U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
PFOA
ECA
Fluoropolymers
Technical
Workgroup
Meeting
Summary,
6/
23/
03
51
participants;
Attendance
list
in
docket
at
OPPT­
2003­
0012­
0125.

The
meeting
included
three
sections:
I.
Presentation
on
scope
of
all
Fluoropolymer
Industry
LOI
commitments
II.
Discussion/
Questions
III.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
for
workgroup
and
plenary
meetings
on
July
9
and
10,
2003.

I.
LOI
Commitments
­
Summary
of
Industry
Presentations
The
Fluoropolymer
Manufacturers
Group
(
FMG)
presentation
detailed
the
fluoropolymer
industry
LOI
commitments,
including
the
topics
of
product
stewardship,
physical
chemical
properties
of
fluoropolymers,
articles
of
commerce
testing,
and
incineration.
The
slide
presentation
is
available
in
the
docket
at
OPPT­
2003­
0012­
0125.

Product
Stewardship
FMG
LOI
Product
Stewardship
commitments
include
funding
additional
toxicity
and
fate
studies;
updating
information
materials
including
their
Guide
for
Safe
Handling
of
Fluoropolymer
Resins
and
Guide
for
Safe
Handling
of
Fluoropolymer
Dispersions
publications;
continued
training
and
technical
support
for
fluoropolymer
processors;
funding
a
study
to
understand
material
fate
for
users
of
dispersion
fluoropolymers;
and
sharing
technology
across
the
fluoropolymer
industry
to
reduce
environmental
emissions.
FMG
stated
that
their
commitment
to
reduce
environmental
emissions
of
APFO
50%
by
2006
is
currently
ahead
of
schedule.

Physical/
Chemical
Properties
FMG
reported
on
their
LOI
commitments
with
regards
to
physical/
chemical
(
p­
chem)
properties
of
fluoropolymers.
They
distributed
a
report
entitled
Basic
Fluoropolymer
Data
to
provide
a
comprehensive
literature
search
of
available
physical/
chemical
properties
data
for
three
principal
fluoropolymers.
FMG
asserted
that
this
information
adequately
addresses
Item
#
2
of
the
EPA
ECA
Preliminary
Framework
document
regarding
physical/
chemical
properties,
and
that
no
further
testing
would
be
needed.
The
workgroup
was
asked
to
review
the
information
and
forward
any
specific
clarification
questions
to
Mary
Dominiak
at
EPA
for
distribution
and
discussion
at
the
next
meeting.

Articles
of
Commerce
Testing
FMG
reported
on
their
LOI
commitments
with
regard
to
Article
of
Commerce
Testing.
The
FMG
presentation
described
their
intent
to
evaluate
the
potential
for
articles
of
commerce
to
contribute
to
APFO
exposure.
The
analysis
of
articles
will
include
dry
fluoropolymer
resins
as
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
2
well
as
liquid
fluoropolymer
dispersions.
FMG
noted
that
most
products
sold
as
dry
powders
and
pellets
have
all
residual
PFOA
removed
prior
to
sale,
while
the
dispersions
contain
a
certain
amount
of
APFO
when
sold.

FMG
reported
that
the
selection
criteria
for
articles
to
be
tested
under
the
FMG
LOI
commitments
will
be
based
on
widespread
consumer
use
and
the
exposure
potential
for
industrial
and
commercial
products.
FMG
stated
that,
due
to
the
small
amount
of
fluoropolymers
present,
little
potential
exposure
is
expected.
The
articles
to
be
selected
would
be
classified
according
to
consumer
applications,
industrial
applications,
high
heat
processing
and
low
heat
processing.
The
high
heat
processing
would
be
expected
to
drive
off
APFO,
while
the
low
heat
processing
would
not.
Test
article
selection
priority
would
be
assigned
based
on
potential
exposure
routes
for
consumer
products,
low
heat
processed
products,
and
higher
volume
industrial
applications.

The
testing
protocol
FMG
proposed
for
articles
testing
would
be
FDA's
21
CFR
175.300
for
new
articles
and
FDA
Test
­
Guidance
for
Industry
dated
April,
2002
for
aged
articles.
FMG
indicated
that
the
next
steps
for
analysis
of
new
articles
will
be
the
review
of
15
candidate
articles
and
the
final
determination
of
articles
for
testing;
the
development
and
finalization
of
the
study
plan;
the
validation
of
all
analytical
methods;
the
identification
of
candidate
articles
from
at
least
2
different
manufacturers
each
for
testing;
and
the
completion
of
a
proposed
time­
line
of
work
through
the
end
of
this
year.
Aged
articles
will
be
evaluated
based
upon
the
results
of
the
new
articles
testing.

