U.
S.
Environmental
Protection
Agency
July
8,
2003
Draft
Agenda
Telomers
ECA
Technical
Workgroup
Meeting
Thursday,
July
10,
2003
9:
00­
12:
00
PM
Mission
Statement:
The
Telomer
Workgroup
will
develop
ECA
proposal(
s)
for
telomers
and
telomer­
treated
products
as
identified
by
the
Plenary
Group.
The
initial
focus
will
be
for
the
data
needs
identified
in
items
2,
3,
4,
5,
6,
7,
8,
9,
and
12
of
Table
I
of
the
Preliminary
Framework
document
prepared
by
EPA,
specifically
addressing:
(
a)
P­
chem
properties
to
inform
fate
testing
for
telomer
chemicals
not
included
in
the
industry­
sponsored
LOI;
(
b)
elucidation
of
degradation
pathways
and
identification
of
degradation
products;
(
c)
determination
of
pchem
fate
and
transport
properties
of
major
degradation
products;
(
d)
determination
of
incineration
byproducts
of
telomers
and
telomer­
treated
products
and
articles;
(
e)
determination
of
p­
chem,
fate
and
transport
properties
of
major
incineration
byproducts;
(
f)
presence/
quantification
of
PFOA
precursors
in
telomer
chemical
products
and
in
telomertreated
or
telomer­
containing
products
and
articles;
(
g)
presence
of
PFOA
precursors
emitted
from
telomer­
treated
products
and
articles
as
they
age
during
use;
and
(
h)
product
stewardship
information.

Meeting
Objective:
Development
meeting
to:
1.
Clarify
the
industry
LOI
and
specifically
identify
further
topics
for
ECA
development.
2.
Discuss
and
develop
an
ECA
proposal
for
incineration
testing.
3.
Discuss
additional
ECA
candidate
topics
and
develop
initial
proposals.
4.
Prepare
workgroup
presentation
to
plenary
session
and
select
spokesperson.
5.
Identify
workgroup
next
steps
and
assignments.

Workgroup
Participants:
3M;
CPSC;
EPA;
EWG;
Rich
Purdy;
TRP
Order
of
Meeting:
°
Introductions:
Chair,
Phil
Oshida,
Director,
Chemical
Control
Division
EPA
Technical
Lead:
David
Lynch,
Economics,
Exposure,
and
Technology
Division
°
EPA
presentation
comparing
LOI
activities
with
EPA
data
needs
and
identifying
potential
topics
for
ECA
development;
discussion.

°
Discussion
of
proposed
ECA
for
incineration
testing;
identification
and
discussion
of
additional
topics
for
ECA
development.

°
Preparation
of
workgroup
report
to
plenary
session
and
identification
of
spokesperson.

°
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments.
PFOA
ECA
Telorner
Technical
Workgroup
Meeting
July
10,
2003
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ECA
Telomer
Technical
Workgroup
Meeting
July
10,
2003
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PFOA
ECA
Telomer
Technical
Workgroup
Meeting
July
10,
2003
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Comparison
of
LOI
Commitments
and
EPA
Data
Needs
/
Identification
of
Potential
Candidate
ECA
Topics
Telomers
ECA
Technical
Workgroup
July
10,
2003
Table
I.
EPA
Data
Needs:
Telomers
None
Required
None
Required
Information
to
be
provided.

Near
completion
All
telomers
and
polymers
made
from
telomers.

*
Comprehensive
telomer
market
information:

CAS
numbers
Chemical
names
Synthetic
sequences
Production/
import
volumes
Uses/
applications
1
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need:
Telomers
Item
Table
I.
EPA
Data
Needs:
Telomers
*
Water
solubility
OECD
105
*
Vapor
pressure
OECD
104
*
UV/
visible
absorption
OPPTS
830.7050
*
Hydrolysis
as
a
function
of
pH
OPPTS
835.2130
*
Soil
and
sludge
adsorption/
desorption
isotherm
OPPTS
835.1220
Telomer
8­
2
alcohol
Water
solubility
Vapor
Pressure
UV/
visible
absorption
Hydrolysis
as
a
function
of
pH
Adsorption­

Desorption
(
soil,

sediment,
sludge
nonlabelled
and
14C)

Specific
gravity
Representative
test
substances
to
be
determined
and
may
include
telomer
iodides
telomer
alcohols
telomer
esters
of
(
meth)
acrylates
telomer
sulfonates
telomer
phosphates
P­
chem
properties
to
inform
fate
testing.

This
information
needed
prior
to
fate
testing
of
representative
test
substances.

Unnecessary
for
certain
polymeric
materials
2
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need:

Telomers
Item
*
Inherent
Biodegradability
Zahn­

Wellens/
EMPA
Test
835.3200
*
Activated
sludge
sorption
isotherm
OPPTS
835.1110
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
systems
OECD
308
Direct
Photolysis
in
Water
OPPTS
835.2210
Indirect
Photolysis
Screening
Test
OPPTS
835.5270
*
Determination
of
air/
water
partition
coefficient/
Henry's
Law
Constant
(
method
to
be
determined)

Simulation
test­
Aerobic
Sewage
Treatment
(
Activated
Sludge
Units)

OECD
303A
Anaerobic
biodegradability
of
organic
compounds
in
digested
sludge:
measurement
of
gas
production,
OECD
311
Telomer
8­
2
alcohol
Only
PFOA
degradation
product
will
be
identified
OECD
301D
Closed
Bottle
Test
(
Ready
Biodegradability)

nonlabelled
and
14C
Atmospheric
Degradation
Long
Range
Transport
Properties
(
Air/
Water)

