U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
PFOA
ECA
Telomer
Technical
Workgroup
Meeting
Summary,
7/
10/
03
64
participants;
Attendance
list,
agenda,
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0147.

The
meeting
included
three
sections:
I.
EPA
presentation
describing
Letter
of
Intent
(
LOI)
commitments
and
preliminary
EPA
data
needs
and
identifying
potential
topics
for
ECA
development,
and
Telomer
Research
Program
(
TRP)
presentation
clarifying
LOI
commitments
based
on
topics
raised
at
June
24,
2003
workgroup
meeting
II.
Discussion/
Questions
III.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
I.
EPA
and
TRP
Presentations
David
Lynch
of
EPA
presented
a
table
summarizing
EPA's
understanding
of
TRP's
LOI
commitments
and
EPA's
preliminary
data
needs.
TRP
presented
information
in
response
to
issues
raised
at
the
June
24,
2003
workgroup
meeting.
TRP's
presentation
included
putting
a
"
public
face"
on
products
and
articles;
a
product
and
article
decision
tree;
a
proposal
of
a
biodegradation
strawman
to
address
environmental
fate
issues;
obtaining
and
gathering
information
on
incineration;
and
seeking
interested
party
input
on
the
TRP
LOI
and
potential
scope
for
ECA
candidates.
Both
presentations
are
summarized
below
according
to
the
numbered
items
in
Table
1
of
the
EPA
ECA
Preliminary
Framework
document
to
which
they
referred.
The
Preliminary
Framework
document
is
in
the
docket
at
OPPT­
2003­
0012­
0056.

ECA
Framework
Item
#
1
EPA
summarized
ECA
framework
item
#
1
as
providing
comprehensive
telomer
market
information
including
CAS
number,
chemical
names,
synthetic
sequences,
production/
import
volumes,
and
uses/
applications
for
all
telomers
and
polymers
made
from
telomers.
EPA
indicated
that
the
TRP
member
companies
had
provided
these
data
as
confidential
business
information
(
CBI),
and
that
EPA
will
use
these
data
to
inform
the
selection
of
representative
test
chemicals.

TRP
provided
a
generic
overview
of
the
telomer
manufacturing
process
noting
that
PFOA
is
not
used
or
added
in
the
processes;
all
processes
are
closed;
and
PFOA
creation
and/
or
emissions
are
expected
to
be
at
very
low
levels.
TRP
noted
that
acrylate
monomers
are
the
most
common
raw
materials
used
to
create
finished
products.

ECA
Framework
Item
#
2
EPA
summarized
the
requirements
of
ECA
framework
item
#
2
as
providing
p­
chem
properties
to
inform
fate
testing
on
representative
test
substances
to
be
determined.
Test
substances
may
include
telomer
iodides,
telomer
alcohols,
telomer
esters
of
(
meth)
acrylates,
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
2
telomer
sulfonates,
and
telomer
phosphates.
TRP's
LOI
testing
commitments
include
water
solubility,
vapor
pressure,
UV/
visible
absorption,
hydrolysis
as
a
function
of
pH,
absorptiondesorption
(
soil,
sediment,
sludge
non­
labeled
and
14C),
and
specific
gravity.
EPA
indicated
that
data
may
be
needed
on
additional
chemicals
beyond
the
12
chemicals
included
with
the
TRP
LOI
commitments.
TRP
requested
that
EPA
report
on
its
selection
scheme
at
the
next
workgroup
meeting.

ECA
Framework
Item
#
3
EPA
summarized
ECA
framework
item
#
3
as
the
elucidation
of
degradation
pathways
and
identification
of
degradation
products
on
representative
test
substances,
and
indicated
that
TRP's
testing
commitments
include
closed
bottle
test
(
ready
biodegradability
non­
labeled
and
14C
[
OECD
301D]),
atmospheric
degradation,
long
range
transport
properties
(
air/
water),
and
inherent
biodegradability
Zahn­
Wellens/
EMPA
(
OECD
302B).
TRP
indicated
that
the
intent
of
the
testing
is
not
the
identification
of
PFOA
only,
but
the
determination
of
all
possible
degradants,
using
14C
labeling.

