3M General Offices 

* //pip 3M Center 

St Paul, MN 55144-1000 

651 733 1110 Fy!0700-/378 8 

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July 7, 2000 

Charles Auer (E403C) 

Director, Chemical Control Division 

Office of Pollution Prevention and Toxics 

Office of Prevention, Pesticides and Toxic Substances 

US Environmental Protection Agency 

401 M. Street, SW 

Washington, DC 

Re: Phase-out Plan for POSF-Based Products 

Dear Mr. Auer: 

As you know, on May 16, 2000 3M announced that it will be phasing out manufacture of 

products based on peffluorooctanyl chemistry. In that announcement, 3M indicated that 

production of these materials would be substantially discontinued by the end of 2000 and that the 

company would work with its customers to implement an orderly phase-out. 

EPA has asked 3M to submit a detailed plan explaining how it intends to fulfill these 

commitments. This letter and attachments are provided in response to EPA's request. As 

discussed with the Agency, 3M's initial plan focuses on products derived from 

perfluorooctanesulfonyl fluoride (POSF); these products constitute over 95 percent of 3M's total 

production of perfluorooctanyl chemistries. Other products covered by 3M's May 16 

announcement, including perfluorooctanoic acid (PFOA), will be separately discussed with EPA. 

We appreciated the opportunity to discuss our phase-out plan with EPA staff on June 20. The 

Agency's comments at the meeting and in subsequent conversations were very helpfid and are 

reflected in this letter and attachments. We have also continued to refine our plan on the basis of 

updated information. Because of these modifications, our latest submission reflects 3M's current 

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phase-out plan and therefore supersedes our letters of June 16 and 23 

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INTRODUCTION AND OVERVIEW 

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During the past two years, 3M has communicated extensively with EPA about fluorochemical 

publicly and EPA is familiar with the considerations on which that decision was based. In 

(FC) issues. We informed EPA management of our phase-out decision before it was announced 

summary, 3M is discontinuing manufacture of perfluorooctanyl materials because of its 

commitment to responsible environmental management and sound business principles. 3M 

concluded that, in light of the persistence of certain FCs and their detection at extremely low 

levels in the blood of the general population and wildlife, other business opportunities were more 

deserving of the company's energies and attention than perfluorooctanyl-based chemistries. As 

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July 7, 2000 

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3M has repeatedly emphasized, all existing knowledge indicates that the presence of these 

chemistries in people and wildlife at the low levels detected does not pose a health or 

environmental risk. 

In deciding how to implement its phase-out decision, 3M has been guided by two objectives. 

First, we wish to fulfill our commitment to accomplish a substantial phase-out of production as 

expeditiously as practicable. Second, we want to minimize marketplace disruption and provide 

for an orderly transition away from POSF-based products by the business sectors that depend on 

perfluorooctanyl chemistries. Balancing these considerations is extremely challenging because 

our POSF-based products are used in a wide range of applications with impacts on numerous 

segments of the economy. 

We are still receiving and evaluating the information necessary to balance these complex 

considerations. However, this letter and attachments provide our best current understanding of 

how we will implement our phase-out plan for POSF-based products. As illustrated in 

Attachment I, 3M's plan will result in a substantial reduction in production and import volumes 

after December 3 1, 2000. Limited further production, at significantly lower levels, will continue 

through the end of 2002. As shown in Attachment 2, production of POSF-derived materials will 

be reduced in 2001 to 12.3 percent of the projected 2000 baseline and would decline to 4.5 

percent of the baseline in 2002. 3M anticipates that manufacture and import of affected products 

will cease entirely at the end of 2002. Thereafter, 3M will continue to distribute small volumes 

of certain previously manufactured products to specific customers. 

After the end of the year, 3M manufacturing capacity will be committed entirely to certain 

proposed "extended phase-out" applications for POSF-based products by our customers or other 

3M businesses. These applications are identified in Attachments 3, 4 and5. [These 

attachments are CBI.] They were selected on the basis of a carehl evaluation process within 

3M. We understand from our discussions with the Agency that EPA believes that 3M's initial 

judgments are reasonable. However, we urge EPA to solicit public comment on extended phaseout applications for POSF-based chemistries when it proposes regulations applicable to these 

chemistries later this summer so that 3M customers and other interested parties can provide input 

to EPA. 

