Proposed

ANPR Approach for

Long-Chain Perfluorinated

Chemicals Action Plan

July 13, 2011

FluoroCouncii _ . Global Industry Council

.- ,1 for FluoroTechnology
Meeting Purpose

Discussthe opportunity to work with EPA to advance

a phased regulatory approach that implements the

LCPFCs Action Plan (''Action Plan") and builds

upon the PFOA Stewardship Program.

• Review EPA/industry partnership success of

the 2010/2015 PFOA Stewardship Program

• Discuss advantages of an ANPR/SNUR

approach as a first step in implementing the

Action Plan

2
PFOA Stewardship Program Overview

• A partnership between EPA and eight major companies

based on voluntary corporate commitments to achieve

global Stewardship Program goals:

o By 2010, achieve a 95% reduction (based on 2000 baseline)

in both facility emissions to all media and product content

levels of PFOA and related chemicals

o Work toward the elimination ofthese chemicals from

emissions and products by 2015

Reduce environmental and

human exposure to PFOA

3
•

•

•

•

FDA Stewardship Program Successes

Annual data reports indicate many participating companies have

already achieved 2010 and/or 2015 goals for PFOA emissions and

product content.

2010 data due in October 2011: expected to indicate significant

success in meeting or exceeding 95% reduction goals.

Through the program, industry has significantly reduced

PFOA emissions and product content and led the

development of alternative chemistries with improved

environmental characteristics.

Industry has invested significantly in:

- R&D - Customer transition support

- New production facilities - Global regulatory clearances

- Emission controls - Process changes and product

reformulation

4
Beyond the Stewardship Program

• The goal ofthe Action Plan is to achieve further

reductions in human and environmental exposures to

PFOA by holding all producers to the same standards

proven to be achievable through the Stewardship

Program.

• The FluoroCouncil supports this goal and is

committed to work with EPA to achieve it through the

Action Plan.

5
= ...

_ ---- -r ,..- --~ -.:---- - ---

ANPR Approach - Overview --------------- ~~------

Builds on the PFOA Stewardship Program and

Begins Implementation ofthe Action Plan

• Would "jump start" implementation ofthe Action Plan

o Sends a strong and early signal that EPA isserious about

using TSCA to control the manufacture and use of these

chemicals

• Announces intent to establish a TSCA Section s(a)(2)

Significant New Use Rule (SNUR) that expands the

current PFAS SNUR to include PFAC substances

• SNUR is a well-vetted regulatory tool that will narrow the

issues for subsequent steps.

6
ANPR Approach - Benefits

•

•

•

•

Begins the process of backstopping the phase-out

underway through the PFOA Stewardship Program

Reduces EPA's ultimate resource burden for

implementing the Action Plan:

o Narrows the scope of later Action Plan rulemaking(s)

o Provides for the collection and assessment of a broad range of

needed information, which will help assure a robust

administrative record to support Action Plan rulemakings

Enables EPA to identify stakeholder positions

(governmental and non-governmental)

Demonstrates progress toward the EPA's Regulatory

Agenda and Priority for ''Assuring the Safety of

Chemicals" 7
Next Steps

• The FluoroCouncil stands ready to assist EPA and

cooperate in the development and implementation of an

ANPR/SNUR approach to address LCPFCs.

• Thank you for your time and consideration.

8
Questions or Comments?

Jessica Steinhilber, FluoroCouncil

202 - 2 49-6737

Jessica_steinhilber@fluorocouncil.com

The FluoroCouncil represents the world's leadingfluoro-technology manufacturers. Our

membership is open to companies that manufacture, formulate or processfluoropolymer

products, fluorotelomer-based products and fluoro-surfactan ts orfluoro-surface property

modification agents. Active members ofthe FluoroCouncil areAsahi Glass Co., Ltd.; Clariant

International, Ltd.; Daikin Industries, Ltd.;and DuPont Company.

9