From: Christian Richter [crichter@thepolicygroup.com]

Sent: Thursday, June 03, 2010 12:02 AM

To: Mulrine.Phil@epamail.epa.gov

Cc: jhannapel@thepolicygroup.com; Marinshaw, Richard; Burns, 

 Sandra

Subject: re: PFOS Phaseout

Attachments: 171172+CHROMKLAD+EMS[1].pdf; 187473+Minimist+Liquid[1].pdf; 

187473+Minimist+US+Jan+09[1].pdf

Phil: 

 

Here are some follow up MSDS sheets for the MacDermid alternatives that 

may also be helpful. Just let me know if additional information, again, 

might be helpful. 

 

Appreciate it. 

 

Best regards, 

 

Christian

 

From: "Christian Richter" <crichter@thepolicygroup.com> 

Sent: Wednesday, June 02, 2010 11:45 PM 

To: Mulrine.Phil@epamail.epa.gov 

Subject: re: PFOS Phaseout 

 

Phil: 

 

I wanted to get back to you on two items: (1) preliminary info on PFC 

alternatives in order to get feedback on what else may be helpful from 

the larger supplier community, and (2) status of information on actual 

vs. allowable concentrations of Cr6 for job shops. Re the latter issue, 

we should have a better perspective by tomorrow sometime from a consensus 

of industry engineering experts. 

 

On the PFC issue, let me know if the info below from additional suppliers 

may be meaningful. We may not be able to provide more detailed

information at this point, but other suppliers may be able to get 

back to us as well in the coming days. I had sent it out some of our

NASF committee members when I received it from you. 

 

Best regards, 

 

Christian 

 

_______________________ 

 

· List of manufacturers or suppliers of substitutes for long-chain PFOS 

 

o MacDermid - Minimist Liquid (decorative chrome), Chromklad EMS (hard 

chrome) 

o Atotech - Fumetrol 21 

o EPi - E-mist 7 

o Uyemura - Non-Mist L 

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o Haviland - CRV-1 

 

PFOS Mfg Info Request.doc 

 

· For each manufacturer and each product that is a substitute for longchain PFOS: 

o Product name - MINIMIST LIQUID, CHROMKLAD EMS 

o Material safety data sheet (MSDS) 

o General chemical formulation, category or family of chemical, or some 

other term for classifying the chemical (if not specified on MSDS) - 

Both are anionic fluorinated surfactant 

o Unit cost (e.g., $ per gallon, if liquid; $ per pound, if solid or 

powder) 

varies by container size and geography - $130 - $150 per gallon 

o Working concentration in plating bath (e.g., ounces per gallon of 

plating tank solution) 

§ If it differs by process type (e.g., hard Cr vs. decorative Cr),

provide concentration for each process 

o Lifetime or replenishment rate (i.e., some measure of how long it 

persists in the bath or how often must it be added to bath) 

§ If it differs by process type (e.g. hard Cr vs. decorative Cr), 

provide concentration for each process 

TDS ATTACHED 

 

o Process applications and limitations (e.g., can it be used in all 

plating baths, can it be used in Cr anodizing baths, can it be used in 

black chromium plating baths, etc.) Minimist is for decorative chrome, 

EMS for hard chrome and black chrome 

o Toxicity or other information that demonstrates why it is better for 

the environment than long-chain PFOS 

 It is six fluorinated carbons that can't break down to PFOA. None of 

the components present in this material at concentrations equal to or 

greater than 0.1% are listed by IARC, NTP, OSHA or ACGIH as a carcinogen. 

o Comparison of annual cost vs. annual cost for long-chain PFOS fume 

suppressant 

§ If appropriate, differentiate by type of process (hard Cr, decorative 

Cr, etc.) 

Comparable for large users. Up to 20% increase for small or infrequent 

users due to chemical breakdown. 

 

From: Mulrine.Phil@epamail.epa.gov 

Sent: Thursday, May 27, 2010 10:37 AM 

To: crichter@thepolicygroup.com 

Subject: PFOS Phaseout 

 

Christian, 

 

 Previously you had mentioned that you could obtain some 

information on alternatives to PFOS fume suppressants. The attached file 

summarizes the information we think we need to collect on alternatives to 

PFOS as a fume suppressant in chromium electroplating. We think we need 

to try to get all of the information listed. If we cannot, we can deal 

with it, but we should try to get it anyway. We are going to need to 

estimate nationwide costs, address the feasibility of the substitutes, 

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and demonstrate that they are better for the environment than are longchain PFOS. To do that, we are going to need some real data. 

 If you cannot provide it, could you at least provide names and 

contact information for the vendors of the products that account for most 

of the market. We could then contact the vendors and request it from 

them ourselves. Maybe you could contact them and give them a head's up 

before we do. If it comes down to it, we can always use Section 114 

authority to get the information. We can figure out how to deal with any 

information that is considered proprietary.

 

 Please let me know if you have any questions or comments. 

Thanks again, 

Phil 

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