14
agreement
in
principle
and
then
handle
those
in
the
15
future
in
forum
such
as
this.

16
We're
particularly
interested
in
attempting
to
17
identify
topics
that
would
be
amenable
to
quick
18
resolution,
those
would
be
ones
that
would
benefit
now
19
from
going
into
technical
discussions
to
discuss.

20
Certain
fate
testing
might
be
an
area
that
would
work,

21
and
then
others
that
would
require
more
discussion.

22
To
the
extent
there
are
areas
where
there's
86
1
agreement
in
principle
at
this
point
where
we
could
2
move
into
technical
groups,
what
I
would
be
looking
to
3
at
that
point
is
to
identify
the
specific
interested
4
parties
who
know
at
this
point
that
they
would
be
5
interested
in
participating
in
what
would
be
more
6
expert
discussions
about
protocols
and
conditions
and
7
et
cetera,
et
cetera,
such
that
we
can
then
constitute
8
those
groups
and
arrange
for
those
discussions
to
9
occur
over
a
period
of
time
after
which
that
group
10
would
report
back
to
a
plenary
session,
they
would
11
also
report
back
to
the
plenary
on
progress,
with
the
12
goal
ultimately
of
that
group
working
to
refine
the
13
agreement
and
then
to
bring
a
proposal
back
into
the
14
plenary
where
we
test
the
consensus
and
then
see
if
15
there's
agreement
among
the
interested
parties
such
16
that
we
could
move
to
actually
drafting
and
finalizing
17
the
Enforceable
Consent
Agreement.

18
Other
issues
where
there's
perhaps
less
19
specifics
available
in
the
form
of
test
guidelines
or
20
test
standards,
those
are
the
kinds
of
things
that
21
might
benefit
from
more
discussion
in
the
plenary
such
22
that
we
could
come
to
a
general
agreement
as
to
the
87
1
scope
of
those
activities,
where
you're
not
trying
to
2
define
the
specifics
of
what
would
be
done,
the
3
methods
and
whatnot,
but
you
would
be
talking
more
4
about
the
shape
of
that
activity,
thinking
here
5
specifically
about
monitoring
studies
or
perhaps
the
6
product
work,
the
aging
product
work,
and
if
we
could
7
have
that
kind
of
a
discussion
perhaps
in
plenary,
you
8
then
can
perhaps
reach
a
general
understanding
and
9
agreement
in
principle
on
that
scope,
and
then
that
10
would
be
referred
to
a
technical
group
made
up
of
11
expert
representatives
amongst
the
interested
parties,

12
who
would
then
work
out
at
a
more
specific
level
of
13
detail,
the
nature
of
the
work
to
be
undertaken
and
14
whatnot,
and
then
that
would
be
brought
back
to
15
plenary
and
you
test
to
see
whether's
agreement
or
not
16
and
then
you
would
proceed
to
finish
that
up.

17
When
you
have
gotten
to
the
point
of
bringing
18
it
back
to
plenary
and
getting
that
agreement
that
19
this
product
from
the
technical
group
is
satisfactory,

20
at
that
point
the
next
step
involves
the
submission
of
21
the
detailed
proposals
for
testing,
these
are
22
developed
by
the
sponsors
of
the
testings,
would
be
88
1
the
companies
who
would
be
responsible
for
doing
that
2
testing,
so
that
would
then
give
you
the
more
specific
3
details,
it
would
be
similar
to
the
kind
of
test
4
standard
requirements
that
appear
in
other
enforceable
5
consent
agreements
that
we
have
developed
where
we've
6
got
(
inaudible)
statements
and
(
inaudible)
statements
7
and
certain
specific
requirements
that
have
to
be
met.

8
That
would
be
the
responsibility
of
the
test
sponsor
9
to
elaborate
the
understanding
at
that
level,
and
then
10
the
whole
package
is
brought
together
and
if
agreement
11
can
be
obtained,
that
then
goes
forward
taking
the
12
form
of
an
enforceable
consent
agreement,
which
would
13
have
the
dates
associated
with
certain
tests
and
14
whatnot
and
then
when
that's
finalized
the
responsible
15
parties
go
off
and
do
the
work
and
then
those
are
16
reported
back.
And
that's
pretty
much
the
way
that
17
the
process
works.

18
EPA
would
be
working
to
at
the
same
time
once
19
you've
got
to
that
point
to
develop
the
specific
20
language
that
goes
into
the
Enforceable
Consent
21
Agreement,
the
protocol­
related
material
is
attached
22
to
that,
you've
got
the
Enforceable
Consent
Agreement
89
1
with
some
boilerplate
sections,
as
well
as
specific
2
sections
as
appropriate
to
this
action
and
then
3
attached
to
that
you've
got
the
protocol
elements,
and
4
then
that
entire
package
constitutes
the
Enforceable
5
Consent
Agreement.

6
So
at
this
point
I
would
like
us
to,
as
the
7
agenda
suggests,
focus
on
identifying
ECA
topics
that
8
might
be
amenable
to
quick
resolution,
that
way
we
9
might
be
able
to
spin
them
into
technical
10
consultations
which
could
happen
sometime
in
the
11
coming
weeks
to
begin
moving
towards
closure
on
the
12
specifics,
and
then
that
would
be
followed
by
13
discussions
of
other
areas
of
where
we
might
have
need
14
for
additional
discussion
in
plenary.

15
So
I
hope
for
those
of
you
who
haven't
been
16
involved
in
this
process
previously,
it
is
17
sufficiently
clear
as
to
what
I
am
trying
to
do,
if
18
there
are
any
questions
I
would
be
happy
to
attempt
to
19
clarify,
but
at
this
point
I
would
like
to
open
the
20
floor
to
the
interested
parties
for
purposes
of
21
identifying
specific
opportunities
for
early
progress.

22
Environmental
Working
Group
followed
by
SPI.
90
1
MS.
THAYER:
Kris
Thayer
from
the
Environmental
2
Working
Group.
I
was
wondering
if
we
might
think
3
about
maybe
a
process
for
given
some
of
the
CBI
4
issues,
just
from
you
know
our
perspective
when
we
are
5
talking
about
specific
products
that
might
be
tested,

6
are
we
going
to
be
given
the
information
at
the
level
7
of
carpet,
paper,
textile
products,
will
it
be
popcorn
8
bags,
Stain
Master,
specific
products,
and
so
without,

9
you
know,
I
am
a
little
concerned
that
if
we
don't
10
have
details,
it's
going
to
be
difficult
for
us
to
11
evaluate
whether
the
breadth
of
product
testing
is
12
sufficient.
And
so
I
was
wondering
if
maybe
you
can
13
think
about
any
way
to
address
those
issues
in
14
short­
term?

15
MR.
AUER:
What
I
would
suggest
for
16
consideration
by
the
interested
parties
is
perhaps,
I
17
think
probably
a
small
group
with
particular
interest
18
in
this
area
might
go
off
and
try
some
general
19
discussions,
so
that
there's
a
clear
understanding
of
20
the
needs
and
expectations
of
the
parties
and
to
see
21
if
there
is
some
way
where
information
could
be
22
provided
at
a
level
that
begins
to
speak
to
some
of
91
1
needs
of
certain
interested
parties,
while
at
the
same
2
time
protecting
CBI
interests
of
others.

3
And
what
I
have
in
mind
is
something
that
would
4
be
along
the
lines
of
what
I
described
in
my
opening
5
remarks,
which
is
that
the
characterization
of
the
6
kinds
of
products
that
the
12
chemicals
covered
and
7
the
fraction
of,
at
least
a
general
statement
as
to
8
the
portion
of
the
market
that
was
represented.

9
This
is
the
kind
of
thing
where
with
those
10
discussions
there
may
be
ways
that
EPA
could
apply
11
those
understandings
in
a
way
that
could
provide
12
information
at
a
more
general
level
of
detail
that
13
would
balance
out
the
two
competing
interests,
and
I
14
tell
you
it's
a
lot
easier
for
us
to
try
to
do
that
if
15
we're
working
with
people
that
have
an
interest
in
16
this
issue
than
if
we
try
to
do
it
against
the
strict
17
requirements
that
we
have.

18
So
I
think
at
this
point
I'll
let
you
think
19
about
that
concept,
let
the
room
think
about
the
20
concept
and
then
we
can
come
back
to
it
and
then
21
perhaps
reach
some
understanding
as
to
how
we
might
22
proceed
with
that
area.
92
1
MS.
THAYER:
We
would
definitely
be
interested
2
in
pursuing
it.

3
MR.
AUER:
Don,
SPI.

4
MR.
DUNCAN:
Charlie,
with
respect
to
trying
to
5
pick
some
low
hanging
fruits
and
to
maybe
come
up
with
6
some
ideas
particularly
on
how
we
might
put
some
7
substance
behind
the
ECA
targets,
I'm
wondering
if
I
8
might
take
the
12
fluoropolymers
11
items
that
were
in
9
your
Framework
and
maybe
comment
on
four
or
five
of
10
them
either
to
invoke
discussion
or
to
solicit
11
unanimity
around
it
as
a
method
of
getting
the
process
12
started.
Would
that
be
okay?

13
MR.
AUER:
That
would
great.

14
MR.
DUNCAN:
If
you
would
excuse
my
back
now,
I
15
would
like
to
refer
to
my
notes.
I
would
like
to
get
16
this
right.
I
am
a
chemical
engineer
by
training
I
17
would
like
to
make
sure
that
something
as
complicated
18
as
this
subject
gets
done
and
at
least
in
as
19
technically
correct
manner
as
possible.

20
What
I
would
like
to
do
is
to
refer
to
probably
21
four
or
five
of
the
11
items
that
are
included
in
the
22
fluoropolymers
piece
of
the
Framework,
and
at
least
93
1
offer
to
you
some
thoughts
in
terms
of
where
the
2
fluoropolymers
industry
is
and
then
allow
that
maybe
3
to
provoke
discussion
and
if
necessary
we
just
take
4
one
at
a
time
until
the
discussions
is
finished.

5
MR.
AUER:
Or
if
you
want
to
outline
it
and
6
then
we
can
perhaps
get
a
general
reaction.

7
MR.
DUNCAN:
Outline
four
or
five
first?

8
MR.
AUER:
That
would
be
good.
And
I
am
hoping
9
that
I
just
get
everyone
to
agree.

10
MR.
DUNCAN:
Okay.
Let's
go
for
it.
The
first
11
item
I
would
like
to
call
your
attention
to
is
item
8
12
in
that
list.
And
item
8
calls
for
the
determination
13
of
incineration
byproducts
of
fluoropolymer
and
14
fluoropolymer
treated
products
and
articles.
Although
15
some
information
is
available
on
incineration
of
16
fluoropolymers
in
this
information
­­
and
this
17
information
is
publicly
availability,
I
think
clearly
18
in
light
of
the
situation
we
find
ourselves
in
today,

19
the
industry
groups
supports
the
need
for
incineration
20
testing
to
better
characterize
potential
byproducts
of
21
fluoropolymer
incineration.
We
recognize
that
what
22
may
be
currently
in
the
information
that's
part
of
the
94
1
public
domain
may
not
be
complete
enough
and
certainly
2
maybe
hasn't
had
the
kind
of
scrutiny
that
it
deserves
3
in
today's
environment.