Incineration
With
respect
to
incineration,
FMG
acknowledged
that
its
LOI
did
not
include
provisions
for
incineration
testing,
but
that
FMG
agreed
that
this
information
would
be
useful
and
could
be
an
appropriate
focus
for
an
ECA.
FMG
reported
that
its
intent
would
be
to
determine
whether
incineration
results
in
the
emission
of
PFOA
from
fluoropolymers
and
fluoropolymer
containing
articles.
FMG
proposed
a
protocol
for
incineration
testing
based
on
the
University
of
Dayton
lab
scale
thermal
degradation
test
which
focuses
on
municipal
and
hazardous
waste
incineration.
FMG
would
select
representative
articles
and
fluoropolymers
for
analysis.
The
incineration
protocol
would
be
adapted
to
evaluate
fluoropolymers
using
the
3M
study
as
a
basis.
Results
of
the
3M
incineration
study
are
forthcoming.
The
adapted
protocol
would
be
reviewed
with
EPA
prior
to
the
start
of
any
testing.

II.
Discussion/
Questions
EPA
clarified
that
the
product
stewardship
elements
generally
included
in
an
ECA
involve
submitting
reports
on
the
nature,
extent
and
range
of
stewardship
activities
during
a
period
on
a
company
by
company
basis.
EPA
noted
that
although
the
LOI
includes
provisions
for
FMG
to
update
the
Agency,
the
LOI
commitment
may
not
extend
to
the
level
of
detail
or
cover
the
period
of
time
that
EPA
might
contemplate
for
an
ECA.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
3
Interested
parties
asked
whether
the
submitted
handout
of
Physical/
Chemical
properties
was
an
effort
to
explain
why
additional
degradation
testing
is
not
necessary.
FMG
responded
that
based
on
inherent
properties,
the
materials
are
highly
resistant
to
thermal
and
chemical
insult,
and
that
conducting
traditional
biodegradation
studies
would,
in
their
opinion,
not
be
productive.
FMG
stated
that
the
handout
document
was
an
effort
to
summarize
the
already
available
data,
and
that
FMG
believes
there
is
no
need
for
additional
testing.
FMG
suggested
that
the
workgroup
review
the
data
and
forward
any
questions
regarding
the
need
for
clarification
to
Mary
Dominiak
for
submission
to
FMG.
FMG
promised
to
make
every
effort
to
submit
the
responses
in
a
timely
fashion.

Many
of
the
workgroup
participants
had
questions
about
the
selection
of
articles
of
commerce,
including
the
list
of
choices
and
the
criteria
for
selection,
and
whether
both
dry
and
dispersion
products
were
being
considered.
The
workgroup
suggested
FMG
provide
a
matrix
describing
which
articles
of
commerce
will
be
included
under
the
LOI
commitments.
The
matrix
would
include
consumer
and
industrial
applications,
and
indicate
whether
they
are
manufactured
at
high
or
low
temperatures.
The
workgroup
expressed
concern
that
without
such
a
matrix,
it
is
not
possible
to
understand
what
testing
is
included
under
the
FMG
LOI
commitment.
FMG
stated
that
they
would
be
able
to
provide
a
matrix
by
the
next
meeting
on
July
9.

Parties
questioned
whether
FDA
175.300
was
the
appropriate
test
for
articles
of
commerce
testing,
given
that
it
is
a
test
for
coatings
that
may
not
be
appropriate
for
all
fluoropolymer
applications.
FMG
responded
that
the
intent
was
to
use
a
well­
recognized
test,
not
a
specific
test
method.

III.
Next
Steps
°
FMG
will
deliver
to
EPA
a
matrix
of
products
and
articles
with
proposed
testing
selection
criteria
by
7/
7
for
distribution.
The
matrix
will
include
consumer
and
industrial
products,
and
temperature
considerations.
°
Send
questions
concerning
p­
chem
properties
in
particular
and
the
FMG
LOI
and
the
FMG
presentation
to
Mary
Dominiak
by
COB
on
6/
27.
These
will
be
forwarded
to
Lynn
Harris
by
7/
3
for
response
prior
to
the
next
workgroup
meeting
on
7/
9.
°
Should
the
3M
incineration
protocol
and
findings
be
available
prior
to
the
7/
9
meeting,
hard
copies
will
be
made
available
for
review
at
the
7/
9
meeting.
Requests
for
hard
copies
should
be
sent
to
Mary
Dominiak
so
that
appropriate
copies
can
be
made.
°
EPA
will
consider
what
information
needs
to
be
included
in
the
proposed
Report
Schedule.
Most
of
the
information
could
already
be
contained
in
the
LOI
commitment.
Any
time­
line
information
not
available
will
be
incorporated
into
a
summary
at
a
later
date.
°
Be
considering
workgroup
spokesperson
for
plenary
meeting
on
7/
10.