Telomer
8­
2
alcohol
and
12
representative
polymer
products
*
Inherent
Biodegradability
Zahn­

Wellens/
EMPA
OECD
302B
Representative
test
substances
to
be
determined
and
may
include
telomer
iodides
telomer
alcohols
telomer
esters
of
(
meth)
acrylates
telomer
sulfonates
telomer
phosphates
Elucidation
of
degradation
pathways
and
identification
of
degradation
products
3
LOI
Commitment
Chemical/
Data
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs:
Telomers
Item
Table
I.
EPA
Data
Needs
Telomers,
continued
Table
I.
EPA
Data
Needs
Telomers,
continued
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Needs
Item
P­
Chem
properties
in
2
above
and
Determination
of
air/
water
partition
coefficient/
Henry's
Law
Constant
(
method
to
be
determined).

Direct
Photolysis
in
Water
OPPTS
835.2210.

Indirect
Photolysis
Screening
Test
OPPTS
835.5270.

Not
Included
Known
degradants
as
determined
in
item
3
Determination
of
p­
chem,
fate
and
transport
properties
of
degradation
products
4
Table
I.
EPA
Data
Needs
Telomers,
continued
"
Laboratory"
Burn
Test
Protocol:

1.
ASTM
E1641:

Decomposition
Kinetics
by
Thermogravimetry.

2.
Laboratory­
Scale
Thermal
Degradation
via
GC/
MS
yielding
the
temperature
for
99%
destruction
efficiency
@
2.0
second
residence
time
&
excess
oxygen.

EPA
is
making
an
ECA
proposal
for
incineration
testing
Not
Included
Representative
telomers
and
telomer
treated
products
and
articles
(
e.
g.,
paper,

textile
and
carpet
products)
from
manufacturers
and
importers
Determination
of
incineration
byproducts
of
telomers
and
telomer
treated
products
and
articles
5
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Needs
Item
Table
I.
EPA
Data
Needs
Telomers,
continued
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need
Item
To
be
determined
based
on
incineration
test
results.

Not
Included
Representative
telomer
incineration
byproducts
Determination
of
p­
chem,
fate
and
transport
properties
of
incineration
byproducts
6
Table
I.
EPA
Data
Needs
Telomers,
continued
Methods
under
review
TRP
plan
will
test
for
PFOA
and
telomer
8­
2
alcohol
in
12
polymers
representing
three
major
end­
use
categories:
carpet,

textiles,
and
paper.

Representative
telomers
from
manufacturers
and
importers
*
Presence/
quantifi
cation
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
in
telomer
chemical
products
7
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need
Item
Table
I.
EPA
Data
Needs
Telomers,
continued
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need
Item
Methods
under
review
The
12
telomer
polymers
from
item
7
will
be
applied
to
carpet
(
4),
textiles
(
6)

and
paper
(
2);
samples
from
these
articles
will
be
tested
for
PFOA.

Representative
telomer­
treated
or
telomer­
containing
products
and
articles
(
paper,
textile
and
carpet
products,

firefighting
foams),

from
manufacturers
and
importers
*
Presence/
quantifica
tion
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
in
telomer­
treated
or
telomer­
containing
products
and
articles
8
Table
I.
EPA
Data
Needs
Telomers,
continued
Methods
under
review
PFOA
and
telomer
8­
2
alcohol
analyses
of
12
temperature­
aged
telomer
polymers;
PFOA
analysis
before
and
after:

temperature
and
photolytic
aging
of
treated
carpet,

textile
and
paper;
abrasion
of
treated
carpet
and
textiles;
washing
and
dry
cleaning
of
treated
textiles;

and
hot
water
extraction
of
treated
carpet
Representative
telomers
and
telomer
treated
products
and
articles
from
manufacturers
and
importers
in
indoor
air
adjacent
to
 
and
dust
from
or
adjacent
to
 
carpet,
textile,
and
paper
products.

*
Presence
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
emitted
from
telomer
treated
products
and
articles
as
they
age
during
use
9
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need
Item
*
Denotes
that
the
TRP
has
committed
to
provide
some,
but
not
necessarily
all,
information
concerning
this
particular
data
need
or
endpoint
for
one
or
more
chemicals.
Analytical
methods
are
to
be
determined,
and
data
quality
requirements
need
to
be
reviewed
to
determine
appropriateness
and
acceptability
in
the
context
of
this
ECA.
To
the
extent
that
chemicals
beyond
those
being
covered
under
the
LOI
are
identified
as
possible
test
candidates,
the
need
for
such
testing
will
be
considered
in
the
context
of
the
ECA
process.

Test
methods
may
be
amended
and
adapted
through
the
ECA
process,
and
where
test
methods
have
not
been
identified,
they
may
be
developed
during
the
ECA
process.

Table
I.
EPA
Data
Needs
Telomers,
continued
Suggested
Test
Methods
to
Address
EPA
Data
Needs
LOI
Commitment
Chemical/
Data
Test
Substances
EPA
Data
Need:
Telomers
Item
None
required.