4
We
would
like
to
suggest
that
this
is
one
of
5
the
things
that
we
can
agree
to,
but
like
a
lot
of
6
other
things,
the
devils
and
details
with
respect
to
7
precisely
how
that
analysis
will
take
place,
what
8
we'll
look
for,
how
the
samples
are
taken,
et
cetera,

9
but
I
think
what
we
want
to
do
as
an
industry
group
is
10
to
say
that
we
concur
with
that
analysis.

11
Even
more
importantly,
if
I
can
move
onto
item
12
9,
before
you
can
get
to
item
9
you
really
have
to
13
have
done
what
needs
to
be
done
in
item
8,
and
so
14
while
item
9
calls
for
determination
of
physical
15
chemical
fate
and
transport
properties
in
incineration
16
products,
we
really
think
that
should
be
deferred
17
until
we
get
a
pretty
good
comprehensive
assessment
of
18
what
the
incineration
byproducts
are.
And
then
after
19
that
determination
is
made,
then
launch
into
the
item
20
9
piece
with
some
degree
of
understanding
as
to
what
21
it
is
we're
going
to
go
into.

22
So
those
two
we
see
kind
of
joined
at
the
hip
95
1
saying
the
first
priority
should
be
with
item
8,
and
2
let's
use
the
best
available
technology
we've
got
3
today
to
define
what
those
incineration
products
are.

4
If
we
do
item
8
right
it
seems
as
though
that
then
5
leads
us
to
the
proper
dealing
with
item
9.

6
The
next
item
I
would
like
to
put
up
then
for
7
consideration
is
item
7,
and
that
calls
for
the
8
determination
of
the
presence
of
PFOA
emitted
from
9
fluoropolymer
treated
products
and
articles
as
they
10
age
during
use.
The
test
substances
are
to
be
11
representative
fluoropolymers
from
manufacturers
and
12
importers
in
indoor
air
adjacent
to,
and
dust
from
or
13
adjacent
to,
in
your
case
you
said
carpet,
textile,

14
and
paper.
Carpet,
textile,
and
paper
are
not
15
necessarily
the
principle
market
segments
into
which
16
the
fluoropolymers
go
into,
but
I
think
if
we
kind
of
17
went
back
to
the
some
of
the
expectations
that
we
put
18
into
our
Letter
Of
Intent
with
respect
to
what
the
19
primary
data
screen
consumer
contact
applications
for
20
fluoropolymers
are,
we
see
this
is
a
very
responsible
21
area
consistent
with
what
we
inferred,
maybe
not
in
22
enough
detail,
but
certainly
what
we
inferred
what
we
96
1
were
looking
to
do
in
the
LOI,
so
again
we
think
this
2
is
appropriate
fine
tuning
it,
so
it
is
very
specific
3
to
those
appropriate
products
that
are
fluoropolymer
4
based,
is
something
that
the
industry
would
not
5
already
agree
to
it,
but
I
think
we
are
already
6
dedicated
to
doing
it.

7
So
that
would
be
item
7,
the
other
candidate
8
that
I
would
nominate
would
be
item
1.
And
item
1
9
calls
for
comprehensive
fluoropolymer
market
10
information,
including
CAS
numbers,
chemical
names
and
11
so
on
and
so
forth.
I
think
I
can
just
briefly
make
12
the
position
that
we
in
the
industry
think
that's
a
13
very
legitimate
request
and
we
fully
support
it,
and
14
if
that's
appropriate
for
an
ECA
item,
we
would
be
15
more
than
willing
to
provide
whatever
data
is
16
necessary
to
make
sure
that
that's
done
correctly.

17
And
then
in
the
last
item
I
would
comment
on
18
would
be
item
11.
And
item
11
calls
for
product
19
stewardship
information
concerning
PFOA
and
20
fluoropolymer
products
and
article
manufacture,
use,

21
and
disposal.
Product
stewardship,
as
you
heard
from
22
a
number
of
speakers
including
Dr.
Chowdhry,
is
an
97
1
integral
part
of
the
entire
plastics
industry,
so
from
2
a
concept
from
a
philosophical
standpoint
there
is
3
absolutely
no
divergence
opinion
on
that.
If
4
anything,
I
think
one
of
the
things
that
maybe
makes
5
this
something
more
than
just
another
good
apple
pie,

6
is
that
the
context
of
product
stewardship
in
the
last
7
five
years
or
so
has
increased
significant.
And
so
I
8
think
bringing
the
full
scope
of
the
current
9
definitions
of
the
product
stewardship
to
bear
on
this
10
issue
is
not
only
appropriate,
but
something
that
11
we're
fully
committed
to
doing.

12
Like
so
many
other
things,
I
think
the
13
definition
of
product
stewardship
that
we
need
to
make
14
sure
that
we
agree
about
that
is
both
the
American
15
Chemical
Society
­­
excuse
me
­­
the
American
16
Chemistry
Counsel
and
the
(
inaudible)
Group
have
17
responsible
care­
type
programs,
they're
pretty
much
18
overlapping,
but
I
think
we
just
want
to
make
sure
19
which
one
would
be
the
one
we
use
as
the
basis
for
20
reporting
back
to
you.
So,
again,
I
think
that's
21
something
that
we
can
agree
to.

22
Now,
the
other
items,
I'm
not
just
leaving
them
98
1
out
because
we're
not
in
agreement
or
anything,
but
I
2
thought
those
are
the
ones
that
we
can
say
very
much
3
up
front
we
agree
with,
we
think
they
are
appropriate.

4
Obviously
there
is
some
definitional
issues,
testing
5
issues,
that
type
of
thing,
but
those
are
the
kinds
of
6
things
that
could
be
given
to
the
subgroups
and
7
challenge
to
work
out
the
appropriate
details
8
necessary
to
make
sure
we
got
the
appropriate
9
responses
and
come
back.

10
So,
Charlie,
that's
an
attempt
to
get
in
touch
11
of
what
we're
trying
to
do
in
this
process.

12
MR.
AUER:
That's
very
helpful,
Don.
I
13
appreciate
that.
Some
points
for
you
and
the
others
14
to
consider,
as
described
in
the
table
work
such
as
15
that
on
8
would
be
applied
to
representative
16
fluoropolymer
and
fluoropolymer
treated
articles.
I
17
think
this
is
the
kind
of
thing
that
could
be
18
discussed
and
elaborated
in
technical
discussions.

19
The
other
point
is
that
the
suggestion
you
made
20
regarding
number
1,
the
comprehensive
market
21
information,
maybe
there's
a
way
for
that
to
be
22
combined
with
Kris's
suggestion
of
EWG,
maybe
for
99
1
purposes
of
the
ECA
that
should
be
information
at
a
2
non­
CBI
level,
which
could
then
be
made
available
to
3
appropriately
inform
the
public
interested
parties
in
4
these
areas
and
then
you,
under
the
LOI,
have
been
5
committed
to
provide
us
with
that
information
much
of
6
it
company
specific
and
CBI,
so
perhaps
that
is
one
7
way
where
you
could
work
towards
this
commitment
and
8
then
the
engagement
with
EWG
and
others
come
to
9
understand
the
needs,
and
in
fact
come
up
with
a
10
better
way
of
meeting
those
needs
while
protecting
the
11
general
interest,
so
I
offer
that
for
the
12
consideration
by
the
room.
West
Virginia,
Dee
Ann.

13
MS.
STAATS:
Yes.
I
would
think
that
item
14
number
2,
the
physical
chemical
properties
to
inform
15
fate
testing,
would
be
another
item
that
probably
the
16
industry
has
most
of
the
information
already
on
that,

17
and
is
something
they
can
move
forward
rather
quickly
18
with
a
technical
group
focused
on
that
that
reports
19
back
to
the
plenary
and
itemizes
and
defines
what
20
physical
chemical
properties
that
they
want
and
the
21
testing
to
be
done,
which
probably
already
has
been
22
done
in
most
situations.
100
1
And
the
idea
that
this
lady
over
here
had
about
2
adding
density
in
there
(
inaudible)
of
pH
on
the
3
migration
and
the
chemical
physical
properties
of
PFOA
4
as
it
moves
through
the
environment.

5
MR.
AUER:
Thank
you
for
that.
That
was
Dee
6
Ann
Staats
from
West
Virginia
Department
of
7
Environmental
Protection.

8
DR.
THOMAS:
Good
afternoon.
My
name
is
Dr.

9
Treye
Thomas
and
I'm
with
the
U.
S.
Consumer
Product
10
Safety
Commission.
And
we
are
interested
it
what
has
11
been
mentioned
about
determining
in
which
products
12
these
compounds
can
be
found
and
we
are
interested
in
13
some
of
CBI
information
as
well.
We
would
like
to
14
know
as
comprehensively
as
possible
where
these
15
compounds
can
be
found,
particularly
consumer
products
16
where
there
would
be
more
direct
exposure.
We're
also
17
interested
in
other
compounds
as
it's
been
mentioned
18
earlier,
that
maybe
in
the
PFOA
families
that
may
or
19
may
not
be
precursors,
but
again
may
have
the
20
potential
exposure
in
consumer
products.

21
MR.
AUER:
Okay,
well,
we
can
certainly
arrange
22
to
share
CBI
with
a
sister
agency,
and
so
that
can
be
101
1
arranged,
part
of
that,
and
then
as
far
as
other
2
chemicals,
I
think
they're
useful
to
understand
and
3
perhaps
useful
to
have
a
discussion
offline
about
4
those,
the
specifics
of
your
interest
in
this
regard
5
and
then
we
can
consider
how
that
might
be
brought
6
into
this
forum
or
if
it's
appropriate
for
dealing
7
with
in
another
forum.
Thanks
for
that.

8
MR.
PURDY:
Rich
Purdy.
I
got
a
question
and
I
9
am
a
little
bit
confused,
and
I
think
it
came
up
when
10
you
talked
about
the
products
for
the
­­
that
would
be
11
tested
for
the
polymers
because
under
the
polymers,
I
12
assume
that
you
meant
mainly
PFE
type
of
polymers
and
13
not
polymers
that
would
be
made
up
of
telomers,
which
14
would
also
be
considered
as
fluoropolymers.
And
since
15
whoever
wrote
that
put
the
products
that
are
the
16
fluorotelomers
in
there
I
just
wanted
to
know
if
there
17
is
a
clear
distinction
that
that
second
list
of
tests
18
is
just
for
the
Teflon­
type
polymers
and
if
the
first
19
list
is
for
telomer­
type
chemicals
which
include
20
polymers
with
telomers
­­
using
telomers.

