# Long **- Chain**  **Perfluorinated Chemicals**  **( LC**  **PFCs) Used**  **in**

**Carpets**

**Contract # EP**  **- W**  **- 08**  **- 010** 

July 2 7 , 2012

-- Does not contain TSCA CBI --

Prepared for: **Economic and Policy Analysis Branch**  Economics, Exposure and Technology Division Office of Pollution, Prevention, and Toxics U.S. Environmental Protection Agency

1200 Pennsylvania Avenue Wa shington, DC 20460This P age I ntentionally Left Blank**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Front Matter ▌**  **pg. iii**  

### Long **- Chain**  **Perfluorinated Chemicals Used in Carpets**  **Table of Contents List of Exhibits**  **................................ ................................**  **................................ ................................**  **...... v**  **Contributors ................................**  **................................ ................................**  **................................ .........**  **vi Executive Summary**  **................................ ................................**  **................................ ...........................**  **vii 1.**  **Introduction ................................**  **................................ ................................**  **............................. 1**  **- 1**  **2. Carpet Manufacturing**  **................................ ................................**  **................................ ............**  **2 -**  **1** 2.1 Introduction ................................ ................................ ................................ .................... 2 - 1 2.2 Manufacturers Using PFCs in Carpet Products ................................ .............................. 2 - 1 2.3 Manufacturers of Remaining Carpet Products with Long - Chain PFCs ......................... 2 - 1 2.3.1 Advanced Polymer, Inc., Carlstadt, NJ ................................ ............................. 2 - 1 2.4 Carpet Manufacturing Process ................................ ................................ ........................ 2 - 2 2.5 Carpet Treatment ................................ ................................ ................................ ............ 2 - 2 **3. Industr** **y Overview ................................**  **................................ ................................**  **.................. 3**  **- 4**  3.1 Sector Definition ................................ ................................ ................................ ............ 3 - 4 3.1.1 Primary Manufacturing: Chemical Manufacturing ................................ ........... 3 - 4 3.1.2 Secondary Manufacturing: Carpet Manufacturing and Treatment ................... 3 - 4 3.2 Economic Activity ................................ ................................ ................................ .......... 3 - 5 3.3 NAICS Sectors Potentially Using PFCs in Carpets ................................ ........................ 3 - 6 3.4 Exports, Imports, and Domestic Consumption ................................ ............................... 3 - 7 3.4.1 U.S. International Trade Commission Data on Imports, 2000

– 2010 ............. 3 - 9 **4. Role of PFCs in Carpet Manufacturing**  **................................ ................................**  **................ 4**  **- 1**  4.1 Fluorotelomers in Carpets ................................ ................................ .............................. 4 - 2 4.2 PFAS in Carpets ................................ ................................ ................................ ............. 4 - 5 **5. Availability of Alternatives**  **................................ ................................**  **................................ ....**  **5 -**  **1** 5.1 Clariant ................................ ................................ ................................ ........................... 5 - 1 5.2 DuPont ................................ ................................ ................................ ............................ 5 - 1**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Front Matter ▌**  **pg. iv**  

### 5.3 AGC Chemicals Americas (Asahi) ................................ ................................ ................. 5 - 3 5.4 Daikin Industries ................................ ................................ ................................ ............ 5 - 3 5.5 Solvay Solexis ................................ ................................ ................................ ................ 5 - 4 5.6 BASF ................................ ................................ ................................ .............................. 5 - 4 5.7 Advanced Polymer Inc. ................................ ................................ ................................ .. 5 - 5 5.8 3M ................................ ................................ ................................ ................................ ... 5 - 5 5.9 Other Alternatives ................................ ................................ ................................ .......... 5 - 5 5.10 Conclusions ................................ ................................ ................................ .................... 5 - 7 **6. References**  **................................ ................................**  **................................ ................................**  **6 -**  **1 Long**  **- Chain**  **Perfluorinated Chemicals ( LC**  **PFCs) in**  **Carpets Contract #**  **EP -** **W -** **08 -**  **010**

**Front Matter ▌**  **pg. v**  

### List of Exhibits Exhibit 1 - 1: Normalized Distribution of Fluorotelomers in Use Sectors Based on Total Reported

Production Volume ................................ ..................... **Error! Bookmark not defined.** 1 - 2 Exhibit 3 - 1: Textile Product Mill Sectors: Economic Activity, 2007 ................................ ................ 3 - 5 Exhibit 3 - 2: Carpet and Rug Mills: Economic Activity, Historical Data ................................ ........... 3 - 5 Exhibit 3 - 3: Carpet and Rug Mill Product Lines: Economic Activity, 2007 ................................ ...... 3 - 6 Exhibit 3 - 4: Carpet and Rug Mills: Imports, Exports, and Implied Domestic Consumption, 2007 ... 3 - 8 Exhibit 3 - 5: Carpet and Rug Mills: Imports, Exports, Value of Shipments ($1,0 00), 2007 .............. 3 - 9 Exhibit 3 - 6: Carpet and Impregnated Fabrics: U.S. Imports, ($1,000,000) ................................ ...... 3 - 11 Exhibit 3 - 7: Carpet Imports, ($1,000,000) ................................ ................................ ....................... 3 - 12 Exhibit 3 - 8: Impregnated Fabrics Imports, ($1,000,000) ................................ ................................ . 3 - 12 Exhibit 4 - 1: PFCs in Carpet ................................ ................................ ................................ ................ 4 - 2 Exhibit 4 - 2: Fluorotelomers and Chemicals Containing Fluorotelomers Used in Polyurethane Resin4 - 3 Exhibit 4 - 3: Fluorotelomers Used in Polyurethane Resin with 2006 IUR Production Data .............. 4 - 4 Exhibit 4 - 4: PFAS Compounds with 2002, or 2006 IUR Production Volume ................................ ... 4 - 5 Exhibit 5 - 1: UNIDYNE Multi - Series TM 

### Water and Oil Repellent Products ................................ ....... 5 - 4**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Front Matter ▌**  **pg. vi**  

### Contributors The EPA analyst responsible for this report is Timothy Lehman of the Economic and Policy Analysis Branch; Economics, Exposure and Technology Division; Office of Pollution Prevention and Toxics. Analytical and draft preparation support was provided by Abt Associates, Inc. under EPA Contract No. EP -W - 08 - 010 .**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Front Matter ▌**  **pg. vii**  

### Executi **ve Summary** Perfluorinated chemicals (PFCs) are substances with special properties that have a variety of industrial applications. PFCs are used in carpets to impart stain, soil, and grease repellant properties (U.S. EPA 2009c ; KEMI 2006 ). During the manufacturing process, PFCs are utilized in the impregnation of carpets or as a chemical finish which endows fabrics with those characteristics. Long - chain perfluorinated chemicals ( LC PFCs) are found world -wide in the environment, wildlife, and humans. They are bioaccumulative in wildlife and humans, and are persistent in the environment ( Danish Ministry of the Environment 2008 ) . There are four typical scenarios for chemical application that could lead to the presence of LCPFCs in carpet products. First, LCPFCs could be applied to carpet at a carpet and rug mill during the manufacturing process. Secondly, LCPFCs could be applied to carpet after the manufacturing process at a separate finishing facility . Thirdly, treatment products containing LCPFCs could be applied to carpets by final consumers in the post manufacturing stage . In the described scenarios, LCPFCs could be domestically produced or imported. In addition, domestically produced carpets could be made using imported fabrics that had been treated with LCPFCs. Finally, carpet containing L CPFCs could be imported into the United States as a final product. The Agency believes that the LCPFC chemical substances included in the proposed rule are no longer being manufactured, processed, or imported for use as part of carpet or for treating car pet (e.g., for use in the carpet aftercare market) in the United States. Partly as a result of the 2010/15 PFOA Stewardship Program , U.S. manufacturers have stopped producing LCPFC -based products used for carpet treatment. Major manufacturers have develope d alternative products that are based on short - chain PFCs. However, a few companies continue to sell previously manufactured products that use LCPFCs. It is expected that no LCPFC -based products will be available for sale in the U.S. once the existing inventory is sold out. In addition to the phase - out of long - chain PFCs in carpet products by domestic manufacturers , EPA believes that imported carpet products do not contain LCPFCs. O nly 16 percent of domestically consumed carpets and rugs are imported , whil e 84 percent of the product is manufactured in the U.S. L ong - chain PFCs may also be imported into the U.S. from countries like China and applied to carpets domestically. T he imports data obtained from ITC suggest that no long - chain PFCs for use in carpet treatment are currently imported into the U.S. Because chemical treatments for carpets are not only applied du ring the manufacturing process but can also be applied to carpets by the consumers in the post manufacturing stage , exposure to carpet treatment chemicals may occur both during and after the manufacturing process . This market profile is developed to support the Significant New Use Rule (SNUR) being proposed by EPA for long - chain PFCs used in carpet s.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Introduction ▌**  **pg. 1**  **- 1**  