TRP
presented
their
expanded
LOI
degradation
study
plan
for
the
telomer
8­
2
alcohol
and
the
12
representative
products.
TRP
noted
that
it
did
not
commit
to
the
inherent
biodegradability
Zahn­
Wellens/
EMPA
(
OECD
302B)
test
for
the
telomer
8­
2
alcohol.
TRP
presented
a
multiple
tier
biodegradation
study
strawman
including
a
modified
aerobic
sewage
treatment
(
OECD
303A)
and
aerobic/
anaerobic
biodegradation
in
soil
(
OECD
307).
TRP
suggested
that
this
strawman
be
forwarded
to
a
subgroup
for
discussion
and
development
as
a
possible
ECA.

ECA
Framework
Item
#
4
EPA
summarized
ECA
framework
item
#
4
as
the
determination
of
p­
chem,
fate
and
transport
properties
of
degradation
products
with
the
test
substances
being
those
degradants
identified
in
item
#
3.
TRP
did
not
include
this
item
in
their
LOI
commitment.

ECA
Framework
Item
#
5
EPA
summarized
ECA
framework
item
#
5
as
the
determination
of
incineration
byproducts
of
telomers
and
telomer­
treated
products
including
paper,
textile,
and
carpet
products.
TRP
did
not
include
this
item
in
their
LOI
commitment.
EPA
provided
an
ECA
proposal
for
incineration
testing
to
address
EPA
data
needs.

TRP
proposed
to
approach
incineration
by
means
of
a
desk
study.
The
initial
step
would
determine
which
telomer­
related
products
would
be
disposed
of
through
incineration.
The
second
step
would
review
U.
S.
incinerator
conditions
to
understand
permitted
temperatures
and
compare
them
to
known
telomer
degradation
temperatures.
TRP
indicated
that
it
had
provided
incineration
information
sources
to
EPA,
and
requested
that
EPA
review
and
further
discuss
this
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
3
information.
TRP
suggested
that
this
topic
be
forwarded
to
a
subgroup
for
development
as
a
possible
ECA.

ECA
Framework
Item
#
6
EPA
summarized
ECA
framework
item
#
6
as
the
determination
of
p­
chem,
fate
and
transport
properties
of
representative
telomer
incineration
byproducts.
TRP
did
not
include
this
item
in
their
LOI
commitment.

ECA
Framework
Item
#
7
EPA
summarized
ECA
framework
item
#
7
as
the
determination
and
quantification
of
the
presence
of
PFOA,
telomer
alcohols,
or
other
PFOA
precursors
in
telomer
chemical
products
from
representative
telomers
provided
by
manufacturers
and
importers.
TRP's
LOI
commitments
include
testing
for
PFOA
and
the
8­
2
telomer
alcohol
in
12
polymers
representing
three
major
end­
use
categories
of
carpet,
textiles,
and
paper.
EPA
indicated
that
it
is
currently
reviewing
the
LOI
commitments
to
determine
whether
the
Agency's
data
needs
may
be
met
by
the
LOI
activity,
although
it
noted
that
additional
products
or
chemicals
might
need
to
be
added
to
the
12
substances
included
in
the
LOI.

ECA
Framework
Item
#
8
EPA
summarized
ECA
framework
item
#
8
as
the
determination
and
quantification
of
the
presence
of
PFOA,
telomer
alcohol
or
other
PFOA
precursors
in
telomer­
treated
or
telomercontaining
products
and
articles
including
paper,
textile,
carpet
products,
and
fire
fighting
foams
provided
by
manufacturers
and
importers.
TRP's
LOI
commitments
include
testing
carpet,
textiles,
and
paper
samples
to
which
the
12
telomer
polymers
from
item
#
7
have
been
applied.
EPA
noted
that
it
is
currently
reviewing
the
LOI
commitments
to
determine
whether
the
Agency's
data
needs
may
be
met
by
the
LOI
activity.

