U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
PFOA
ECA
Telomers
Technical
Workgroup
Meeting
Summary,
6/
24/
03
53
participants;
Attendance
list
in
docket
at
OPPT­
2003­
0012­
0128.

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

I.
LOI
Commitments
­
Summary
of
Industry
Presentations
The
Telomer
Research
Program
presented
background
on
its
formation.
TRP
is
a
sciencefocused
research
consortium
founded
3
years
ago
in
response
to
a
need
to
develop
data
on
telomer
products.
The
members
include
Asahi
Glass,
Clariant,
Daikin
Industries,
and
DuPont.
The
goals
of
the
group
were
to
develop
test
methods
and
protocols
to
be
used
to
conduct
analyses
on
products
in
the
areas
of
toxicology,
pharmocokinetics,
and
environmental
fate.
TRP
indicated
that
for
the
last
year
it
has
refocused
much
of
its
energy
into
development
and
execution
of
the
LOI..
The
slide
presentation
is
available
in
the
docket
at
OPPT­
2003­
0012­
0128.

TRP
stated
that
the
purpose
of
the
LOI
is
to
give
the
Agency
and
other
interested
parties
a
clear
idea
of
what
is
covered,
what
is
not
covered,
and
why
it
is
not
covered.
The
TRP
said
that
it
is
seeking
input
on
the
LOI
process
and
hopes
to
identify
items
for
inclusion
in
the
ECA
while
not
compromising
the
work
already
underway.
The
overall
objective
of
the
LOI
is
to
determine
potential
releases
of
PFOA
from
product
manufacture,
processing,
products,
and
treated
articles
and
to
gain
a
better
understanding
of
the
environmental
fate
and
effects
of
these
releases.

TRP
indicated
that
the
testing
approach
will
be
to
determine
relevant
releases
and
exposures
to
PFOA
from
select
products.
Release
and
exposure
studies
will
be
conducted
in
a
mill
pilot
facility
using
a
closed
system.
The
TRP
believes
that
identification
of
the
environmental
compartments,
pathways,
and
the
potential
exposures
is
the
first
step.
Fate
and
monitoring
studies
will
be
conducted
based
on
these
release
and
exposure
findings.
TRP
proposed
conducting
many
tests
in
parallel
using
12
representative
polymeric
telomer
products
used
in
the
three
primary
markets
of
carpet,
textiles,
and
paper.

TRP
presented
a
comparison
of
the
LOI
commitments
with
the
EPA
ECA
Preliminary
Framework
document
dated
May
20,
2003,
and
stated
that
the
only
area
not
covered
by
the
LOI
at
this
time
concerns
releases
and
exposures
from
fire
fighting
foams
(
Item
#
11).
TRP
stated
that
a
representative
from
the
Fire
Fighting
Foam
Coalition
(
FFFC)
will
present
information
at
the
next
plenary
meeting
on
July
10,
2003.
TRP
presented
detailed
progress
in
each
of
the
other
EPA
ECA
framework
document
areas.
TRP
indicated
their
understanding
that
all
physical
chemical
properties
information
has
been
completed
and
submitted
to
the
docket.
Determination
of
degradation
pathways
and
products
will
be
conducted
using
the
pilot
mill.
The
p­
chem
properties
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
2
of
the
degradation
products
will
be
conducted
once
product
pathways
are
identified.
TRP
stated
that
the
incineration
by­
products
cannot
be
identified
until
the
primary
method
of
disposal
is
identified.
TRP
will
look
at
the
12
representative
products
and
determine
their
individual
methods
of
disposal.
TRP
indicated
that,
under
their
LOI
commitment,
incineration
analyses
will
only
be
conducted
on
those
products
that
are
identified
to
have
incineration
as
their
primary
disposal
method.
TRP
reported
that,
under
their
LOI
commitments,
the
determination
of
the
presence
of
PFOA
and
PFOA
precursors
in
telomer
products
and
telomer
articles
is
underway,
and
that
analytical
techniques
and
method
validation
are
currently
being
developed
to
make
that
determination.
Product
and
article
aging
is
also
underway
under
the
TRP
LOI
commitments.
In
the
aging
studies,
products
will
be
subjected
to
high
temperatures
to
simulate
storage
and
transportation.
Aged
articles
will
be
subjected
to
high
temperatures
and
photolysis
to
simulate
use
under
normal
conditions.
With
respect
to
product
stewardship,
TRP
stated
that
the
member
companies
are
committed
to
safe
handling
and
use
of
their
products
at
the
manufacturing
site
as
well
as
at
customer
and
handler
sites.
TRP
indicated
that
its
goal
is
to
develop
a
TRP
Safe
Handling
and
Use
Handbook
for
customers
who
use
TRP
products
similar
to
the
FMG
industry
guide.