## 1. **Introduction** Perfluorinated chemicals (PFCs) are substances with special properties that have a variety of industrial applications. PFCs are used widely in the textile industry because of their thermo - stability, ability to adapt to a variety of surface characteristics, high chemical stability , and other characteristics (Armeduri and Bouterin 2004 ) . PFCs are used in carpets to impart stain, soil, and grease repellant properties (U.S. EPA 2009c ; KEMI 2006 ) . During the manufacturing process, PFCs are utilized in the impregnation of carpets or as a chemical finish which endows fabrics with those characteristics. Long - chain perfluorinated chemicals ( LC PFCs) are found world -wide in the environment, wildlife, and humans. They are bioaccumulative in wildlife and humans, and are persistent in the environment ( Danish Ministry of the Environment 2008 ) . To date, significant adverse effects have not been found in the general human population 1 

### ; however, LCPFCs have been linked to a number of health effects, including thyroid disease and reproductive function (Knox, et al., 2011; Melzer, et al., 2010) . Although three broad types of PFCs are used in textiles : fluorotelomers, fluoropolymers, and perfluoroalkyl sulfate (PFAS) , we found no evidence of fluoropolymers used in carpet treatment products. This market profile is developed to support regulatory activities that would limit or eliminate the use of long - chain PFCs (LCPFCs) in carpets. This market profile in support for the Significant New Use Rule (SNUR) being proposed by EPA for LCPFCs used in carpet s is structured in the following way:
 Section 2 identifies individual manufacturers of PFCs and provides a description of the carpet manufacturing process.  Section 3 provides an o verview of the carpet manufacturing sector and its economic activity.  Section 4 defines the role of PFCs in the carpet industry.  Section 5 lists available alternatives to LCPFC -b ased carpet treatment products.

1 Based on review

of a number of studies examining health effects of LCPFCs.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **2 -**  **1** 

## 2. **Carpet Manufacturing 2.1**  **Introduction** U.S. manufacturers have stopped producing LCPFC -based products used for carpet treatment . The manu facturers have developed alternative products that are based on short- chain PFCs. Specific technologies and products for each of these companies are described in Section 5 . However, a few companies continue to sell previously manufactured products that use LCPFCs. It is expected that no LCPFC -based products will be available for sale in the U.S. once the existing inventory is sold out. This section presents a list of companies that manufacture PFC -based products for use in carpets. During the manufacture of carpets, PFCs may be applied to carpets for oil, stain, grease repellency (U.S. EPA 2009b ). It is important to note that chemical treatments for carpets are not only applied during the manufacturing process but can also be applied to carpets by the consumers in the post manufacturing stage ( 3M Company 1999 ) . Therefore, exposure to carpet treatment chemicals may occur both during and after the manufacturing process. EPA’s ORD reviewed literature and found that there were high levels of PFAC in carpet and carpet treatment products (levels were from 0.04 - 14,100 ng/g) 2 

### (U.S. EPA 2009b ). This is of particular concern for children since they engage in a variety of activities on carpets for longer periods of time in their earliest years and can be exposed to chemicals in carpets via inhalation. (U.S. EPA 2009b ). 

### 2.2 **Manufacturers Using**  **PFCs in Carpet**  **Products** EPA is not presenting a list of manufacturers of PFCs used in carpets due to the proprietary nature of the se data . 

### 2.3 **Manufacturers of**  **Remaining Carpet**  **Products with**  **Long -**  **Chain PFCs** The U .S. manufacturers listed above have stopped producing LCPFC -based products used in carpets. However, a few companies continue to sell previously manufactured products that use LCPFCs. It is expected that no LCPFC -based products will be available for sale in the U.S. once the existing inventory is sold out. Additional details on those companies that are found to continue to offer LCPFC -based products are provided in this section. **2.3.1 Ad**  **vanced Polymer, Inc., Carlstadt, NJ** 

### Advanced Polymer, Inc. lists a product, APG - 5295, in its catalog, which is described as a “Perfluoroalkylacrylate emulsion” by the manufacturer and can be used to carpet protection3 

### (product description is dated April 6th 2011). APG - 5295 is also described in a product catalog as a “C8 -based fluorochemical system.” 4 

### This product in no longer manufactured, although limited stock is still

2 EPA referenced the research by ORD in their 2009 Long - Chain Perfluorinated Chemicals (PFCs) Action Plan. Therefore, the research and review of the research was completed prior to 2009 (U. S. EPA 2009b ). 3 http://www.advpolymer.com/do cs/APG - 5295.pdf (Accessed 11/30/2011) 4 Advanced Polymer, Inc. 2011. Product Catalog. Revised June 23, 2011.Available at: http://www.advpolymer.com/docs/PRODUCT_CATALOG.pdf (Accessed 11/30/2011).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **2 -** **2** 

### available for purchase on a first come first served basis. 5 

### A company representative indicated that currently C8 -based c arpet protection products are being replaced with C - 6 alternatives. 6 

### 2.4 **Carpet Manufacturing Process** There are two different processes of carpet manufacturing: 1) tufting and 2) weaving. Tufting is a process that uses machines and synthetic materials to manufacture a carpet (WFCA 2011b ). The tufting process involve s the following steps: (1) Weaving fibers into a backing material, (2) Dyeing the carpet7 

### , (3) Applying a coating of latex to the primary back and a secondary backing and sending the carpet though a h eat press to be squeezed together8 

### , and (4) S hearing (WFCA 2011b ). The second carpet manufacturing process, weaving, may be done by hand, looms, or industrial machinery using fibers and yarn (WFCA 2011b ). The process involves stretching fibers in one direction, called warps, tight on a frame and weaving yarn through them, and then laying fibers, called wefts, horizontally across the yarn (WFCA 2011b ). Currently, 90 percent o f carpets are made with synthetic (i.e., man - made) fibers (WFCA 2011a .) . Synthetic fibers are either nylon, polypropylene, and polyester, while the most common natural fibers are wool, silk and bamboo (WFCA 2011a). 

### 2.5 **Carpe t Treatment**  Anti - stain and anti - soil chemicals can be applied to a wide variety of textiles, including fibers, yarns, fabrics, and carpet using the following techniques ( Kissa 2001 ):
 Spraying
 Padding  Kiss -roll
 Foam application  Exhaust methods

5 Personal Communication with a s ales representative at Advanced Polymer, Inc. on 12/13/2011 . 6 Personal Communication with a s ales representative at Advanced Polymer, Inc. on 12/13/2011 . 7 Dyeing can occur before the other steps or at the end of the manufacturing process. Carpets that are dyed before the final steps are normally one color; while carpets that are dyed at the end of the process usually have a pattern or style. (WFCA 2011b ). 8 At the point in the process, manufacturers can apply an anti - stain treatment (WFCA 2011b ).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **2 -**  **3** 

### For carpets, spraying is the most popular technique for applying anti - stain and anti - soil chemicals. In most cases, these chemicals are applied at the last step of the manufacturing process before the carpet is dried (Kissa 2001 ). However, based on a report by 3M company in 1999, it appears to be possible for anti - stain treatment to occur during fiber manufacturing before these fibers are manufactured into a carpet .**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -** **4** 

## 3. **Industry**

**Overview 3.1**  **Sector Definition 3.1.1**  **Primary Ma**  **nuf acturing**  **: Chemical Manufacturing**  

### Chemical manufacturing is broadly captured under NAICS 325. This three - digit NAICS sector represents an industry involved in the transformation of raw materials (both organic and inorganic) via a chemical process and the fo rmulation of products (U.S. Census Bureau 2011c ) . Perfluorinated chemicals could be manufactured under a variety of six - digit NAICS codes , within NAICS 325: Chemical Manufacturing. Based on a revi ew of NAICS code definitions, t he following NAICS codes were identified as industries potential ly involved in production of perfluorinated chemicals . **NA ICS Code**  **NA ICS Description**  325120 Industrial Gas Manufacturing * 325188 All Other Basic Inorganic Chemical Manufacturing 325199 All Other Basic Organic Chemical Manufacturing 325211 Plastics Material and Resin Manufacturing 325212 Sy nthetic Rubber Manufacturing 325991 Custom Compounding of Purchased Resins 325998 All Other Miscellaneous C hemical Product and Preparation

Manufacturing *Includes Fluorocarbon gases manufacturing. **3.1.2 Secondary**  **Ma nufacturing**  **: Carpet Manufacturing and Treatment**  

### Carpet manufacturing and treatment is part of the textile industry, which primarily involves the design or manufacture of clothing as well as the distribution and use of textiles. The textile industry include s fiber production (natural and synthetic), raw weaving, knitting, dyeing, felting, finishing and printing and final make -up into garments (e.g. carpets, fabrics). Natural fibers include animal wools and cellulose products such as cotton and flax , while s ynthetic fibers include rayon, acrylic, polyester, polyurethane, polyamide and others. Textiles also include leather articles, upholstered household furniture, mattresses, and draperies. Carpet manufacturing and treatment is represented by NAICS 314110 “Carpet and Rug Mills“ and falls under NAICS 314 (Textile Product Mills) that represents manufacturers that produce textile products, excluding apparel. The processes used in this sector include cutting and sewing of fabric in order to make non - apparel textile products such as woven and tufted carpets (U.S. Census Bureau 2011d).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **5** 

### The Carpet and R

ug Mills industry comprises establishments primarily engaged in the following activities (U.S. Census Bureau 2011d):

(1) Manufacturing woven, tufted, and other carpets and rugs, such as art squares, f loor mattings, needlepunch carpeting, and door mats and mattings, from textile materials or from twisted paper, grasses, reeds, sisal, jute, or rags. (2) Finishing carpets and rugs. 