TRP
presented
a
product
and
article
work
flow
diagram
including
details
of
PFOA
and
telomer
8­
2
analysis
of
commercial
products
including
4
carpet
products,
6
textile
products
and
2
paper
products.
TRP
noted
that
method
development
is
currently
underway
at
contract
labs;
that
method
validation
will
follow;
and
that
actual
product
testing
will
follow
method
validation.
TRP
provided
a
"
public
face"
table
of
products
and
articles
selected
for
analysis.
TRP
indicated
that
companies
considered
market
end­
use,
chemistry
type/
class,
chemical
volume,
article
type,
and
potential
for
human
exposure
when
selecting
products
for
evaluation.
The
individual
TRP
companies
used
representative
products
from
their
product
lines
in
the
sectors
of
carpet,
textile
and
paper.
TRP
stated
that
telomer
products
are
sold
for
what
they
do,
not
what
they
are.
The
"
public
face"
table
(
available
in
OPPT­
2003­
0012­
0147)
is
a
general
description
of
products,
articles,
and
uses
and
applications.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
4
ECA
Framework
Item
#
9
EPA
summarized
ECA
framework
item
#
9
as
the
determination
and
quantification
of
the
presence
of
PFOA,
telomer
alcohol,
or
other
PFOA
precursors
emitted
from
telomer­
treated
products
and
articles
as
they
age
during
use.
TRP's
LOI
commitments
include
analysis
for
PFOA
and
telomer
8­
2
alcohol
on
12
temperature­
aged
telomer
products,
and
PFOA
analysis
before
and
after
temperature
and
photolytic
aging
of
treated
carpet;
abrasion
of
treated
carpet
and
textiles;
washing
and
dry
cleaning
of
treated
textiles;
and
hot
water
extraction
of
treated
carpet.
EPA
noted
that
it
is
currently
reviewing
the
LOI
commitments
to
determine
whether
the
Agency's
data
needs
may
be
met
by
the
LOI
activity.

TRP
presented
a
screening
study
decision
pathway
diagram
for
articles
treated
with
the
12
representative
commercial
telomer
polymer
products.
The
screening
study
includes
a
phase
1
analysis
of
newly
manufactured
products,
and
of
those
products
after
exposure
to
elevated
temperatures
and
to
photolysis
conditions;
and
a
phase
2
including
abrasion,
laundering,
dry
cleaning,
and
hot
water
extraction/
steam
cleaning.
TRP
stated
that
results
of
the
phase
1
testing
will
determine
the
need
for
additional
phase
2
testing.
A
level
of
quantification
(
LOQ)
will
be
established
for
PFOA
and
used
to
select
products
for
phase
2
testing.
TRP
stated
that
any
product
that
exceeds
the
LOQ
will
continue
to
phase
2
testing.
TRP
noted
that
method
development
is
currently
underway
at
contract
labs;
that
method
validation
will
follow;
and
that
actual
product
testing
will
follow
method
validation.

ECA
Framework
Item
#
12
EPA
summarized
ECA
framework
item
#
12
as
the
provision
of
product
stewardship
information
concerning
telomer
products
and
articles.
TRP
included
documenting
product
stewardship
programs
among
its
LOI
commitments.

II.
Discussion/
Questions
Parties
asked
how
EPA
would
define
representative
substances
and
whether
the
telomer
ethoxylates
or
known
degradation
products
are
being
considered
for
evaluation.
EPA
stated
that
it
searched
the
public
inventory
for
telomer
chemicals
and
grouped
them
into
21
categories
to
define
the
potential
universe
of
candidates
for
testing,
and
that
additional
chemicals
from
that
list,
beyond
the
12
products
covered
by
the
TRP
LOI,
could
be
subjects
for
inclusion
in
an
ECA
commitment.

In
response
to
a
question
regarding
where
the
reference
temperatures,
conditions,
etc.
could
be
found
for
the
proposed
incineration
ECA,
EPA
said
that
the
references
could
be
found
and
provided
for
interested
parties.

Parties
asked
about
using
indirect
food
product
testing
required
by
FDA
as
a
basis
for
understanding
the
leaching
of
polymers
from
food
contact
paper
products,
and
asked
whether
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
5
information
submitted
to
FDA
could
be
made
available
for
review.
EPA
responded
that
government
agencies
can
share
information,
but
would
need
to
determine
which
elements
could
be
made
public.
EPA
agreed
to
work
with
FDA
to
determine
what
data
are
available.

