~ I FLUOROCHEMICAL USE, DISTRIBUTION AND RELEASE OVERVIEW I Prepared by 3M Company May 26,1999 TABLE OF CONTENTS & gg Introduction .................................................................................................................................... 3 The 3M ECF Process ..................................................................................................................... 3 3M Production of Sulfonyl based Fluorochemicals .................................................................... 4 3M Sulfonyl based Fluorochemical Products ............................................................................. 5 Profile of Major Product Categories ............................................................................................ 7 Surface Treatment Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Paper and Packaging Protectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Performance Chemicals ..................................................................................................... 10 Ongoing and Proposed Exposure Assessment and Stewardship Initiatives ........................... 11 Chart 1: POSF Fluorochemical Reaction Tree ........................................................................ 13 Table 1: Fluorochemical Glossary ............................................................................................. 14 Chart 2: Product Building Block ............................................................................................... 15 Table 2: Estimated Fluorochemical (FC) Usage by Application ............................................ 16 Table 3: Features of Fluorochemical Surfactants .................................................................... 17 Appendix 1 PCP Carpet Business . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 49 Appendix 2 PCP Home Textile Business.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SO 100 Appendix 3 PCP Apparel and Leather Business.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . .. lOl 152 Appendix 4 3M Aftermarket Application and Retail Consumer Business . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153 194 Appendix 5 Performance Chemicals.. . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .195 326 Appendix 6 Paper and Packaging Business.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .327 347 000004 2 FLUOROCHEMICAL USE, DISTRIBUTION AND RELEASE OVERVIEW 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 of this 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. 3M expects that more realistic estimates of human exposure and environmental release levels will be available once its exposure assessment plan is implemented.

The 3M ECF Process FCs are components of several important 3M product lines due to their unique and useful properties. As components of products, they repel both water and oil, reduce surface tension much lower than other surfactants, act as catalysts for oligomerization and polymerization, and function where other products would rapidly degrade.

3M Company utilizes a process known as Simons Electra Chemical Fluorination (ECF) to synthesize organofluorine molecules. In this process, organic feedstocks are dispersed in liquid, anhydrous hydrogen fluoride, and an electric current is passed through the solution, causing the hydrogen atoms on the molecule to be replaced with fluorine. The predominant components of the products created by this process have the same carbon skeletal arrangement as the feedstock used, but with all of the hydrogen atoms replaced by fluorine. However, fragmentation and rearrangement of the carbon skeleton can also occur and significant amounts of cleaved, branched and cyclic structures may be formed. The degree of fluorination of the organic feedstock is also dependent upon the specific carbon chain length of the feedstock and parameters of the ECF process such as electrical current and the length of time the process is run. It is possible to synthesize fully fluorinated or perfluorooganic molecules where all of the hydrogen atoms of the hydrocarbon feedstock have been replaced by fluorine atoms. Using these perfluorooganic molecules as basic building blocks, unique chemistries can be created by further reactions with functionalized hydrocarbon molecules.

000005 3 3M built the first manufacturing pilot scale ECF process in 1949 and has continued to develop and improve the Simons ECF process for the production of fluorochemical products. Currently, 3M has three manufacturing sites in the United States using the ECF process (Cottage Grove (pilot production only), MN, Cordova, IL, and Decatur, AL). FC production using the ECF process occurs outside the United States at 3M's facility in Antwerp, Belgium.

3MProducLkm of Suffon vl 6asedF/ crrochemicals 3M has produced sulfonyl based fluorochemicals commercially for over 40 years using the ECF process. A basic building block of such products and the highest production volume fluorochemical3M manufactures is perfluorooctanesulfonyl fluoride (POSF). POSF is produced in the United States primarily at 3M's Decatur facility in quantities of around . The starting feedstock for producing POSF is 1 octanesulfonyl fluoride.

Reaction I c& 17So2F + 34W e e > c8 Ft7S02F + 17 HZ ECF 1 Octanesulfonyl Fluoride Perfluorooctanesulfonyl fluoride (POSF)

The electrochemical fluorination process yields about 34% 40% straight chain (normal) POSF, and a mixture of byproducts and waste of variable composition. Because of slight differences in process conditions, raw materials, and equipment, the mixture produced by the electrochemical fluorination process varies somewhat from lot to lot and from plant to plant. The product that results f? om electrochemical fluorination is thus not a pure chemical but rather a mix of isomers and homologues.

During production, byproducts and waste products are formed. The volatile waste products, such as perfluoromethane, are vented to the atmosphere, but a program is underway to capture and destroy these releases by thermal oxidation. The tars formed in the process are incinerated at 3M corporate hazardous waste incinerator. The byproducts, many of which are incompletely fluorinated with hydrogen atoms still present, can be recycled back into the ECF process or are partially degraded in stabilization processes, and eventually discharged to controlled, in house, wastewater treatment systems. The treatment sludge is either landfilled or land incorporated. Some of the non POSF byproducts are recovered and sold for secondary uses.

POSF is itself a commercially viable product, and in 1997 was sold in quantities of approximately for use as an industrial raw material (mainly outside the US). However, the primary use of POSF is within 3M, where it functions as an important intermediate in the synthesis of substances used in many other 3M fluorochemical products. The majority of internally consumed POSF is used to produce functionally derivatized fluorochemicals and high molecular weight polymeric products. Table 1 identifies POSF based fluorochemicals, their acronyms, chemical names, and formulas. To a lesser extent, some homologues of POSF, [CnF( 2,,+ l) S02F where n= other than 81, principally perfluorohexanesulfonyl fluoride, are also intermediates in the formation of other 3M products.

Perfluorooctane sulfonic acid (PFOS) will result from the chemical or metabolic hydrolysis of POSF derived FCs. Under appropriate conditions, the perfluorooctane sulfonate anion can form salts with monovalent metalliccations. Current information indicates that PFOS or its salts cannot be broken down further 4 000006 chemically under normally occurring environmental conditions. Therefore PFOS is the ultimate degradation product from POSF derived fluorochemicals and will generally persist in that form. PFOS is also a commercialized product used for a variety of surfactant applications (mainly fire fighting foams and coating additives). 3M sells approximately Using POSF as a basic building block, unique chemistries can be created by derivatizing POSF through the sulfonyl fluoride moiety of the molecule using conventional hydrocarbon reactions. Charts 1 and 2 outline the general classes of fluorinated materials made by 3M. The major intermediates are represented by the trunk of the "tree" in Chart 1. POSF is reacted with methyl or ethyl amine to produce either N methyl or N ethylpeffluorooctanesulfonamide (FOSA). FOSA is subsequently reacted with ethylene carbonate to form either N methyl or N ethylperfluorooctanesulfonamidoethanol (FOSE). The FOSA and FOSE intermediates are the principal building blocks of 3M's product lines. By poundage, methyl fose based intermediates and products slightly predominate over ethyl fose based materials.

The secondary reactions producing all of these derivatives are single or sequential batch processes that do not necessarily produce pure products. There may be varying amounts of fluorochemical residuals (unreacted or partially reacted starting materials or intermediates) that are carried forward to the final product. Examples of such residuals include PFOS, n methyl and n ethyl FOSA and N MeFOSE and N Et FOSE alcohols. Typically, where present, these residuals can be found at a concentration of l 2% or less in final products and, in the aggregate, represent roughly l 2% of total FC production volume. (FC residuals in 3M products have the potential to degrade or metabolize to PFOS.) In addition, during product use or disposal, the non. ffuorochemical moieties added to the sulfonyl fluoride group of POSF can also be removed through a variety of degradation processes (chemical, environmental and metabolic). In such instances, the fluorochemical . species which is ultimately produced as a result of such degradation will generally be PFOS as well.

3MSulfonyf basedFlaorocltemicajproduc&

The 3M Chemical product lines that use POSF based fluorochemicals are summarized below. In some cases, 3M manufactures the final commercialized product. In other cases, 3M sells a fluorochemical which another company incorporates into its final product. (Product lines using fluorochemicals which contain no sulfonyl groups are not listed).

POSF derived fluorochemicals (polymers and monomers) are formulated with water or solvent, with the FC component (or FC solids) representing percent of the formulation. Total U. S. production of FC solids across 3M's product lines is about . 3M produced FC solids represent plus of the total production of sulfonyl based fluorochemicals in the U. S. The breakdown of 3M FC production into different product categories is shown in Table 2.

