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Reporting Guidance Clarifications for the 2010/15 PFOA Stewardship Program Progress Reports

The comments below summarize EPAís clarifications and recommendations for the upcoming Stewardship Program progress reports on reductions achieved through the end of 2006. They are based on EPAís review of the baseline year data submitted in 2006 and discussions with some participants. These comments are intended to improve consistency in reporting across all the participating companies, and thereby enhance utility of the data and information documenting achievements made under the Stewardship Program. Sections of the guidance document (PDF)   (22 pp., 136 KB, About PDF) referred to in the comments are italicized in parenthesis.

General Comments

1. To help standardize the company reports, it is important that companies use official program forms in lieu of individual company forms. EPA encourages additional reporting by individual companies where official program forms do not provide sufficient opportunity for reporting. (Appendices C, D, E and F)

2. Note that Appendices C and D ask that the information for the chemical, which is part of the Stewardship Program, be reported per facility, not per company. (Appendices C and D)

3. Companies in the Stewardship Program agreed to work towards the elimination of PFOA, PFOA precursors and related higher homologues from products. As the concentrations of these chemicals in products are reduced, their total mass, if product volumes are constant, will also diminish. To make the relationship between concentration and mass more transparent, EPA recommends that the companies continue reporting product content as average concentrations in public reports, but report both the concentration and mass in the CBI reports. Itís also important that companies continue reporting ranges of production volumes in public reports, but provide site specific and product specific production volumes in CBI reports. (Appendices D and F)

4. EPA recommends that chemical concentrations in release, treatment, and recycle streams, as well as that of products be reported as numerical values. If the measured value is less than the analytical method level of detection (LOD), EPA recommends that LOD be used in subsequent calculations for the purpose of describing progress toward Stewardship Program goals. Similarly, if the measured value is greater than the LOD but less than the analytical method Level of Quantitation ( LOQ), EPA recommends that the numerical value be reported, but LOQ be used in calculations for the purpose of describing progress toward Stewardship Program goals. It is important that the procedures used to determine the LOD and LOQ be fully explained and any appropriate publications be cited. (Appendices C, D, E and F)

5. Process diagrams are very useful for understanding the material balance and environmental releases. EPA recommends that companies include in their reports diagrams such as (1) a supply chain diagram showing raw material, intermediates and associated final commercial products, and US EPA September 2007 (2) a block flow diagram showing major unit operations, and feed, intermediate, and effluent streams, including release, recycle, and disposal streams. (Appendix C, Section III)

6. Some submitters specified in the submissions the approach used (e.g. mass balance, engineering calculation) associated with the release, treatment, and recycle amounts. EPA recommends that submitters also include data sources and details on the how the approaches were applied. For example, sample calculations for estimating the amounts of release, recycle, and treatment streams, as well as product content would be very useful. (Appendix C)

7. It is important that companies report releases for individual media for each site, as explained in Appendix C. (Appendix C)

8. EPA recommends that companies provide destinations of exports and sources of imports (country and company) for the chemicals subject to the reports. (Appendices C and D)

9. EPA recommends that the programís annual progress reports contain descriptions of any relevant modifications of facilities covered by the program, including descriptions of processes and operating conditions for recovery and destruction of PFOA, PFOA precursors, and higher homologues. (Appendices C and D)

10. EPA recommends that companies include reporting of manufactured amounts and product content for each commercial product type and grade for each individual site. (Appendix D)

Fluoropolymers

1. EPA recommends that companies also report on non-AFD (Aqueous Fluoropolymer Dispersion) products in addition to AFD products. (Appendices C and D)

2. EPA recommends that companies report the chemical content of commercial products on a dry basis in addition to a wet basis to allow a site overall mass balance of the chemical. (Appendix D, Section IV)

3. EPA recommends that companies provide a destruction and recycle index, consisting of the fraction of PFOA used that is destroyed or recycled. Furthermore, a P2 index consisting of the ratio of PFOA used to product manufactured would be very useful in determining how PFOA reductions are being achieved, i.e., by recycling, destruction, or by actual reductions of PFOA used. (Appendices C and D)

Telomers

1. EPA recommends that companies account for all precursors that can break down to PFOA, direct and indirect, in releases and product content. Furthermore, in completing the program forms, EPA recommends that the data entry in Appendix C, Section III for amount manufactured include the amounts for all PFOA precursors that were accounted for in releases and product content. (Appendices C, D, E and F)


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