0704- - [5666,5? COMPANY SANITIZED DOES September 17, 2004 ?f NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION By Certi?ed Mail Document Processing Center IN 1 5 6 6 Attention TSCA 8(e) Coordinator Of?ce of Pollution Prevention and Toxics 5m mm A ?Washington, DC 20460 I 1111 8 Re: Information Submission Under TSCA Section 8(e) Dear Sir or Madam: Pursuant to Section 8(e) of the Toxic Substances Control Act Deleted] is submitting information pertaining to the following three substances: 1. perfluorooctanoic acid CAS No. 335-67-1 73;; 2. per?uorononanoic acid CAS No. 375-95?1; and 0% 3. per?uorodecanoic acid CAS No. 335?762 The information we are providing, which is attached to this letter, consists of worker monitoring data that were recently obtained and tabulated by Deleted] . These data re?ect measured levels of the subject chemicals in blood samples taken from workers at the Deleted] facility located at Deleted] . Blood levels were monitored in a total of 281 individuals working on three production lines: a production line for Deleted] in which Deleted] was used as a processing aid; a production line for Deleted] and a production line for Deleted] . In addition, a small number of workers in Deleted] research and development and quality assurance divisions were also included among the 281 individuals sampled. Deleted] believes that the attached information does not rise to the level of ?substantia?? risk? information that must be submitted under TSCA Section for the following reasons: 4' .1 a First, Deleted] believes that the worker monitoring data on PFOA that were :l "f 7 obtained by Deleted] are merely corroborative of information that is already wail known to EPA. We are aware that extensive information has previously been submitt? to the Agency under TSCA Section 8(e) and other provisions of TSCA pertaining to blood levels of PFOA in workers at US. facilities that produce and/or utilize Deleted]. NHL 5737??) 51 Document Processing Center Attention TSCA 8(e) Coordinator September 17, 2004 Page 2 0 Second, Deleted] believes that worker monitoring data gathered from the Deleted] are irrelevant to assessing potential exposures and risks in the United States, because Deleted] employs a unique process for using Deleted] that is not utilized in any facility in the United States. To the extent that differences in blood levels are observed between workers in the United States and workers at Deleted], those differences are likely attributable to the unique manufacturing process employed by Deleted] . 0 Third, to the best of our knowledge, there are no facilities in the United States that manufacture Deleted] . Consequently, blood monitoring data from the Deleted] are irrelevant to assessing risks and/or exposures to workers in the United States. Thus, the worker monitoring data obtained by Deleted] are either corroborative of information that is already well known to EPA and has previously been submitted to the Agency under TSCA Section 8(e) and other provisions or (ii) irrelevant to assessing risks in the United States. As a consequence, the data do not constitute ?substantial risk? infomiation that must be reported under TSCA Section Nevertheless, Deleted] is submitting this information under Section 8(e) to bring these data to the Agency?s attention, consistent with our company?s commitment to product stewardship, and out of an abundance of caution. If you have any questions regarding this submission, please contact me at Deleted] Also, please note that this submission contains con?dential business information that should be protected against public disclosure. A ?sanitized? version of this submission, from which CBI has been deleted is also being submitted herewith. Sincerely, Deleted] Attachment COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION I Worker Monitoring Results for PFOA at the Deleted] PFOA 200 a Number of Workers 100 50 .- 19 6332137421201 0~0.5 1.0~2.0 30"40 50~50 Blood Concentration of PFOA (ppm) PFOA 50 Blood Concentration of 0 PFOA (ppm) 30 . 10 '2'1 0 Average Minimum Maximum COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION Worker Monitoring Results for PFNA at the Deleted] PFNA I 250 200 Number of 240 Workers 150 I 100 50 I I I F?w?l' I I 0 Blood Concentration of PFNA (ppm) I 0 0.5 0.5 1.0 1.0 2.0 2.0 3.0 3.0 4.0 4.0 5.0 5.0 10.0 Blood Concentration of PFNA 0.0 Average Minimum Maximum COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION Worker Monitoring Results for PFDA at the Deleted] PFDA 200 7 - 150 Number of Workers 0 1 0 0.05~0.1 Blood Concentration of PFDA (ppm) PFDA I 0.06 0.05 Blood Concentration of 0.03 0.01 -mu 0 i 0.000 1 Average Minimum Maximum