As you know, 3M is developing substitutes for certain products that will require Premanufacture 

Notice (PMN) submissions before commercialization. We are pleased that EPA and 3M have 

begun a dialogue on these substitute chemistries. This ongoing dialogue, which we hope will 

continue during the PMN review process, will help 3M provide informed guidance to our 

customers on substitution options at the earliest possible date so that they can switch to 

acceptable alternates with minimum delay. 

The remainder of this letter addresses five aspects of 3Ms phase-out plan: 

+ Scope of the plan 

+ Details of production scale-down 

+ Proposed extended phase-out applications 

+ Proposed substitutes for POSF-based products 

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July 7, 2000 

+ 3M stewardship actions during the phase-out period 

SCOPE OF 3M’S PLAN 

P 

Global Impacts. 3M’s phase-out plan is global in scope. In developing the plan, we have applied 

a consistent framework to production and use activities within and outside the US. 3M 

recognizes that EPA does not have jurisdiction over manufacture and use of POSF-based 

products outside the US, but we want the Agency to be informed about our phase-out actions on 

a worldwide basis. 

Attachment 2 provides projected Year 2000 production volumes for POSF-based products for the 

US and entire world. 3M management is in the process of determining which manufacturing 

locations in the US and Europe will be used for production during 200 1 and 2002. It is possible 

that all production will be consolidated at a single facility in order to reduce costs and re-deploy 

manufacturing resources efficiently. We will keep EPA informed of our manufacturing plans as 

they evolve. 

Status ofFDA Regulated Products. The 3M phase-out plan includes products used in food 

packaging, medical devices and other applications regulated by the Food and Drug 

Administration (FDA). For purposes of comparison, we have provided a breakout of FDAregulated applications and associated production volumes. 3M will be informing FDA of our 

phase-out plans for products within that agency‘s jurisdiction. 

Inclusion of Additional Chemistries. Following our initial announcement, 3M has decided to 

discontinue manufacture of products based on C-6 and C-10 homologs of POSF. We made this 

decision because, in management’s judgment, the rationale for our phase-out decision applied to 

these products as well as to our C-8 sulfonated materials. The C-6 and C- 10 products represent 

relatively small volumes and are highlighted in the attachments to this letter. 

DETAILS OF PRODUCTION SCALE-DOWN 

Baseline Inventory ofAffected Products. To establish a baseline for phase-out decisions, 3M 

inventoried all POSF-based products currently manufactured by the company. This inventory is 

presented in Attachment 6. [Attachment 6 is CBI] The Attachment groups these products by use 

category and then lists individual products in each category by 3M product code, CAS Number, 

chemical name and the percentage of fluorochemicals (FCs) present in the product. In addition, 

the Attachment provides projected Year 2000 production totals for each individual product and 

use category. 

Since six months remain in Year 2000, 3M used updated business forecasts prepared at the end 

of 1999 to estimate production volumes for the remainder of the year. These estimated volumes 

are presented for both the FC portion of the product and the entire product formulation (FC plus 

other components). The FC poundages represent total solids (including reactants combined with 

the FC starting material) and do not represent the POSF molecule itself. 

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July 7, 2000 

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Year 2000 Ordering Process. 3M has asked customers to place final orders by October 1,2000. 

We are informing customers that final order amounts cannot exceed 50 percent of their purchase 

volumes during 1999. Our intention is to meet customer requirements with product 

manufactured during this calendar year. Depending on the size of the orders we receive, total 

production volumes for 2000 could exceed the forecasted levels reflected in Attachment 6. 

Production of Starting Materials and Intermediates. 3M has previously identified to EPA the 

different raw materials and intermediates (including POSF itself) used in the manufacture of 

POSF-based products. 3M was required to provide 1997 production volumes for several of these 

chemicals under the 1998 TSCA Inventory Update Rule (IUR). Attachment 7 provides these 

IUR production figures, corrected to reflect a recent reanalysis of 1997 production data. The 

Attachment shows 1997 U.S. production volumes for POSF of 4,083,000 lbs. For year 2000, a 

1.5% decrease is anticipated from that number, which would be 4,022,000 lbs. Because the IUR 

submissions only include U. S, production and importation, a hrther adjustment is needed to 

reflect POSF production at 3M's Antwerp facility. After accounting for Antwerp operations, we 

estimate that total worldwide POSF production in 2000 will be 8,100,000 Ibs. 