21
MR.
AUER:
Well,
it
is
my
understanding,
let
me
22
try
that,
is
that
Don
was
speaking
to
the
102
1
fluoropolymer
manufacturers
and
I
am
looking
forward
2
to
hearing
from
the
telomer
group.

3
MR.
PURDY:
I
was
curious
if
you,
the
EPA,
made
4
a
distinction
whether
the
telomer­
based
polymers
are
5
in
the
first
group
or
the
second
group.

6
MR.
AUER:
Our
understanding
is
that
they
are
7
in
the
TRP
group,
but
I
could
stand
to
be
corrected
in
8
that
regard.
What
I'm
trying
to
do
here
is
to
be
as
9
clear
as
we
can
and
the
proposals
that
are
being
10
offered
and
those
limits
and
I
would
presume
that
11
there
would
be
one
set
of
ECAs
for
fluoropolymers
and
12
a
separate
set
of
ECAs
for
telomers
as
the
ultimate
13
product.
And
it
may
be
that
some
issues
are
ready
to
14
go
into
technical
groups
from
both
of
those
entities
15
and
there
are
other
issues
where
one
is
ready
and
16
other
are
issues
that
would
benefit
from
plenary
17
discussion.

18
MR.
PURDY:
I
guess
my
concern
is
if
you
have
a
19
telomer­
based
polymer
and
you
should
be
looking
at
it
20
holistically
in
one
that
can
break
down
(
inaudible)
of
21
the
telomers
can
break
it
down,
and
you
would
­­
your
22
evaluation
you
would
probably
want
to
keep
them
103
1
together
rather
than
putting
them
in
the
two
different
2
groups
you
have
right
now,
the
polymer
group
and
the
3
group
of
chemicals
that
could
break
down
into
PFOA.

4
MR.
AUER:
Well,
it
is
the
kind
of
issue
where
5
I
think
the
starting
point
for
it
is
to
deal
with
the
6
industry
that's
associated
with
that
product
and
it
7
may
be
that
as
you
have
these
discussions,
there's
8
agreement
to
try
to
work
together
and
find
9
commonalities
wherever
possible
or
they
have
10
separately
come
into
the
plenary,
and
that's
another
11
opportunity
to
try
to
look
for
more
common
approaches
12
as
appropriate.

13
MR.
PURDY:
I
don't
think
it's
a
big
issue,
I
14
just
think
it's
just
the
way
they're
split
or
lumped.

15
MR.
AUER:
I
think
that
at
least
the
starting
16
point
is
that
the
way
that
we
present
it
is
that
you
17
have
the
telomer
portion
and
you
have
the
18
fluoropolymer
portion,
we
could
agree
here
to
lump
19
them
or
we
can
agree
here
to
split
them.
I
mean,
the
20
hand's
in
the
group,
but
as
I
say
the
starting
point
21
is
to
keep
them
separate
and
to
maintain
that
and
22
eventually
it
will
come
back
to
plenary
and
if
it
104
1
looks
like
a
good
ideas
for
one
group,
for
those
to
be
2
considered
in
the
other.

3
MR.
DUNCAN:
Just
to
respond
to
that
for
a
4
minute,
while
we
can
see
the
technical
maybe
incentive
5
for
that
there's
some
practical
incentives
basically
6
starting
with
the
LOI
procedures
that
already
have
7
kind
of
lined
up
a
process
that
we're
going
to
follow
8
here,
so
we
would
just
like
to
put
it
in
our
vision
to
9
try
to
maintain
that
continuity
and
the
degree
of
10
coordination
between
the
groups
integrity
of
those
11
LOI­
based
and
then
subsequent
ECA­
based
things
is
very
12
important
I
believe,
but
we
will
try
not
to
let
that
13
be
a
barrier
between
the
two
groups.

14
MS.
SMYTHE:
Katie
Smythe
for
the
Telomer
15
Research
Program.
Just
a
point
of
clarification,
two
16
points
actually,
one
in
response
to
the
CPSC
question
17
earlier
today
about
photolysis.
There
is
work
that
is
18
already
under
the
Letter
Of
Intent
that
has
been
19
planned,
it
is
in
the
design
mode
to
monitor
PFOA
20
formation
on
consumer
products,
carpets
and
textiles,

21
and
that
the
study
plans
have
already
been
submitted
22
to
EPA
and
the
protocol
is
being
developed
now,
the
105
1
work
will
proceed,
but
that
is
already
under
the
LOI,

2
so
it's
already
in
place.

3
Other
items
specifically,
and
we'll
provide
the
4
details
item­
by­
item
based
on
what
was
laid
out
in
the
5
EPA
Framework
Document,
but
the
bulk
of
the
items
are
6
already
addressed
in
some
manner
under
the
LOI,
but
we
7
will
offer
­­
the
TRP
is
already
offering
to
expand,

8
preferably
for
the
sake
of
doing
the
work
in
a
more
9
timely
manner
we
can
expand
the
LOI
items
or
it
can
be
10
offered
as
an
item
for
the
technical
discussion
11
through
the
ECA
process.
But
the
items
specifically
12
relate
to
analyzing
for
the
telomer
alcohol
raw
13
material
in
products
which
addresses
ECA
item
7,

14
that's
an
addition
that
the
TRP
is
ready
to
move
15
forward
on.
Analyzing
also
telomer
alcohol
in
aged
16
products
which
is
addressing
ECA
item
9,
and
the
third
17
area
would
be
the
release
and
exposure
assessments
18
which
is
ECA
item
10.
That's
the
addition
of
the
19
telomer
alcohol.

20
The
second
addition,
if
you
will,
is
21
incineration
studies
on
telomer
products,
which
we
22
agreed
to
move
forward
on
that
work
that
is
addressing
106
1
ECA
item
5.
In
both
of
these
areas
they're
looking
to
2
address
the
fate
issue,
which
has
been
obviously
the
3
cornerstone
to
EPA's
comments
on
the
ECA.
And
we
can
4
certainly
provide
the
details
of
the
other
items
in
5
our
follow­
up
written
submission.
But
again
these
two
6
items,
telomer
alcohol
work
and
the
incineration
7
studies,
we
would
have
a
preference
to
do
it
under
the
8
current
Letter
of
Intent
to
expand
our
Letter
of
9
Intent
commitments
just
because
it
would
be
faster
to
10
do
it
in
that
mode.
Thank
you
11
MR.
AUER:
Thank
you
for
that.
As
we
12
indicated,
we
certainly
want
to
keep
whatever
work
13
that's
been
committed
under
the
LOIs
within
the
LOIs
14
to
speed
that
work.
You
know
one
proposal
to
offer
15
here
perhaps
bring
the
group
to
either
agreement
or
16
disagreement
in
this
area
is
to
accept
the
suggestions
17
made
by
SPI
and
by
the
TRP,
it
seems
like
a
good
18
starting
point
in
those
technical
discussions
would
be
19
to
lay
out
the
details
of
what
would
be
handled
within
20
the
LOIs,
that
technical
group
can
then
consider
that
21
and
if
there
are
additional
issues
or
needs
that
22
emerge,
those
could
be
dealt
with
as
appropriate
in
107
1
that
group
and
can
be
brought
back
to
the
plenary.

2
And
I
think
that
that
affords
an
opportunity
for
3
clarity
for
all
of
the
interested
parties
as
to
the
4
work
that
would
be
included
within
the
LOI
and
any
5
work
that
would
be
appropriate
for
being
dealt
with
6
otherwise.

7
So
let
me
test
that
suggestion
around
the
room.

8
I
am
asking
for
you
to
agree
to
constitute
a
technical
9
panel,
whether
it
is
one
or
two
you,
can
figure
out
10
the
details
of
that,
that
we
would,
or
however
many
11
are
appropriate,
that
we
would
have
the
issues
that
12
have
been
mentioned
by
SPI
which
were
number
8
and
the
13
question
triggering
the
findings
from
number
8,
which
14
I
think
is
pretty
much
contemplating
that
in
our
15
proposal,
number
7
the
presence
as
products
age,

16
number
1
the
market
information,
and
I
think
products
17
to
which
I
don't
know
if
we
need
a
discussion
per
se,

18
we
can
work
out
the
language
to
incorporate
that
19
within
the
ECA.

20
And
then
the
other
would
be
to
consider
with
21
regard
to
the
telomers
the
items
under
7,
9
and
10
22
where
TRP
has
indicated
that
they
are
including
the
108
1
telomer
alcohol
as
a
precursor
in
that
LOI
testing,

2
and
then
otherwise
to
discuss
what
would
come
forth
3
under
the
LOI
and
then
consider
whether
there
are
any
4
additional
needs
that
should
be
considered
and
then
5
number
5
on
the
incineration
studies.

6
So
I
am
proposing
to
get
agreement
in
the
group
7
to
move
to
those
into
technical
discussions.
Okay.
I
8
think
I
have
the
agreement
in
the
group.
Thank
for
9
that.

10
I
have
given
you
a
chance
to
think
about
EWG's
11
CBI
proposal,
I
would
suggest
a
way
to
possibly
link
12
that
into
item
number
1,
asked
TRP
to
think
about
your
13
willingness
to
move
in
this
direction
as
well.
I
14
wonder
if
there
is
any
reaction
to
my
thought
starter
15
proposal
of
trying
to
get
a
small
group
that
could
go
16
off
and
talk
about
this
issue
and
come
to
provide
the
17
understanding
as
to
the
needs
and
expectations
and
18
whatnot,
and
see
if
there's
some
general
guides
to
set
19
that
may
be
able
to
come
forward
as
to
the
kind
of
20
information
that
would
be
provided
in
non­
CBI
form
as
21
part
of
the
ECA
to
provide
the
information,
otherwise
22
in
number
1
in
the
EPA
Framework.
109
1
So
any
reaction
to
that
proposal?
Silence
is
2
agreement.