Surface Treatments (High Molecular Weight (MW) polymers or formulated products Carpet Protector with low percentages of non polymeric FC solids)

Fabric/ Upholstery Protector Apparel and Leather Protector Protective Products for After Markets and Consumer Application Paper and Packaging Protectors (Phosphate esters or high MW polymers) Food Packaging 5 Paper Products Performance Chemicals (Low MW chemical substances) Fire Extinguishing Foam Concentrates Mining and Oil Surfactants Electroplating and Etching Bath Surfactants Household Additives Chemical Intermediates Coatings and Coating Additives Carpet Spot Cleaners Insecticides Raw Materials Surface treatment products for carpets, textiles and apparel are typically sold under the ScotchgardB tradename; 3M markets its paper and packaging protective products under the Scotchban@ tradename; and some performance chemicals are sold under the Fluorad@ tradename.

Surface Treatment Products. 3M fluorochemicals produced for surface treatment applications provide soil, stain, and water resistance to personal apparel and home furnishings. The great bulk of these products are manufactured as high molecular weight polymers although some surface treatment products used for aftermarket and consumer spray application contain a significant fraction of unpolymerized FC components. Polymeric surface treatment products are primarily N MeFOSEA based; the fluorochemical is polymerized with urethane, acrylate and/ or adipate reactants. Such protective products function through the fluorocarbon moiety on the polymer lowering the surface energy of the material to which they are applied.

Paper Protectors. The 3M paper protectors are used in food packaging and commercial applications. They can be divided into two general classes of chemistries. One class consists of mixtures of mono, di and tri phosphate esters of N EtFOSE alcohol, roughly in the proportions of lo%, 85% and 5% percent, respectively. The other class is N MeFOSEA acrylate copolymer. Applied to paper, the per fluorocarbon moiety in these classes of products has the effect of lowering the surface energy of the individual paper fibers. This lowered surface energy greatly contributes to the holdout of low surface energy liquids such as greases and oils.

Performance Chemicals. POSF derived chemistries used as performance chemicals are relatively low molecular weight (GO0 daltons) surface active materials and monomers. Some of these chemicals are sold by 3M, or incorporated by 3M customers into formulated products, for use as surfactants in a range of industrial or consumer applications. Other performance chemicals are used as intermediates from which 3M or its customers make other finished products. Such fluorochemical intermediates can be covalently bound to a variety of polymeric hydrocarbon backbones to make higher molecular oligomeric or polymeric products with unique performance characteristics.

POSF derived performance chemicals with fluorochemical surfactant properties differ greatly from conventional hydrocarbon and silicone surfactants. In most systems they are far more efficient in reducing surface tension to levels that are unreachable with other types of surfactants. In some aqueous systems, surface tensions as low as 1.5 to 16 dynes/ cm can be attained. The fluorochemical surfactants normally produce these extremely low values at concentrations as low as 100 parts per million, or less. Equally important is the fact that certain of these fluorochemical surface active agents are stable and effective in many extremely hostile 6 000008 environments, including strongly acidic, strongly alkaline and even strongly oxidizing systems. Table 3 summarizes the features of fluorochemical surfactants.

Another unique physical characteristic of certain POSF based performance chemicals is their ability to form tough, yet resilient foams. Such foams usually contain low molecular weight fluorochemicals (including PFOS) and have been formulated to resist the action of high temperature or aggressive chemicals and vapors. These formulations have found commercial application in suppressing flammable liquid, chemical and organic fires or toxic and obnoxious vapors and odors.

Profiie ofMaior Product Cafepories The Appendices to this paper provide detailed profiles of each of the major use categories for sulfonyl based FCs. For each use category, the Appendices present:

l Chemical composition information for 3M products.

l A description of the relevant business, including the scope of FC usage and distribution and location of key customers.

l A synopsis of use and distribution patterns, including potential exposure pathways during the initial application of FCs by 3M's customers, potential environmental release scenarios and opportunities for exposure during end use of products to which FCs are applied.

Key information about each use category is highlighted below.

Surface Treatment Products l These products provide soil resistance and repellency (fluorochemical products). Industrial, non retail customers for products in this class consist of( i) carpet manufacturers and fiber producers who serve the markets for residential, commercial and transportation flooring; (ii) textile mills and commission finishers who produce upholstery fabric for residential furniture, home decor items such as slipcovers, mattress pads and shower curtains, and automotive, truck and van interiors or produce non woven fabrics for use in medical or industrial applications; and (iii) textile mills, leather tanneries, finishers and chemical formulators who treat fabric and leather used for garments, footwear, accessories and non garment functional fabrics.

l These products consist of polymeric FCs with high molecular weights. Industrial, commercial and consumer exposure is primarily to polymeric substances, although most of the 3M products contain low amounts of monomeric FC residuals (typically at 1 percent or lower levels) to which some exposure may occur.

l Upon distribution to mills, fiber manufacturers or other customers, the 3M surface treatment product is typically mixed with other additives and diluted. It is then applied to uncut fiber, textile or leather raw materials. Application methods include spray, foam, pad or co application. Depending on the market segment, the application process occurs in an enclosed or open operation. In the latter case, mill production workers could have inhalation 7 000009 and/ or dermal exposure to FCs although such exposure would be predominantly to polymers. Some additional exposure may occur during processing operations such as drying, shearing, cutting and shipping although exposure levels should be low.

l Losses of FC polymers to the environment are expected during 3M customer operations. These losses could involve discharges of process wastewater and air releases during initial application of surface treatment formulations to uncut carpet, fiber, fabric or leather. Additional wastes (typically solids coated with FC polymers) are created during cutting, shearing and other packaging operations and are typically landfilled or recycled. Total FC losses during downsteam operations will vary by application but it is estimated that they could range between l The end use of consumer articles is another source of FC losses to the environment. For example, vacuuming and cleaning of carpets is estimated to result in substantial removal of the FC treatment over time; carpet containing FC coatings is also landfilled upon end of life disposal. Similarly, FC losses to the environment are also expected in wastewater from dry cleaning and laundering of garments, upholstery and leather goods and from landfilling of these items after they are discarded.

l 3M surface treatment products have extensive aftermarket applications and are distributed through retail and commercial channels for direct treatment of upholstery, carpet, auto interiors, apparel and leather by individual consumers or professional applicators.

l Retail products in this category are aerosol can spray cleaners and protectors for residential use. These products are manufactured by independent non 3M facilities under contract with 3M and are distributed through grocery, hardware and autoparts stores and other retail outlets. A variety of formulations are manufactured for this market. Typically, they include non polymeric fluorochemical salts and residuals at levels of between . These have the potential to degrade to PFOS. These products are intended for occasional home use only.

l Commercial 3M surface treatment products are marketed to (i) commercial cleaning services and (ii) commercial film processing facilities. Products in the first category are liquid, water based materials applied through low pressure or paint type spray equipment to upholstery, carpet and other surfaces in homes, commercial buildings or retail furniture outlets. These products contain non polymeric FC solids and residuals in concentrations of between . The second class of products includes liquid, photocurable coating for film negatives which is typically machine applied at commercial film processing facilities.

Paper andl? ackagh g Protectors l 3M markets fluorochemical sizing agents to the packaging and paper industries. These products impart grease, oil and water resistance to paper and paperboard substrates. They are used for food contact applications (` plates, food containers, bags and wraps) and non food applications (folding cartons, containers and carbonless forms and masking papers).

8 ooooio l Fluorochemical sizing agents are applied to paper and paperboard substrates predominantly by paper mills which treat paper fibers and, to a much lesser extent, by converters who transform paper and/ or paperboard into wraps, bags or cartons for desired end uses. Application methods vary but approximately 75 percent of paper mill use of these products occurs via the size press. The fluorochemical product received by 3M customers is typically diluted in a starch/ water solution and applied in a concentration to the paper web, which is then dried to evaporate the water and converted into rolls for shipment. Mix preparation, treatment of the paper web, and conversion are all carried out in open systems although fluorochemical exposure to workers is generally considered to be limited because of the dilute form of the sizing mixture and predominance of high molecular weight FC esters or polymers. Some loss of the fluorochemicals to the environment occurs as a result of spillage, cleanup and releases during the opening, rinsing and recovery of FC totes or drums. Environmental media for FC releases include wastewater and air (for losses during papermaking) and landfills (for disposal of end use paper products).

l 3M's food packaging products include a high molecular weight phosphate ester produced using N EtFOSE and an acrylate copolymer based on N MeFOSEA. Both of these products are regulated by the Food and Drug Administration (FDA) for direct food contact under 21 C. F. R. 176.170. The first product has been subject to considerable dialogue between FDA and 3M as a result of a petition for approval for microwave popcorn applications filed by 3M. In a risk assessment recently submitted to FDA in connection with this petition, 3M presented analyzes indicating that PFOS could be formed in vivo as a result of the hydrolysis of certain product components and the metabolic conversion of FC residuals. '

l 3M's grease, oil and water repellant products for non FDA applications are similar in composition to its food contact products. Consumer exposure to the FC residuals is expected to be minimal because use scenarios for paper and packaging products containing them involve very occasional dermal contact.

