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3M and Scotchgard: Voluntary?

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Less than three months before the phase out announcement, 3M vetted a very different proposal to EPA that was not mentioned in its press release. In a presentation by company officials to EPA on March 7, 2000, 3M put forth its concept for a "Fluorochemical Re-engineering Initiative" in which the chemical would be kept on the market, but through "continuous process improvement," they would attempt to achieve exposures one-tenth the current levels. (view entire document)

3M's re-engineering proposal came close on the heels of a "notice of substantial risk," to EPA describing the results of PFOS exposure studies on rats. The studies found significant numbers of deaths even in the first generation of offspring of exposed rats, and other effects extending to the second generation. According to a May 16 internal EPA memo, at the higher doses in this study, all offspring in the first generation died within four days of birth, and at an even lower dose many of the offspring of the second generation died. "It is very unusual to see such second generation effects," wrote the director of EPA's Chemical Control Division. (view entire document)

3M submitted amendments to this rat study stating that increased deaths did not, in fact, occur in the second generation, and a later EPA hazard assessment reports only on the other (non-death) second generation effects. (view entire document)

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last updated: march.27.2009

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