3
MR.
DUNCAN:
We
would
certainly
agree
to
be
a
4
part
of
the
team.

5
MR.
AUER:
That
was
Don
Duncan.
Anyone
from
6
TRP?

7
MS.
SMYTHE:
TRP
also
would
be
willing
to
8
agree.

9
MR.
AUER:
Thank
you.
So
TRP
has
also
agreed
10
to
participate
in
that.

11
MS.
BITTNER:
Patte
Bittner
from
the
Consumer
12
Product
Safety
Commission.
We
would
certainly
want
to
13
be
part
of
that
discussion.
I
did
want
to
ask
Don
14
however
with
number
1
are
you
­­
initially
were
you
15
suggesting,
Don,
that
you
would
provide
the
use
under
16
use
application
and
information
just
general
17
categories
or
would
you
also
be
willing
to
share
who
18
your
members
might
be
selling
to,
so
that
we
could
get
19
further
information
on
the
products
specifically?
I
20
guess
I
am
wondering
if
it
is
a
general
thing
or
if
we
21
could
find
out
what
specific
products
might
be
22
included.
110
1
MR.
DUNCAN:
At
the
risk
of
this
becoming
a
2
dialogue,
I
think
maybe
the
best
thing
is
for
us
to
3
get
together
outside
this
room
and
talk
about
it,
but
4
part
of
the
things
that
maybe
you're
interested
in
we
5
have
included
in
the
LOI
in
the
area
fluoropolymer
6
applications,
and
we
have
tried
to
take
fluoropolymer
7
applications
and
split
them
up
into
various
critical
8
application
areas,
one
of
which
consumer
products,

9
consumer
oriented
products.
I
think
that
would
be
a
10
good
place
for
us
to
start
here
and
see
how
much
more
11
information
you
need
beyond
that.

12
So
all
I
can
say
is
without
monopolizing
the
13
time
here
there's
a
lot
of
information
that
can
be
put
14
in
the
public
record
that
could
be
part
of
the
public
15
record
that
that
public
information
we
would
be
16
willing
to
share
with
you.

17
MR.
AUER:
And
I
would
also
note
we
can
share
18
CBI
with
you
once
the
appropriate
steps
would
be
taken
19
to
the
extent
the
information
is
available
to
us.

20
Let
me
ask
if
there
are
other
interested
21
parties
who
would
like
to
be
part
of
this
discussion
22
group
on
dealing
with
CBI,
if
you
are
interested
111
1
indicate
now
or
identify
yourselves
subsequently,
EWG,

2
yeah,
I
have
you
on
record.
When
you
start
the
idea,

3
you
definitely
get
involved.
Okay,
good.

4
I
think
I
can
take
from
the
silence
that
the
5
group
is
prepared
to
accept
that
as
a
component
of
6
another
special
technical
workgroup,
if
you
will,
to
7
go
off
and
try
to
develop
an
approach
here
which
could
8
then
be
brought
back
into
the
room
and
provide
the
9
basis
for
production
use,
et
cetera,
reporting
at
a
10
non­
CBI
level.
Okay,
thank
you
for
that.

11
Let
me
check
with
my
colleagues.
I
guess
in
12
consulting
the
notes,
West
Virginia
Department
of
13
Environmental
Protection
suggested
number
2,
the
14
p­
chem
properties
specifically
including
an
addition
15
to
the
points
note
that
EPA
Framework
density
pH,
ask
16
the
group
whether
this
is
an
area
that
would
be
17
appropriate
for
consideration
in
the
first
set
of
18
technical
groups
that
we
had
set
up
or
would
you
19
prefer
that
this
be
an
area
that
we
discuss
further
in
20
plenary?
So
if
I
could
test
the
group
on
that
one,

21
any
reaction
to
that.

22
The
proposal
is
or
at
least
is
raised
by
Dee
112
1
Ann
in
this
discussion
item
to
move
the
points
under
2
number
2
on
P­
chem
properties
into
technical
3
discussions
at
this
point,
and
then
have
them
come
4
back
to
the
plenary
at
some
point
in
the
future.
Any
5
reaction
to
that,
SPI?

6
MR.
DUNCAN:
For
clarification,
those
the
are
7
physical
chemical
properties
for
the
fluoropolymers
or
8
for
PFOA?
I
mean,
we
presume
fluoropolymers.

9
MR.
AUER:
Fluoropolymers.
Is
that
a
yes
or
10
no?

11
MR.
DUNCAN:
Yes.

12
MR.
AUER:
Thank
you.
FMG
has
indicated
that
13
they
would
be
prepared
to
take
that
into
the
technical
14
group.
Any
reaction
from
TRP
on
this
or
do
you
want
15
to
think
more?
If
you
want
to
think
about
it
more
we
16
can
try
to
sweep
it
up
in
the
future.
Okay,
I
guess
17
these
are
the
set
of
items
where
we
believe
there's
18
agreement
in
principle
and
they're
moving
into
19
technical
discussion.

20
One
item
yet
to
be
closed
on,
we'll
get
back
to
21
it.
I
would
ask
if
there
are
interested
parties
who
22
would
want
to
participate
in
those
technical
groups,
113
1
one
on
fluoropolymers
and
another
on
the
telomers,
for
2
expert
discussions
to
indicate
your
interest
at
this
3
time,
so
we
can
begin
to
build
a
list
and
you
will
be
4
given
an
opportunity
to
identify
your
interest
in
the
5
coming
week
or
so
as
well.

6
So
if
there
are
interested
parties
who
would
7
want
to
be
part
of
that
group,
if
you
could
indicate
8
your
interest
and
maybe
you
could
just
read
off
the
9
names
of
the
groups.
Environmental
Working
Group,
do
10
you
have
a
comment
as
well?

11
MS.
THAYER:
Maybe
not
deciding
today,
would
12
there
be
any
kind
of
message
sent
out?

13
MR.
AUER:
Yes,
yes.
We
would
try
to
arrange
14
the
discussions
to
be
compatible
with
the
needs
as
15
much
as
we
could
of
the
expert,
obviously
the
larger
16
the
group
gets
the
more
difficult
that
could
become.

17
So
at
this
point
would
be
FMG
and
its
member
companies
18
would
participate
on
that
side,
EWG
is
interested
in
19
participating,
the
TRP
and
its
member
companies
would
20
be
interested
in
participating
on
the
telomer,
EWG
21
would
like
to
participate
in
that
as
well.

22
Are
there
any
other
interested
parties
who
114
1
would
like
so
indicate
their
interest
to
participate?

2
Okay,
Bennett
&
Williams.

3
MS.
ALLER:
The
fluoropolymers
group.

4
MR.
AUER:
Okay,
for
the
fluoropolymers
group.

5
And
then
Rich
Purdy
for
the
telomer
group,
and
CPSC,

6
and
of
course
EPA
is
going
to
participate,
but
that's
7
understood.
Okay,
well,
thank
you
for
that.

8
I
think
that
that's
quite
excellent
progress
in
9
working
towards
the
elements
of
early
agreement
and
10
certifying
the
process
and
moving
them
into
the
11
technical
discussions.

12
Once
again,
if
an
interested
party
has
an
13
interest
in
participating
in
those
technical
groups,

14
please
indicate
your
interest.
As
far
as
the
timing
15
for
that
first
meeting,
if
the
interested
parties
who
16
have
said
they
would
like
to
participate,
if
you
could
17
think
about
whether
­­
I
would
like
to
push
this
if
we
18
could
­­
the
first
meeting
in
two
weeks,
is
that
19
reasonable
or
is
three
weeks
something
that's
20
necessary
in
order
for
people
to
get
appropriately
21
organized,
I
hope
more
time
is
not
required,
but
I
22
would
like
to
try
to
not
necessarily
set
the
date
115
1
today,
but
to
know
whether
it
is
going
to
be
two
weeks
2
or
three
weeks
or
whenever,
so
if
you
could
think
3
about
that
and
then
we'll
try
to
capture
that
as
we
4
close
today
okay.

5
Why
don't
we
move
on
from
this
to
the
remaining
6
issue
areas
which
would
be
areas
where
we,
by
virtue
7
of
them
not
being
identified
for
early
resolution,
we
8
would
want
to
have
more
discussion
in
the
plenary
and
9
if
we
could
have
some
discussion
as
to
ideas
that
10
people
have
as
to
ways
that
we
might
approach
those
11
issues
within
the
next
plenary
meeting
to
allow
us
to
12
make
as
much
progress
as
possible,
we
have
them
13
specifically
separated
into
telomer
and
fluoropolymer.

14
I
think
that
is
necessary
to
acquire
that
strict
15
order.

16
So
the
floor
is
now
open
for
ways
to
deal
with
17
these
other
issue
areas
in
the
context
of
continued
18
discussion
in
the
plenary,
or
if
it
is
easier
we
just
19
move
them
into
technical
groups.
So
any
help
from
the
20
floor
here?

21
One
suggestion
of
a
way
to
perhaps
move
this
22
forward
is
in
the
monitoring
area
or
if
there
are
116
1
additional
talk­
related
studies
that
haven't
been
2
dealt
with,
we
could
agree
to
discuss
at
the
next
3
plenary
scope
elements
of
what
such
a
monitoring
4
program
might
involve.
EPA
and
other
interested
5
parties
could
develop
our
thinking
and
try
to
bring
6
that
forward
to
allow
for
an
informed
discussion,
the
7
proposal
that
we
offered
in
our
Framework
to
remind
8
everyone
was
to
use
the
3M
and
DuPont
monitoring
as
a
9
starting
point
for
those
discussions.

10
I
think
my
view
on
it
is
that
this
could
be
a
11
very
difficult
and
complex
area
and
our
thinking
is
12
that
what
we
might
to
attempt
to
do
initially
is
to
13
develop
an
agreement
as
it
relates
to
almost
a
14
screening
level
of
assessment
at
sites,
the
3M
and
15
DuPont
studies
tend
to
be
more
best
in
order
­­
or
the
16
protocols
do.
Rather
than
now
attempting
to
develop
17
what
might
be
follow­
up
work
for
more
comprehensive
18
work
that's
appropriate
in
specific
areas,
and
so
this
19
could
evolve,
for
example,
doing
the
work
at
20
representative
sites,
you
would
have
to
talk
about
21
what
that
would
mean.
It
would
mean
work
that
we
can
22
to
attempt
to
comprehensively
characterize
but
attempt
117
1
to
provide
a
more
initial
level
of
understanding
which
2
after
that
work
is
done
it
could
be
evaluated
as
3
appropriate
additional
more
detailed
work
could
be
4
pursued
in
subsequent
ECA
discussions,
so
that
at
5
least
one
way
that
we
could
carry
the
issue
into
the
6
next
plenary
discussion.
So
if
there
is
any
reaction
7
to
that
or
if
there
are
better
ideas
out
there,
we
are
8
certainly
open
to
that.
So
I
will
let
you
think
about
9
that
for
while.

10
One
of
the
other
areas
where
­­
and
I
draw
this
11
to
your
attention
because
it
would
be
one
of
the
12
points
that
would
need
to
be
addressed
here
­­
is
13
biodegradation,
degradation
studies
that
wasn't
14
included
in
the
early
agreement
work
that
we
talked
15
about,
so
that's
another
one
of
the
areas
that
we
need
16
to
consider
here,
so
you
might
think
about
approaches
17
in
bringing
that
work
back.