`Environ Corporation, Revised Interim Safety Assessment of FC 807 and 807A: Two Fluorochemical based Indirect Food Additives, January 25, 1999. 9 000011 Performance Chemicafs l Products in this category are distributed for a variety of specialized industrial, commercial and consumer applications, often where the surfactant properties of fluorochemicals offer significant benefits. Many of these products are low molecular weight POSF derived chemistries; some are fluorochemical intermediates covalently bonded to a variety of polymeric hydrocarbon backbones. Since these products tend to serve niche markets, volumes are generally small.

l Fire Fighting Foams. Light Water@ and ATCB are trademarks for 3M products that are aqueous film forming foams (AFFF) and alcohol resistant concentrate (AR AFFF) used to suppress and/ or extinguish flammable liquid fires and suppress flammable liquid and toxic chemical vapors. The great bulk of these products are sold to "fire fighters" who mix the concentrate with water to form a foam and apply it to the tire or flammable liquid either manually or through an automated system. User categories for the foams include chemical and petroleum plants, fire departments, vessels, off shore drilling platforms, the military, and environmental remediation companies. The 3M foam products contain low concentrations which is typically present at levels of in the foam as applied. After application, the foam is disposed of, typically through wastewater treatment, but uncontrolled releases to surface water or land are known to occur.

l Mining and Oil Surfactants. 3M sells surfactants to copper and gold mines to increase wetting of the sulfuric acid or cyanide that leaches the ore, enhancing the amount of metal recovery. Oil well service firms and oil companies also use these surfactants in a "well stimulation" formulation that is injected into wells to enhance oil or gas recovery. These `products contain low molecular weight FCs present at low levels in the range of l Metal Plating and Electronic Etching Baths. Users of 3M surfactants in this category include chrome and plastic preplate etchant platers seeking to suppress oxidizing mist for purposes of worker protection. 3M surfactants are sold either as powders to formulators or as liquids directly to platers. Electronics manufacturers also add 3M surfactants as strong acids in order to etch precise patterns in a silicon wafer or a printed circuit board. The 3M products are . As distributed to formulators, these products typically contain FC solids at levels of or higher but are diluted down to concentrations of when added to metal plating or electronic etching baths. Because of the presence of strong acids and other corrosive materials, workers who prepare and apply the baths normally use personal protective equipment. Disposal of the spent baths is either to wastewater treatment facilities or to hazardous waste landfills or incinerators when the baths qualify as hazardous waste for purposes of RCRA.

10 000012 l HouseholdAdditives. 3M surfactants are now (or previously have been) sold to a variety of formulators to improve the wetting of water based products marketed as alkaline cleaners, floor polishes, photographic film, denture cleansers and shampoos. Several of these products (alkaline cleaners, floor polishes, shampoos) are (or previously were) marketed to consumers; some products are also sold to janitorial and commercial cleaning services. Some of the alkaline cleaners are spray applied and could result in inhalation or ingestion exposure. The primary exposure route for other products is dermal. The 3M surfactants are As supplied to formulators, the 3M products contain in the range of FC solids but are then heavily diluted and are present in final products at extremely low levels l Intermediates. 3M sells limited quantities of fluorochemical intermediates which are combined with other monomers to produce polymers. The intermediates sold by 3M in the U. S. include, fluorinated alkyl acrylate and fluorinated alkyl alcohol. Polymers produced by 3M customers are believed to have trace levels of FC residuals.

l Coatings and Coating Additives. 3M sells fluorochemical polymer coatings and coating additives which are used as received or diluted with water or butyl acetate to impart soil or water repellency to surfaces (including printed circuit boards or photographic film). These polymers contain FC residuals in low levels (typically 4% or less). Other formulators add 3M fluorochemical polymers as a thickener to aqueous coatings used to protect tile, marble and concrete. Products in this class have some distribution tu commercial and consumer channels.

l Carpet Spot CZeaner. 3M supplies a non polymeric fluorochemical to formulators of carpet spot cleaners in which the fluorochemical provides stain and soil resistance. These products are marketed to consumers in pump and aerosol cans for spray application to carpets. The FC component of these products is present at levels of l Insecticides Raw Materials. The 3M products are processed by 3M customers into active ingredients in bait stations for leaf cutter ants, pharoah ants, cornfield ants and a variety of household ants. These products are used mainly in commercial and industrial applications. The fluorochemicals are present in the pesticide formulation at levels of On~ okp and Proposed Exposure Assessment and Ste wardship IniZa~* ves Based on the results of its initial product use, distribution, and release overview, 3M has undertaken or is planning a variety of stewardship and exposure assessment initiatives intended to better characterize the highest priority human and environmental exposure pathways while taking initial steps to minimize exposure and release levels for products containing PFOS or PFOS precursors.

11 000013 3M has undertaken extensive research and development programs to reengineer POSF based products to reduce PFOS and precursor residuals and ultimately to transition to chemistries with lower accumulation potential.

3M has updated fluorochemical based MSDS's and has begun an industrial hygiene program with customers aimed at helping to promote improved use and handling of fluorochemicals and reduction of occupational exposures where appropriate. As part of this program, 3M has volunteered to make available its industrial hygiene professionals for qualitative workplace assessments at customer facilities. 3M is also conducting use simulation studies to determine potential consumer exposure levels for FCs released during spray application of surface treatment products marketed to consumers.

Exnosure Assessment Plan Overview Building on 3M's initial assessment a plan also has been developed to assess potential environmental exposure pathways associated with the manufacture, use and disposition of major 3M fluorochemical products. A detailed description of all the exposure/ product stewardship initiatives is beyond the scope of this paper but the four principle components are as follows:

1) The characterization of fate and transport properties is being addressed in multiple steps. The specific projects planned and/ or initiated to characterize fate and transport properties of fluorochemicals are:

a> Physical/ chemical properties testing of persistent fluorochemical degradation products as well as selected fluorochemical products. This includes (where applicable): melting point, boiling point, vapor pressure, disassociation constant, hydrolysis, water solubility, air/ water partition coefficient, octanol/ water partition coefficient, soil/ water partition coefficient, bioconcentration in fish.

b) Photodegradation studies 4 Atmospheric chemistry evaluation d> Studies to assess aerobic and anaerobic biodegradability e> Development of appropriate models for the prediction of physical/ chemical properties of fluorochemicals not tested.

2) Using the initial estimates in the attached assessment and sales data from 1997, releases from manufacturing, the supply chain, use and disposal at all steps are being estimated for the products identified as important. Release data is also being determined by sampling and analyses of 3M manufacturing plant process wastes and effluents. In addition to providing the information necessary to assess distribution and exposure, release estimates will aid in determining sampling sites and substantiate results from sampling. It is anticipated that this effort may also identify those fluorochemicals which require further analysis of fate, transport and exposure.

3) Modeling and sampling is being undertaken to estimate fluorochemical concentrations and better characterize the distribution of FCs in the environment. These activities are to be conducted in an iterative fashion and will become refined and focused as more data become available. The specific projects planned and/ or initiated to characterize environmental distribution are:

12 000014 4) Exposure levels for all possible pathways that could lead to human ecological exposure from the prioritized products will be estimated. When release and distribution data become available, the most important pathways will be hypothesized. Iterative sampling and modeling will be employed to test these hypotheses and determine the important pathways to be used in risk assessment. The specific projects planned and/ or initiated to estimate exposure are:

SUMMARY Efforts are underway at 3M to assess the risk of POSF based 3M fluorochemicals to both human health and the environment. To augment 3M's initial review an exposure assessment plan for POSF based fluorochemicals is being implemented. As new information becomes available it will be summarized and communicated to the EPA. A POSF based fluorochemical environmental "white paper" is currently being prepared and will be submitted upon completion.

