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.