Documentation
of
Product
Stewardship
Programs
Telomer
products
and
articles
Product
stewardship
information
concerning
telomer
products
and
articles
12
EPA
Data
Needs
Beyond
the
LOI
Commitments
*
Water
solubility
OECD
105
*
Vapor
pressure
OECD
104
*
UV/
visible
absorption
OPPTS
830.7050
*
Hydrolysis
as
a
function
of
pH
OPPTS
835.2130
*
Soil
and
sludge
adsorption/
desorption
isotherm
OPPTS
835.1220
Representative
test
substances
to
be
determined
P­
chem
properties
2
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs
Beyond
LOI
Commitments
Item
*
Inherent
Biodegradability
Zahn­
Wellens/
EMPA
Test
835.3200
*
Activated
sludge
sorption
isotherm
OPPTS
835.1110
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
systems
OECD
308
Direct
Photolysis
in
Water
OPPTS
835.2210
Indirect
Photolysis
Screening
Test
OPPTS
835.5270
*
Determination
of
air/
water
partition
coefficient/
Henry's
Law
Constant
(
method
to
be
determined)

Simulation
test­
Aerobic
Sewage
Treatment
(
Activated
Sludge
Units)
OECD
303A
Anaerobic
biodegradability
of
organic
compounds
in
digested
sludge:
measurement
of
gas
production,
OECD
311
Representative
test
substances
to
be
determined
Elucidation
of
degradation
pathways
and
identification
of
degradation
products
3
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs
Beyond
LOI
Commitments
Item
EPA
Data
Needs
Beyond
the
LOI
Commitments
"
Laboratory"
Burn
Test
Protocol:

1.
ASTM
E1641:
Decomposition
Kinetics
by
Thermogravimetry.

2.
Laboratory­
Scale
Thermal
Degradation
via
GC/
MS
yielding
the
temperature
for
99%
destruction
efficiency
@
2.0
second
residence
time
&
excess
oxygen.

EPA
is
making
an
ECA
proposal
for
incineration
testing
Representative
telomers
and
telomer
treated
products
and
articles
(
e.
g.,
paper,

textile
and
carpet
products)
from
manufacturers
and
importers
Determination
of
incineration
byproducts
of
telomers
and
telomer
treated
products
and
articles
5
P­
Chem
properties
in
2
above
and
Determination
of
air/
water
partition
coefficient/
Henry's
Law
Constant
(
method
to
be
determined).

Direct
Photolysis
in
Water
OPPTS
835.2210.

Indirect
Photolysis
Screening
Test
OPPTS
835.5270.

Known
degradants
as
determined
in
item
3
Determination
of
p­
chem,
fate
and
transport
properties
of
degradation
products
4
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs
Beyond
LOI
Commitments
Item
EPA
Data
Needs
Beyond
the
LOI
Commitments
To
be
determined
based
on
incineration
test
results.

[
half
life
gas
phase
HO.
Reactivity]

Representative
telomer
incineration
byproducts
Determination
of
p­
chem,
fate
and
transport
properties
of
incineration
byproducts
6
Methods
under
review
Representative
telomers
from
manufacturers
and
importers
*
Presence/
quantifi
cation
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
in
telomer
chemical
products
7
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs
Beyond
LOI
Commitments
Item
EPA
Data
Needs
Beyond
the
LOI
Commitments
Methods
under
review
Representative
telomers
and
telomer
treated
products
and
articles
from
manufacturers
and
importers
in
indoor
air
adjacent
to
 
and
dust
from
or
adjacent
to
 
carpet,
textile,
and
paper
products.

*
Presence
of
PFOA,
telomer
alcohol
or
other
PFOA
precursors
emitted
from
telomer
treated
products
and
articles
as
they
age
during
use
9
Methods
under
review
Representative
telomer­
treated
or
telomer­
containing
products
and
articles
(
paper,
textile
and
carpet
products,

firefighting
foams),
from
manufacturers
and
importers
*
Presence/
quantifi
cation
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
in
telomer­
treated
or
telomer­
containing
products
and
articles
8
Suggested
Test
Methods
to
Address
EPA
Data
Needs
Test
Substances
EPA
Data
Needs
Beyond
LOI
Commitments
Item
*
Denotes
that
the
TRP
has
committed
to
provide
some,
but
not
necessarily
all,
information
concerning
this
particular
data
need
or
endpoint
for
one
or
more
chemicals.
Analytical
methods
are
to
be
determined,
and
data
quality
requirements
need
to
be
reviewed
to
determine
appropriateness
and
acceptability
in
the
context
of
this
ECA.
To
the
extent
that
chemicals
beyond
those
being
covered
under
the
LOI
are
identified
as
possible
test
candidates,
the
need
for
such
testing
will
be
considered
in
the
context
of
the
ECA
process.

Test
methods
may
be
amended
and
adapted
through
the
ECA
process,
and
where
test
methods
have
not
been
identified,
they
may
be
developed
during
the
ECA
process.
July
10,
2003
EPA
ECA
Proposal
for
Telomer
Incineration
Testing
Rationale
Incineration
testing
of
telomers,
telomer
products,
and
articles
treated
with
telomers
containing
perfluoroalkyl
groups
was
not
included
in
the
TRP
LOI
commitments.
The
degradants
of
perfluorinated
materials
vary
greatly
as
a
function
of
incineration
temperature
and
residence
time.
Thermodynamically,
at
a
temperature
of
about
1200
°
C,
a
destruction
efficiency
of
99.99%
for
a
C­
F
chemical
bond
can
be
obtained.
Information
on
the
extent
of
destruction
and
full
characterization
of
the
types
of
degradants
formed
at
lower
incineration
temperatures
is
unknown.
This
is
further
confounded
because,
based
on
US
information,
there
are
three
types
of
incinerators
in
operation
across
the
US:
1)
medical
waste
incinerators
operating
around
650
°
C;
2)
municipal
waste
incinerators
(
static
grate)
operating
between
400­
600
°
C;
and
3)
chemical
(
hazardous
waste)
incinerators
operating
up
to
1300
°
C;
and
it
is
expected
that
the
extent
of
destruction
and
types
of
degradants
will
vary
across
each
incinerator
type.

