PFOA 2006
US EPA 2010/15 PFOA Stewardship Program.
January 25, 2006.

 
 

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http://www.epa.gov/opptintr/pfoa/pfoastewardship.htm#letter

-- Also see EPA Press Release

U.S. Environmental Protection Agency

2010/15 PFOA Stewardship Program

On January 25, 2006, EPA Administrator Stephen L. Johnson signed a letter to fluoropolymer and telomer manufacturers inviting them to participate in a global stewardship program on PFOA and related chemicals. The text of the letter appears below. Corporate commitments to the program and other related information will be posted to this website.

The companies receiving this invitation are:

3M/Dyneon
Arkema, Inc.
AGC Chemicals/Asahi Glass
Ciba Specialty Chemicals
Clariant Corporation
Daikin
E.I. duPont de Nemours and Company
Solvay Solexis

Text of letter
Enclosure about commitments
Glossary of Terms


Mr. Charles O. Holliday, Jr.
Chairman and Chief Executive Officer
DuPont
1007 Market Street
Wilmington, DE 19898

Dear Mr. Holliday:

As you are aware, DuPont and other proactive companies have been working collaboratively with the Environmental Protection Agency (EPA) to better understand the sources and pathways of exposure to perfluorooctanoic acid (PFOA) and related chemicals. Considerable progress has been made by putting in place a comprehensive testing and research program that will fill in many of the critical information gaps that exist around our understanding of potential exposures and risks. We all recognize that PFOA is persistent in the environment, that it has been detected in human blood, and that animal studies indicate effects of concern. The data from the research and testing programs will allow the Agency and others to make informed decisions about any potential risk management actions that are warranted.

In the meantime, absent the certainty that these data will provide, I am asking you to join with EPA and other stakeholders to commit to a global stewardship program whose goal is to work toward essentially eliminating emissions and product content levels of PFOA and related chemicals.

Participation in the stewardship program requires voluntary corporate commitment to two goals:

1) To commit to achieve, no later than 2010, a 95 % reduction, measured from a year 2000 baseline, in both: facility emissions to all media of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals, and product content levels of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals.

2) To commit to working toward the elimination of PFOA, PFOA precursors, and related higher homologue chemicals from emissions and products by five years thereafter, or no later than 2015.

While these program goals are ambitious, some participating companies may attain or even surpass some aspects of the goals before achieving others, some companies may have achieved portions of these goals already, and some may wish to commit to a more aggressive timeline. I encourage participating companies to identify specific individual commitments that go beyond the overall program goals, such as achieving the emissions and/or product content reductions before the 2010/15 goal years. The Agency also recognizes that technological and cost issues may preclude eliminating PFOA and related chemicals entirely from emissions and products by 2015. Annual reporting should help to identify and focus attention on these areas to encourage progress toward that ultimate goal.

Many activities are underway concerning PFOA and related chemicals, including additional research by companies, government agencies, and universities. Participation in the stewardship program will be in addition to a company's existing commitments to the Agency which may include research efforts, enforceable consent agreements, and memoranda of understanding. These ongoing efforts will combine with the 2010/15 PFOA Stewardship Program to further our understanding of this family of persistent, bioaccumulative, and toxic chemicals, and to achieve true long-term environmental and public health benefits. Although our risk assessment activities are not yet complete and new data may change the current picture, to date EPA is not aware of any studies specifically relating current levels of PFOA exposure to human health effects. This may offer us a window of opportunity now to ensure, through the 2010/15 PFOA Stewardship Program and other related efforts, that potential concern levels are never reached.

I hope that you will accept this invitation to step forward into environmental leadership. Please respond by letter with your commitment to the 2010/15 PFOA Stewardship Program by March 1, 2006. Additional information on the details of program commitments is enclosed with this letter. If you have questions concerning this program and your participation in it, please contact Mary Dominiak in the U.S. EPA Office of Pollution Prevention and Toxics, Chemical Control Division, by telephone at 202-564-8104, or by email at dominiak.mary@epa.gov.

I look forward to working with you and achieving these goals.

Sincerely,
Stephen L. Johnson
Administrator

Enclosure


2010/15 PFOA Stewardship Program

Commitments Corporate commitment letters should include commitments to both goals of the Stewardship Program:

1) To commit to achieve, no later than 2010, a 95% reduction, measured from a year 2000 baseline, in both: facility emissions to all media of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals, and product content levels of PFOA, precursor chemicals that can break down to PFOA, and related higher homologue chemicals.

2) To commit to working toward the elimination of PFOA, PFOA precursors, and related higher homologue chemicals from emissions and products by five years thereafter, or no later than 2015.

Companies participating in this 2010/15 PFOA Stewardship Program will be asked to submit their year 2000 baseline numbers for emissions and product content to EPA by October 31, 2006. To ensure transparency, companies will submit annual public reports on their progress toward the goals in October of each successive year, expressing their progress in terms of company-wide percentage achievements both for U.S. operations and for the company's global business. Companies will also provide to EPA detailed information on their progress in support of their public reports. By participating in the Program, companies grant permission to EPA to share information submitted under the Program with its contractors, including information contained within detailed progress reports that may be claimed as confidential.

These chemicals present considerable scientific challenges in ensuring accurate and reproducible results in chemical analyses. To ensure that the results reported under the 2010/15 PFOA Stewardship Program are both comparable and reliable, each participating company will also commit to work with EPA, other PFOA Stewardship Program participants, and others in order to establish scientifically credible analytical standards and laboratory methods for measuring the chemicals in the program by 2010, the first goal attainment year. Participants will also make a general commitment to continue research to better understand the sources, pathways of exposure, and potential risks of these chemicals.

Corporate commitment letters should be submitted by March 1, 2006, and should be addressed to:

Stephen L. Johnson, Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W. (1101A)
Washington, DC 20460

With a courtesy copy to:
Charles M. Auer, Director
U.S. EPA Office of Pollution Prevention and Toxics
1200 Pennsylvania Avenue, N.W. (7401M)
Washington, DC 20460

Glossary of Terms

Higher homologue chemicals: PFOA is an eight-carbon chain length chemical. Chemicals similar in structure to PFOA but with nine or more carbons in the chain would be higher homologues of PFOA.

Homologue: One of a series of compounds, each of which has a structure differing regularly by some increment (number of carbons, presence of a CH2 group) from adjacent members of the group.

Precursor: A chemical that can break down to form another chemical, in this case, PFOA. For example, some residual monomer chemicals from the telomer manufacturing process such as telomer alcohols and telomer iodides may remain in the final product and break down into PFOA.

Telomer biodegradation testing: Studies to determine whether fluorotelomers could break down in the environment to release PFOA from their polymer backbones, not just from contamination of the polymer with residual monomer chemicals from the manufacturing process ("PFOA precursors") that break down to release PFOA.

 
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