13 000015 Chart 1 POSF Fluorochemical Reaction Tree Fatty Acid Alcohols Urethanes Amides Oxazolidinones (N Alkylperfluo%% iesulfonamide)

Quatematy Ammonium Salts Sulfonates (PFOS)

POSF (Perfluorooctanesulfonyl fluoride)

14 000016 Table 1. Fluorochemical Glossary Designation Molecular Formula POSF W17sozF PFOS W17SO3` Technical Name (CAS Name)

Peffluorooctanesulfonyl fluoride (I Octanesulfonyl fluoride, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro)

Perfluorooctanesulfonate CBFI~ SO~ H W, WW,

CBF17S03Li ,CeF, rS02NHCH2CH3 (I Octanesulfonic acid anion, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro)

Peffluorooctanesulfonic acid (I Octanesulfonic acid, 1,1,2,2,3,3,4,4.5,5,6,6.7,7,8,8,8 heptadecafluoro)

Ammonium perfluorooctanesulfonate (I Octanesulfonic acid, 1 ,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro, ammonium salt)

`Perfluorooctanesulfonate, diethanolamine salt `( I Octanesulfonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro, compd. with 2,2' iminobis[ ethanol] (1: 1))

IPotassium perfluorooctanesulfonate (1 Octanesulfonic acid, I .1.2,2,3,3,4.4.5,5,6,6,7,7,8,8,8 heptadecafluoro, potassium salt)

Lithium perfluorooctanesulfonate (l Octanesulfonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro, lithium salt)

Perfluorooctanesulfonamide (I Octanesulfonamide, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,& heptadecafluoro)

IN pedluorooctylsulfonyl N ethylglycinate (Glycine. N ethyl N[( heptadecafluorooctyl) sulfonyl], anion)

N Ethylperfluorooctanesulfonamide (l Octanesulfonamide, N ethyl l, l, 2.2,3,3,4,4,5,5,6,6.7,7,8,8,8 heptadecafluoro)

N Methylperfluorooctanesulfonamide (I Octanesulfonamide, 1 ,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro N methyl)

N Ethylperfluorooctanesulfonamidoethanol (I Octanesulfonamide, N ethyl l, 1 ,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8 heptadecafluoro N( 2 hydro~ ethyl))

N Methylperfluorooctanesulfonamidoethanol N MeFOSA N EtFOSE N MeFOSE I WOctanesulfonamide, 1 ,l ,2,2.3,3,4,4,5,5,6,6,7,7,8,8,8 heptade~ fluoro N( 2 hydro~ ethyi) N methyl)

N EtFOSEA CsF, 7S02N( CH2CH3) CH2CHZOCOCH= CH2 N Ethylperfluorooctanesulfonamidoethyl acrylate (2 Propenoic acid, 2[ ethyl[( heptadecafluorooctyl) sulfonyl] amino] ethyl ester)

N EtFOSEMA CsF, 7SO~ N( CH2CH3) CH2CH10COC( CH3)= CH2 N Ethylperfluorooctanesulfonamidoethyl methacrylate (ZPropenoic acid, 2 methyl, 2[ ethyl[( heptadecafluorooctyl) sutfonyl] amino] ethyl ester)

N MeFOSEA Cr, F, 7SOzN( CH3) CH2CH20COCH= CH2 N Methylperfluorooctanesulfonamidoethyl acrylate I I 1( 2 Propenoic acid, 2[[( heptadecefluoro~~ yl) s~ lfonyl] methylamino] ethyl ester) i 15 16 000018 Table 3 Features of Fluorochemical Surfactants SURFACE ACTIVITY AQUEOUS SYSTEMS Some of these surfactants can lower surface tension to less than 16 dynes/ cm and function at low concentrations. They are effective in dramatically reducing surface tension in a wide variety of aqueous media, including acidic and basic systems.

NON AQUEOUS SYSTEMS Fluorochemical Surfactants have been developed which uniquely reduce surface tensions of many organic media to about 20 dynes/ cm, including solvents such as esters, alcohols and ethers and resin systems including epoxies, polyesters, urethanes and acrylics.

WETTMG Reduced surface tensions result in the ability to improve the wetting of a variety of materials, including such hard to wet surfaces as plastics and oily metals.

BETTER SPREADING Low surface tension in combination with low interfacial tension tiects spontaneous spreading of a liquid over various surfaces. This is important in reducing pinholes, craters, and edge crawling of coatings applied to unclean surfaces.

REDUCED WATER SPOTTING Because of reduced droplet formation, the need for distilled or deionized water in rinsing operations may be eliminated.

SMALLER GAS BUBBLES These smaller gas bubbles produced at the surface of metal during chemical etching will have less tendency to adhere, grow and cause surface imperfections.

SMALLER DROP FORMATION Smaller drops are desired in tine aerosol mists.

BEnER LIQUID PENETRATION The force required to cause liquids to move through small pore spaces can be greatly reduced.

IMPROVED FILM UNIFORMITY Smoother, more even films are produced from polishes, finishes and coatings. LEVELING Emulsion coatings applied to diffkult to wet surfaces can show greatly improved leveling with the addition of small quantities of these materials.

FOAMING Stable foams can be produced in hostile media such as chromic acid or sodium hydroxide, where conventional surface active agents would be destroyed.

EMULSIFICATION While generally not effective as emulsifiers in water organic systems, these materials can be quite efficient emulsifiers in specialty applications, where fluorinated materials comprise either the continuous or the dispersed phase.

STABILITY Some of these surface active agents are stable in such rigorous environments as hot chromic acid, anhydrous hydrazine, hot concentrated sulfuric acid, hot concentrated hydrofluoric acid and hot concentrated sodium hydroxide solutions.

Thermal While all of these materials have very good stability at moderate temperatures, a few can withstand temperatures in excess of 300° F in air.

LOW CONCENTRATION These materials are normally effective at extremely low concentrations, and often are utilized at concentrations of 100 parts per million active solids or less.

17 000019 * 18 000020 0 0 I. SANITIZED COPY Protective Chemical Products Carpet Business Fluorochemical Use, Distribution, and Release Overview 000022 20 Foreword This report is a comprehensive Iook at exposure to 3M's fluorochemicals in the Floorcoverings business. It attempts to answer the following questions.

l Whatproductsarecustomersexposedto?

l Where does exposure happen?

l What type of exposure is it?

The 3M ffuorochemical business is compiex and global. Markets served are hi@ y mented involving multiple 3M products that are applied to multiple substrates, sold into multiple market segments and used for multiple end products.

Information for this report was developed solely fkom internal 3M sources. These include:

l Knowledge of product handling and use practices Corn field sales and technical personnel l Best estimates of end use applications from known customer activities.

l Internal sales reports l Knowledge of worldwide activhies (where applicable), by St Paul based personnel How To Read This Rewwt Situation Analysis: Provides background on business and products.

Distribution Chain and Points of Contact: Follows the path of a 3M fluorochemical throughout the distribution chain to final end user. Objective is to identify all points of contact with our chemicals  Erom arrival on customer's loadingdock through product usage and disposal.

Exposure Information Charts Attempts to e type and length of exposure and number of workers exposed to our chemicals within the distribution chain.

Summary Table: Combines 3M product de& il with the exposure routes to provide a summary of total business exposure by product type.

000023 .

21 Table of Contents I. Chemical Names 11. Situation Analysis A Business D& n& ion B. Market Segments C. Fluorochemicdl Usage D. Customer Location Map III. Exposure Assessment A. Distributim Chain 1 Points. of Contact B. Exposure Routes C. Application Methods and Disposal D, EndUser formation E. Summary Table 000024 22 Chemical Names l 000025 23 _. i ChemicdNames .

The following is a list of ChemicaI Abstract Services (CAS) names and numbers for individual products. The foIlowing infbrmation is presented:

Generic Code: Indicates au internal 3N designation of the product( s).

CAsNIxmbec IixiicatesthechemicaIAbstracts services IlImlhcr( s) offhmrochemicals cozminedwithincachprodnct.

Chemical Name (complete CAS name or IUPAC names ifCAS name does not exist): Indicates the Chemical Abstracts Services name( s) of fIuorochemicals contained witbin mod

chemidctass: IIldicatesashorten~ gene! ricchuIlicaInam.

000026 Y 24 Chemical Names Generic Code CAS Number Chemical Name (complete CAS name or IUPAC name If dAS name does not exist) Chemical Class Carpet w 1 ) CP 2, CP 3, CP 5, CP 6 CP 2 CP 5, CP 6 CP 7 CP 3 CP 4 l Situation Analysis .