ECA
Proposal
It
is
proposed
that
incineration
testing
be
conducted
to
meet
the
following
data
needs:
<
Define
by
test,
the
temperature
needed
to
provide
99.99%
destruction
of
each
perfluorinated
test
substance/
material,
both
as
the
manufactured
perfluoro
compound
and
the
article
employing
the
perfluoro
compound.
<
Create
an
incineration
temperature
profile
versus
characterized
degradants
Test
substances:

Tier
1:
EPA
recommends,
as
a
starting
point,
that
testing
be
conducted
for
each
of
the
products
TRP
committed
to
PFOA
testing
for
the
LOI.
Tier
2:
Depending
on
test
results,
specifically
whether
higher
C
chain
length
(
C8
typically)
acids
form,
an
additional
representative
number
of
product
formulations
and
articles
in
commerce
may
need
to
be
tested.
EPA
recommends
that
the
formulations
and
articles
be
determined
by
members
of
a
technical
subgroup
on
Incineration
Testing.

Test
Method:
Testing
is
to
be
conducted
using
methods
equivalent
to
those
described
or
reviewed
in
"
Guidelines
for
Determination
of
Polyhalogenated
Dibenzo­
p­
dioxins
and
Dibenzofurans
in
Commercial
Products"
(
see
40CFR,
section
766.1
through
766.18)
and/
or
the
3M
protocol.

Although
the
average
residence
time
may
vary
across
incinerators,
testing
under
this
ECA
proposal
should
satisfy
a
2
second
residence
time.
Incineration
testing
within
these
three
(
3)
temperature
ranges,
as
specified
under
Rationale
section
above,
will
provide
data
that
is
crucial
in
determining
potential
pathways
into
the
environment
of
perfluoro
compounds
and
their
degradants
which
may
be
precursors
to
PFOA.
July
10,
2003
2
The
laboratory
equipment
needed
to
define
temperatures,
residence
times
and
byproducts
produced
includes
a
high
temperature
tubular
furnace
with
carrier
gas
connected
to
a
gas
chromatograph
followed
by
a
mass
spectrometer.
Note:
a
GC­
GC­
MS
arrangement
will
likely
be
necessary
for
sub­
ppm
data
generation.
Thermogravimetric
analysis
will
be
used
before
initiating
the
laboratory
incineration
testing
to
document
the
low
temperature
(<
500
°
C)
behavior
of
the
test
compounds
(
or
articles)
and
to
verify
gasification
of
material
following
ASTM
E1641,
Decomposition
Kinetics
by
Thermogravimetric
Analysis.

EPA
GLP
Data
Quality
and
Quality
Assurance
Requirements:
All
testing
must
conform
with
EPA
GLP
Data
Quality
and
Quality
Assurance
requirements.

Data
Reporting:
The
final
report
on
each
test
substance
tested
must
include
a
detailed
description
of
the
specific
test
conditions
used,
the
test
data
including
any
associated
calculations,
spectra
and
curves.
Details
of
data
to
be
reported
shall,
at
a
minimum,
include
information
similar
to
those
outlined
under
40
CFR,
section
761.70
for
Incineration.
TRP
Telomer
Research
Program
ECA
Process
Telomer
Technical
Work
Group
10
July
2003
10
July
2003,
page
2
Telomer
Research
Program
TRP
Meeting
Objectives
for
9­
10
July
`
03

Provide
specific
feedback
on
23­
24
June
meeting
action
items

Monitoring
LOI
Commitment
Details
and
Clarification

Present
"
Public
Face"
on
Products
and
Articles
included
in
LOI

Product
and
Article
Decision
Tree

Biodegradation
Strawman:
Environmental
Fate

Incineration:
Obtain
and
Gather
Information

TRP
LOI
and
Docket
Submissions
Compilation

Seeking
interested
party
input
on
the
TRP
LOI
and
potential
scope
for
ECA
candidates

Focus
on
items
we
can
identify
to
define
as
part
of
the
ECA
and
not
compromise
our
LOI
efforts
10
July
2003,
page
3
Telomer
Research
Program
Presentation
Outline:
10
July
`
03

LOI
Background

Product
&
Article
Information
and
Workflow

"
Public
Face"
on
Products
and
Articles

Biodegradation
Strawman

Incineration

Documentation

Next
Steps
10
July
2003,
page
4
Telomer
Research
Program
TRP
LOI
Overall
Program
Objectives

Investigate
the
potential
formation
and/
or
release
of
perfluorooctanoic
acid
(
PFOA)
from

Fluorotelomer­
based
polymeric
products
and
consumer
articles
treated
with
such
products

Manufacturing
operations
making
or
using
these
products
10
July
2003,
page
5
Telomer
Research
Program
TRP
Approach
to
the
LOI
and
ECA
Processes

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

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

Considers
testing
and
measurements
in
an
iterative
step­
wise
approach
triggered
by
improved
knowledge
gained
10
July
2003,
page
6
Telomer
Research
Program
Product
and
Article
Analysis
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles
TRP
LOI
Commitments
Outline:

Potential
Future
Sources
of
PFOA*

*
Analyses
on
Polymeric
Products
for
Carpet,
Textile,
and
Paper
Segments
Most
of
these
analyses
will
be
done
in
parallel,
not
sequential
Commercial
Items
Potential
PFOA
Release
from
Article
Manufacture
Potential
PFOA
Release
from
Product
Manufacture
+
Commercial
Manufacture
Incineration
Analysis
Biodegradation
Analysis
of
Polymeric
Products
+

and
Fate
10
July
2003,
page
7
Telomer
Research
Program
TRP
LOI
vs.
ECA
Framework
Table
1
Review
Telomer
ECA
Item
Number
Description
­
Brief
Captured
in
LOI;
Location
1
Market
Information
Yes;
Item
#
1
2
P­
chem
Properties
Yes;
In
Related
Activities
3
Degradation
Pathways
and
Products
Yes;
Items
#
5
&
In
Related
Activities
4
P­
chem
of
Degradation
Products
TBD
5
Incineration
Byproducts
Yes;
Item
#
6
6
P­
chem
of
Incineration
Byproducts
TBD
7
Presence
of
PFOA
and
precursors
in
Telomer
Products
Yes;
Item
#
1
8
Presence
of
PFOA
and
precursors
in
Telomer
Articles
Yes;
Item
#
1
9
Product
"
Aging"
and
"
In­
use"
Articles
Yes;
Item
#
2
10
Release
and
Exposure
in
Telomer
Products
Yes;
Items
#
3&
4
11
Release
and
Exposure
in
Fire
Fighting
Foams
No;
FFFC
12
Product
Stewardship
Yes;
In
Related
Activities
10
July
2003,
page
8
Telomer
Research
Program
CF2=
CF2
Tetrafluoroethylene
F(
CF2CF2)
nI
Telomer
A
Iodide
F(
CF2CF2)
nCH2CH2I
Telomer
B
Iodide
F(
CF2CF2)
nCH2CH2OH
Telomer
B
Alcohol
F(
CF2CF2)
nCH2CH2OC(
O)
CH=
CH2
Telomer
Acrylate
Monomer
n
=
2
­
8
Finished
Products
F(
CF2CF2)
nCH=
CH2
Telomer
B
Olefin
Acrylate
Monomer
is
the
most
common
raw
material
used
to
create
Finished
Products
Telomer
Intermediate
"
Building
Blocks"

Telomer
Manufacturing
Process
:

A
Generic
View
°
Actual
processes,

manufacturing
practices,
and
products
vary
by
company
°
PFOA
is
not
used
or
added
in
these
processes
°
Generally,
these
processes
are
closed
and
PFOA
creation
and/
or
emissions
are
expected
to
be
at
very
low
levels
10
July
2003,
page
9
Telomer
Research
Program
Product
and
Article
Analysis
10
July
2003,
page
10
Telomer
Research
Program
Product
and
Article
Analyses:

Work
Flow
Diagram
Screening
Study
Testing
Plan
for
the
12
Commercial
Polymeric
Products
As
Made
­
Commercial
Elevated
Temperature
45
C
for
12
weeks
plus
controls
1
year
ambient
exposure
Photolysis
Xenon
Lamp
NA
Products
C
=
Carpet
(
4)

T
=
Textile
(
6)

P
=
Paper
(
2)

PFOA
Screening
Study
C8F17CH2CH2OH
Analysis
PFOA
Screening
Study
C8F17CH2CH2OH
Analysis
Status:
method
development
underway
at
contract
labs;
method
validation
to
follow
Actual
product
testing
follows
validation
10
July
2003,
page
11
Telomer
Research
Program
Screening
Study:
Articles
Treated
with
12
Commercial
Polymeric
Products
In­
Use
Analysis
and
Conditions
As
Made
Elevated
Temperature
45
C
for
12
weeks
simulates
1
year
ambient
exposure
plus
controls
Photolysis
Xenon
Lamp
24
hours
simulates
1
year
ambient
exposure
plus
controls
Abrasion
Carpet
­
Vetterman
Drum
Textile
­
AATCC
119­
1994
Paper
­
NA
Laundering
Textiles
­
Washing
AATCC
135­
1995
Carpet
and
Paper
­
NA
Dry
Cleaning
Textiles
AATCC
132­
1998
Carpet
and
Paper
­
NA
Hot
Water
Extraction
or
Steam
Cleaning
Carpet
­
AATCC
171­
1995
Textile
and
Paper
­
NA
Articles
C
=
Carpet
(
4)

T
=
Textile
(
6)

P
=
Paper
(
2)

PFOA
Screening
Study
via
extraction
methods;

PFOA
Screening
Study
via
extraction
methods;

PFOA
Screening
Study
via
extraction
methods;
C,
T,
P
Phase
1
C,
T,
P
Phase
1
C,
T,
P
Phase
1
If
PFOA
level
increases
by
?
X
versus
as
made,
then
proceed
to
Phase
2
tests
If
PFOA
level
increases
by
?
X
versus
as
made,
then
proceed
to
Phase
2
tests
C,
T
Phase
2
T
Phase
2
T
Phase
2
C
Phase
2
PFOA
Screening
Study
via
extraction
methods;

As
applicable
on
10
treated
articles
PFOA
Screening
Study
via
extraction
methods;

As
applicable
on
6
treated
articles
PFOA
Screening
Study
via
extraction
methods;

As
applicable
on
6
treated
articles
PFOA
Screening
Study
via
extraction
methods;

As
applicable
on
4
treated
articles
TRP
Plan
is
to
conduct
work
in
Phase
2
unless
PFOA
levels
are
<
LOQ
Status:
method
development
underway
at
contract
labs;
method
validation
to
follow
Actual
article
testing
follows
validation
10
July
2003,
page
12
Telomer
Research
Program
"
Public
Face"
Discussion
10
July
2003,
page
13
Telomer
Research
Program

TRP
member
companies
selected
"
representative"
products
and
consumer
articles
treated
with
such
products.