18
It
may
make
sense
­­
I
mean
I
test
this
in
the
19
group
­­
would
you
like
to
take
a
break
and
allow
20
groups
to
caucus?
Before
we
rush
to
that,
if
there
21
are
any
other
approaches
that
interested
parties
would
22
like
to
offer
as
to
the
way
we
might
tee
this
issue
up
118
1
at
the
next
plenary,
I
don't
want
to
take
the
one
2
proposal
and
run
with
it,
is
there
any
other
ways
that
3
interested
parties
would
like
others
to
consider
4
during
this
caucus
break,
I
would
invite
those
5
interventions
now,
so
if
there
is
anything
there,
any
6
comment
as
we
look
carefully.
All
right.
Why
don't
7
we
­­
it's
now
about
3:
30,
why
don't
we
come
back
in
8
20
minutes,
is
that
enough
time
for
groups
to
caucus
9
and
to
think
about
how
we
might
feel
with
these
issues
10
in
subsequent
plenary
discussion,
so
with
that
we're
11
adjourned
for
the
next
20
minutes.

12
(
Short
break.)

13
MR.
OSHIDA:
I
would
like
to
call
your
14
attention
to
we
tried
to
summarize
on
the
flip
chart.

15
The
three
groups
that
we
feel
that
we
agreed
to
and
16
the
issues
that
have
been
moved
into
the
technical
17
groups.
We
hope
to
make
some
more
progress,
but
this
18
is
what
we've
got
so
far.
When
you
get
a
chance
take
19
a
look
at
it
and
see
if
you
agree
that
this
is
where
20
we
are.

21
MS.
SMYTHE:
The
TRP
would
like
to
suggest
that
22
with
the
items
in
the
ECA
that
relate
to
the
telomer
119
1
data
needs
that
we
would
like
to
move
that
discussion
2
directly
into
technical
groups,
all
the
ECA
items
that
3
are
listed,
with
that
being
a
staging
area
and
a
4
discussion
area
for
the
technical
details
that
can
be
5
brought
back
to
the
plenary
session
whenever
that
6
occurs.
The
exception
would
be
ECA
item
11
as
it
7
relates
to
the
TRP,
which
relates
to
the
fire
fighting
8
foams
and
we
will
let
that
be
handled
by
others,
so
9
ECA
item
11
as
it
relates
to
TRP
we
would
not
be
a
10
participant
in
that
particular
ECA,
but
the
rest
we
11
would
suggest
that
they
go
straight
to
technical
12
groups.

13
MR.
DUNCAN:
We
had
tried
put
some
the
of
low
14
hanging
fruit
up
there
that
might
be
good
candidates
15
for
the
early
ECA
things,
but
after
caucusing
I
think
16
we
would
like
to
take
one
of
the
tougher
items
that
17
we've
got
which
is
item
10
in
the
fluoropolymers
18
Framework.
And
what
I
would
like
to
do
is
to
maybe
19
share
with
the
rest
of
the
group
how
the
20
Fluoropolymers
Manufacturers
Group
sees
this
issue
21
because
this
is
probably
one
of
the
most
complex
22
segments
that
we
have
in
all
of
the
11
items
that
you
120
1
got
and
plus
all
of
the
activities
that
involve
the
2
entire
PFOA
area.
So
if
I
could,
I
would
like
to
3
maybe
read
in
somewhat
in
a
summary
fashion
how
we
4
would
like
to
address
this.

5
We
think
it
is
fairly
comprehensive
and
if
6
there's
a
discussion
on
that
we
would
be
more
than
7
delighted
to
listen
to
it
and
if
there's
a
need
to
8
take
this
beyond
what
we're
suggesting,
perhaps
this
9
could
be
separate
candidate
for
a
separate
technical
10
committee
itself
simply
because
of
the
extreme
11
complexity
and
diversity
of
this
particular
issue.
So
12
if
I
can,
I
would
like
to
share
with
you
our
13
perspective
items.

14
First
of
all,
item
10
calls
for
release
and
15
exposure
assessments
adjacent
to
PFOA
and
16
fluoropolymer
manufacturing
and
use
facilities,
also
17
of
control
areas.
The
FMG
supports
the
need
for
18
release
exposure
assessments
adjacent
to
such
19
facilities,
as
such,
and
we'll
make
some
comments
and
20
I'll
try
to
simplify
from
the
standpoint
of
referring
21
back
to
the
LOI,
but
as
such
in
the
LOI
we
have
22
committed
to
conduct
an
exposure
assessment
adjacent
121
1
to
the
new
APFO
manufacturing
facility
that
has
just
2
been
constructed,
of
course
DuPont
has
responsibility
3
for
that
and
they
have
submitted
a
complete
workplan
4
for
this
effort
to
EPA
based
on
the
workplan
that
was
5
developed
in
West
Virginia.
So
there's
a
model
there
6
we'll
be
following
and
that
model
will
be
used
in
and
7
for
­­
is
being
used
now
for
the
APFO
manufacturing
8
facility
being
constructed
in
North
Carolina.

9
Similarly
the
FMG
is
committed
to
conducting
10
exposure
assessment
adjacent
to
a
representative
11
sample
of
fluoropolymer
manufacturing
facilities
in
12
the
U.
S.
The
protocol,
these
assessments
will
be
based
13
upon
the
protocol
developed
and
approved
by
the
states
14
of
West
Virginia
and
Ohio
along
with
region
3
and
5
of
15
the
U.
S.
EPA.
The
entire
workplan,
quality
assurance
16
plan,
and
results
of
the
study
in
the
area
of
the
17
possible
Washington
Works
have
been
submitted
to
the
18
EPA
record.
This
workplan
includes
sampling
of
19
surface
water
as
well
as
ground
water
and
soil
20
sampling.

21
And
finally,
the
FMG
is
committed
to
conducting
22
material
balance
assessment
in
representative
122
1
fluoropolymer
dispersion
processing
customers,
these
2
are
our
downstream
customers
who
take
the
polymers
3
produced
by
the
resin
manufacturers
and
convert
them
4
into
products.
The
fluoropolymer
dispersion
customers
5
assessment
will
be
based
on
an
industry
developed
6
protocol
using
appropriate
methods.
For
example,

7
there
is
an
OPPT­
2003­
OO12­
OO40.
Since
dry
resin
is
8
not
expected
to
contain
any
significant
amount
of
9
PFOA,
the
FMG
does
not
feel
that
the
appropriate
10
include
dry
resin
processes
at
this
time.

11
So
what
we
are
going
to
do
is
go
after
the
12
processors
that
would
have
the
highest
expectation
of
13
potentially
having
the
emissions,
do
those
and
if
14
appropriate
do
something
else
later
on.
The
FMG
15
supports
the
overall
attempt
of
item
10
and
believes
16
the
critical
elements
of
item
10
are
basically
17
included
in
our
LOI,
but
again
that
definition
of
18
what's
appropriate
I
think
is
one
of
these
things
that
19
we
look
forward
to
having
further
discussion
with
the
20
EPA
and
other
parties,
but
as
I
say,
this
is
an
21
extremely
complex
area.

22
And
just
to
kind
of
summarize
it,
if
you
look
123
1
at
the
supply
chain
aspect
of
the
PFOA
trail
starting
2
with
the
APFO
producer,
the
fluoropolymer
producers
3
and
then
the
downstream
processors,
we
think
on
the
4
top
two
tiers
of
that
we've
a
pretty
good
5
comprehensive
analysis
program
to
review
for
you
and
6
we've
got
the
beginnings
of
an
analysis
program
of
7
processors
to
see
if
there
are
issues
at
that
level
as
8
well.

9
So
we
consider
this
to
be
one
of
the
biggest
10
area
of
activities
we've
got
in
terms
of
the
11
characterization
of
the
PFOA
influence,
if
you
will,

12
from
those
sites.
We
think
it
is
pretty
13
comprehensive,
it
has
been
adopted
in
two
states
now,

14
and
we
are
actively
engaged
in
implementing
it
in
15
those
areas.

16
So
I
just
wanted
to
share
not
only
with
the
17
EPA,
but
other
people
involved
here
what
is
already
in
18
place
and
my
comment
would
be
if
there's
more
that's
19
needed
we
are
certainly
willing
to
consider
it
and
20
deal
with
it
on
a
technical
basis.
But
we
wanted
to
21
make
sure
if
there
was
a
discussion
on
this
subject
we
22
at
least
had
the
benefit
of
what
is
already
in
place.
124
1
Thank
you
very
much.

2
MR.
AUER:
So
as
I
understand
it
what
you're
3
suggesting
is
that
I
offer
this
for
consideration
by
4
the
group,
as
I
understand
it,
to
form
a
technical
5
committee,
a
separate
technical
committee.
And
it
6
sounds
like
what
you're
proposing
to
do
is
to
explain
7
to
that
group
what
you
anticipate
doing
under
the
8
monitoring
program
for
the
purposes
of
your
LOI
and,

9
that
would
fully
inform
this
technical
group
as
to
the
10
scope
of
that
activity
and
the
sites
and
appropriate
11
details
on
the
monitoring
procedures
and
whatnot,
and
12
then
that
group
could
then
consider
whether
there
are
13
any
additional
needs
that
they
would
like
to
raise,

14
and
it
would
be
those
additional
needs
that
might
be
15
appropriate
for
consideration
within
the
Framework
of
16
the
ECA.

17
And
so
the
starting
point
is
to
educate
this
18
technical
group
as
to
what
your
LOI
delivers
and
then
19
with
that
understanding
what
additional
work
might
be
20
necessary.
Is
that
the
case?

21
MR.
DUNCAN:
I
mean,
we
can
live
with
that.
We
22
can
live
with
that.
125
1
MR.
AUER:
Any
comment
on
that
with
EWG?

2
MS.
THAYER:
It
sounds
like
a
fine
process
and
3
we
are
just
sort
of
hoping
that
I'm
not
sure
of
the
4
amount
of
information
would
be
given
to
the
technical
5
group,
but
it
would
be
nice
to
have
sort
of
a
broad
6
list
of
manufacturing
sites.
I'm
not
sure
if
we
would
7
just
be
presented
with
the
candidate
sites,
but
it
8
would
be
nice
to
have
a
comprehensive
list
and
then
9
may
be
how
they
were
selected.

10
MR.
AUER:
Don,
if
there
is
any
reaction
from
11
FMG
to
that
suggestion
or
if
you
want
to
think
about
12
it
or
if
you
want
a
moment.
Other
comments,
Bennett
&

13
Williams.

14
MS.
ALLER:
I
just
wanted
to
make
sure
that
15
we're
not
going
to
limit
number
10
to
only
new
ideas
16
and
that
I
have
been
involved
with
some
of
the
17
sampling
methodologies
at
particularly
what
relates
to
18
what
was
done
to
the
Washington
Works
site,
and
I
19
believe
that
there
is
some
insufficiencies
in
those
20
whether
or
not
they
have
been
approved
by
two
state
21
agencies,
so
I
just
wanted
to
make
sure
we're
not
22
limiting
­­
126
1
MR.
AUER:
No,
there's
not
any
attempt
to
2
define
the
scope
so
much
as
I
understand
it
to
inform
3
as
to
what
the
industry's
plans
to
do
under
their
4
Letter
Of
Intent
and
then
to
the
extent
that
there
are
5
other
issues
or
needs
that
emerge
from
that,
those
6
could
be
appropriately
suited
in
the
scope
of
the
7
Enforceable
Consent
Agreement.