Production of starting materials and intermediates for POSF-based products will necessarily 

decline very significantly in 200 1 and 2002 because of the substantial scale-down in production 

of the end-products themselves. However, the precise volumes of POSF and its derivatives 

produced during these years will depend on the chemical compositions and quantities of the 

extended phase-out products which 3M continues to manufacture. Once the mix of these 

products is finalized, 3M will be in a position to determine anticipated production levels for the 

corresponding raw materials. 3M will assemble this information if EPA believes it is needed to 

to develop regulations applicable to POSF-based chemistries. 

PROPOSED EXTENDED PHASE-OUT APPLICATIONS 

Process for Selection. To identify product uses for which production would continue aRer the 

end of 2000, 3M screened its entire product line using three criteria: 

1. Does the end-use product provide environmental, health or safety benefits to 

which the fluorochemical component makes a substantial contribution? 

2. Does the end-use product perform a unique or important hnction which is lost 

without the fluorochemical component and is there either no technically 

acceptable substitute available for the fluorochemical or is additional time 

needed to qualify or prove out such a substitute? 

3. Is use of the product specified by a federal or state agency or would 

governmental activities (such as national defense) be affected if the product were 

no longer available? 

Products meeting one or more of these criteria were assigned to the extended phase-out category 

and deemed suitable for production following December 3 1, 2000. 

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Attachment 3 provides background on extended phase-out products identified during 3M's 

screening process. The Attachment sorts these products into three categories based on 3M's 

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July 7, 2000 

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criteria for extending production beyond 2000. Where more than one criterion applies, the 

product has been classified on the basis of the predominant rationale for extended phase-out. For 

each affected product, the Attachment also provides a detailed description of the technological 

complexities or other factors that preclude immediate availability of an acceptable substitute. 

Attachment 4 complements this information by providing CAS numbers, chemical compositions 

and projected volumes for the extended phase-out products. Finally, Attachment 5 indicates the 

intended distribution of the extended phase-out products to different global markets. 

The three Attachments should be reviewed in conjunction with the more detailed use profiles for 

POSF-based products provided in 3M’s May 26, 1999 white paper entitled Fluorochemical Use, 

Distribution and Release Overview. EPA should also note that the CAS names that appear in 

Attachment 4 are those that are specifically tied to 3M’s proposed extended phase-out products. 

Additional extended phase-out products that are identified subsequent to the date of this 

submission may require limited production of chemicals not shown in the CAS names column. 

Attachments 1 and 2 indicate the small volumes that 3M will produce for extended phase-out 

applications during 2001 and 2002 in the aggregate and by product category. Anticipated 

production volumes in 2001 should be 12.3 percent of the projected 2000 baseline on a global 

basis. In 2002, global production should decline to 4.5percent of the 2000 baseline, with no 

production currently anticipated in 2003. 

Need for Further Input on Selection of Extended Phase-out Products. It is important to keep 

in mind that the judgments reflected in Attachment 3, 4 and 5 are preliminary and were based on 

information currently available to 3M regarding the applications in which POSF-based products 

are used. 3M necessarily has incomplete knowledge of the end-use products and processes of its 

customers and, therefore, cannot make definitive judgments about the availability of substitute 

materials or the precise impacts of phasing out specific products. We also made the decision not 

to consult extensively with our customer base until we had reviewed our phase-out plan with 

EPA. For this reason, our screening process has not hlly captured customer views on extended 

phase-out applications. To permit users of POSF-based products or other interested parties to 

address this subject, we would encourage EPA to solicit public comment at the earliest possible 

date. 

Surfactant Properties of POSF-Based Materials. As Attachment 3 illustrates, the great majority 

of the proposed extended phase-out products identified by 3M are in the industrial surfactant 

category, which represents roughly 10 percent of projected Y2000 production of POSF-based 

materials. Surfactants are crucial additives in many formulator applications used widely in 

transportation, construction, electronic, oil and other market segments. They provide value 

through two basic modes of operation. First is their ability to lower surface tension of liquids 

and/or solids. Second is their ability to emulsify and disperse a host of materials. These 

surfactant characteristics are typically achieved at very low concentrations within a formulation 

due to the surfactant’s ability to migrate to interfaces and surfaces. 