Selection
criteria:
market
end­
use;
chemistry
type/
class;
chemical
volume;
article
type;
and
potential
for
human
exposure

Each
company
selected
products
representative
of
its
product
line.
Therefore
the
selected
treated
articles
are
representative
of
the
product
classes
produced
in
the
US
market

Major
end
use
sectors:
carpet,
textile,
and
paper

TRP
member
companies
each
have
unique
products.
Products
are
sold
for
what
they
do,
not
what
they
are.


General
description
of
products,
articles,
uses/
applications
incorporated
in
a
"
public
face"
document
table
to
follow.


This
is
TRP
member
company
level
of
information;
data
not
shared!


EPA
is
only
entity
who
knows
complete
identity
and
rationale
Analysis
of
Products
and
Articles
for
PFOA:

"
Public
Face"
Document
10
July
2003,
page
14
Telomer
Research
Program
Analysis
of
Products
and
Articles
for
PFOA
Carpet
Nylon
Residential
use
(
cut
pile)
Stain
resistance
and
newness
retention
Urethane
Foam
or
spray
applied
Carpet
Nylon
Residential
use
(
cut
pile)
Stain
resistance
and
newness
retention
Acrylate
Foam
or
spray
applied
Carpet
Nylon
Residential
use
(
cut
pile)
Stain
resistance
and
newness
retention
Acrylate
Foam
or
spray
applied
Carpet
Nylon
Residential
use
(
cut
pile)
Stain
resistance
and
newness
retention
Acrylate
Foam
or
spray
applied
Textile
Polyester
Apparel
Water
and
stain
repellency
Acrylate
Pad
application
Textile
Polyester
Apparel
Water
and
stain
repellency
Acrylate
Pad
application
Textile
Polyester
Apparel
Water
and
stain
repellency
Acrylate
Pad
application
Textile
Polyester
Apparel
Water
and
stain
repellency
Acrylate
Pad
application
Textile
Nylon
Outerwear
Water
and
stain
repellency
Acrylate
Pad
application
Textile
Cotton
Apparel
and
upholstery
Water
and
stain
repellency
Acrylate
Pad
application
Paper
Cellulose
Treatment
of
pet
food
bags
and
for
direct
and
indirect
food
contact
items
Oil
and
Grease
Repellency;

Barrier
Coating
Acrylate
Mill
applied
by
size
press
method
Paper
Cellulose
Treatment
of
pet
food
bags
and
for
direct
and
indirect
food
contact
items
Oil
and
Grease
Repellency;

Barrier
Coating
Acrylate
Mill
applied
by
size
press
method
Typical
Function
Typical
Application
Methods
Telomer­
Based
Polymeric
Product
Substrate
Typical
Uses
Treated
Article
10
July
2003,
page
15
Telomer
Research
Program
Discussion
and
Next
Steps
10
July
2003,
page
16
Telomer
Research
Program
TRP
Environmental
Fate
:

Biodegradation
Strawman
10
July
2003,
page
17
Telomer
Research
Program
TRP
LOI
Degradation
Studies

8­
2
Telomer
B
Alcohol
C8F17CH2CH2OH

Preliminary
Biodegradation
Screening
(
Cold)
Studies
(
DuPont,
AR226­
1262,1263,1264)


Modified
OECD
301D
28­
Day
Ready
Biodegradation
Study
with
14C
(
Underway)


OECD
106
Adsorption­

Desorption,
Soils,
Sediments,

Sludge
with
14C
(
Underway)


Higher­
tier
studies
to
be
considered
based
upon
results
of
these
studies

Telomer
Polymeric
Products
(
12)


Modified
OECD
302
28­
Day
Inherent
Biodegradation
(
Zahn­

Wellens)


protocol
development
underway

PFOA
and
Fluoride
endpoints

Abiotic

Article
Aging
Study

photolysis

thermal
degradation

Incineration
10
July
2003,
page
18
Telomer
Research
Program
Polymeric
Product
Higher­
Tier
Biodegradation
Studies
Strawman

Modified
OECD
303A
Simulation
Test
­
Aerobic
Sewage
Treatment
Addresses

"
down
the
drain"
waste­
water
compartment
relevance

where
and
whether
PFOA
through
Simulation
Test
­
Aerobic
Sewage
Treatment

Modified
OECD
307
Aerobic
/
Anaerobic
Biodegradation
in
Soil
Addresses

landfill
&
sludge
compartment
relevance

will
determine
whether
polymer
alone
biodegrades

The
Telomer
Polymeric
Products
will
be
representative
test
substances

TRP
needs
to
discuss
this
and
will
be
prepared
to
propose
the
test
substances
for
these
studies
10
July
2003,
page
19
Telomer
Research
Program
Next
Steps

Technical
Team
meet
as
described
in
24
June
`
03
TWG
session
to

Have
technical
discussion
on
tests
to
run
and
applicability

Understand
test
limits
for
this
class
of
materials

Decide
on
what
products
to
run
in
these
proposed
tests
10
July
2003,
page
20
Telomer
Research
Program
Incineration
10
July
2003,
page
21
Telomer
Research
Program
Incineration
:
Study
Approach