8
MS.
ALLER:
Like
I
said,
my
only
concern
with
9
that
is
you
keep
saying
other,
if
something
is
already
10
addressed
and
there
might
be
some
concerns
about
how
11
it
would
be
inadequately
addressed
­­

12
MR.
AUER:
I
am
not
attempting
to
­­
I
mean
I
13
am
not
contending
that
if
there
is
a
given
approach
14
which
is
viewed
as
having
issues
that
that's
locked
15
up,
that's
not
the
case.
I
think
what
the
industry
is
16
suggesting
is
that
they
plan
to
run
a
monitoring
17
program
which
is
based
on
that,
and
then
it's
for
the
18
ECA
process
to
consider
whether
for
the
purposes
that
19
we're
going
at
here
in
that
the
initial
level
of
20
understanding
on
these
issues,
whether
that's
okay
or
21
if
there
are
other
elements
that
might
be
appropriate
22
for
consideration,
and
these
may
go
beyond
the
Letter
127
1
Of
Intent.

2
MS.
ALLER:
That's
fine.

3
MR.
AUER:
West
Virginia
Class
Action.

4
MR.
BILOTT:
Rob
Bilott.
We
would
support
with
5
the
Environmental
Working
Group
with
respect
to
6
getting
an
identification
from
both
the
FMG
and
the
7
TRP
group
of
the
various
sites
that
would
be
among
8
those
to
consider.
I
think
everybody
needs
to
see
the
9
list
of
exactly
which
are
these
manufacturing
sites,

10
new
sites,
production
sites,
potential
foam
spill
11
sites,
that
needs
to
be
produced
up
front,
so
that
12
there
can
be
meaningful
discussion
about
how
to
go
13
about
doing
the
monitoring.

14
MR.
AUER:
You
know
one
suggestion
on
that
is
15
that
if
we
decide
to
form
this
group
to
go
off
and
16
talk,
the
industry
could
present
what
it
could
at
that
17
point,
and
this
could
be
a
topic
that
the
CBI
group
18
talk
about
specifically
to
see
if
there
is
a
way
to
19
form
in
this
area
in
a
way
that
doesn't
present
any
20
CBI
issues,
so
I
offer
that
for
consideration
by
the
21
group.

22
DR.
ZUCKERMAN:
Hi,
I'm
Diana
Zuckerman
from
128
1
the
National
Center
for
Policy
Research
for
Women
and
2
Families.
I
have
a
question
on
clarification.
It
3
wasn't
clear
to
me
that
the
focus
was
going
to
be
only
4
on
the
new
plants,
but
not
on
old
plants,
and
I
would
5
like
clarify
about
that
because
obviously
there
are
6
old
plants
that
have
been
manufacturing
for
a
long
7
time
that
could
have
a
different
set
of
problems,
even
8
if
they're
no
longer
in
use.

9
MR.
AUER:
Thanks
for
that.
While
I
think
10
about
that
for
a
minute,
FMG?

11
MR.
DUNCAN:
The
definition
of
terms
is
always
12
important.
The
place
where
new
and
old
came
into
play
13
was
in
the
manufacturing
of
APFO,
the
old
plant
which
14
has
been
shut
down
now
which
was
operated
by
3M
and
15
there
is
a
separate
LOI
that
covers
3M's
16
responsibility
and
their
legacy
activities
that
are
17
associated
with
that.
The
new
plant
then
is
the
one
18
that
has
been
built
by
DuPont
and
that
has
a
whole
set
19
of
already
formal
obligations
associated
with
it.
I
20
think
to
answer
your
question,
both
of
them
are
21
covered
extensively,
both
the
old
and
the
new.

22
MS.
SMYTHE:
With
regard
to
the
monitoring
129
1
issues
the
TRP
members
would
suggest
that
maybe
that
2
technical
group
be
a
joint
group
between
the
­­
not
3
distinguished
telomers
and
fluoropolymers,
that
it
4
should
involve
all
the
parties
that
might
contribute
5
to
the
presence
of
PFOA
both
past
and
present
parties,

6
and
the
difficulty
to
distinguish
the
source
of
PFOA
7
and
all
parties
involved
in
that
discussion
group.

8
MR.
AUER:
Okay.
Well,
we
now
had
a
discussion
9
about
the
monitoring
item
suggestion
being
to
form
a
10
separate
technical
committee
which
would
start
with
11
the
clear
understanding
of
what's
intended
under
the
12
LOIs
and
then
discuss
as
appropriate
any
issues
that
13
go
beyond
that.
It's
been
suggested
that
this
14
technical
group
look
at
both
fluoropolymers
and
15
telomers,
you
know,
as
a
combined
group
for
purposes
16
of
having
that
discussion.

17
The
other
point
that
was
made
here
was
the
18
proposal
from
TRP
that
all
of
the
other
issues,
except
19
number
11,
be
moved
into
technical
groups
which
for
20
the
telomers,
just
so
it's
clear
to
everyone,
this
21
would
be
the
p­
chem
and
degradation
and
incineration,

22
so
it
would
be
the
p­
chem
properties,
the
130
1
biodegradation
and
the
incineration
work,
2,3,
and
8
2
in
the
table,
they're
recommending
it
would
be
3
appropriate
to
go
into
the
technical
group.

4
Now,
we
did
have
the
consideration
point
picked
5
up
before,
so
that's
consistent
with
what
we
had
6
worked
out
with
the
Fluoropolymer
Manufacturing
Group
7
and
so
the
new
elements
in
the
proposals
are
in
the
8
p­
chem
properties
and
the
biodegradation
issue.

9
So
I
think
the
bottom
­­
I
think
where
we
are
10
at
this
point,
and
I
ask
others
to
check,
is
that
I
11
think
that
what
this
means
is
that
for
the
telomer
set
12
1
through
9
are
moved
into
the
technical
groups,

13
number
10
which
is
monitoring
is
in
this
special
group
14
on
monitoring,
and
then
the
open
issue
is
number
11
on
15
the
fire
fighting
foams.
Am
I
correct
in
that
recap
16
of
where
we
are,
and
we're
trying
to
get
the
same
17
explanation
for
FMG
as
well.

18
MR.
PENBERTHY:
Item
number
1
from
the
19
fluoropolymer
data
needs
is
the
fluoropolymer
market
20
information,
that
would
be
in
the
CBI
group
as
before,

21
then
there
is
an
interest
in
item
number
2,
item
22
number
7,
item
number
8,
item
number
9,
and
item
131
1
number
11
in
the
fluoropolymers
group,
and
then
there
2
would
be
a
separate
group
for
number
10,
which
is
3
environmental
monitoring
coupled
with
the
telomers
4
effort
in
that
area.
Did
I
do
that
right?
So
that
5
would
mean
missing
from
the
fluoropolymers
data
needs
6
would
be
the
degradation
pathways,
the
p­
chem
7
properties
and
then
the
PFOA
contamination
in
8
fluoropolymers
and
then
fluoropolymer
treated
9
articles,
that's
not
covered
yet
so
far
­­
yeah,
it
is
10
in
there
­­
excuse
me.

11
MR.
AUER:
I
don't
know
how
clear
this
is
to
12
everybody,
I
think
what
we
have
at
this
point
is
a
13
situation
where
many
of
the
issues
that
we
started
out
14
today,
we've
reached
agreement
to
move
those
issues
15
into
the
technical
workgroups.
There
are
a
limited
16
number
of
issues
where
we
don't
have
that
agreement,

17
and
to
test
my
memory,
I
think
one
is
on
the
telomers
18
and
the
fire
fighting
foam
situation,
for
the
19
fluoropolymers
we
have
the
degradation
and
p­
chem
20
properties
on
the
fluoropolymers
where
FMG
had
21
identified
questions
on
that
initially.

22
And
then
the
remaining
open
items
for
FMG
would
132
1
be
the
determination
of
PFOA
contamination
in
2
processed
fluoropolymer
and
the
presence
of
PFOA
in
3
fluoropolymer
products
and
articles,
although
there
is
4
some
testing
on
that
last
one
that
would
be
done
under
5
the
LOI.
You
know,
I
think
that's
really
substantial
6
progress,
any
time
you
get
things
moving
into
the
7
technical
groups
I
think
there's
a
chance
of
8
resolution.

9
And
so
what
I
would
suggest
at
this
point
is
10
that
testing
the
group
on
this,
that
we
agree
to
11
proceed
in
that
way.
We
would
schedule
technical
12
groups,
schedule
a
subsequent
plenary
and
the
items
13
that
would
be
considered
in
the
plenary
would
be
the
14
items
which
we
have
not
moved
into
the
technical
15
groups,
so
it
would
provide
an
opportunity
for
16
interested
parties
to
discuss
issues
or
needs
or
17
technical
problems,
or
whatever
the
case
might
be
with
18
those
open
areas
of
the
Framework
that
EPA
has
19
proposed,
and
then
to
decide
what
happens
at
that
20
point.

21
There
may
be
issues
where
we
know
we're
not
22
going
to
get
consensus
in
which
case
we
would
go
off
133
1
and
do
what
we
had
to
do
would
or
there
could
be
other
2
areas
that
could
be
right
for
moving
into
technical
3
groups,
or
we
may
need
additional
plenary
discussions
4
on
those
items.

5
So
that's,
I
think
where
we
are,
set
of
6
activities
moving
into
workgroups,
you've
got
a
7
fluoropolymer
group
dealing
with
those
issues
as
8
appropriately,
you
got
a
telomer
group
dealing
with
9
those
issues,
we
got
a
CBI
group
dealing
specifically
10
with
that,
and
we
have
a
monitoring
group
dealing
with
11
those
issues,
so
those
are
the
four
technical
12
workgroups
that
we've
got,
we
have
another
set
of
13
issues,
ones
I've
just
gone
through
which
would
be
14
returned
to
the
plenary
for
additional
discussion
15
among
a
larger
group
at
some
point
in
the
future.
So
16
if
I
could
test
amongst
the
interested
parties
whether
17
there's
agreement
on
that
principle
to
move
in
that
18
direction?
I
see
a
lot
of
nodding,
okay.