### 3.2 **Economic A ctiv**  **ity** Exhibit 3 - 1 presents the 2007 value of shipments for the 6 - digit industry sector “ Carpet and Rug Mills ” and compares it to the economic activity of NAICS 314 (Textile Product Mills). As shown in the table, the Carpet and Rug Mills sector accounts for almost half of economic activity within NAICS 314. **Exhibit 3**  **- 1**  **: Textile Product Mill Sectors**  **: Economic A** **ctivity ,**  **2007 NA**  **ICS Code NA**  **ICS Description Value of**  **Shipments ($1,000)**  **% of Total Product** 

**Mill Industry** 314110 Carpet and rug mills $13,054,338 45.5% **314 Textile Product Mills**  **$28,682,164 100.0%**  Source: U.S. Census Bureau 2010 

### Exhibit 3 - 2 presents historical data from Census on the number of establishments and value of shipments for the Carpet and Rug Mills sector. A significant industry growth in terms of the value of shipments is observed between 1992 and 2002 and a slight slowdown is exhibited between 2002 and 2007. **Exhibit 3**  **- 2**  **: Carpet and Rug Mills**  **: Economic A** **ctivity ,**  **Historical Data Year of Data**  **Number of**

**Establishments 5**  **- Year Percent**  **Change Value of Shipments**  **($1,000) 5**  **- Year Percent** 

**Ch ange**  2007 335 - 17.3% $13,054,338 - 6.5% 2002 405 - 14.2% $13,958,654 21.5% 1997 472 5.8% $11,492,786 16.9% 1992 446 - 6.1% $9,828,300 0.3% 1987 475 - $9,795,000 - Sources: 2007 data: U.S. Census Bureau, 2010 2002 data: U.S. Census Bureau, 2005a 1997 data: U.S. Census Bureau, 2005b 1992 and 1987 data: U.S. Census Bureau, 1996 (SIC Based) Notes: 1992 and 1987 data are SIC - based. SIC 2273 is equivalent to NAICS 314110 (Carpet and Rug Mills).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **6** 

### 3.3 **NA ICS Sectors Potentially**  **Using PFCs in Carpets** Itis likely that not all carpet and rug mills manufacture finished products that contain PFCs. Fluorinated telomers are primarily utilized in the impregnation of carpets or as a chemical finish which endows fabrics with stain, soil, or grease repellant characteristics. The focus of this analysis is on the economic activity of the carpet manufacturing sectors that impregnate and chemically finish their carpets at the textile mill level . It is important to note that carpet mill manufacturers may also purchas e fabric s for use in carpets that are already treated with PFCs . EPA believes that carpet treatment products containing long - chain PFCs are not manufactured in or imported into the U.S. Exhibit 3 - 3 shows product lines under the Carpet and Rug Mills sector, the corresponding number of companies with shipments of $100,000 or greater, and the value of shipments for these products. **Exhibit 3**  **- 3**  **: Carpet and Rug Mill Product Lines**  **: Economic A** **ctivity ,**  **2007 NA**  **ICS Code NA**  **ICS Description Number of**  **Companies with**  **Shipments of >$100,000**  **Products**

**Shipments Value ($1,000)**  **% of**

**Industry Value**  314110 Carpet and rug mills N $12,910,484 100.0 % 31411011 Carpet and rugs, woven 14 $444,004 3.4 % 31411031 Carpet and rugs, tufted

only or tufted & finished in sam e plant 73 $11,469,402 88. 8 % 31411032 Carpet and rugs, finishing

only 15 $319,137 2. 5 % 31411051 Other carpet, rugs, and

ma ts 32 $432,731 3. 4 % 3141103Y Carpet and rugs, tufted,

nsk N $9,626 0. 1 % 314110W Carpet and rug mills, nsk,

total N $235,584 1.8% Source: U.S. Census Bureau 2009 . Notes: Sectors where carpet and rug treatment with PFCs takes place are highlighted in grey. nsk - "not specified by kind" N - "Not available or not comparable" Product shipments value is the total value of all products produced and shipped by all producers. 

### Generally, tufted carpet is treated with some form of stain resisting chemicals, which helps to lengthen the life o f the carpet. Of the product line codes listed under the Carpet and Rug Mills sector, carpet and rug treatment with PFCs is likely to take place under the following prod uct line codes:
 31411031: Carpet and rugs, tufted only or tufted & finished in same plant;  31411032: Carpet and rugs, finishing only.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **7** 

### As shown in Exhibit 3 - 3 , most finishing of carpet and rugs occurs at the same plant where the carpet or rug is manufactured (89 percent of industry value)

– NAICS 31411031 . In some instances (2.5 percent of industry value), carpet finishing takes place separately from the manufacturing process

– NAICS 3141103Y . Furthermore, in some instances, fibers are treated before they are sent to a mill for manufacturing carpet s or rug s ( 3M Company 1999 ) . 

### 3.4 **Exports, Imports, and Domestic Consumption** Exhibit 3 - 4 presents data on imports and exports for the Carpet and Rug Mills sector. The table also shows the implied domestic consumption, import penetration and export intensity. Exhibit 3 - 5 presents the economic activity figures for the Carpet and Rug Mills sector . In 2007, the value of shipments is $13.1 billion, the value of imports is $2.2 billion, and the value of exports is $1.0 billion. According to 2007 Economic Census data and U.S. International Trade Commission (ITC) data, U.S. import s represent 16 percent of domestic consumption and export s represent eight percent of the value of ship ments. The values for the imports and exports are originally reported in HTS codes that are mapped to NAICS codes. The import value represents the cost, insurance, and freight value (C.I.F.), which is the landed value of the products at the first port of arrival in the U.S. (U.S. Census Bureau 2011a). The C.I.F. import value is essentially the sum of the import charges and the customs value (U.S. Census Bureau 2011a). The export value is based on the free alongside ship (F.A.S.) value, which represents the value of exports at the U.S. seaport, airport, or border port of export (U.S. Census Bureau 2011a). This value is based on the transaction price, which includes inland freight, insurance, and other charges, but excludes the cost of loading the merchandise aboard the exporting carrier and the freight, insurance, and any charges or transportation costs beyond the port of exportation (U.S. Census Bureau 2011a). The value of shipments is reported by U.S. Census Bureau data for each NAICS code.**Long -**  **Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **8** 

### Exhibit **3 -** **4 :**  **Carpet and Rug Mills :**  **Imports, Exports, and Implied Domestic Consumption, 2007 NA**  **ICS Code**  **NA ICS** 

**Description Products** 

**Description Value of** 

**Shipments ($1,000)**  **1 Imports** 

**($1,000) 2**  **Exports**

**($1,000) 2**  **Implied**

**Domestic Consumption**  **($1,000) Import** 

**Penetration Export** 

**Intensity** 314110 Carpet and rug

mi lls Carpets and

Rugs $13,054,338 $2,238,584 $1,047,551 $14,245,371 16% 8% Sources: **1** U.S. Census Bureau 2010 2 U.S. Census Bureau 2011b Notes: Imports and exports values are based on products (HTS codes) and not on industry classification (NAICS codes). Import penetration figures are calculated as a rat io of imports over the value of domestic consumption. Ex port intensity figures are calculated as a ratio of exports over the value of shipments.**Long -**  **Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **9** 

### Exhibit **3 -**  **5 :**  **Carpet and Rug Mills** : **Imports, Exports, Value of Shipments ($1,000),**

**2007**

Sources: U.S. Census Bureau 2010 ; U.S. Census Bureau 2011b **3.4.1 U.S.**  **International Trade Commission Data on Imports, 2000 –**  **2010** 

### Historical import data on imports for carpets and treated textile fabrics are available from the U.S. International Trade Commission (U.S. ITC). Data on the following HTS codes were accessed via the Interac tive Tariff and Trade DataWeb.