The scientific literature documents that the lowest surface tensions attainable are derived from 

the use of fluorosurfactants (perfluoro-containing surfactants). This is because the unique 

physicochemical characteristics of perfluorinated compounds give them greater surface tension 

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July 7, 2000 

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reduction capability than other surfactants, such as silicone or hydrocarbon oils. Accordingly, 

while fluorosurfactants may not be essential in some applications, they are irreplaceable in many 

others. For these applications, 3M is proposing to continue production through 2002 while 3M 

works [CBT]. 

While Attachments 3 and 4 list extended phase-out applications known to 3M at this time, we 

expect that more will be identified as 3M's customer base focuses on the implications of our 

phase-out announcement. To address this possibility, we urge that any regulation developed by 

EPA allow additional extended phase-out uses during 2001-2002 if such uses are identified by 

3M or its customers. To place limits on such uses, this regulation might include an annual cap 

on total production of POSF-based products during 2001 and 2002. Assuming that production 

does not exceed this cap, 3M could market these products for additional uses first identified after 

December 3 1, 2000 if 3M or its customer files a notice with EPA confirming that the use meets 

the criteria for extended phase-out. 

INTRODUCTION OF SUBSTITUTES FOR POSF-BASED PRODUCTS 

At the current time, 3M is planning [CBI.] 

3M STEWARDSHIP ACTIONS DURING THE PHASE-OUT PERIOD 

Environmental Controls. Since 1997, manufacturing releases of perfluorooctanyl chemistries at 

3M's Decatur facility have been reduced by 50 percent for wastewater discharges and 40 percent 

for air emissions. During the phase out of POSF-based products, 3M will continue to implement 

these emission reduction programs. These include source reduction and recycle, off-site disposal 

of designated waste streams, and end-of-pipe treatment. Drying systems have been installed and 

are operating at all 3M manufacturing facilities to recover and reuse POSF. Designated 

wastewater streams are being collected and transported off-site for disposal at permitted 

hazardous waste thermal treatment facilities. These practices will continue during production 

phase-out and additional waste streams continue to be included in this program. 3M will also be 

utilizing carbon adsorption systems to recover POSF from more dilute wastewater streams. 

Systems have been installed and are operating in both Antwerp, Belgium and Decatur, Alabama. 

Carbon adsorption has been shown to be effective in the removal of POSF and POSF based 

compounds. 

Continuation of Research Program As previously discussed with EPA, 3M is committed to 

continuing its ongoing research program on the environmental fate and distribution, ecotoxicity 

and human health effects. We plan to share new data when it becomes available and to continue 

our scientific dialogue with EPA on the interpretation of key studies. 

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July 7, 2000 

We look forward to continuing dialogue with EPA on our phase-out plan. We expect to be 

refining the information in the attachments based on hrther feedback from our own organization 

and customers and will submit updated attachments to EPA as appropriate. “b 

We appreciate EPA’s cooperation on this matter. 

x 

William A. Weppner, Ph.D. 

Director 

Environmental, Health, Safety and Regulatory Affairs 

Specialty Materials Markets Group 

3M Center, Bldg. 236-1B-10 

St. Paul, MN 55144 

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POSF-Containing Chemistry Production Phase-Out 

3000 

2500 

2000 

1500 

1000 

500 

0 

% of 

2000 Baselint 

88 88 0 13U 13U 

0% 

4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 

2000 2001 2001 2001 2001 2002 2002 2002 2002 2003 

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Summary of the Phase-Out Plan for the production of POSFContaining Chemistry 

Attachment 2 

This summary presents total estimated production for 2000, which is useful as a baseline for comparing 

production levels in subsequent plan years. The summary also presents projected production levels for 

2001 and 2002. Extended transition period uses requiring production in 2001 and 2002 are included on 

Attachment 3. 

Total 3M POSF Containinp Chemistry manufactured 

Y2000 Baseline 

Y2000' POSF containing chemistry-pounds produced globally: 

Y2000 POSF containing chemistry-pounds produced in US: 

9,895,500 

6,490,000 

Other Information for Baseline comparison 

1999 POSF containing chemistry-pounds imported into the Us: 

Y2000 POSF containing chemistry-pounds used for FDA applications are 3,532,000 

239,900 

Y2001 

Y2001 POSF containing chemistry-pounds to be produced globally: 1,215,300 or 12.3% of 2000 base-line. 

See categories below for US production numbers. 