000028 I 26 Situation Analysis  I; zoorirtg Business Segment Business Definition This segment is comprised of carpet manuf& turers and% ber producers to whom we supply fvluorochemical and s& blocker protective treatments for carpet. These products provide soil resistance and repellency (fluorochemical products) and s+ n resistance (stainblockers).

The Flooring Business Unit defines its market by the following segments:

l Residentialcarpet l Commercial Carpet l Transportation Carpet l he a Rugs (minimal activity)

The following two pages &rther depict the Flooring Market Segment and our business in those segments:

000029 27 1998 US. Flooring Market Segments Residential Carpet Commercial Carpet Trans or& tbn c! arpet Area Rugs .

* Replacement DIY Professional l Res. Contract New construction Tenant improvement l Specifier Off ice Hdsgitality institutional Retail l Main Street l Automotive OEM Replacement Throw Mats l Mobile Hoines l R8Or88ttOnal V8hiCl8S Motor l iomes Marine 0 Tufted Rugs l Scatter Rugs l Indoor/ Outdoor/ Grass l BraidecUVVo~ en l Airline .

MM sq, Yds. 912 363 708 181 Fluorochemical Usage This table is simply a breakdown of fluorochemicaf poducts by volume. These volumes are then fbrther divided by apphtion method. These numbers are based on sales volumes and 3M sourcesinc~ gsaies, technicalservice, aud~.

29 30 008032 Product Volumes and Use Patterns This summary is based on individual products. It is a description of the application, chemistry, use pattern, exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which exposure was assessed. The route of exposure,. the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following definitions apply: Process: use of fluorochemical containing product in another product. Application: use of fluorochemical containing product to treat a substrate EndUse: use. oflreatedsubstmte Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold in 1997. (M= looo)

Chemistry: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

o/ o Residuals: Sum total of concemration of the mixture of fhrorochemicals that are meacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used;. f~. industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure, ingestion, dermal, and inhalation. Marks the most likely route of exposure with an T.

Environmental Fate: Identifies the most likeiy disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Information was compiled Born available 3M sources including sales, technical service, marketing and regulatory expertise.

000033 31 Product Volumes and Use Patterns PrOdlJCt Code F CP 1 CPA CP 3 F CP 4 1 CP S kcass or Volume % End U& sold ~hemlstry Residuals .UtiPaltem RobteofExtMtre.

I I Mltm. oi Fd Sdidk Fibet %InProd. ki Defmai Treatment Treatment Fiber I I 0.3 x x ,. x 0.3 X x. X Treatment Carpet Treatment 3105 X X X Carpet Treatment Carpet Treatment 3to5 X X x 0.9 1 X X X 1 Carpet X X x  _ I . . .

l Customer Location Map The following. U. S. map identifies the location of chemical purchasing customers in the Floorings market segment. The grayscale key indicates where applic& on of 3M fluorochemicals for aqwt occurs. Treated goods are fbund throq$ out the United States. 1 Carpet Treatment Breakdown w P : ::. ,_ . . : :

, ; I I 000036 .__ ,. . . . .._.. _.._.  7;  ; ,, ' .. ' Exposure Information.

000037 *

; . 0 35 Distribution Chain / Points of Contact This d@ am represents the path the 3M product takes fkom the time it leaves 3M to its ultimate end use. It reqresents an overview of both the distributioo chain and the significant points of contact where the 3M product may be handled and used. This distributionchain represents the typical use of the product line; not every product will go through each step. This ixSormation was compiled f? om 3M internal knowledgq of the marketplace based on 3M technical senicekales visits and generaI information from the customer interactions.

000038 .

.36 Distribution ChaMPojnts of Contact Carpet \1/ Carpet Mill (Inventory) I cturer (Inventory I Bulk Formuiating 1 Bulk Mefer'ing 1 1 I 1 I I \I/

/Ceramic Guide Applicationl Mill Processing Tufli~, finishing 3M Pluorochemical Exposure Information From the Points of Contact flow chart, each step in the customer use process is isolated. All i& ormation is based on the use and handling of 3M fluorochemicals, materials containing. 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an `X'.

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure duringused.

E& mated Exposure Time: Indicates the amount of time that workers potentially may be exposeddlllinguse.

Physical Form: Indicates the physical state (liquid. solid,. <EMAIL_ADDRESS>or vapor). of the product at time of exposure.

Open or Closed System: Open system: is defined as one that allows workers to come in direct contact with 3M fluorochemical. Closed system: is defined as one that, under normal conditions,. does not allow workers to come in direct contact with 3M fluorochemical.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Information was compiled from available 3M sources includmg sales, technical service, marketing and regulatory expertise.

oooq40 38 Point of Contact Type of Exposure I I Oral Oermal t x I l 3 I x LW lncldrnce. cw Ptoduct I I I I I I I Tufting IXlXl x 1 I I 2 H I H I I x I x I L L X I Number of Open or Workers Exposure Times Physlcal Form Closed System Comments I I I I I 1 HrslOay OayaNear <l = Low dQ= LOW 1 4 = Medium 50 100  Medium .4 = High ~100 = High Llquld ~ Sdkl Aemd Vapor Open ClOMd Mix Preparation Bulk Metering Die X X 2 2 M M H H x x. x x X X Application CO ADD 2 L L x x X PIunUUV CP 7 I I I I I I I I 2 I i .i X' I ~~ . Foam I x I x I I Spray iulvt "I I Al! I I I I I I v I v I v I "

`2 X Pflmafiiy CPd x x x 0 Seaming & 01 Salvaae I ZI Shearina I 164 Shearinn Waste I X I 2 I H I H I I x I X tIMdUng Finiahed oooda . I 2 I H i i 1 x 1 I X XI x I 2 L H 1x1 .I X EWWU~* bCldFlOur  r e

Roll up X 4 H H X X Fiber Processiho I I I I I e Application X 3Q+ H H x . .X 0llrdtht~~ 1n~ fchsph~ 1kh Drawing & Texturiting x x x 2 H l l X x x Poulblr V& M llddwb Spin, Twist, & Set X X X 1 H H X X fb runo Shipping Fiber X 2 `H H X. X HrndYnOFldbWOCW r 1 Number of Open or Iosed System Comments Open Closed Typ Boint of Contact 1 iure Workers t af Exp Dermal Exoosure Times `hysk Solid X X x X X X x X I Form I C Days/ Year 40 = Low 50 100 = Medium ~100 = HlPh HrslDay 4 = Low 14 = Medium >4 5 Hlgh Liquid X 2 z 3 25+ 25+ H H Jnwrapping Rolls X X Poaiblr Vdolllkod fW! duala X Exposure lo Cut Flbm X 7 X H H H H I X 2 t 2 H H X X X X Poslble VdaWed flesklwL H H X l 2 ~ 2 ,H H H H H X Carpet Cleaning M I= H / X Landfill 1 .'

 . . .._._.... _._ ._.__ . l. r .. L Product Flow Diagrams These diagrams show the places that 3M fluorochemicals are introduced and lost in the life cycle of a csrpet. Each application method is broken out seqara~ ely in order to show greater detail. This i& ormation is based on 3M intemal knowledge and best estimates on how customers handle 3M tiorochemical produds. Ii& mation was compiled ftom available 3M sources in& ding sales, technical service, marketing and regulatory =P@ i= Prod UCt HOW Diagram *Fiber with 3M Fiber b Treatments I,, f 4 *SPW *Foam I t More detail on the application boxes can be bund on the foflowing pages.

I Disposal sharing and Trimming b Fiber Treatments . . .

CP 1, CP 2, CP 3, cP4 n Dilution Ratio: T r I I ,

I ..m ..

Non FC Chemicals In Bath: Spin Finish Oil Amount of use: _ FC fiber trgtments for carpet Exposure Routes:

1 43 .

000045 i' Smw Amktion Dilution Ratio:

Non FC Chemicals In Bath:

Amount of use:

Exposure Routes: Product :

None carpet treatments Ingestion, Dexmd, Inhaiation 44 000046 :I_ Foam AWication d : `. t  <.

.*.

A CP 3, CP 6, CP 7 l . b   . _ . $ t Dilution Ratio: Product : Bath Non FC Chemicals In Bath: Foaming Agent Amount of use:

Exposure Routes: DennaI FC carpet Geatments 45 000047 *` .*.

Co Amdication 4 ?

_

cP 6, CP 7  . . . )F Dilution Ratio:

Non FC Chemicals InBath:

Amount of use:

Exposure Routes: . .

Product : Bath FC carpet treatments Dermal 000048 46 .