19
So
that's
the
way
that's
the
way
that
we'll
20
proceed.
I
hope
that's
sufficiently
clear
for
21
everyone.
We
will
summarize
this
hopefully
with
great
22
clarity
in
the
near
future
to
make
sure
that
we
134
1
haven't
misunderstood
anything.
It
would
be
useful
2
for
interested
parties
to
think
about
whether
they
3
would
like
to
be
participants
in
the
monitoring
group,

4
as
well
as
any
interested
parties
who
wish
to
further
5
associate
or
additional
groups
to
associate
themselves
6
with
the
CBI,
the
FMG,
or
it
telomer
groups,
as
laid
7
out
on
the
flip
chart.

8
The
other
thing,
what
I
am
going
to
do
at
this
9
point
is
we'll
shift
into
the
public
comment
period
10
for
30
minutes
and
then
I
would
like
to
come
back
and
11
close,
where
we
try
to
work
out
the
schedule
for
when
12
we're
going
to
attempt
to
have
the
first
of
the
13
technical
discussions
and
then
the
time
frame
for
the
14
next
plenary,
okay,
so
think
about
that.

15
And
if
in
addition
there
are
any
points
that
I
16
have
lost
along
the
way
that
have
been
raised
by
17
interested
parties,
after
the
public
comment
period
18
that
would
be
the
chance
for
us
to
pick
up
any
missed
19
items
and
make
sure
they
are
carried
forward
with
us.

20
So
we
are
now
into
the
public
comment
period.

21
We
are
going
to
start
with
Della
Tennant
who
had
22
started
her
intervention
earlier
and
asked
her
to
135
1
defer
to
this
point.

2
MS.
TENNANT:
By
now
everybody
knows
I
am
Della
3
Tennant
and
I
live
at
15
Mansion
Boulevard
in
4
Parkersburg,
West
Virginia.
Along
with
my
husband
we
5
own
Tennant
Rentals,
the
address
there
is
3117
6
Parkersurg,
West
Virginia,
Middle
Ohio
Valley
Teflon
7
contaminated
area.
I
come
to
you
today
as
a
very
8
concerned,
very
concerned
mother,
grandmother,
sister,

9
and
landlord,
neighbor
and
friend
of
the
Middle
Ohio
10
Valley.
We
own
property
next
to
the
DuPont
landfill
11
located
Route
68
south
and
our
property
is
located
12
around
15
hundred
feet
from
the
DuPont
landfill.

13
Although
I
know
we
are
not
here
today
to
14
discuss
the
landfill,
but
we
are
here
today
to
discuss
15
the
PFOA,
or
as
I
say
it,
the
Teflon­
related
chemicals
16
and
the
Teflon
contamination
in
the
Middle
Ohio
17
Valley.
We
owned
68
acres
of
that
property
that
was
18
sold
to
DuPont
and
it
was
not
sold
for
any
unregulated
19
or
regulated
chemical
dumping
in
any
way.
We
sued
20
DuPont
a
few
years
back.
Going
up
against
DuPont
was
21
hard
to
do
and
especially
for
our
family,
we
are
awful
22
small
people,
and
they
are
an
awful
big
business,
but
136
1
it
was
something
that
we
needed
to
do.

2
Our
family
has
been
sick,
we
have
lost
several
3
heads
of
cattle,
so
there
was
a
need
there
that
needed
4
to
be
done.
Jim's
brothers,
Jack
and
Earl
are
both
5
sick
and
their
families
are
all
sick
now.
Earl
is
6
having
problems
with
his
lung
respiratory
and
Jack
is
7
having
problems
with
his
respiratory
and
also
heart
8
problems.
His
mother
got
sick
very
sudden,
now
this
9
was
before
the
lawsuit,
but
it
was
during
it
time
that
10
we
had
sold
our
property
to
DuPont
and
they
began
11
dumping
these
chemicals.
I
took
care
of
her.
I
can
12
relate
to
the
suffering
that
she
suffered
and
I
also
13
helped
take
care
of
the
cattle,
and
I
feel
like
it
is
14
related.

15
And
as
I
mentioned
before,
during
this
lawsuit
16
we
was
represented
by
two
of
the
most
outstanding
law
17
firms
there
is
in
the
United
States
and
two
of
the
18
best
lawyers
that
any
of
God's
children
could
ever
19
hope
to
have,
and
that
would
be
Rob
Bilott
and
20
(
inaudible)
and
I
think
they
should
be
commended
for
21
the
job
that
they
did,
because
they
did
a
fantastic
22
job.
They
discovered
during
the
time
of
the
lawsuit
137
1
that
C8
was
in
our
water.

2
In
March
I
put
an
article
on
the
medical
chart
3
and
the
Middle
Ohio
Valley
Medical
Directory
opposing
4
the
landfill
that
was
coming
up,
the
landfill
permit
5
that
was
coming
up
for
renewal
or
came
up
for
renewal
6
in
April
2002.
This
article
came
out
in
the
paper
on
7
March
the
31st
with
over
50,000
copies
printed.

8
During
that
same
time
the
EPA
had
announced
on
9
the
(
inaudible)
that
they
would
like
to
have
10
interested
parties
to
send
in
their
comments
to
the
11
EPA
in
preparing
for
a
June
hearing
with
anybody
that
12
was
interested
in
what
problems
with
the
C8
in
their
13
water
that
had
contaminated
their
water.
I
talked
to
14
Kris
and
she
gave
me
all
the
information,
so
I
took
15
the
information
that
she
gave
me
and
posted
it
on
my
16
website
thinking
that
I
could
get
more
news
out
to
17
people
knowing
that
there
was
50,000
copies
of
the
18
medical
directory
that
had
just
been
printed.

19
When
I
put
that
on
the
website
I
got
a
call
in
20
a
couple
of
day
s
that
my
Post
Office
box
had
been
21
blocked.
This
lady
called
me
and
said
that
she
had
22
sent
a
letter
and
was
asking
me
if
I
knew
who
might
138
1
have
put
that
article
in
the
newspaper
about
the
2
landfill
and
opposing
the
landfill
permit.
Of
course
3
there
was
a
big
chance
I
knew
the
answer
to
that
4
question.
I
told
her
I
would
call
her
back,
so
I
5
called
the
Post
Office
to
see
what
the
problem
was
and
6
I
had
a
block
put
on
our
Post
Office
box
with
all
my
7
mail
returned
to
sender,
so
I
called
her
back
and
I
8
picked
up
the
letter.
This
really
upset
me.
I
was
9
infuriated.
I
don't
know
why
I
cannot
have
a
Post
10
Office
box.

11
I
opened
the
Post
Office
box
for
the
petition
12
only.
The
petition
is
a
follow­
up
from
the
lawsuit
13
that
we
had
with
DuPont
with
the
problems
that
we're
14
having
in
the
Middle
Ohio
Valley.
I
began
going
15
door­
to­
door
talking
to
people,
we
stopped
at
every
16
house
and
we
told
the
people
about
the
landfill
permit
17
coming
up
for
renewal
and
asked
them
to
give
it
a
18
chance
if
they
would
like
to
oppose
this
that
they
19
were
more
than
welcome
to
sign
this
petition,
at
20
during
which
time
I
told
them
about
the
EPA
asking
21
people
to
send
letters
and
comments
to
them
with
their
22
concerns.
139
1
I
began
receiving
letters
from
people,
people
2
telling
me
of
the
problems
that
they're
having
with
3
their
health,
and
at
this
time
I
would
like
to
thank
4
whoever
that
was
that
made
the
mistake
of
and
put
a
5
block
on
my
Post
Office
box
because
if
that
had
not
6
been,
I
would
not
be
going
door­
to­
door.
I
had
no
7
intentions
of
going
door­
to­
door.

8
These
people
were
telling
me
that
they
are
very
9
sick.
They
are
on
oxygen
respirators,
heart
problems,

10
thyroid,
gall
bladder,
liver
problems,
cancer,

11
problems
with
breaking
out
in
rashes
and
breaking
out
12
in
hives
whenever
they
take
a
shower
or
bath,
scared
13
to
let
their
children
play
in
a
bathtub,
scared
to
14
give
their
child
a
drink
from
the
kitchen
faucet.
Our
15
tenants
who
live
close
to
the
DuPont
landfill
have
16
been
sick
with
respiratory
problems,
congestive
heart
17
failure,
and
also
have
been
diagnosed
with
cancer.

18
And
that
the
very
reason
that
(
inaudible)
is
not
here
19
with
us
today
because
she
is
at
the
Cleveland
Clinic
20
for
more
tests,
she
has
colon
cancer.

21
MR.
AUER:
Excuse
me.
We
have
outlined
three
22
minutes
for
the
public
statements.
140
1
MS.
TENNANT:
I
have
two
more
paragraphs.

2
MR.
AUER:
Okay.
And
then
if
you
would
care
to
3
submit
something
in
writing
you
could
do
that
as
well.

4
MS.
TENNANT:
Thank
you.
People
with
small
5
children
with
their
teeth
decaying,
so
that
they
have
6
to
have
all
their
teeth
pulled
to
prevent
infections,

7
kids
missing
school
with
flu­
like
symptoms,
kids
being
8
hospitalized
with
acid
reflux
and
the
people
in
the
9
churches
that
are
sick,
losing
weight
and
not
knowing
10
what
the
answer
is.

11
People
in
the
Middle
Ohio
Valley
are
very
12
concerned
about
all
of
the
contamination
from
Teflon.

13
They
are
afraid.
People
want
to
speak
up
and
say
14
something
about
the
chemical
but,
they
are
afraid
they
15
will
lose
their
jobs.
People
cannot
afford
to
lost
16
their
jobs
there
is
too
much
sickness,
they
need
their
17
insurance,
and
they
are
afraid
if
they
do
speak
up
18
they
will
lose
their
jobs.

19
I
feel
that
DuPont
is
responsible
for
the
20
Teflon
contaminated
area
around
the
Lubeck
water
and
21
Little
Hocking
water.
I
have
family
in
the
Little
22
Hocking
area
and
I
have
family
in
the
Lubeck
area.
141
1
They
are
responsible
for
the
contamination
in
the
2
Middle
Ohio
Valley,
they
are
responsible
for
the
3
contamination
in
the
Ohio
River.
People
in
the
Middle
4
Ohio
Valley
are
afraid
of
what
this
has
done
to
their
5
family
and
they
are
afraid
of
what
the
chemicals
have
6
done
to
their
families
and
their
friends.
Please
stop
7
this
pollution
by
giving
us
clean
air
to
breathe
and
8
clean
water
to
drink.

9
Thank
you
and
may
God
bless
America.

10
DR.
ZUCKERMAN:
I'm
Dr.
Diana
Zuckerman
from
11
the
National
Center
for
Policy
Research
for
Women
and
12
Families
in
Washington
and
our
focus
is
on
taking
13
research,
complicated
scientific
research
information
14
and
trying
to
translate
it
into
something
resembling
15
useable,
understandable
information
for
consumers,
for
16
policy
makers,
and
opinion
leaders,
and
for
the
media.

