U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
PFOA
ECA
Fluoropolymer
Technical
Workgroup
Meeting
Summary,
7/
9/
03
55
participants;
Attendance
list,
presentation
materials,
and
EPA
ECA
incineration
proposal
in
docket
at
OPPT­
2003­
0012­
0145.

The
meeting
included
four
sections:
I.
EPA
presentation
summarizing
Letter
of
Intent
(
LOI)
commitments
with
preliminary
EPA
data
needs
and
identifying
potential
topics
for
ECA
development
II.
Fluoropolymer
Manufacturing
Group
(
FMG)
presentation
clarifying
LOI
commitments
based
on
topics
raised
at
the
June
23,
2003
workgroup
meeting
III.
Discussion/
Questions
IV.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
I.
EPA
presentation
Greg
Fritz
of
EPA
presented
a
summary
of
EPA's
understanding
of
FMG
commitments
under
the
LOI
and
asked
for
clarification
on
any
misunderstood
items.
With
respect
to
physicalchemical
(
p­
chem)
properties,
EPA
indicated
that
the
data
provided
in
a
handout
at
the
June
23,
2003
workgroup
meeting
were
beneficial,
and
concurred
with
FMG's
statement
that,
due
to
the
low
vapor
pressure
and
water
solubility,
those
data
would
not
be
necessary
on
individual
products.
FMG
was
encouraged
to
clarify
the
distribution
of
molecular
weights
below
1,000
and
to
confirm
the
absence
of
oligomeric
contamination.
EPA
noted
that
the
long­
term
stability
of
the
polymers
was
established
through
submitted
weathering
and
exposure
studies,
and
that
hydrolysis
testing
would
not
be
warranted
by
expectations.
EPA
expressed
a
need
for
long
term
photolysis
studies;
long
term
soil
sorption
and
biodegradation
without
usual
p­
chem
information;
and
identification
of
degradants.

EPA
summarized
the
FMG
product
and
article
selection
criteria
as
including
(
1)
low
and
high
heat
processing;
(
2)
dry
resins
and
dispersions;
(
3)
consumer
and
industrial
applications
covering
12
different
use
applications;
(
4)
PTFE,
fluoroelastomers
and
fluoroplastics;
and
(
5)
production
volume
and
exposure
potentials.
EPA
stated
that
the
limitation
with
the
selection
criteria
was
that
there
was
no
indication
of
ranking
or
prioritization
of
criteria
in
the
determination
of
articles
to
be
tested.
EPA
indicated
that
additional
information
would
be
helpful
in
the
areas
of
the
sampling
schemes
for
product
coverage;
understanding
the
tiered
approach
to
aged
products
currently
in
use;
and
test
method
validation.
EPA
stated
that
they
were
aware
of
at
least
4
chemicals
being
tested
in
the
proposed
products,
but
that
additional
products
and
chemicals
may
also
be
relevant.
The
tiered
approach
to
aged
products
was
unclear
regarding
the
identities
of
the
specific
products
to
be
tested.
EPA
questioned
the
applicability
of
the
proposed
FDA
testing
procedure.

EPA
also
provided
the
workgroup
with
an
ECA
proposal
for
incineration.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
2
II.
FMG
presentation
FMG
presented
a
sample
survey
form
that
would
be
completed
by
each
FMG
company
detailing
the
percent
of
estimated
market
share
volume
of
each
application
listed
using
FY
2002
production
and
import
data
for
each
CAS
number,
and
submitted
to
EPA
by
August
15,
2003.
The
data
submitted
will
be
considered
CBI
and
it
will
be
the
responsibility
of
the
EPA
to
aggregate
and
disseminate
the
information
to
the
workgroup
following
CBI
guidelines.
FMG
proposed
that
ECA
preliminary
framework
item
#
1
would
be
considered
complete
after
submission
and
review
of
this
information.