Product: Bath  Waste Dis~ osd*

l Toti carpet mill solid waste is approximately 60,000, OOO IbsJye~

l This waste includes shearing selvedges, and backed seamcuts.

l This equals about 1 to 1.5 MM f?? of waste per year.

l l 0 l 0 l Unbacked seamcuts are typically recycied into carpet tmderlayzctti Some shearing waste is being landfilled separately so that it can be recovered if a use is found for it.

The fluorochemical portion of shearing waste is as foUows:

l Fiber Treatments (CP 3KP 4)

l Approximately lbs. of soIids in slularhg was&

l Topical Treatments (mainly CP 6)

l ApproximateIy tbs. of solids in shearing waste l Switching fkom sp*& ing and foaming to co application would reduce this amount by up to _ because the treatment is evenly distributed on the fiber.

When carpet is cleaned, the wastewater wilI contain OEM fluorochemicai.

The majority of the wastewater treatment burden lies on the lo& utilities. .

When a typical residential carpet is thrown away, it contains * These numbers were generated internaIry based on customer . information. These numbers are intended to be used as estimates until they can be confirmed by the industry.

47 000049 End User Information .* :.

Typical Use l The average resider& I carpet sees 15,000 foot trafb per year.

l Carpetsarevacuumedevezy1to2weeksonaverage.

l Carpets are profession& y cleaned every 3 years.

l Factors contributing to removak l Temperature of the cleaning solution l The pH of the cleaning solution l The type of sufktants that are used Lifetime of Residential Carpet l Residential carpet is in a home for an average of 12 years.

A graph representing the removal of OEM treatments can be found OLB the next page.

48 000050 _ QOOO51 49 Protective Chemical Products Home Textiles Business Fluorochemical Use, Distribution, and Release Overview l Home Furnishings, Home Fashions, Automotive l Nonwovens 50 Foreword This report is a comprehensive look at exposure to 3M's fluorochemicals in the Home Textiles and Nonwoven business. It attempts to answer the following questions.

l What products are customers exposed to?

l Where does exposure happen?

l What type of exposure is it?

The 3M fluorochemical business is complex and global. Markets served are highly fragmented involving multiple 3M products that are applied to multiple substrates, sold into multiple market segments and used for multiple end products.

Sources of Information For This Report Information for this report was developed solely from internal 3M sources. These include:

w Knowledge of product handling and use practices from field sales and technical personnel.

n Best estimates of end use applications from lmown customer activities.

n Internal sales reports 9 Knowledge of worldwide activities (where applicable) by St. Paul based personnel.

. How To Read This Report The following types of information are available in this report:

Situation Analysis: Provides background on business and products.

Distribution Chain and Points of Contact: Follows the path of a 3M fluorochemical throughout the distribution chain to final end user. Objective is to identify all points of contact with our chemicals  from arrival on customer's loading dock through product usage and disposal Exposure Information Charts: Attempts to quantify type and length of exposure and number of workers exposed to our chemicals within the distribution chain.

Product Volumes and Use Patterns: Combines 3M product detail with the exposure routes to provide a summary of total business exposure by product type.

57 000053 Home Textiles Fluorochemical Use, Distribution and Release Overview Table of Contents I. Chemical Names II. Situation Analysis A. Home Furnishings, Home Fashions, Automotive 1. Business Definition 2. Products and Markets 3. Application Methods 4. Customer Location Maps B. Nonwovens A. Business Definition B. Products, Markets, and Application C. Customer Location Map III. Exposure Assessment A. Home Furnishings, Home Fashions, Automotive 1. Distribution Chain 2. Points of Contact 3. Exposure Routes 4. Waste Stream/ Recycle Characterization 5. Product Volumes & Use Patterns B. Nonwovens 1. Distribution Chain 2. Points of Contact 3. Exposure Routes 4. Product Volumes & Use Patterns 52 000054 Chemical Names The following is a list of Chemical Abstract Services (CAS) names and numbers for individual products. The following information is presented:

Generic Code: Indicates an internal 3M designation of the product( s).

CAS Number: Indicates the Chemical Abstracts Services number( s) of fluorochemicals contained within each product.

Chemical Name (complete CAS name or IUPAC names if CAS name does not exist): Indicates the Chemical Abstracts Services name( s) of fluorochemicals contained within each product.

Chemical Class: Indicates a shortened, generic chemical name.

53 000055 Chemical Names .

Generic Code CAS Number Chemical Name (complete CAS name or IUPAC name if CAS name does not exist) Chemical Class HT 1 HT 1, HT 2, Home Textiles 1 HT 3, HT 7 1 I 1 HT 7, HT 8 1 I I Chemical Names ,

Generic Code CAS Number Chemical Name (complete CAS name or IUPAC name if CAS name does not exist) Chemical Class HT 3, HT 7, HT 8, HT 9 HT 5 HT 6 HT 8 HT 9 HT 9 HT 9 HT IO wemical Names Generic Code CAS Number t% Hlka~ Name (complt# e CAS name or IUPAC name IiCAS name does not exist) Chemical Class Nonwovens NW l NW 2 NW 2 NW 3 NW 4 II. Situation Analysis A. Home Furnishings, Home Fashions, Automotive Business Definition Home Furnishings  This segment is comprised of OEM customers (textiles mills and commission fishers) sharing a common need for protective treatments which impart soil and stain resistance and/ or cleanability properties to upholstery fabric and other textile substrates used primarily in residential furniture. 3M protective chemicals are sold direct to the customer.

Home Fashions  This segment is comprised of OEM customers (primarily textile mills) sharing a common need for protective treatments which impart soil and stain resistance or stain release to fabrics used in home decor items such as window treatments, fabric wallcoverings, decorative pillows, slipcovers, bedspreads and comforters, mattress pads, shower curtains, and table linens. Some of these items can be laundered; others require professional cleaning.

Specification by US manufacturing companies drives OUS sales in this category.

Automotive  This market is comprised of OEM customers (textile and carpet mills) who provide protective treatments on upholstery fabrics, carpet and other textiles (headliners) used in automobile, truck, and van interiors. U. S. Product Portfolio  Total FC Volumes This chart outlines the products used in the Home Furnishings, Home Fashions, and Automotive markets in the U. S. The following information is provided for each product: The total fluorochemical pounds of each sold in the U. S. in 1997, and the chemical components that make up the product.

58 000060 U. S. Product Portfolio  Total FC Volumes Home Furnishings, Home Fashions, Automotive 1997 Product Pounds (000) Chemistry HT 4 HT 1 HT 6 Total Chemical .

59 U. S. Product Portfolio by Market This chart groups the products used in the business by market segment, Home Furnishings, Home Fashions, and Automotive, and provides fluorochemical volumes sold both by product and market segment. U. S. Product Portfolio by Market Product 1997 FC Lbs. 0 HT 8 I Total Home Furnishings Home Fashions . HT 3 Total Home Fashions I Automotive HT 1 HT 6 Total Automotive I 61 000063 Application Methods Home Furnishings, Home Fashions, and Automotive The following chart presents the methods of applying fluorochemical in these market segments. The percentages represent the mix of these methods based on fluorochemical volumes used.

62 000064 Home Furnishings, Home Fashions, Automotive Application Methods Key Customers 1997/ 1998 Customer Location Map The following U. S. map identifies the location of all chemical purchasing customers in the Home Furnishings, Horrie Fashions, and Automotive market segments. In each case, the chemical is applied in the city indicated.

64 Distribution Chain This diagram represents the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used. This distribution chain represents the typical use of the product line; not every product will go through each step. This information is based on 3M internal knowledge of the marketplace.

000068 66 Distribution Chain Home Furnishings, Home Fashions and Automotive `I Textile Mill/ Finisher +

Fabric Retailer v Consumer Manufacturer `It Retailer j Consumer j *

Converter v 1 Cut and Sew 67 000069 Points of Contact The Points of Contact diagram details the path the product takes within the distribution chain startiug with the arrival of 3M product at the 3M customer. This information was compiled f? om 3M internal knowledge of the marketplace based on 3M technical service/ sales visits and general information from the customer interactions.

000070 68  . .  Points of Contact at Textile MU Home Furnishings, Home Fashions and Automotive QC Lab Formulation and Development Work Loading Dock Inventory 1 I Mix/ Drug Room Application Method 4 Pad I Foam + Open/ Closed Spray I I I v Inspection/ Piece Wrap (50 Yards) I I Rework (5%)

*

Inventory (Fabric) * .Yif 69 000071 3M Flnorochemical Exposure Information From the Points of Contact tlow chart, each step in the customer use process is isolated. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during used.