**HTS Code Description**  57 Carpets and other textile floor coverings 5903 * Textile fabrics impregnated, coated, covered or laminated with plastics Source: U.S. ITC 2010 *5903 HTS code is not specific to carpets and reflects all textile fabrics impregnated with plastics. 

### In addition to the phase - out of long - chain PFCs in carpet products by domestic manufacturers, EPA believes that LCPFC chemical substances are not being imported as part of carpet . As presented in Exhibit 3 - 6 , only 16 percent of domestically consumed carpets and rugs are imported from abroad , while 84 percent of the product is manufactured in the U.S. L ong - chain PFCs may be imported into the U.S. from countries like China and applied to carpets domestically. We obtained relevant imports data from ITC and concluded that PFCs for which **Value of Shipments**  **$13,054,338 Imports**  **$2,238,584 Exports,** 

**$1,047,551 Long**  **- Chain Perfluorinated Chemicals (LCPFCs) in Carpets**  **Contract # EP -** **W -** **08 -**  **010**

**Industry Overview**  **▌ pg.**  **3 -**  **10** 

### imports data are available are not used in carpets. 9 

### EPA believes that imported carpets do not contain LCPFCs. Exhibit 3 - 7 and 

### Exhibit 3 - 8 present general imports ($1,000,000) for carpets and impregnated fabrics, respectively, for each year, from 2000 to 2010. From 2000 to 2010, carpet imports increased by 19 percent and impregnated fabric imports increased by 107 percent (more than doubled) . The following figures present the time trend for these two industry sectors .

9 A s a result of our conversation with an ITC representative.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **11** 

### Exhibit **3 -**  **6 :**  **Carpet and Impregnated Fabrics: U.S. Imports, ($1,000,000)**  **Ma terial**  **HTS**

**Code 2000**  **2001 2002**  **2003 2004**  **2005 2006**  **2007 2008**  **2009 2010**  **% Change (2000**  **- 2010)**  Carpet 57 $1,469 $1,415 $1,535 $1,667 $1,838 $2,000 $2,133 $2,118 $1,914 $1,487 $1,742 **19%** Impregnated Fabrics 5903 $281 $257 $318 $374 $427 $465 $521 $538 $525 $422 $581 **107%** Source: U.S. ITC 2011**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Industry Overview**  **▌ pg.**  **3 -**  **12** 

### Exhibit **3 -**  **7 :**  **Carpet Imports, ($1,000,000)**

Source: U.S. ITC 2011 

### Exhibit **3 -**  **8 :**  **Impregnated Fabrics Imports, ($1,000,000)**

Source: U.S. ITC 2011

$0 $500 $1,000 $1,500 $2,000 $2,500

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010**I m** **p o** **r t** **s (** **$ 1** **, 0** **0 0** **, 0** **0 0** **)**



### Year

$0 $100 $200 $300 $400 $500 $600 $700

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010**I m** **p o** **r t** **s (** **$ 1** **, 0** **0 0** **, 0** **0 0** **)**



### Year**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 1**  

## 4. **Role of PFCs in Carpet Ma**  **nufacturing** Two broad types of fluorochemicals are used in carpets: fluorotelomers (described in Section 4.1 ) and perfluoroalkyl sulfate , PFAS (described in Section 4.2 ) . According to 2006 data, carpet and carpet care products are the second largest group of consumer products manufactured using fluorotelomers, after apparel (U.S. EPA 2009b ). Fluorotelomers are not manufactured using PFOA, but may degrade to form PFOA (U.S. EPA 2009b ). Fluorotelomers are essentially polymers with a functional group on the end of the carbon chain ( Danish Ministry of the Environment 2008 ). On the other hand, PFAS is a generic grouping term that encompasses any fully fluorinated carbon chain length sulfonate, including perfluorooctane sulfonate (PFOS) (OECD, 20 07). To date no evidence of fluoropolymers used in carpet treatment has been found. 10 

### The flowchart below presents the broad categories of PFCs used in carpet treatments, their subcategories, and estimated production volumes of those chemicals. PFOA’s pres ence in each chemical category was also identified. The following abbreviations are used in the flowchart:
 FT: Fluorotelomer  TFE: Tetrafluoro ethylene  PFAS: Perfluoroalkyl sulfonate  PFOA: Perfluorooctanoic acid

10 A s a result of a conversation with an ITC representative , w e believe that none of the im ports data on PFCs available through ITC are applicable to carpets.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 2**  

### Exhibit **4 -**  **1 : PFCs in Carpet** 



### 4.1 **Fluorotelomers in Carpets** Worldwide, repellents account for 4.1 percent of finishing products for textile applications; Fluorocarbons make up 59 percent of the repellents category, with paraffins (39 percent) and silicones (two percent) comprising the remaining portion ( Schindler and Hauser 2004 ). Fluorotelomers are used in the textile market because of their thermo - stability, ability to adapt to a variety of surface**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 3**  

### characteristics, low refractive indexes, low dielectric constants, and high chemical stability (Armeduri and Bouterin 2004 ) . Fluorotelo mers are used as soil retardants and stain repellents in carpets (Kissa, 2001). Fluorotelomers are used to treat textiles which cannot be laundered, including carpets, by preventing or reducing the adhesion of liquid or solid contaminants to the textile fibers. Fluorotelomer carpet treatments are incorporated in polymers including fluorinated polyurethanes , fluorinated vinyl polymers (Kissa, 2001) and fluorinated acrylate and methacrylate polymers (Scheirs, 1998). These fluorinated polymers have a non - fluorinated backbone with fluorinated alkyl chains which provide the desired physical characteristics. Fluorinated polyurethanes are noted to be tough but resilient and can withstand foot traffic on carpets (Kissa, 2001). Fluoroacrylate and fluoromethacrylate p olymers are used primarily for fibers and textiles ( Drobny 2009 ), however, at least one company markets fluorinated acrylate polymers for use in carpets . 11 

### Exhibit 4 - 2 summarizes the fluorotelomers identified as ingredients in carpet treatments. **Exhibit 4**  **- 2**  **: Fluorotelomers and Chemicals Containing Fluorotelomers Used in** 

**Poly urethane Resin**  **Chemical Formula Chemical Description**  **Source** F(CF2) n OH n = 6 – 12 Perfluoroalk yl alcohol Kissa, 2001 F(CF 2 ) n CH 2 CH 2 OH n = 6 - 14 Perfluoroalk ylethyl alcohol Kissa, 2001 F(CF 2 ) n CH 2 CH 2 OC(=O)NH(CH 2 ) xn is unspecified Perfluoroalk yl carbamic acid esters Kissa, 2001 F(CF 2 ) 8 SO 2 N(CH 3 )CH 2 CH 2 OH n - Eth yl(perfluorooctane) sulfonamidoethyl alcohol Kissa, 2001 F(CF 2 ) n SO 2 CH(CH 3 )CH 2 OC(=O)C(CH 3 )=CH 2 Perfluoroalk ylethyl me thacrylate Kissa, 2001 F(CF 2 ) n SO 2 CH(CH 3 )CH 2 OC(=O)CCH 3 =CH 2 n is unspecified Perfluoroalk ylsulfon yl ethy lm ethacrylate Kissa, 2001 F(CF 2 ) n CH 2 CH 2 C(=O)OCH=CH 2 Perfluoroalk ylethyl acrylate n is unspecified Kissa, 2001 n = 6 - 12 Kissa, 2001 NA Fluorinated acryl ic resins Scheirs, 1998 NA Fluoroalk ylethyl phosphates Danish, 2008 Sources: Page 150 of Scheirs, 1998; Pages 565 - 568 of Kissa, 2001, Table 2.1, page 24 of Danish Ministry of Environment, 2008.