TRP
concluded
that
the
LOI
is
a
comprehensive
document
that
addresses
the
majority
of
the
ECA
items,
and
that
the
LOI
would
be
the
most
expeditious
method
to
conduct
work.
TRP
stated
that
by
employing
a
technically
sound,
step­
wise
testing
approach,
the
LOI
would
serve
the
interests
of
all
the
parties.

II.
Discussion/
Questions
The
workgroup
participants
had
questions
regarding
the
submission
of
the
physical
chemical
properties
of
telomer
8­
2
alcohol.
TRP
responded
by
stating
that
all
suggested
tests
were
complete
and
submitted
to
the
docket,
with
the
exception
of
the
absorption/
desorption
test
which
is
due
for
completion
within
3
months.

Parties
questioned
whether
additional
chemicals
needed
to
be
addressed,
and
particularly
whether
TRP
should
test
for
chemicals
beyond
PFOA
and
the
8­
2
alcohol,
possibly
including
C10,
PFDA,
and
other
perfluorinated
degradation
products
found
in
human
blood.
TRP
responded
by
stating
that
the
LOI
commitment
focused
on
PFOA
and
the
telomer
8­
2
alcohol
because
PFOA
was
what
the
available
literature
had
described
as
a
problem.
TRP
mentioned
that
iodides
are
intermediates
whose
identities
disappear,
and
the
esters
have
potential
to
hydrolyze
to
form
the
alcohol.

Meeting
participants
questioned
the
proposed
biodegradation
testing,
particularly
the
duration
of
tests
and
the
appropriateness
of
the
TRP
"
triggering
scheme"
that
would
lead
to
additional
testing.
EPA
indicated
that
the
aerobic
soil
test
is
a
fundamental
biodegradation
test,
and
suggested
the
OECD
307
(
Aerobic
and
Anaerobic
Transformations
in
Soil)
and
OECD
308
(
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
systems)
protocols.
TRP
stated
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
3
that
it
believed
that
the
ready
biodegradation
test
would
help
build
an
analytical
method
for
longer
term
testing,
and
that
the
higher
level
tests
cannot
be
conducted
until
other
tests
are
completed.
The
workgroup
recognized
that
available
test
methods
may
not
adequately
address
the
biodegradation
data
needs
for
telomers
and
decided
to
convene
a
Biodegradation
Test
Methods
Development
subgroup
comprised
of
technical
experts
tasked
to
reach
agreement
on
acceptable
test
methods.
EPA
agreed
to
solicit
expert
subgroup
participants
from
among
the
interested
parties
and
to
convene
meetings
of
the
subgroup,
which
may
take
place
through
conference
calls.

Numerous
questions
arose
concerning
the
adequacy
of
the
chemical
coverage,
the
number
of
samples,
and
the
rationale
behind
the
selection
process.
Several
questions
arose
regarding
the
selection
of
the
12
representative
products
for
inclusion
in
the
studies.
Workgroup
members
wanted
to
know
specific
information
regarding
these
products,
including
specific
chemical
identity,
specific
uses,
and
whether
they
were
truly
representative
of
all
products
available.
TRP
responded
by
stating
that
the
12
representative
products
were
selected
based
on
the
most
amount
of
material
used
and
in
what
markets,
and
were
based
on
largest
volume
of
product
selling
to
the
various
uses.
TRP
stated
generically
that
each
product
has
a
common
fluorine
backbone
which
is
formulated
into
different
products
with
different
CAS
numbers,
and
that
they
are
acrylic
and
urethane
type
polymers.
No
TRP
company
knows
which
specific
chemicals
are
being
assessed
by
other
companies
due
to
competitive
issues
in
these
markets.
TRP
stated
that
the
12
products
represent
the
major
market
end
uses
of
carpet,
textile,
and
paper
(
i.
e.
pet
food
bags),
although
the
detailed
rationales
of
why
the
specific
chemicals
were
chosen
are
confidential.
TRP
agreed
to
provide
a
"
public
face"
for
the
12
chemicals
and
their
uses
for
the
next
meeting.
EPA
noted
that
questions
remain
concerning
the
12
chemicals
selected
and
whether
they
adequately
characterize
the
universe
of
telomer
products
in
commerce,
and
that
it
will
be
addressing
questions
to
the
individual
companies
on
their
CBI
information.