TRP
has
agreed
to
study
the
applicability
of
incineration
to
its
Telomer­
treated
products
and
related
articles
in
the
US
in
a
"
desk
study"


Initial
steps
will
be
to
first
understand
the
US
disposal
methods
and
in
what
markets
incineration
is
applicable

Second
review
the
US
incinerator
conditions
to
understand
permitted
temperatures
and
compare
with
known
Telomer
degradation
temperatures

The
"
desk
study"
will
define
the
scope.
The
design
of
the
study
and
nature
of
the
methodology
needs
to
be
discussed
to
measure
PFOA
emissions
from
incineration
of
telomertreated
articles
10
July
2003,
page
22
Telomer
Research
Program
Incineration
Desk
Study
Information

Franklin
Associates,
Ltd.


1999
MSW
in
the
U.
S.
was
57%
to
landfill,
28%
recovered,
and
15%
to
combustion.


"
Municipal
Solid
Waste
in
The
United
States
:
2000
Facts
&

Figures"
U.
S.
EPA

land
disposal
55%,
recovery
30%,
combustion
15%


TRP
are
reviewing
these
and
other
references
for
data
relevant
to
telomer­
treated
articles
10
July
2003,
page
23
Telomer
Research
Program
Medical
Incinerators

In
Air
Pollution
Control
and
Waste
Incineration
for
Hospitals
and
Other
Medical
Facilities,
Louis
Theodore*
states
that
three
types
of
incinerators
are
primarily
used
for
medical
waste.


Controlled
Air
Incinerators,
Multiple
Chamber
Incinerators,
and
Rotary
Kiln
Incinerators.


All
three
types
use
two
chambers.


The
ignition
or
primary
chamber

The
second
chamber
is
designed
to
complete
the
combustion
process
Controlled
Air
Multiple
Chamber
Rotary
Kiln
Primary
Chamber
400
to
980*
C
540
to
980*
C
760*
C
Second
Chamber
980
to
1200*
C
980
to
1200*
C
980*
C
*
Theodore,
L.:
Air
Pollution
Control
and
Waste
Incineration
for
Hospitals
and
Other
Medical
Facilities,
Van
Nostrand
Reinhold,
New
York,
1990,
pp
313­
320.
Note
that
Rotary
Kilns
for
other
wastes
may
be
operated
in
the
range
of
760*
C
to
1,670*
C
10
July
2003,
page
24
Telomer
Research
Program
Incineration
:
Next
Steps

TRP
will
continue
its
"
desk
study"
efforts
to
better
understand
the
landscape
to
make
informed
choices
and

TRP
member
companies
are
willing
to
discuss,
in
a
technical
work
group,
how
best
to
conduct
incineration
studies

Incineration
is
a
likely
ECA
candidate
10
July
2003,
page
25
Telomer
Research
Program
Information
and
Document
Submissions
and
Cross
References
TRP
Submissions
to
EPA
(
Study
Reports)
30
June
2003
Date
Title
/
Description
Contractor
EPA
Reference
#

15­
Jan­
03
Acute
Oral
Toxicity
Study
 
Fixed
Dose
Method
(
final
report)
Haskell
Lab
AR226­
1196
15­
Jan­
03
In
vivo
Rat
Micronucleus
Assay
(
final
report)
Covance
Lab
AR226­
1198
15­
Jan­
03
Salmonella­
E.
coli
/
Mammalian­
Microsome
Reverse
Mutation
Assay
(
final
report)
Covance
Lab
AR226­
1197
10­
Mar­
03
Acute
Aquatic
Toxicity
Tests:
Fish,
Daphnia,
Algae
(
final
reports,
6
total)
Noack
Lab
AR226­
1218,
1219,
1222,
1223,

1225,
1226
10­
Mar­
03
Microbial
Respiration
Inhibition
Test
with
Activated
Sludge
(
final
report)
Noack
Lab
AR226­
1220
21­
Mar­
03
Bioconcentration
in
Carp
[
Note:
This
study
was
conducted
for
Japan
METI]
CERI
AR226­
1276
21­
Mar­
03
The
First
Environmental
Survey
of
PFOS
and
Related
Compounds
in
Japan
(
journal
article)
Japan
AIST
AR226­
1278
21­
Mar­
03
Levels
of
PFOA
and
Other
Related
Compounds
in
the
Blood
of
Japanese
People
(
journal
article)
Yokohama
Univ.
AR226­
1279
21­
Mar­
03
University
of
Toronto
Year
1
Progress
Report
on
Fluorotelomer
Alcohols
Univ.
of
Toronto
Docket
#
OPPT­
2003­
0012­
0010;

AR226­
1281
21­
Mar­
03
Preliminary
Biodegradation
Screening
(
cold)
Study
­
DuPont
study
(
final
report)
DuPont
AR226­
1262,
1263,
1264
31­
Mar­
03
Aqueous
Stability
of
8­
2
Telomer
B
Alcohol
as
a
Function
of
pH
(
final
report
+
study
summary)
DuPont
AR226­
1290
31­
Mar­
03
Physical­
Chemical
Properties
of
8­
2
Telomer
B
Alcohol
­­
Water
Solubility,
Vapor
Pressure,
Ultraviolet
Spectrum
(
3
final
reports
+
study
summaries)
DuPont
AR226­
1287,
1288,
1289
5­
May­
03
Subchronic
Toxicity
90­
day
Oral
Gavage
Study
in
Rats
with
90­
day
Recovery
(
final
report
­
3
volumes
+

study
summary)
Haskell
Lab
5­
May­
03
Repeated
Dose
Oral
Toxicity
Gavage
Range
Finding
Study
in
Rats
 