Some
parties
expressed
the
opinion
that
analyzing
existing
products
 
for
example,
treated
carpets
with
several
years
of
real
use
 
in
conjunction
with
newly
manufactured
products
would
establish
a
realistic
consumer
scenario
and
provide
a
comparison
between
results
obtained
from
actual
aging
and
accelerated
aging.
CPSC
noted
they
have
not
always
found
correlations
between
accelerated
versus
actual
aging
results.
TRP
stated
that
actual
product
testing
was
a
good
idea;
however,
there
would
be
no
control
for
the
experiments
and
the
purpose
of
the
study
envisioned
by
TRP
is
the
determination
of
a
baseline
and
a
delta.
TRP
stated
that
another
problem
with
existing
products
could
be
contact
with
acidic
solutions
(
i.
e.,
soda),
carpet
cleaners
containing
PFOA,
etc.,
which
could
give
questionable
results.

Several
questions
were
asked
regarding
the
selection
of
test
methods,
including
why
abrasion
tests
were
proposed
only
for
carpeting
and
not
paper
products;
why
humidity
testing
was
not
proposed;
whether
there
were
standard
tests
for
products
to
be
conducted
under
photolysis
and
elevated
temperatures
and
whether
these
tests
might
be
appropriate;
and
whether
there
were
different
extraction
methods
for
PFOA
and
telomers.
TRP
responded
that
because
paper
products
were
a
one
time
use,
abrasion
was
not
an
appropriate
test.
TRP
was
not
sure
whether
different
extraction
methods
would
be
required.

Parties
asked
questions
regarding
the
decision
making
criteria
for
continued
testing
including
the
LOQ
level
and
"
x"
times
increase
in
PFOA
level;
and
whether
there
are
significant
environmental
and
release
concerns
for
PFOA
loss
below
the
LOQ.
TRP
responded
that
the
products
have
previously
been
tested
for
performance
in
laundry,
dry
cleaning,
etc.,
and
said
that
some
of
these
data
might
be
available
through
the
Carpet
and
Rug
Institute.
TRP
could
not
answer
the
question
about
significance
of
releases
below
the
LOQ,
and
observed
that
TRP
is
currently
working
on
method
development
and
will
follow
with
method
validation.

Numerous
questions
were
asked
regarding
the
samples
to
be
tested
and
the
pathways
of
testing,
for
example:
whether
all
tests
would
be
performed
on
the
same
sample
in
a
cumulative
fashion
or
whether
separate
samples
would
be
evaluated;
and
whether
tests
would
be
conducted
in
a
certain
sequence.
TRP
stated
that
the
same
sample
would
be
used
to
conduct
all
tests,
but
that
a
new
piece
from
the
sample
would
be
used
to
conduct
each
test.
TRP
stated
that
no
cumulative
testing
is
proposed
at
this
time.
All
phase
1
tests
("
as
made"
[
i.
e.,
newly
manufactured],
after
exposure
to
photolysis,
and
after
exposure
to
elevated
temperature)
are
conducted
in
parallel.
Phase
2
tests
take
place
for
only
those
tests
and
only
those
samples
where
the
LOQ
or
the
magnitude
of
PFOA
generation
"
x"
values
warrant
further
testing.

Several
questions
were
raised
regarding
the
"
public
face"
placed
on
the
12
products
and
articles
presented
by
TRP.
Parties
expressed
concern
about
a
lack
of
sufficient
detail
in
the
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
6
"
public
face"
to
alert
consumers
to
which
products
might
contain
these
chemicals,
in
case
individuals
wanted
to
reduce
their
potential
exposures.

III.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
The
workgroup
elected
David
Lynch
of
EPA
to
present
a
summary
of
workgroup
activities
to
the
Plenary
session.

°
EPA
will
look
at
the
12
representative
LOI
chemicals
and
determine
whether
additional
chemical
coverage
is
necessary.
The
selection
criteria
used
will
be
made
available
to
interested
parties,
although
the
chemicals
themselves
will
be
CBI.
°
EPA
will
provide
reference
information
used
for
incineration
ECA
development.
°
Recommendation
for
formation
of
expert
technical
subgroups
in
the
areas
of
degradation
and
incineration
for
ECA
development
to
meet
1
or
2
times
by
mid­
September.
The
meetings
may
occur
by
conference
call.
EPA
will
provide
a
time­
line
within
two
weeks.
Groups
wishing
to
participate
will
notify
EPA.
°
Other
items
identified
for
more
discussion
in
the
full
workgroup
are
forthcoming
p­
chem
property
data,
the
presence
in
products
and
articles,
aged
studies
and
product
stewardship.
°
The
entire
Telomer
Workgroup
will
convene
during
the
week
of
Sept
15,
2003.