11 Mason Chemical, e.g., Masurf® FS - 810 Fluoroaliphatic Polyacrylate Oligomer Fluorosurfactant . http://www.masonsurfactants.com/Products/Masurf_FS_810.htm .**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 4**  

### Exhibit 4 - 3 presents 2006 IUR production data for fluorotelomers used in polyurethane resin 12



### . **Exhibit 4**  **- 3**  **: Fluorotelomers Used in Poly**  **urethane Resin with 2006 IUR Production** 

**Data CA** **S Number**  **Description R**  **F Length**  **2006 IUR**

**Production (lb)**  **Perfluoroalkylethyl A lcohol**  647 - 42 - 7 1 - Octanol, 3,3,4,4,5,5,6,6,7,7,8,8,8 -

tridecafluoro 6 > 500K - 1M 678 - 39 - 7 1 - Decanol,

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10 - heptadecafluoro 8 > 1M - 10M 865 - 86 - 1 1 - Dodecanol,

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12 ,12 - heneicosafluoro 10 > 500K - 1M 39239 - 77 - 5 1 - Tetradecanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12 ,13,13,14,14,14 - pentacosafluoro 12 < 500K 68391 - 08 - 2 Alcohols, C8 - 14, γ - ω - perfluoro 6 - 12 < 500K **Perfluoroalkylethyl A crylate**  17741 - 60 - 5 2 - Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12 ,12 - heneicosafluorododec yl ester 10 > 1M - 10M 27905 - 45 - 9 2 - Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10 - heptadecafluorodec yl ester 8 > 1M - 10M 34362 - 49 - 7 2 - Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12 ,13,13,14, 14,15,15,16,16,16 - nonacosafluorohexadec yl ester 14 < 500K 34395 - 24 - 9 2 - Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12 ,13,13,14,14,14 - pentacosafluorotetradecyl ester 12 < 500K Source: OECD 2007 , U.S. EPA 2011a

12 The 2006 IUR required reporting for chemicals manufactured or imported in quantities above a 25,000 lb site - specific production threshold. Thus, it is possible that fluorotelomers may be produced in quantities below this threshold and then used in carpets treatment products that are not included in the 2006 IUR dataset.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 5**  

### 4.2 **PFA S in**  **Carpets** Perfluoroalkyl sulfonate (PFAS) 13 

### based compounds are used for treating textiles , fabrics and carpet, most notably under the trade name Scotchgard, owned by 3M . Scotchgard upholstery and fabric protectors are designed to repel spills and make clean -ups easier. It is also used to protect rugs and carpets against soiling and restore their original look . Prior to 2003, Scotchgard formulation was based on perfluorooctane sulfonate (PFOS) compounds, which contain eight perfluorinated carbons (considered a long - chain PFC) . After 2003, 3M reformulated its Scotchgard product to be based on perfluorobutane sulfonate (PFBS) compounds containing four perfluorinated carbons (considered a short - chain alternative PFC) ( Renner 2006 ). Itis important to note that based on the literature reviewed and the IUR data, we have not found any evidence that PFAS is currently used elsewhere in textile treatment , aside from PFBS in Scotchgard. Exhibit 4 - 4 presents 2002 and 200 6 IUR production data for all PFAS based compounds. The specific PFAS compounds used in textiles and carpet are not known. In the 2002 IUR, 24 PFAS compounds were reported, with perfluorinated carbon chain lengths ranging from four to ten (OECD 2007 ). In 2006, only two PFAS compounds were rep orted, both of which are PFBS with perfluorinated carbon chain length of four (short - chain) . Notably, the reformulation of Scotchgard in 2003 to short - chain PFC -based product corresponds with the lack of reported data on long - chain PFAS chemicals in the 20 06 IUR data. All chemicals listed in Exhibit 4 - 4 were reported to IUR by 3M only. **Exhibit 4**  **- 4**  **: PFA** **S Compounds with 2002, or 2006**  **14** 

### IUR Production Volume **CA S**  **Number Description**  **Rf Length**  **IUR Production (lbs)**

**2002 2006**  1763 - 23 - 1 1 - Octanesulfonic acid,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro 8 10K - 500K No Reports 29117 - 08 - 6 Poly(ox y- 1,2 - ethanediyl), α - [2 -

[ethyl[(heptadecafluorooctyl)sulfonyl] am ino]eth yl] - ω - hydrox y8 10K - 500K No Reports 67584 –42 – 3 Cyclohexanesulfonic acid,

decafluoro(pentafluoroethyl) - , potassium salt 8 10K - 500K No Reports

13 Perfluoroalkylsulfonates (PFAS) refers to the group o f perfluorinated chemicals of any carbon chain length terminated with a sulfonate ( - SO3 - ) functional group. The two PFAS com pounds described in this section are perfluoro butylsolfuonate (PFBS; italics added to identify the infix describing carbon chain len gth), which contains four perfluorinated carbons, and perfluoro octylsulfonate (PFOS; italics added to identify the infix describing carbon chain length), which contains eight perfluorinated carbons. 14 2006 is the latest year for which IUR data are availab le.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 6**  **CA S**  **Number Description**  **Rf Length**  **IUR Production (lbs)**

**2002 2006** 

68867 - 62 - 9 2 - Propenoic acid, 2 - me thyl - , 2 -

[ethyl[(heptadecafluorooctyl)sulfonyl] am ino]eth yl ester, telomer with 2 - [ethyl[(nonafluorobutyl)sulfonyl]amino]ethyl 2 - me thy l - 2 - propenoate, 2 - [ethyl[(pentadecafluoroheptyl)sulfonyl]amino]et hy l 2 - me thyl - 2 - propenoate, 2 - [ethyl[ (tridecafluorohex yl)sulfonyl]amino]ethyl 2 - me thyl - 2 - propenoate, 2 - [ethyl[(undecafluoropentyl)sulfonyl]amino]ethyl 2 - me thyl - 2 - propenoate, 1 - octanethiol and α - (1 - oxo - 2 - propenyl) - ω - me thoxypoly (oxy- 1,2 - ethanediyl) 4 - 8 10K - 500K No Reports

68958 - 61 - 2 Poly(ox y- 1,2 - ethanediyl), α - [2 -

[ethyl[(heptadecafluorooctyl)sulfonyl] am ino]eth yl] - ω - me thoxy8 10K - 500K No Reports 306974 –45– 8 Sulfonic acids, C6 - 8 - alkane, perfluoro,

com pds. with polyethylene polypropyleneglycol bis(2 - aminopropyl) ether 6 - 8 10K - 500K No Reports 307 – 35– 7 1 - Octanesulfonyl fluoride,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro 8 10K - 500K No Reports 375 - 72 - 4 1 - Butanesulfonyl fluoride, 1,1,2,2,3,3,4,4,4 -

nonafluoro 4 10K - 500K >500K -

1M 376 – 14 – 7 2 - Propenoic acid, 2 - me thyl - , 2 -

[ethyl[(heptadecafluorooctyl)sulfonyl]amino] ethy lester 8 10K - 500K No Reports 383 – 07 – 3 2 - Propenoic acid, 2 -

[but yl[(heptadecafluorooctyl)sulfonyl]amino]eth yl ester 8 10K - 500K No Reports 1691 - 99 - 2 1 - Octanesulfonamide, N - ethy l 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro - N - (2 - hydroxyethy l) - 8 10K - 500K No Reports 1869 - 77 - 8 Glycine, N - ethy l - N -

[(heptadecafluorooctyl)sulfonyl] - , ethyl ester 8 10K - 500K No Reports 2263 - 09 - 4 1 - Octanesulfonamide, N - buty l 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro - N - (2 - hydroxyethy l) 8 10K - 500K No Reports 2795 - 39 - 3 1 - Octanesulfonic acid,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro - ,potassium salt 8 10K - 500K No Reports 4151 - 50 - 2 1 - Octanesulfonamide, N - ethy l 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro 8 10K - 500K No Reports 13417 - 01 - 1 1 - Octanesulfonamide, N - [3 -

(dimethylamino)propyl] - 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro 8 10K - 500K No Reports 29420 - 49 - 3 1 - Butanesulfonic acid, 1,1,2,2,3,3,4,4,4 -

nonafluoro - , potassium salt 4 10K - 500K < 500K**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Role of PFCs in Carpet Manufacturing ▌**  **pg. 4**  **- 7**  **CA S**  **Number Description**  **Rf Length**  **IUR Production (lbs)**

**2002 2006**  31506 - 32 - 8 1 - Octanesulfonamide,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro - N - me thyl 8 10K - 500K No Reports 34454 - 97 - 2 1 - Butanesulfonamide, 1,1,2,2,3,3,4,4,4 -

nonafluoro - N - (2 - hydroxyethy l) - N - me thyl 4 10K - 500K No Reports 50598 - 28 - 2 1 - Hexanesulfonamide, N - [3 -

(dimethylamino)propyl] - 1,1,2,2,3,3,4,4,5,5,6,6,6 - tridecafluoro 6 10K - 500K No Reports 56773 - 42 - 3 Ethanaminium, N,N,N - triethyl - , salt with

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 - heptadecafluoro - 1 - octanesulfonic acid (1:1) 8 10K - 500K No Reports 67906 - 42 - 7 1 - Decanesulfonic acid,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10 - heneicosafluoro - , ammonium salt 10 10K - 500K No Reports 68156 - 06 - 9 Cyclohexanesulfonyl fluoride,

decafluoro(pentafluoroethyl) - 8 10K - 500K No Reports 307 - 35 - 7 Perfluoro - 1 - octanesulfonyl fluoride 8 10K - 500K No Reports Source: OECD 2007

, U.S. Environmental Protection Agency (U.S. EPA) 2011a , b

. Note: Grey highlights indicate chemicals with production data for 2006.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 1**  

## 5. **Av ailability** 

**of A lternatives**  Short chain fluorotelomers are being used as substitutes for long chain fluorotelomers in products such as textile, carpet and paper additives uses, and tile surface treatments. As of April 2010, EPA received a total of more than 75 PMN notices for short chain fluorotelomers (U.S. EPA 2010 ). Furthermore, through the end of 2008, over 100 alternatives of various types have been received and reviewed by EPA (U.S. EPA 2009a). Itis important to note that while fluorotelomers, such as substances with an alkyl chain length of C6 or less, have been used as substitutes for PFOS in a variety of products, telomerization results in various telomers of different chain lengths, even if the majority h as less than six carbons ( Danish Ministry of the Environment 2008 ). Thus, impurities could be found in the short chain products. Below is a list of alternative s developed by major manufacturers of PFC -based carpet products. Note that f or Clariant, AGC, and BASF , s ome of the alternatives may not be used on carpets

– the manufacturer website s do not always provide sufficient information on specific product use s . 