FMG
restated
the
objective
of
ECA
framework
item
#
6
as
the
detection
of
the
presence
of
PFOA
in
fluoropolymer
articles.
FMG
stated
that
they
have
committed
on
a
company
by
company
basis
to
reduce
APFO
emissions
by
50%
by
2006
and
are
currently
ahead
of
schedule.
FMG
provided
an
overview
of
the
fluoropolymer
industry
broken
down
into
the
manufacture
of
dry
melt
resins,
dry­
non
melt
resins/
gums
and
aqueous
dispersions
and
the
subsequent
processing
and
conversion
to
final
articles.
FMG
noted
that
the
majority
of
the
products
are
made
using
dry
melt
resins
and
dry
non­
melt
resins/
gums
rather
than
aqueous
dispersions.
The
overview
included
the
possible
pathways
from
manufacture
to
processing
to
conversion
to
final
products
including
manufacturing
conditions;
processing
conditions;
and
examples
of
the
final
articles
produced.
A
comprehensive
list
of
these
articles
was
provided
to
the
workgroup
for
review
(
OPPT­
2003­
0012­
0145).

FMG
presented
their
selection
criteria
for
the
12
articles
of
commerce
including
considerations
of
the
type
of
manufacture;
consumer
and
industrial
application
potential;
high
and
low
heat
processing;
production
volume;
and
exposure
potential.
FMG
demonstrated
example
decision
pathways
for
dry
melt
resins,
dry
non
melt
resins/
gums
and
aqueous
dispersion
showing
how
the
test
articles
were
selected.
The
decision
"
trees"
included
consideration
of
high
or
low
processing
temperature;
consumer
or
industrial
application;
and
production
volume
or
exposure
potential
used
to
determine
the
representative
products.
FMG
provided
an
article
of
testing
matrix
which
categorized
the
articles
by
consideration
of
low
heat
consumer,
low
heat
industrial,
high
heat
consumer,
and
high
heat
industrial.

FMG
discussed
the
methodologies
proposed
for
articles
of
commerce
testing.
The
proposed
testing
would
be
in
accordance
with
FDA
Guidance
for
Industry
 
Chemicals,
April
2002.
The
extraction
conditions
would
include
water
for
all
articles
and
other
appropriate
solvents
based
on
the
particular
article
(
i.
e.
corn
oil,
alcohol,
etc).
The
analytical
methods
would
be
LC/
MS/
MS
and
Exygen
Research
Analytical
Laboratory
Method
(
01M­
008­
046
revision
1).

FMG
defined
the
objective
of
ECA
framework
item
#
7
as
the
determination
whether
PFOA
is
emitted
from
fluoropolymer­
containing
articles
as
they
age
during
use.
FMG
stated
that
they
believe
that
aged
testing
is
an
appropriate
candidate
for
ECA
negotiations
and
suggested
necessary
steps
including
proposed
test
protocol
FDA
Guidance
for
Industry
 
Chemicals,
April
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
3
2002;
review
of
articles
of
commerce
testing
results;
proposed
selection
criteria
for
articles
of
commerce
aged
articles;
review
with
interested
parties;
and
review
overall
program
and
articles.

FMG
stated
the
objective
of
ECA
framework
item
#
8
as
the
determination
of
incineration
byproducts
of
fluoropolymer
containing
articles.
FMG
previously
provided
incinerator
information
showing
2
chambers
to
the
agency
for
review.
FMG
stated
that
they
believe
that
incineration
is
an
appropriate
candidate
for
ECA
negotiations
and
suggested
necessary
steps
including
use
of
the
3M
incineration
protocol
and
model
from
which
the
industry
group
will
develop
a
protocol,
review
the
protocol
with
interested
parties,
and
finalize
the
protocol
in
a
technical
meeting
to
be
scheduled.
FMG
restated
the
objective
of
ECA
framework
item
#
9
as
the
determination
of
physical
chemical
fate
and
transport
properties
of
incineration
products.
FMG
suggested
that
this
cannot
be
discussed
further
until
completion
of
incineration
testing.

FMG
stated
the
objective
of
ECA
framework
item
#
2
as
submission
of
the
p­
chem
properties
to
inform
fluoropolymer
fate
testing.
FMG
submitted
documents
for
PTFE,
FEP
and
PFA
polymer
p­
chem
properties
on
June
20,
2003
and
proposed
that
similar
p­
chem
property
documents
will
be
prepared
for
the
remaining
fluoropolymers
and
fluoroelastomers.
These
data,
along
with
3M
documents
on
APFO,
will
be
submitted
by
August
1,
2003.
FMG
believes
that,
based
on
submission
of
the
data
for
PTFE,
FEP
and
PFA,
ECA
framework
item
#
2
is
complete
for
those
materials
and
with
the
submittal
of
the
data
for
APFO
and
the
other
polymers,
item
#
2
will
be
evaluated
for
completion.