Estimated Exposure Time: Indicates the amount of time that workers potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure.

Open or Closed System: Open system: is defined as one that allows workers to come in direct contact with 3M fluorochemical. Closed system: is defined as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochemical.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Mbrmation was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

70 000072 : FP Exposure Information Home Furnishings, Home Fashions and Automotive Most Likely Route of Estimated Estimated Point of Contact Open or Exposure Number of Exposure Time Physical Form Closed System Comments Workers <I hr/ day for +Odayslyear = Low  1 4hrslday for 50

Ingestion Dermal Inhalation (per plant) 100dWyr = Medium >rlhrs/ day for L squid Solid Aerosol Vapor Open Closed >I OOdays/ yr = High Loading Dock (Spills) X l 2 Low X X Low incidence rate.

Inventory 1 2 Low X X Closed system. No Mix/ Drug Room exposure.

weighing, diluting X l 3 Medium High X X QC Lab X I 3 Low X X Application  Pad, Foam X 2 3 Medium High X X Application  x x X Spray  Open 2 4 Medium High X x x x Application  Spray  Closed x x 2 4 Medium High X x x X Spray Tip Cleaning x x x ,l Low X x x x Drying x x 3 6 High x x X Exposure Information Home Furnishings, Home Fashions and Automotive Most Likely Route of Estimated Estimated Point of Contact Exposure Number of Exposure Time Physical Form Open or Workers Wvlday for Closed System Comments CbOdayslyear = Low I 4hrsIday for 50

Ingestion Dermal inhalation (per plant) 100dWyr = Medium L >4hrs/ day for [quid Solid Aerosol Vapor Open Closed >lOOdayslyr = High Mechanical ~~

Processing (face finishing, x x l 2 High x x X tiggering, shearing)

Roll up Inspection/ Piece Wrap QC Lab (Fabric)

nventory/ Loading Dock (Fabric)

Fabric Distributor Furniture Manufacturer Cutter Seating Manufacturer X l 3 High X X Product dried on fabric.

X 1 3 High X X Product dried on fabric.

X 2 3 Medium X X Product dried on fabric.

I 2 Low X X Product dried on fabric.

X ~6 Low X X Product dried on fabric. Product dried on X 25 50 Medium High X X fabric.

x x 25 50 Medium High xj x X Product dried on fabric.

X 15 40 Medium High X X Product dried on fabric. Exposure Information Home Furnishings, Home Fashions and. Automotive PaintofConBcl . .. . ,. kely Route of Estimated Estimated Exposure Number of Exposure Time Physical Form Open or Comments Workers cl hr/ day for Closed System I I  I I I I <50days/ year = Low I I I I I I Automobile Assembly Mhrslday for 50

Ingestion Dermal Inhalation (per plant) ~OOdaWr = Medium >4hrs/ day for L' squid Solid Aerosol Vapor Open Closed >iOOdaysiyr = High X 15 40 Medium High Product dried on fabric.

Converter X 15 20 Low X X Product dried on fabric.

Cut and Sew All Retailers and Consumers X X 25 50 Medium High X X X X Product dried on fabric. Product dried on fabric.

. III. Exposure Assessment  Home Furnishings, Home Fashions, Automotive 6. Waste Stream/ Recycle Information An approximation of the actual disposition of the chemical after it arrives at a customer site is given below. No exact values are known.

Chemical State As shipped As shipped Dilute mix Dilute mix Dilute mix Dried on fabric Dried on fabric Dried on fabric Dried on fabric ble Cause for Loss . . easonable Estimate Residual in shipping drums Spills Unused pad/ foam mix Non recovered spray l Coating on equipment l overspray l Vented material Start up and shut down excess Shearing and face fishing Unrecoverable, off quality fabric Seam cut outs Quality/ SQC samples 74 000076 00007'7 75 Product Volumes and Use Patterns This summary is based on individual products. It is a description of the application, chemistry, use pattern, exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which exposure was assessed. The route of exposure, the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following definitions apply: Process: use of fluorochemical containing product in another product. Application: use of fluorochemical containing product to treat a substrate End Use: use of treated substrate Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold in 1997. (M= lOOO)

Chemistry: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

Amount of Fluorochemical Present: The fluorochemical concentration in process or end use.

% Residuals: Sum total of concentration of the mixture of fluorochemicals that are unreacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used; food, industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Environmental Fate: Identifies the most likely disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information.

76 000078 Product Volumes and Use Patterns Global Product Portfolio . Home Furnishing Home Fashions ant Aost Likely Route o 4utomotive T Applicatior Process 01 End Use Product Code Use I Envir andfil Comments Inges

lion Food vvErF Water Treat ment Indust rial Con sumar Inhal ation Incin eration Comm ercial lerma HT 3 X X X Application X X End Use X X X HT 3 HT 7 <.

&f 7 Applicatior X X X X X End Use X X X X Product Volumes and Use Patterns Global Product Portfolio . Home Furnishing Home Fashions and Lost Likely Route of I posu rutomotive Esti bated 54 Resld uals Volume Sold 1997 (Ibs product) Application Process or End Use t t Product Cod9 :hemlslty mental Fate Use I Indust rial ttern Zomm ercial fnvirc .andfill Comments on Inhal ation Water Treat ment X Con sumer Incln Inges tion FOOd Iermal X Application Foam or pad appplied. HT 4 X X t IT 4 X X X x End Use Application HT 1 X X X HT 1 End Use X X X Product Volumes and Use Patterns Global Product Portfolio . u,...... C*."". I L:^ U^....^ l l.: em. 4 A..,*:..

."I "I I I "

E& i Application Sold 1997 mated % Product Process or (Ibs Resid I Most Likely Routf Code End Use product) Chemistry uals Use Pattern Exoosure 1 Environmental Fate 1 Comments I \Inl,, mn nu111f3 ~~~ III~ IIIII~~. nuiiit: raslllulki aiiu ~~~ UIIIUIIV~:

I I ? of  r m  . . . .  .._

waste Water lndust Comm Con Inhal Inges Incin Treat FOOd rial erclal sumer Dermal alion tion Landfill eration ment HT 2 Application X X X HT 2 End Use HT 5 Application HT 5 End Use x x x x X x x x X Spray applied x x x x . `_ _I :I * Product Volumes and Use Patterns Global Product Portfolio . Home Furnishinas, Home Fashions and Automotive Volume ESU Application Sold 1997 mated % Product Process or (Ibs Rasld Most Likely Route of Code End Use product) Chemistry uals Use Pattern Exposure Environmental Fate Comments Waste Water Indust Comm Con Inhal Inges Incin Treat

FOod rial ercial sumer Dixmal ation ti0ll Landfill eration merit HT 6 Application X X X HT 6 End Use x x x x x Product Volumes and Use Patterns Global Product Portfolio .

I I dome Wrnishinas. Home Fashions and Automotive Most Likely Route of End Use p& duct) Chemistry uals Use Pattern Exposure Environmental Fate Comments waste HT 8 lndust Comm Water Con Inhal Food rtal Inges Incin Treat ercial 6~~ 3 Dermal ation tion Landfill eration mant X X X Foam applied.

HT 8 x x x x HT IO HT 10 1 x x x x x x x x I I II. Situation Analysis B. Nonwovens Business Definition Nonwovens  This market is comprised of OEM customers (nonwoven plants, finishers) sharing a conmron need for oil and water resistance. Additionally, master batch producers process our polymer melt product into a form that is more readily handled by extrusion processes at selected nonwoven mills. The fabrics produced are used as medical fabrics (surgical gowns, drapes and wraps) as well as industrial materials, primarily filter media. 3M protective chemicals are sold direct to the customer.

.

82 000084 Key Products  Nonwovens This chart outlines the products used in the Nonwovens market in the U. S. Included in the chart of the total fluorochemical volumes sold to each of nine key customers, the application method these customers used to apply the chemical, and intended end use of the treated goods.

83 000085 Key Products Nonwovens NW 3 I NW 2 NW 3 NW 4 NW 4 NW 3 NW 4 NW 4 Application End Use Pad Medical Fabric Pad Filter Media Pad Disposable Workwear Pad Filter Media Extrusion Compound Extrusion Medical Fabrics Pad Extrusion Extrusion Medical Fabrics Concentrate Outdoor Furniture 84 Customer Location Map The following U. S. map identifies the location of all chemical purchasing customers in the Nonwovens market segment. In each case, the chemical is applied in the city indicated.