### 5.1 **Clariant** Clariant developed a prod uct series, called Nuva® N, which uses short - chain (C6) chemistry. One product, called Nuva® N2116 liq, is a PFOA - free 15 

### repellent for synthetic fibers and nonwovens, and can be used on a variety of textiles. 16 

### Another PFOA - free repellent product, called Nuva® N2114 liq, is used in a variety of textiles including, but not limited to, sunshades, umbrellas, shoes, bedding, mattress protectors, military uniforms, and sportswear. 17 

### Nuva® N5151 liq is a PFOA - free, soil and stain repellent product for foam applicati ons which can be used on carpets. 18 

### 5.2 **DuPont** DuPont developed an alternative to PFOA -based fluorotelomer products in a step toward reaching PFOA elimination targets under EPA’s PFOA Stewardship Program ( DuPont 2011 ). A new line of surface protection products , CapstoneTM, based on short - chain chemistry (short - chain molecules that cannot break down to PFOA in the environment), is an alternative to fluorotelomer-based products such as Zonyl®. Capstone® repellents and surfactants are based on short - chain technology consisting

15 It is important to note that when a fluoropolymer is called PFOA - free, it means that the PFOA content is below the limit of detection. 16 Clariant Textile Chemicals: Nuva® N2116 liq. 2011. Available at: http://www.textiles.clariant.com/C12571C400483A78/vwWebPagesByID/8A961FBAA5272607C12575D 00048F470 (Accessed October 3, 2011). 17 Clariant Textile Chemicals: Nuva® N2114 liq. 2011. Available at: http://www.textiles.clariant.com/C12571C400483A78/vwWebPagesByID/ABCE5BDE71BE7555C12572 AC0049E92D (Accessed October 3, 2011). 18 Clariant Textile Chemicals: Nuva® N5151 liq. 2011. Available at: http://www.textiles.clariant.com/C12571C400483A78/vwWebPage sByID/506A4218AA031289C12575D0 0048FF30 (Accessed October 3, 2011).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 2**  

### of six or fewer fluorinated carbons, bound to a “delivery system” such as a polymer or surfactant. DuPont CapstoneTM products for textile finishes provide a step - change reduction in trace impurities below the limit of detection, designed to off er the same or better performance than their predecessors without compromising fluorine efficiency. CapstoneTM products also meet the goals of the U.S. EPA 2010/15 PFOA Stewardship Program targets for PFOA and precursors. For the vast majority of textiles a pplications, including mills and finishers, DuPontTM CapstoneTM products are the key ingredient in fabric finishes for apparel, home furnishings and other textiles that will be sold to mills by Huntsman under the Huntsman trade name Oleophobol® CP. DuPontTM Capstone® products are commercially available in home furnishings, firefighting foam, fluorosurfactants, paper packaging, textiles, stone and tile, and leather end uses. DuPont’s goal is to transition the majority of the textiles business to short - chain ch emistry by the end of 2010. 19 

### DuPont has developed LX Platform of fluorotelomer-based product s that include s DuPontTM Teflon®, Zonyl® and Foraperle® technologies. 20 

### LX Platform products meet high performance and value requirements, while removing nearly all trace levels of PFOA and direct precursors to PFOA. The LX Products are among the world’s first commercial fluorotelomer products to meet the EPA’s PFOA and direct precursor reduction criteria (including the reduction of higher homologue acids and direct precursors). 21 

### Because the LX Platform products were developed using technology to remove unintended levels of PFOA and direct precursors, they are intended to be drop in replacements for the existing DuPont products that do not require new equipment or inve stments, causing no disruption or delay in the manufacturing process. DuPont claims that this new manufacturing process will remove greater than 97 percent of all trace levels of PFOA, its homologues and direct precursors from the LX Platform Products. DuPont also states that telomer chemistry, on which LX Platform Products are based, is not made with PFOA, nor is PFOA added during the manufacture of DuPont telomer -based products. However, PFOA is found at trace levels in some fluorotelomer products as an unintended byproduct of the manufacturing process. DuPont believes that no one can substantiate statements that fluorotelomer products are “PFOA Free” or have “Zero PFOA” even if test results are below the limit of detection. DuPont believes such a claim must be made with scientific accuracy, and analytical methods continue to advance to ever- lower detection limits. 22 

### DuPont states that their LX Platform Products are listed on global regulatory clearances, such as the U.S. (TSCA), Europe (EINECS), Canada (DSL) and Japan (ENCS). 23

19 http://www2.dupont.com/Capstone/en_US/uses_apps/textiles/textiles.html 20 DuPont. 2011. Textiles and Carpet Care. Available at: http://www2.dupont.com/Zonyl_Foraperle/en_US/uses_apps/carpet_pgs/textiles.html (Accessed 11/28/2011). 21 http://www2.dupont.com/Zonyl_Foraperle/en_US/products/lx.html 22 http://www2.dupont.com/Cap stone/en_US/prod_steward/claims_you_can_trust.html 23 DuPont. 2011. Textiles and Carpet Care. Available at: http://www2.dupont.com/Zonyl_Foraperle/en_US/uses_apps/carpet_pgs/textiles.html (Accessed 11/28/2011).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 3**  

### While DuPont is not using long chain PFCs in its products , f luorinated telomers may break down into long chain PFCs as unintended byproducts of the manufacturing process. 

### 5.3 **AG C Chemicals A** **mericas (A sahi)**  AGC Chemicals Americas, Inc., a subsidiary of the Asahi Glass Company of Japan, produces fluorotelomers and flouropolymers (e.g., PTFE, and carboxylate) that are used heavily in textiles. AGC Chemicals Americas manufactures a fluoropolymer, known as their Fluon® PTFE (Polytetrafluoroethylene) Resins. 24 

### This resin is manufactured in three forms: as an aqueous dispersion, a coagulated dispersion, or as granular powders. Fluon® PTFE can be used to make textile membranes. Aqueous dispersions of Fluon® PTFE can be used to make coatings for woven fabrics. 25 

### AGC has developed a stain resistant and water and oil repellent PFC product, Guard E - SERIES. 26 

### This product does not contain PFOA or long - chain PFCs and their precursors. Instead, this product has six carbons, which is considered a short chain PFC. These PFCs are applied to textiles because the produc t imparts stain resistance and water and oil repellency, while still maintaining the texture, breathability and color of the textile. The Guard E - SERIES essentially keeps textile products, such as fabric and leather, looking new for longer. Furthermore, this product can also be used in applications such as food wrapping materials, trays, cooking paper, water repellent tents, paper, and board. 