FMG
reviewed
the
objective
of
ECA
framework
item
#
3
as
the
elucidation
of
degradation
pathways
and
identification
of
degradation
products.
FMG
proposed
that
the
data
submitted
to
date
indicate
that
fluoropolymers
are
unlikely
to
degrade,
and
that
elucidating
pathways
and
identifying
degradants
would
not
be
necessary.
FMG
proposed
that
interested
parties
review
all
the
data
that
have
been
submitted
concerning
p­
chem
and
fate,
and
that
an
ECA
could
be
considered
if
technical
questions
could
not
be
adequately
answered
on
the
basis
of
those
data.
FMG
concluded
that,
if
its
suggestions
are
valid,
item
#
2
would
be
considered
complete
for
PTFE,
FEP
and
PFA,
and
the
same
review
process
would
follow
for
the
remaining
fluoropolymers
and
fluoroelastomers
when
those
data
are
submitted.
Similarly,
FMG
restated
the
objective
of
ECA
framework
item
#
4
as
the
determination
of
p­
chem
fate
and
transport
properties
of
major
degradation
products,
and
indicated
that
item
#
4
would
not
be
relevant,
based
on
the
data
already
submitted,
because
the
polymers
are
stable
and
do
not
degrade
via
normal
degradation
pathways.

III.
Discussion/
Questions
Interested
parties
raised
questions
regarding
the
issue
of
no
oligomer
contamination
of
products.
EPA
asked
that
FMG
provide
the
percent
molecular
weight
below
1000
and
the
level
of
oligomer
contamination.
FMG
committed
to
providing
molecular
weight
distribution
data.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
4
Concerning
EPA's
definition
of
a
high
chain
length
in
the
incineration
proposal,
parties
asked
if
a
minimum
C8
chain
length
could
be
assumed.
EPA
stated
that
the
focus
was
not
solely
on
C8,
but
at
looking
at
the
long
C
chain
carboxylic
acid
formation
as
an
indicator
for
investigation.
It
was
suggested
that
this
topic
be
further
discussed
at
the
incineration
technical
subgroup
meeting.

Interested
parties
raised
questions
regarding
the
possible
uses
of
PTFE
in
items
such
as
light
bulbs
and
barrier
creams.
FMG
responded
that
PTFE
could
be
used
as
a
coating
for
light
bulbs
in
some
applications
and
in
barrier
creams
for
military
and
commercial
application.
CPSC
requested
to
know
what
type
of
products
contain
PFOA
to
estimate
exposures
from
these
products.
FMG
stated
that
the
articles
testing
would
clarify
the
products
issue
(
although
no
barrier
creams
were
proposed
as
applications
for
testing
under
the
LOI).

Interested
parties
questioned
where
in
the
fluoropolymer
manufacture
process
APFO
is
lost;
where
oligomers
are
lost;
and
where
and
how
air
emissions
are
accounted
for.
FMG
stated
that
loss
could
occur
at
isolation
and
drying
and
at
extrusion
and
mold
processing,
but
that
most
APFO
is
destroyed
during
isolation
and
drying.
FMG
further
stated
that
oligomers
are
removed
during
isolation
and
drying
for
long
molecular
weight
chains.
FMG
addressed
air
releases
by
explaining
that
industry
has
worked
for
20
years
to
develop
and
share
emissions
reduction
technology.
The
industry
commitment
is
a
50%
reduction
in
emissions
by
2006.
Measurement
of
air
emissions
for
2002
as
submitted
to
EPA
were
arrived
at
by
using
material
balances
aided
by
sampling.

The
question
was
asked
regarding
the
choice
of
solvent
proposed
for
testing.
One
suggestion
was
to
use
methanol
since
it
seemed
to
be
the
solvent
most
likely
to
maximize
recovery.
FMG
stated
that
they
will
look
at
different
solvents
including
corn
oil,
water,
and
alcohol
for
individual
articles.