17
In
this
case
that's
both
hard
and
easy
to
do,

18
there's
not
much
research
on
this
issue
and
so
it's
19
hart
to
know
how
to
translate
that
into
useable
20
information
when
we're
lacking
so
much
information.

21
My
training
is
in
epidemiology,
so
when
I
hear
a
story
22
like
yours.
142
1
First,
I
want
to
thank
you
because
it
is
very
2
hard
to
come
here
and
to
tell
a
personal
story,
and
it
3
is
particularly
moving
to
me
because
I
know
that
there
4
are
a
lot
of
other
stories
like
that
for
every
person
5
who
has
the
guts
and
resources
to
come.
As
an
6
epidemiologist
I
know
that
to
look
at
the
patterns
7
from
those
you
don't
know
what
to
do
with
the
8
anecdotal
information
there's
a
lot
of
it.

9
There
are
a
long
range
of
illnesses
that
you
10
mentioned
and
it
is
hard
to
know
what
might
be
11
relevant,
but
that
doesn't
mean
you
shouldn't
look
and
12
look
really
carefully.
These
are
complicated
issues,

13
we've
heard
that
from
the
industry
and
they
are
very
14
complicated
issues
and
consumer
groups
and
individual
15
consumers
are
at
a
real
disadvantage
when
it
comes
to
16
technical
workgroups,
how
do
we
have
our
voices
heard,

17
how
do
we
help
scrutinize
industry
developed
protocols
18
to
make
sure
that
those
protocols
really
do
look
at
19
the
issues
that
need
to
be
looked
at
in
the
way
that
20
we'll
get
the
most
truthful
accurate
information.

21
So
all
I
can
say
to
you
is
to
beseech
you
to
do
22
whatever
you
can
to
make
sure
there
is
that
balance
143
1
that
consumer
needs
and
interests
are
being
2
represented,
that
there
is
scrutiny
on
all
sides
of
3
all
of
issues
that
you
are
looking
at
and
I
really
do
4
thank
you
for
the
opportunity
be
here
and
to
see
what
5
is
going
on.

6
MR.
AUER:
Thank
you
for
that.
One
comment
I
7
would
offer
in
that
regard
is
I
think
that
this
8
process
by
virtue
of
this
public
component,
I
think
9
provides
a
real
opportunity
for
interested
parties
be
10
they
technically
qualified
or
a
public
interest
group
11
or
community
group
or
whatever
the
case
might
be
to
12
participate
and
understand,
and
I
think
that
one
of
13
the
virtues
of
having
the
technical
groups
go
off
is
14
they
can
go
off
and
do
their
work
where
hopefully
you
15
have
the
appropriate
balance
of
expertise
and
16
interested
parties
and
whatnot,
and
then
it
ultimately
17
comes
to
the
plenary
where
the
work
of
the
technical
18
group
is
ultimately
accepted
or
modified
or
sent
back
19
for
the
work
or
whatever
the
case
might
be,
so
we
20
believe
very
much
that
the
public
component
is
a
21
critical
element
in
this
process
and
look
forward
to
22
continued
working
with
the
all
of
the
members
of
the
144
1
interested
parties
and
then
listening
to
the
comments
2
from
the
public
as
we
proceed
in
our
work.

3
Does
that
take
care
of
everyone
among
the
4
public
speakers?

5
MS.
TENNANT:
Thank
you
for
giving
me
a
chance
6
to
speak.

7
MR.
AUER:
Thank
you.
We
appreciate
your
8
comments.

9
One
second,
and
then
we're
going
to
talk
about
10
the
schedule.
We've
listed
on
the
flip
chart
the
11
monitoring
group
and
we
have
also
identified
those
12
areas
from
among
the
EPA
Framework
that
will
be
coming
13
back
to
the
plenary,
so
if
there
is
any
comment
on
any
14
area
there,
please
bring
it
forward
now.
EWG,
do
you
15
have
a
comment?
And
one
of
the
open
items
which
maybe
16
we
should
talk
about
now
is
who
amongst
the
interested
17
parties
would
like
to
join,
I
guess,
the
monitoring
18
group
is
a
new
group
and
then
beyond
that
to
the
19
extent
moving
any
of
the
other
issues
into
the
telomer
20
or
fluoropolymer
group,
causes
someone
to
want
to
be
21
involved
in
that
technical
group,
please
identify.

22
And
EWG
indicated
that
they
would
wish
to
145
1
participate
in
the
monitoring
group
and
Rich
Purdy
as
2
well
in
the
monitoring
group,
and
we
have
Little
3
Hocking
Water
Association,
West
Virginia
Class
Action
4
Plaintiffs,
Bennett
&
Williams.
And
I
don't
recall
5
the
name
of
your
organization
­­

6
DR.
ZUCKERMAN:
National
Center
for
Policy
7
Research
for
Women
and
Families.

8
MR.
AUER:
And
to
the
extent
that
there
are
9
others
who
wish
to,
amongst
the
interested
parties
10
participate,
please
identify
yourself.
The
next
item
11
is
schedule
when
we
might
reconvene.
What
I
would
12
propose
for
the
group
is
that
we
consider
scheduling
a
13
plenary
during
the
week
of
July
7th,
we
can
be
14
somewhat
flexible
as
to
the
day
during
the
week.
I
15
would
propose
that
we
do
not
do
it
on
a
Friday
since
I
16
think
that
poses
problems
for
people
especially
when
17
someone
is
coming
from
out
of
town,
but
would
try
to
18
find
a
date
during
that
week
that
would
be
appropriate
19
for
the
next
plenary,
we
would
communicate
that
out
to
20
the
interested
parties,
and
then
for
the
various
21
workgroups
I
would
like
to
get
that
work
going
pretty
22
quickly,
so
I
am
going
to
suggest
dates
that
might
146
1
push
people.
I
ask
you
to
think
about
it,
if
it's
a
2
problem,
let's
talk
about
it,
but
I
would
propose
that
3
those
the
workgroups
and
I
think
it
is
useful
for
all
4
four
to
have
an
initial
discussion.

5
I
would
like
to
propose
that
the
workgroups
6
first
convene
during
the
period
of
the
week
of
the
7
16th
of
June
through
the
week
of
the
23rd
of
June,
so
8
that's
a
two­
week
period.
Given
the
overlap
in
the
9
groups,
there
may
be
value
in
thinking
about
the
ways
10
we
can
run
the
meetings
on
sequential
dates
or
11
whatever
the
case
might
be,
but
I
would
propose
for
12
the
interested
parties
that
we
look
at
holding
these
13
first
discussions
during
that
two­
week
period
with
14
those
groups
as
appropriate
reporting
back
to
the
15
plenary
here.
One
suggestion
is
that
to
the
extent
16
that
we
schedule
the
plenary
on
either
the
9th
or
the
17
10th
that
could
be
open
about
8
if
there
is
value
in
18
certain
of
the
workgroups
getting
together
to
talk
19
about
things
to
see
if
they
can
advance
things
before
20
reporting
things
into
the
plenary
on
either
the
9th
or
21
the
10th,
so
that's
our
proposal
for
how
we
go
forward
22
regarding
dates,
so
if
there's
any
reaction
to
that?
147
1
MR.
SPEAKER:
(
Inaudible)

2
MR.
AUER:
I
suspect
that's
a
more
general
3
sentiment.
I
take
it
I
have
the
agreement
of
the
4
group
to
work
within
the
dates
as
I've
outlined
them
5
to
set
up
the
plenary
and
what
we'll
do
with
the
6
workgroups
is
we
will
work
with
those
interested
7
parties
who
have
identified
themselves
and
then
try
to
8
find
dates
that
can
be
most
easily
accommodated
from
9
amongst
those
groups.

10
The
last
items
­­
is
there
a
comment?

11
MS.
SPEAKER:
(
Inaudible)

12
MR.
AUER:
I
don't
know
that
there's
any
date
13
in
the
future
that
get
together
on,
but
I
appreciate
14
the
point.
If
there
is
a
more
general
issue
with
that
15
week
if,
I
can
get
a
read
from
the
group,
I
suggested
16
the
9th
and
10th,
but
there
could
be
people
taking
the
17
whole
week.
I
would
propose
that
we
keep
that
week
18
recognizing
that
we
will
lose
some
people,
but
that
we
19
not
do
anything
at
least
on
the
Monday,
so
I
think
20
we're
talking
about
the
technical
discussions
on
21
Tuesday
the
8th
with
the
plenary,
I
think
likely
on
22
the
9th
to
provide
for
a
meet
ing
opportunity
on
two
148
1
dates
the
other
alternative
the
is
to
go
to
Wednesday,

2
Thursday,
technical
group
on
Wednesday,
the
plenary
on
3
Thursday,
if
people
would
like
an
extra
day
for
4
vacation.
Is
that
all
right?
Why
don't
we
go
with
5
that,
technical
discussions
on
Wednesday
the
8th,

6
plenary
on
Thursday
the
9th
­­
I
am
sorry,
I
am
sorry
7
­­
all
right.
Let's
have
it
on
Wednesday
the
9th
and
8
Thursday
the
10th.
Okay,
the
workgroups
on
the
9th
9
and
the
plenary
on
the
10th,
okay.

10
Are
there
any
loose
ends
that
we
need
to
be
11
reminded
of
and
carry
into
our
further
discussions?

12
MR.
OSHIDA:
Can
we
make
sure,
since
we're
13
going
to
do
most
of
the
communications
by
email,
that
14
we
have
everybody's
email
address
on
the
registration,

15
if
you
haven't
done
that
can
you
please
either
go
back
16
and
add
it
to
your
list
or
send
Mary
something
and
so
17
that
we
then
have
your
address.
Thank
you
very
much.

18
MR.
AUER:
Okay.
Are
there
any
other
points
19
that
any
of
the
interested
parties
would
wish
to
make
20
at
this
juncture.
It
is
about
ten
of
five,
I
am
sure
21
people
want
to
get
going
if
they
can.

22
Well,
thank
you.
I
think
we
have
made
149
1
wonderful
progress
and
I
thank
you
for
all
your
help
2
and
in
moving
towards
the
understandings
and
3
agreements
that
we
have
so
far,
and
I
look
forward
to
4
additional
discussions.

5
6
(
Whereupon,
at
4:
50
p.
m.
the
meeting
adjourned.)

7
­
oo0oo­

8
9
10
11
12
13
14
15
16
17
18
150
CERTIFICATE
OF
STENOTYPE
REPORTER
I,
Monica
L.
Knight,
Stenotype
Reporter,
do
hereby
certify
that
the
foregoing
proceedings
were
reported
by
me
in
stenotypy,
transcribed
under
my
direction
and
are
a
verbatim
record
of
the
proceedings
had.

_______________________________

MONICA
L.
KNIGHT