### 5.4 **Daikin Industries** Daikin Industries, Ltd and its subsidiaries are attempting to stop manufacturing, selling, and us ing PFOA C8 telomer -based water and oil repellent products by the end of 2012. Daikin specifically uses PFOA as a polymerization aid for the manufacture of some of its fluoropolymers and fluoroelastomers. They are planning on manufacturing alternatives wit h processing aids that are not PFOA, by 2012. They have also developed a short chain, C6, alternative for their water/ oil repellent C8 fluorotelomer products. Daikin has already begun the process of replacing these products (Daikin Industries Ltd 2011b ). Daikin Industries, Ltd has jointly developed a product with Dow Corning Corporation called UNIDYNE Multi - Series TM



### . 27 

### UNIDYNE Multi - Series TM 

### products are made from C6. Specifically,

24 AGC Chemicals Americas Inc. 2011a. "Fluon® PTFE Resins." Available at: http://www.agcchem.com/products/fluoropolymer - resins - com pounds/fluon -ptfe - resins (Accessed September 29, 2011). 25 AGC Chemicals Americas Inc. 2011b. “Coagulated Dispersion Polymers.” Available at: http://www.agcchem.com/docs/fluon- technical data/2011/03/16/Fluon®%20Coagulated%20Dispersion%20Polymers.pdf?Status=Master (Accessed September 29, 2011). 26 AGC Chemicals Americas, Inc (AGC). “Asahi Guard E - SERIES.” Available at: http://www.agcchem.com/products/specialty - chemicals/asahi - guard - e - series (Accessed September 28, 2011). 27 Daikin Industries Ltd. 2011. "Activities for Environmental Issues of UNIDYNE TM " Available at: http://www.daikin.com/chm/pro/kasei/unidyne_multi/feature/env.html (Accessed September 30, 2011).**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 4**  

### these products use ifluoro - silico ne hybrid technology. 28 

### Exhibit 5 - 1 provides a list of these products and their features. **Exhibit 5**  **- 1**  **: UNIDYNE Multi**  **- Series**  **TM** 

### Water and Oil Repellent Products **Product Name Features**  TG - 5601 Soft - hand feel; high wash durability TG - 5541 Soft - hand feel; high water repellency TG - 5543 Soft - hand feel ; high wash durability TG - 55 02 High water bearing pressure; high alcohol resistance TG - 8111 O il and grease resistance to paper products Source: Daiken Industries Ltd. 2012 . Note : TG - 5601, TG - 5541, and TG - 5543 were jointly developed with Dow Corning Corporation . 

### 5.5 **Solvay Solexis** In 2009, Solvay Solexis announced that it had developed an alternative to PFOA that will be used in its products. Specifically, the PFOA - free Fluorolink products were developed for textile and leather good surface treatment in which the PFPE structure delivers reduction of surface energy, water and oil repellency, and stain and soil resistance. The Fluorolink products are based on a perfluoropolyether structure (rather than perfluoroalkyl) which contains functional groups that are able to facilitate interactions with the targeted substrate. The Fluorolink products can be used on natural and synthetic fibers, washable fabrics like domestic and industrial clothing, and furniture fabrics requiring stain and soil release properties. Additionally, Fluorolink products can be used for upholstery, wall coverings, and rugs that require durable stain release or rainwear, awnings, or sportswear that require highly durable water repellency29



### . 

### 5.6 **BA SF**  BASF has developed the Lurotex Duo Systems for stain repellent and stain release to protect textiles from soiling and staining. The technology is made up of a Lurotex fluorocarbon finish based on advanced C6 technology compared to the current C8 technology which allows for an undetecta ble amount of PFOA. The Lurotex products can be used in consumer apparel like rainwear, business wear, casual wear or corporate wear. They can also be used in home textiles like upholstery, tablecloths, drapes, mattress

28 Daikin Industries Ltd. 2011. "Water and Oil Repellents." Available at: http://www.daikin.com/chm/products/fiber/index.html (Accessed September 30, 2011). 29 Solvay Solexis, 2009. “Textiles and Leather.” Available at: http://www.solvaysolexis.asia/marketsapps/specificmarket/marketapplication/0,,40542 - 2 - 0,00.htm . (Accessed October 3, 2011) .**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 5**  

### covers, and bed linen. Additionally, the Lurotex alternative technology can be used in technical textiles like awnings, parasols, tents, luggage, and transportation fabrics. 30 

### 5.7 **Ad vanced Poly**  **mer Inc.** Advanced Polymer has a line of short - chain PFC and PFOA - free technologies used in textiles call ed AdvaPel. AdvaPel - 712 is a C6 based, non - PFOA contributing, waterborne, cationic, fluoropolymer emulsion system designed to impart oil, water and soil repellency to apparel, carpeting and automotive fabrics. AdvaPel - 734 is a water -based, air dry, fluoroc hemical finishing agent that imparts water, oil and soil repellency to textiles, upholstery and carpeting. AdvaPel - 734 is a non - C8 based fluoroalkyl compound and is considered PFOA - free. 31 

### 5.8 **3M** As aforementioned in S ection 4.2 , prior to 2003, 3M produced a product containing PFOS called ScotchgardTM, which protected textiles from stains and soil. 3M began a voluntary phase out of PFOS - and PFOA -based p roducts on May 16, 2000 ( Hakes and Jariwala 2010 ). 3M’s new Sco tchgardTM product contains PFBS (Perfluorobutane Sulfonate), which has a 4 carbon chain, as opposed to the 8 carbon chain present in PFOS (EWG 2011 ). These products can be used as oil and water repellents coatings for apparel, carpets, furniture, and leather ( H akes and Jariwala 2010 ) . 

### 5.9 **Other A lternatives**  A research paper ( Lindemann 2007 ) evaluating commercially available PFOA - free repellent finishes was developed at North Carolina State University in 2007. A list of alternative finishes was developed and a number of products were selected for evaluation. Results of the work indicated that none of the commercially available alternatives tested performed at the same level as the traditional PFOA - containing products. Short - chain PFCs showed the highest level of performance. These were the only products which were able to provide oil repellency. Silicone and hydrocarbon wax products were also evaluated and showed varying levels of performance. The two primary non PFC -based alternatives for fluorocarbon finishes are (1) hydrocarbon hydrophobes and (2) polysiloxane based finishing options. Paraffin wax containing repellents are the oldest and least expensive water repellent finishing option for textiles. Paraf f in wax containing repellents (hydrocarbon wax) are both inexpensive and PFOA f ree. They are applied as aluminum or zirconium soaps. Several other waxes have been developed, but there have been significant issues that have affected the viability of these options in the textile industry. For example, DuPont created Chrome complexes, a wax based finish, which unfortunately had a blue/green color to it. Two other waxes, Pyridinium complexes and N - methylol compounds, may release formaldehyde, a pos sible carcinogen.

30 BASF, 2010. “Lurotex®Duo Systems for stain repellent and stain release.” Available at: http://www.performancechemical s.basf.com/ev - wc ms - in/internet/en_GB/portal/showcontent_tc/content/EV/EV8/textile_processing/lurotex/lurotex . (Accessed October 3, 2011). 31 http://www.advpolymer.com/index.php/products/chemistry/fluoropolymers/**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 6**  

### Polysiloxane based finishes are water repellent, but may also be a better alternative than Paraf fin wax because they are considered more durable, have a better tear strength, improved sewabil ity, and impart a softer feel to the material (referred to as soft hand). 32 

### One of the benefits of polysiloxanes is that they do not lose their water repellency after being washed, which tends to be the case for fluorocarbon finishes. 33 

### However, one of the disadvantages to polysiloxanes is that repellenc y can decrease with over- application, or even be lost if the layer of polysiloxane layer is cracked. 34 

### Furthermore, neither hydrocarbon waxes nor polysiloxanes have the property of oil repellency. 35 

### Lindemann ( 2007 ) also evaluated other alternatives in the early stages of development. The following three methods are being researched and developed (as of 2007), and could be viable alternatives for finishing in the future. Plasma aided textile finishing is a “dry” process, instead of “wet” finishing process, which would get rid of waste water and the fabric drying processes. Another benefit of this alternative is that it does not affect fabric properties. One study, by Zhang, et al. compared plasma finishing with a fluorocarbon and ScotchgardTM and found that the plasma treatment worked well in a variety of areas, including softness, whiteness of the samples, water vapor permeability, and abrasion resistance. 36 

### Another possible method looks at surface roughness, which increases wetting properties because of the increased surface area. 37 

### In one research study, the researchers created an ultra -hydrophobic surface on a microfiber polyester fabric, based on the findings on surface roughness. 38 

### Several other studies have been conducted that look into the relationship between the texture of a surface and water repellency. Finally, fluorinated polysiloxanes may also become an alternative. One study, by Shao, et al., looked at a perfluoroalkly - containing multi - epoxy compound (PFME) and found that the chemical was oil repellent and had moderate durable press properties. 39

32 In Lindemann 2007 this information comes from: Schindler, W. D.; Hauser, P. J.; Textile Institute i n Chemical F inishing of textiles; Crc; Woodhead: Boca Raton; Cambridge, England, 2004 , pp 213. 33 In Lindemann 20 07 this information comes from : Lee, M.; Nishi, K.; Jeong, D. S.; Tokuyama, T.; Itazu, T.; Miyaji, Y.; Wakida, T. Sen'i Gakkaishi 2005, 61, 309. 34 This can occur during washing. 35 In Lindemann 2007 this information comes from : Kissa, E. In Fluorinated surfactants and repellents; Surfactant Science Series; Marcel Dekker: New York, 2001; Vol. 97, pp 615. and Schindler, W. D.; Hauser, P. J.; Textile Institute in Chemical F inishing of textiles; CRC ; Woodhead: Boca Raton; Cambridg e, England, 2004, pp 213. 36 In Lindemann 2007 this information comes from: Zhang, J.; France, P.; Radomyselskiy, A.; Datta, S.; Zhao, J. A.; van Ooij, W. J Appl Polym Sci 2003, 88, 1473. 37 In Lindemann 2007 this information comes from: Bico, J.; Marzolin, C.; Quere, D. Europhys. Lett. 1999, 47, 220. 38 In Lindemann 2007 this information comes from : Gao, L. C.; McCarthy, T. J. Langmuir 2006, 22, 5998. 39 In Lindemann 2007 this information comes from: Shao, H.; S un, J. Y.; Meng, W. D.; Qing, F. L. Text. Res. J. 2004, 74, 851.**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**Alternatives ▌**  **pg. 5**  **- 7**  