Data
Summary
(
report
+
study
summary)
Haskell
Lab
30­
June­
03
Acute
Aquatic
Studies:
Fish,
Daphnia,
Algae,
Microbial
Inhibition
(
study
summaries,
7
total);
related
final
reports
were
submitted
on
10­
March­
03
(
AR226­
1218,
1219,
1220,
1222,
1223,
1225,
1226)
Noack
Lab
30­
June­
03
Terrestrial
Toxicity
Studies:
Earthworm,
Nematode,
Plants
(
3
final
reports
+
study
summaries)
Noack
Lab
EPA
Docket:
www.
epa.
gov/
edocket
(
Docket
ID#
OPPT­
2003­
0012)

AR­
226:
request
copy
of
AR­
226
Index
from
<
oppt.
ncic@
epa.
gov>
(
Tel:
202­
566­
0280)
TRP
Letter
of
Intent
(
LOI)
Submissions
to
EPA
30
June
2003
Date
Title
/
Description
Submitted
by
EPA
Reference
#

14­
Mar­
03
TRP
Letter
of
Intent
(
LOI)
TRP
Docket
#
OPPT­
2003­
0012­
0013;

AR226­
1305
24­
Mar­
03
TRP
Database
List
(
LOI
Commitment
Item)
TRP
AR226­
1292,
1293,
1294
28­
Mar­
03
General
Description
of
Telomer
Process
(
LOI
Commitment
Item
3)
TRP
AR226­
1266
31­
Mar­
03
Umbrella
Letter
of
Intent
(
APFO
Users,
Telomer
Companies,
3M)
FMG/
SPI,
TRP,
3M
Docket
#
OPPT­
2003­
0012­
0016;

AR226­
1306
31­
Mar­
03
Biodegradation
Research
(
8­
2
Telomer
B
Alcohol)
­
Scope
&
Rationale
(
LOI
Commitment
Item)
TRP
AR226­
1283
31­
Mar­
03
Product
&
Article
Analysis
­
Scope
&
Rationale
(
LOI
Commitment
Item
1)
TRP
Docket
#
OPPT­
2003­
0012­
0053
31­
Mar­
03
LC/
MS/
MS
Analysis
of
Articles
and
Products:
Samples
and
Suggested
Sampling
Procedures
(
LOI
1)
TRP
Docket
#
OPPT­
2003­
0012­
0054;

AR226­
1274
9­
May­
03
"
Aging"
&
"
In
Use"
Analysis
­
Draft
Study
Plan
&
Rationale
(
LOI
Commitment
Item
2)
TRP
Docket
#
OPPT­
2003­
0012­
0050
9­
May­
03
Biodegradation
Analysis
(
Polymeric
Products)
­
Study
Plan
&
Rationale
(
LOI
Commitment
Item
5)
TRP
Docket
#
OPPT­
2003­
0012­
0051
9­
May­
03
Study
Protocol:
Inherent
Biodegradation
Test
(
Polymeric
Products)
(
LOI
Commitment
Item
5)
TRP
Docket
#
OPPT­
2003­
0012­
0052
9­
May­
03
TRP's
Response
to
EPA's
Follow­
up
Questions
regarding
TRP
LOI
Commitments
TRP
Docket
#
OPPT­
2003­
0012­
0049
6­
June­
03
TRP
Opening
Statement
­­
June
6
Public
Meeting
TRP
Docket
#
OPPT­
2003­
0012­
0117
26­
June­
03
TRP
Presentation
to
ECA
Monitoring
Work
Group
(
23­
June­
03)
TRP
Docket
#
OPPT­
2003­
0012­
0126
26­
June­
03
TRP
Presentation
to
ECA
Telomers
Work
Group
(
24­
June­
03)
TRP
Docket
#
OPPT­
2003­
0012­
0128
March­
03
Company­
specific
information
on
LOI
test
products
(
LOI
Commitment
Item
1)
­­
CBI
Submissions;

includes
chemical
identity,
2002
use
and
volume
data,
market
coverage,
etc.
TRP
companies
(
Asahi,
Clariant,

Daikin,
DuPont)
numerous
listings
in
AR226
(
see
Index)

March­
03
Air
monitoring
data
for
PFOA
from
DuPont
operations
at
Chambers
Works
(
LOI
Appendix
1)
DuPont
AR­
226
(?)

March­
03
Employee
blood
monitoring
data
from
telomer
manufacturing
+
PFOA
recycle
operations
(
LOI
App.
1)
DuPont
AR­
226
(?)

May­
03
Company
information
on
all
fluorinated
products
(
LOI
Commitment
Item
1)
­­
CBI
Submissions;

includes
chemical
identity,
2002
use
and
volume
data,
market
coverage,
etc.
TRP
companies
(
Asahi,
Clariant,

Daikin,
DuPont)
numerous
listings
in
AR226
(
see
Index)

EPA
Docket:
www.
epa.
gov/
edocket
(
Docket
ID#
OPPT­
2003­
0012)

AR­
226:
request
copy
of
AR­
226
Index
from
<
oppt.
ncic@
epa.
gov>
(
Tel:
202­
566­
0280)

Information
provided
by
TRP
Member
Companies
directly
to
EPA
