Abstract |
This paper and accompanying appendices provide an overview of the use, distribution and environmental release of sulfonyl-based fluorochemicals (FCs) produced by 3M Company. The paper and appendices are intended to present a preliminary review of FC pathways for human and environmental exposure from the time these materials leave the control of 3M through their end-use and/or disposal. This assessment is primarily qualitative and is based on available information within 3M and the experience and judgment of 3M's FC marketing and technical support personnel. 3M undertook this review for two purposes: (i) to support initial judgments about the exposure scenarios of greatest significance and set priorities for in-depth quantitative evaluation of the use and disposal profile of selected FC products; and (ii) to guide and set priorities for product reformulation, customer communication and other product stewardship activities. Although the review is preliminary and qualitative, it may be useful in providing EPA and other agencies with an introduction to FC exposure issues. 3M has already taken a range of actions based on this preliminary review. These include product and environmental stewardship initiatives to reduce FC exposures and releases at 3M and downstream manufacturing locations. In addition, 3M is in the process of developing a comprehensive exposure assessment plan which will include further modeling, monitoring and product use simulations. Preliminary work to support this assessment is already underway. A summary of 3M's stewardship initiatives and exposure assessment workplan is presented in the final section ofthis paper. Because the information in this paper and appendices is preliminary and qualitative, it contains some worst- case estimates of potential exposure and release levels. For this reason, the information in the paper should be used with caution. SM expects that more realistic estimates of human exposure and environmental release levels will be available once its exposure assessment plan is implemented. |