## Proposed ANPR Approach for Long-Chain Perfluorinated Chemicals Action Plan July 13, 2011 

## FluoroCouncii

_ . Global Industry Council .- ,1 for FluoroTechnology

# Meeting Purpose Discuss the 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 im pl ementing the Action Plan

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## PFOA Stewardship Program Overview
• A partnership between EPA and eight major companies base d on voluntary corporate commitments to achieve global Stewardship Program goals: o 

### B y 2010, 

### ac hieve a 95% reduction (based on 2000 

### baseline) in bo th facility emiss ions to all media and product content levels of PFOA and related chemicals o 

### Work toward the elimination of these chemicals from emiss ions and products by 2015 

### Reduce environmental and human exposure to PFOA 3

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# 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 of the 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.

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# ANPR Approach - Overview

---------------**~~------** Builds on the PFOA Stewardship Program and Begins Implementation of the Action Plan
• Would "jump start" implementation of the Action Plan o Sends a strong and early signal that EPA is serious 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 Ru le (SNUR) that expands the current PFAS SNUR to include PFAC substances • SNUR is a well-vetted regu latory 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 t ime and cons ideration.

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# Questions or Comments? Jessica Steinhilber, F luoroCo uncil 20 2 - 2 49 -6737 J

essica_steinhilber @fluoroco u nci l .com T

he F luoroCouncil repre sents th e world ' s leadingfluoro-technology manufacturer s. O ur member ship is open to companies that manufa cture, formulate or proce ssfluoropolymer produ cts, fluorotelomer -based products and fluoro- surfactan ts or fluoro- surface property modification agents. Active memb ers of the F luoroCouncil are Asahi Glass C o., Ltd.; Clariant International , Ltd. ; Daikin Indu stries, Ltd.; and DuPont C ompany.
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