There
were
numerous
questions
regarding
the
selection
criteria
proposed
by
FMG
for
analysis
of
PFOA
and
PFOA­
containing
articles.
EPA
stated
that
if
additional
products
would
need
to
be
added
to
the
testing
protocol,
the
individual
companies
would
be
contacted
for
discussion.
FMG
requested
that
the
addition
of
articles
of
commerce
be
allowed
by
modification
of
the
existing
LOI
rather
than
formation
of
an
ECA
so
as
to
not
slow
down
progress.
FMG
stated
that
products
will
come
from
2
or
more
manufacturing
facilities
among
FMG
and
sent
to
the
Society
of
the
Plastics
Industry
(
SPI)
where
they
will
then
be
sent
to
the
contract
laboratory
for
analysis.
This
process
was
adopted
to
ensure
the
products
come
from
FMG
member
companies
and
to
maintain
the
chain
of
custody.

Interested
parties
expressed
questions
regarding
the
processing
conditions
for
articles;
whether
samples
could
be
tested
from
both
the
high
and
low
end
temperature
ranges;
and
whether
the
low
temperature
articles
would
behave
differently
than
the
high
temperature
ones.
FMG
stated
that
the
processing
ranges
encompass
all
fluoropolymer
families
and
are
processed
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
5
at
different
temperatures.
The
specific
processing
temperatures
for
a
particular
article
could
be
considered
CBI
by
the
individual
companies.

Several
questions
were
raised
with
regard
to
the
testing
methods
to
be
conducted
for
the
articles
of
commerce.
Interested
parties
questioned
whether
the
approach
provided
by
FMG
would
accurately
depict
all
of
the
possible
conditions
where
PFOA
could
be
generated
or
released
from
the
products.
CPSC
asked
about
analysis
of
products
such
as
cookware
under
normal
"
misuse"
conditions.
FMG
stated
that
consumer
education
information
is
provided
with
their
products
and
that
testing
data
are
available
for
routine
use
conditions
as
well
as
at
elevated
temperatures.
The
suggestion
was
made
for
FMG
to
report
back
to
the
workgroup
on
their
current
consumer
education
information.

Parties
noted
that
4
companies
are
participating
in
the
FMG,
while
2
other
companies
have
been
identified
as
possible
importers
into
the
US.
FMG
stated
that
they
conducted
a
worldwide
material
balance
of
the
manufacture
of
APFO
and
do
not
know
whether
anyone
other
than
the
companies
surveyed
who
make
products
with
APFO.

V.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
The
workgroup
elected
Greg
Fritz
of
EPA
to
present
the
workgroup
summary
to
the
Plenary
session.

°
Recommendation
for
formation
of
expert
technical
subgroups
in
the
areas
of
aged
articles
and
incineration
for
ECA
development
to
meet
1
or
2
times
by
mid
September.
The
meetings
were
proposed
to
be
by
conference
call.
FMG
will
provide
a
time­
line
within
two
weeks
and
a
listing
of
who
will
participate
from
industry.
°
Additional
p­
chem
information
on
fluoropolymers
and
fluoroelastomers
to
be
submitted
August
1,
2003.
°
FMG
committed
to
providing
molecular
weight
specification
data
for
review
°
FMG
committed
to
providing
information
on
specific
chemical
use
and
production
volume
information
by
August
15,
2003.
°
Additional
degradation
pathway
questions
are
to
be
addressed
by
industry.
If
the
testing
information
sufficiently
answers
the
questions,
then
no
further
action
is
needed;
however,
if
the
information
is
not
sufficient,
then
the
topic
will
be
forwarded
to
a
technical
subgroup
for
possible
ECA
development.
°
All
submitted
information
is
to
be
reviewed
and
any
questions
addressed.
°
FMG
will
submit
additional
material
balance
information.
°
FMG
to
evaluate
the
current
Consumer
Education
information
for
their
products
and
report
to
the
group
next
time.
°
The
entire
fluoropolymers
workgroup
will
convene
during
the
week
of
Sept
15,
2003.