### 5.10 **Conclusions** As a result of our research on alternative technologies and products used for carpet treatment, we found that major manufacturers of PFC -based carpet products currently offer alternative product s that use short - chain PFCs. Additional research is needed to assess performance of those alternative products in comparison to LCPFC -based products .**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**References ▌**  **pg. 6**  **- 1**  

## 6. **References** 3M Company. 1999. Fluorochemical Use, Distribution and Release Overview . EPA - HQ - OPPT 2002 - 0051 - 0003. B. Armeduri and B. Bouterin. 2004. Applications of Flourinated Telomers . Well -Architectured Floropolymers: Synthesis, Properti es, and Applications. (p. 71) . San Diego, Elsevier Ltd. . Daiken Industries Ltd. 2012. "Water and Oil Repellents." Available at: http://www.daikin.com/chm/products/fiber/index.html (Accesse d January 6, 2012). Daikin Industries Ltd. 2011a. "Water and Oil Repellents." Available at: http://www.daikin.com/chm/products/fiber/index.html (Accessed December 8, 2011). Daikin Industries Ltd. 2011b. "Elimination of PFOA in Fluorochemical Products." Available at: http://www.daikin.com/chm/pfoa/index.html (Accessed Septermber 30, 2011). Danish Ministry of the Environment. 2008. Survey and Environmental/Health Assessment of Fluorinated Substances in Impregnated Consumer Products and Impregnating Agents: Survey of Chemical Substances in Consumer Products, No. 99 . M. J. A. Dinglasan - Panilio and S. A. Mabury. 2006. Significant Residual Fluorinated Alcohols Present in Various Fluorinated Materials. Environ. Sci. Technol. . 40(5): 1447 - 1453. J. G. Drobny. 2009. Technology of Fluoropolymers. Second Edition. CRC Press. DuPont. 2011. "DuPontTM Capstone®." Available at: http://www2.dupont.com/Capstone/en_US/uses_apps/textiles/textiles.html (Accessed September 13, 2011). Environmental Working Group (EWG). 2011. "Human Toxome Project: PFBS (Perfluorobutane sulfonate) " Available at: http://www.ewg.org/sites/humantoxome/chemicals/chemical.php?chemid=100300 (Accessed October 21, 2011). D. C. Hakes and C. P. Jariwala. 2010. New Sustainable 3M Fluorochemical Technology for Oil and Water Repellent Coatings . June 22, 2010. E. Kissa. 2001. Fluorinated Surfactants and Repellents. Surfactant Science Series. Marcel Dekker, Inc.: New York. C. E. Lindemann. 2007. Evaluation of Commercially Available PFOA
-Free Repellent . Raleigh, North Caroline, North Carolina State University. Masters of Science **:** 145. March 21, 2007. Organisation for Economic Co - operation and Development (OECD). 2007. Lists of PFOS, PFAS, PFOA, PFCA, related compounds and chemicals that may degrade to PFCA . Available at: http://www.oecd.org/officialdocuments/displaydocumentpdf/?cote=env/jm/mono(2006)15&d oclanguage=en . R. Renner. 2006. The long and the short of perfluorinated replacements. Environmental Science and Technology . 40: 12

– 13. W. D. Schindler and P. J. Hauser. 2004. Chemical Finishing of Textiles. Woodhead Publishing. M. M. Schultz, D. F. Barofsky and J. A. Field. 2003. Fluorinated Alkyl Surfactants. Environmental Engineering Science. . 20(5): 487

– 501. SRI Consulting. 2009. 2009 Directory of Chemical Producers: United States. Swedish Chemicals Agency (KEMI). 2006. Perfluorinated Substances and their Uses in Sweden , Swedish Chemicals Agency. November 2006. U.S. Census Bureau. 2009. "2007 Economic Census. EC0731I2: Sector 31: Manufacturing: Industry Series: Products Statistics for the United States: 2007." Available at: http://factfinder.census.gov/servlet/EconSectorServlet?caller=dataset&sv_name=*&_SectorI d=31&ds_name=EC0700A 1&_lang=en&_ts=341833788346 (Accessed December 13, 2011). U.S. Census Bureau. 2010. "EC0731SG2. Sector 31: Manufacturing: Summary Series: General Summary: Detailed Statistics by Subsectors and Industries: 2007 " Available at:**Long -**  **Chain Perfluorinated Chemicals (**  **LC PFCs)**  **in Carpets**  **Contract # EP**  **- W**  **- 08**  **- 010** 

**References ▌**  **pg. 6**  **- 2**  

### http://factfinder.census.gov/servlet/EconSectorServlet?caller=dataset&sv_name=*&_SectorI d=31&ds_name=EC0700A1&_lang=en&_ts=33448704896 1 (Accessed September 22, 2011). U.S. Census Bureau. 2011a. "Guide to Foreign Trade Statistics: Description of the Foreign Trade Statistical Program." Available at: http://www.census.gov/foreign trade/guide/sec2.html#cif_value (Accessed September 26, 2011). U.S. Census Bureau. 2011b. "U.S International Trade Statistics. Value of Exports, General Imports, and Imports by Country by 6 - digit NAICS : (314) Textile Mill Products: World(0000). December 2007 ()." Available at: http://www.census.gov/foreign -trade/statistics/country/ (Accessed September 22, 2011). U.S. Census Bureau. 2011c. "Industry Statistics Sam pler: NAICS 325: Chemical Manufacturing." Available at: http://www.census.gov/econ/industry/def/d325.htm (Accessed January 24, 2012). U.S. Census Bureau. 2011d. "Industry Statistics Sampler: NAICS 314 Textile Product Mills." Available at: http://www.census.gov/econ/industry/def/d314.htm (Accessed September 12, 2011). U.S. Environmental Protection Agency (U.S. EPA). 2009a. 2010/15 PFOA Stewardship Program Overview and Update . Workshop on Managing Perfluorinated Chemicals and Transitioning to Safer Alternatives . T. Krasnic. February 12 - 13, 2009 U.S. Environmental Protection Agency (U.S. EPA). 2009b. Long - Chain Perfluorinated Chemicals (PFCs) Action Plan . 12/30/2009. U.S. Environmental Protection Agency (U.S. EPA). 2009c. "Perfluorooctanoic Acid (PFOA) and Fluorinated Telomers: Basic Information." Available at: http://www .epa.gov/oppt/pfoa/pubs/pfoainfo.html (Accessed August 24, 2009 ). U.S. Environmental Protection Agency (U.S. EPA). 2010. "New Chemical Review of Alternatives for PFOA and Related Chemicals." Available at: http://www.epa.gov/opptintr/pfoa/pubs/altnewchems.html (Accessed August 30, 2011). U.S. Environmental Protection Agency (U.S. EPA). 2011a. "Inventory Update Reporting and Chemical Data Reporting. 2006 IUR Database." Available at: http://www.epa.gov/iur/tools/data/2006archivedata.html (Accessed October 5, 2011). U.S. Environmental Protection Agency (U.S. EPA). 2011b. "Non - confidential 2002 IUR Company/Chemical Records." Available at: http://www.epa.gov/iur/tools/data/2002 - com p chem -records.html (Accessed October 6, 2011). U.S. International Trade Commission (U.S. ITC). 2011. "Accessed via Interactive Tariff and Trade DataWeb. General Customs Value by HTS Number and General Customs Value for ALL Countries: Available at: U.S. General Imports: Annual Data." Available at: http://dataweb.usitc.gov/ (Accessed Novermber 2, 2011). United States International Trade Commission (U.S. ITC). 2010. Harmonized Tariff Schedule of the United States (2011). USITC Publication 4201 . December 23, 2010. World Floor Covering Association (WFCA). 2011a. "Carpet Terms." Available at: http://www.wfca.org/Pages/Carpet - Terms.aspx (Accessed December 1, 2011). World Floor Covering Association (WFCA). 2011 b. "How Carpet Is Made." Available at: http://www.wfca.org/Pages/How - Carpet - Is - Made.aspx (Accessed December 1, 2011).