Y200 1 POSF containing chemistry-pounds used for FDA applications will be 300,000. 

____ 

Y2002 

Y2002 POSF containing chemistry-pounds to be produced globally: 447,900 or 4.5% of 2000 base-line. 

See categories below for US production numbers. 

Y2002 POSF containing chemistry-pounds used for FDA applications will be zero. 

SORTED BY CATEGORY 

Paper & Packaging Category 

Global 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

US Onlv 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

3,297,200 

zero 

2,670,700 

zero 

Estimation based on Y2000 forecasts from customers before phase-out plan announcement. 

This estimate includes total solid pounds of fluorochemical containing compound and has not been broken 

Imports are not included in 2000 production totals. 3M is presenting 1999 import figures because 

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down to the POSF molecule. 

projections for 2000 are not available. 

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Textile, Leather, and Carpet Treatment Catepory 

This category includes Apparel & Leather, Afrermarket (sold as part of commercial warranty packages), 

Carpet, Fabric & Upholstey, and Commercial Care (consumer and professional) Fabric Protectors. 

Global 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

4,762,900 

zero 

US Only 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

2,356,700 

zero 

Industrial Surfactants, Additives and Coatinw Catepory 

This category includes the External sales of Coatings, Electroplating & Etching Surfactants, Household 

Additives, Insecticides, Intermediates, and Mining & Oil and Internal 3M Applications 

Global 

Y2000 POSF containing chemistry-pounds produced: 

Y200 I POSF containing chemistry-pounds to be produced: 

Y2002 POSF containing chemistry-pounds to be produced: 

US Only 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

Y2002 POSF containing chemistry-pounds to be produced: 

1,501,800 

881,700 

432,600 

1,259,000 

808,400 

428,400 

Fire Fiphtinp Foams Category 

Global 

Y2000 POSF containing chemistry-pounds produced: 

Y200 1 POSF containing chemistry-pounds to be produced: 

Y2002 POSF containing chemistry-pounds to be produced: 

333,600 

333,600 

15,300 

US Onlv 

Y2000 POSF containing chemistry-pounds produced: 203,500 

Y200 1 POSF containing chemist&-pounds io be produced: 

Y2002 POSF containing chemistry-pounds to be produced: 

203,500 

15,300 

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Attachment 7 

2991 -5 1-7 

41 51 -50-2 

3 1506-32-8 

1691 -99-2 

24448-09-7 

423-82-5 

25268-77-3 

F 

salt 12,180 

I-Octanesulfonamide, N-ethyl-I, 1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoro- 31,081 

I-Octanesulfonamide, 1 ,I ,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoro-N-methyl- 48,300 

I-Octanesulfonamide, N-ethyl-l,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoro-N-(2-hydroxyethy1)- 2,149,000 

I-Octanesulfonamide, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoro-N-(2-hydroxyethyl)-N-methyl- 1,861,000 

2-Propenoic acid, 2- 

[ethyl[( heptadecafluorooctyl)sulfonyl]amino]ethyl ester 7,678 

2-Propenoic acid, 2- 

[[( heptadecafluorooctyl)sulfonyl]methylamino]ethyl ester 777,765 

POSF and Core Reactant Product Volumes 

376-14-7 

14650-24-9 

CAS Name 

I-Octanesulfonyl fluoride, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoroI-Octanesulfonamide, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- 

heptadecafluoro2-Propenoic acid, 2-methyl-, 2- 

[ethyl[( heptadecafluorooctyl)sulfonyl]amino]ethyl ester 53,507 

2-Propenoic acid, 2-methyl-, 2- 

[[( heptadecafluorooctyl)sulfonyl]methylamino]ethyl ester 36,327 

1yy7us 

Production as 

Reported in 

1998 IUR 

Submission 

(Ibs) 

3.492.001 

423-50-7 

1997 US 

Production 

based on May 

2000 rework 

(Ibs) 

4.083.00( 

1 -Hexanesulfonyl fluoride, 1,1,2,2,3,3,4,4,5,5,6,6,6-tridecafluoro- 501,634 

I I I I Glycine, N-ethyl-N-[( heptadecafluorooctyl)sulfonyl]-, potassium I 

307-51 -7 

1 -Decanesulfonyl fluoride, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,1 O-heneicosafluoro- 24,171 

07/07/2000 Page 1