Of
particular
interest
were
the
proposed
incineration
evaluations.
In
response
to
questions,
TRP
stated
that
initially
an
analysis
on
primary
means
of
disposal
would
be
conducted,
and
that
only
those
items
determined
to
be
primarily
incinerated
would
be
tested.
The
incineration
test
method
would
have
to
be
based
on
the
determination
of
the
incinerator
conditions
in
the
US.
Thermal
profile
would
not
be
part
of
the
evaluation.
EPA
agreed
to
provide
a
basic
incineration
method
for
evaluation
by
the
TRP.

Questions
were
raised
regarding
the
testing
methods
proposed
for
aged
articles,
and
included
whether
the
methods
would
be
sufficient
to
identify
whether
the
articles
are
a
source
of
PFOA
exposure,
and
what
testing
methods
are
proposed
to
identify
potential
exposures.
The
CPSC
stated
that
they
typically
use
dermal,
washing,
sweat,
and
saliva
tests
to
determine
the
potential
for
human
exposure.
TRP
responded
that
the
initial
analyses
must
be
performed
prior
to
more
specific
tests
being
performed.
Analysis
of
the
aged
and
used
articles
must
be
put
together
and
a
decision
made
on
how
to
proceed.
Proposed
tests
could
include
rub­
off,
washing,
etc.
This
led
to
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
4
the
realization
that
it
was
not
possible
to
understand
the
full
extent
of
the
testing
to
be
performed
under
the
LOI
commitments
without
a
flow
chart
or
similar
visual
aid.

The
workgroup
participants
asked
TRP
to
develop
a
diagram
of
"
What
ifs"
to
put
into
perspective
the
decision
pathways
the
TRP
would
undertake
throughout
their
LOI
testing
process.
The
TRP
committed
to
develop
such
a
diagram
for
review
at
the
next
meeting
on
July
10.
TRP
indicated
that
the
diagram
may
not
be
complete,
but
would
give
the
participants
a
better
idea
of
what
considerations
and
decision
paths
are
proposed
and
what
testing
would
be
done
under
the
LOI.

The
workgroup
came
to
the
conclusion
that
a
comprehensive
list
of
all
documents
provided
to
the
docket
would
allow
the
participants
to
review
all
submitted
information
in
an
orderly
manner.
Katie
Smythe
will
develop
this
document
and
forward
it
to
Mary
Dominiak
for
distribution
to
the
workgroup
before
the
July
10
workgroup
meeting.

III.
Next
Steps
I.
TRP
to
provide
a
"
What
if"
flow
diagram
describing
the
decision
logic
and
details
of
their
LOI
testing
commitments.
II.
TRP
will
prepare
a
document
to
"
put
a
public
face"
on
the
12
chemicals
selected
for
testing
by
members
of
the
TRP
under
their
LOI
commitments
to
better
inform
the
interested
parties
of
where
and
how
these
chemicals
are
used
and
why
they
were
selected
for
testing.
III.
TRP
will
identify
where
information
relevant
to
its
LOI
testing
program
can
be
found
in
the
public
record.
Katie
Smythe
will
forward
to
Many
Dominiak
a
crosswalk
document
linking
data
submissions
to
LOI
testing
commitments.
IV.
Responsibility
of
the
workgroup
to
look
at
all
identified
documents,
including
the
rationales
supporting
the
TRP
LOI
testing
commitments.
V.
EPA
to
provide
a
basic
incineration
method
for
review.
VI.
Identification
of
technical
specialists
to
participate
in
a
Biodegradation
Test
Methods
Development
subgroup.
VII.
Be
considering
identification
of
workgroup
spokesperson
for
plenary
meeting
on
7/
10.