000087 85 86 000088 Distribution Chain This diagram represents the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used. This distribution chain represents the typical use of the product line; not every product will go through each step. This information is based on 3M internal knowledge of the marketplace.

87 000089 . Nonwovens Distribution Chain 3M 5 v I t Topical Nonwovens: Mill/ Finisher Cut 4% Sew (Medical)

Packaging Sterilization Hospital 1 i' Waste/ Incineration Points of Contact The Points of Contact diagram details the path the product takes within the distribution chain starting with the arrival of 3M product at the 3M customer. This information was compiled from 3M internal knowledge of the marketplace based on 3M technical service/ sales visits and general information from the customer interactions.

000091 89 Points of Contact  Mill Topical Nonwovens Loading Dock *

QC Lab Formulation Development , Wor . Pad Application t I Dryer Mechanical Processing Micrex, Softening +

Lamination I I Inspection/ Piece Wrap I Rework (5%)

+

Inventory (Fabric)

Loading Dock (Fabric)

90 OOOQ92 i . Points of Contact  Masterbatch Producer Nonwovens PMA Loading Dock Line Feed/ Drum to Hopper ExtruderMrands Chop f ship to Nonwovens Producer 91 000093 Points of Contact  Extruder Nonwovens PMA Loading Dock I I I I Container to Hopper Air/ Vacuum Fed Hopper to Extruder Fiber Draw Collection I I Thermal Bond I 1 Lamination Inventory (Fabric)

Loading Dock (Fabric)

92 000094 3M Fluorochemical Exposure Information From the Points of Contact flow chart, each step in the customer use process is isolated. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during used.

Estimated Exposure Time: Indicates the amount of time that workers potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure.

Open or Closed System: Open system: is defined as one that allows workers to come in direct contact with 3M fluorochemical. Closed system: is defmed as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochemical.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products, Information was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

000095 a? I II Lamination nspection/ Piece Wrap nventorylloading Dock (Fabric) Point of Contact Most Likely Route of Exposure Dermal Loading Dock (Spills) X Inventory QC Lab QC Lab X X Pad ADoIication Pad Application X X Drying Drying Mechanical Mechanical Processing Processing x (Micrex, (Micrex, softening) softening)

Roll up Roll up X X T Estimated Number of Workers (per plant)

I 1 2 X l 2 c 1 3 X 1 2 3 I I I 2 3 Low 7 Exposure Information Nonwovens

I I 1 I Ooen nr I Estimated Exposure Time Physical Form I.. .

cl hrlday for Closed System c5Qdayslyear = Low 1 4hrs/ day for 50 1 OOdays/ yr = Medium >4hrslday for L* squid Solid Aerosol Vapor Open Closed >lOOdays/ yr = High Mill  Pad Application Comments Low Low X x X Low incidence rate.

X Closed system m. No I I exposure. Low X X Medium High X X High X X Medium I lXIXl lx1 I Hinh 1 Ix1 1 Ix1 IProductdriedonI I I I I I I I rabnc. I I n. .* a* I Medium 1 1x1 I 1 x 1 1 rroauct ortea on 1 I I Exposure Information Nonwovens ,

Most Likely Route of Estimated Point of Contact Estimated Open or Exposure `$ nerif Exposure Time Physical Form Closed System Comments <I hrlday for K50dayslyear = Low l llhrslday for 50

Ingestion Dermal Inhalation (per plant) 10~ aWr = Medium >4hrs/ day for L' squid Solid Aerosol Vapor Open Closed >lOOdays/ yr = High Loading Dock (Spills) X Inventory Line Feed/ Drum x x to Hopper Zxtruder/ Strands X Water Cool Chop X Drum x x Ship to Nonwovens X Producer Masterbatch Producer 1 2 Low X X Product is flake.

2 3 . Low X X Product is flake. Product is flake, 2 3 Medium X X potential for dust. 2 3 Medium X x x 2 3 Medium X X 2 3 Medium X X 2 3 Medium X X X X j:

J Exposure information Nonwovens ,

Most Likely Route of Estimated Estimated Point of Contact Exposure Number Of Exposure Time Physical Form Open or Workers <Ihr/ day for Closed System Comments 60dayslyear = Low Mhrs/ day for 50

Ingestion Dermai Inhalation (per plant) 100daWr = Medium L' >rlhrs/ day for squid Solid Aerosol Vapor Open Closed MOOdayslyr = High Extruder Loading Dock (Spills) Inventory Container to Hopper Hopper to Extruder Fiber Draw Collection Thermal Bond Roll up (Fabric) Lamination QC Lab (Fabric) X 2 3 Low 1 2 Low l 2 Medium 1 2 Medium X 2 3 Medium X 2 3 Medium X 2 3 Medium X X 2 3 Medium x 1 2 3 Low X X X X X X X X X x x X X X X X X X X X Exposure Information Nonwovens Estimated Estimated Point of Contact Most Likely Route of Exposure Number of Workers Exposure Time cl hr/ dav for 1 Ingestion Dermal lnhalalion (per plant) lmdays'yr = Medium 1 1 1 1 H;:;:;:~ igh Liquid X 2 3 Low Downstream Proces ng 01 Roll Goods x x 3 5 Low X X Product dried on nonwoven. Product dried on or x x 15 20 High X X incorporated into nonwoven. Physical Form Open or Closed System Comments Open Closed nventory/ Loading Dock (Fabric)

bsembly (Filters)

Cut and Sew (Medical)

Packaging Sterilization All End Users X X 3 5 High X X X X Product dried on or incorporated into nonwoven. Product dried on or incorporated into nonwoven. Product Volumes and Use Patterns This summary is based on individual products. It is a description of the application, chemistry, use pattern, exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which exposure was assessed. The route of exposure, the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following def@ itions apply: Process: use of fluorochemical containing product in another product. Application: use of fluorochemical containing product to treat a substrate End Use: use of treated substrate Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold in 1997. (M= looO)

Chemistry: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

Amount of Fluorochemical Present: The fluorochemical concentration in process or end use.

% Residuals: Sum total of concentration of the mixture of fluorochemicals that are unreacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used; food, industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an `X".

Environmental Fate: Identifies the most likely disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information. Product Volumes and Use Patterns Global Product Portfolio Nonwovens Volume ES& Application Sold 1997 mated % Product Process or (lbs Resid Most Likely Route of Code End Use product) Chemistry uals Use Pattern Exposure Environmental Fate Comments waste Waler Indust Com Con Inhal hFJs Incin Treat Food rial mercial sumer Dermal alion lion Landfill eralion ment NW 1 Appk. ation X X X NW l End Use X .x x x x NW 3 Application X X X Pad applied NW 3 End Use X X x x Product Volumes and Use Patterns Global Product Portfolio Nonwovens 0' 0 Volume Application Sold 1997 %oduct Process or (Ibs ES%

matad O/ O Resid . . . . . . .  te of MOSt Likely KOUl Code End Use product) Chamislty uals Use Pattern Exposure Environmental Fate Comments waste Water Indust Com Con Inhal Inges Incin Treat FOOd rial mercial sumer Dermal ation lion Landfill eration ment NW 2 Application X X X Pad applied NW 2 End Use x x x x x NW 4 Application X x x x x x NW 4 End Use x x x x x Protective Chemical Products Apparel and Leather Business Fluorochemical Use, Distribution, and Release Overview Foreword Confidential Business Information This report is a comprehensive look at exposure to 3M's fluorochemicals in the Apparel and Leather business. It attempts to answer the following questions.

l What products are customers exposed to?

l Where does exposure happen?

l What type of exposure is it?

The 3M fluorochemical business is complex and global. Markets served are highly fragmented involving multiple 3M products that are applied to multiple substrates, sold into multiple market segments and used for multiple end products.

This report includes global information based largely on the knowledge of worldwide activities by St. Paul based personnel.

Sources of Information For This Report Information for this report was developed solely from internal 3M sources. These include:

l Knowledge of product handling and use practices from field sales and technical personnel l Best estimates of end use applications from known customer activities.

l Internal sales reports showing regional sales breakdowns for apparel and leather products.

How To Read This Report The following types of information are available in this report:

Situation Analysis: Provides background on business and products. Helpful to understand Apparel and Leather customer base, global scope and diversity of markets.

Distribution Chain and Points of Contact: Follows the path of a 3M fluorochemical throughout the distribution chain to final end user. Objective is to identify all points of contact with our chemicals  from arrival on customer's loading dock Exposure Information Charts: Attempts to quantify type and length of exposure and number of workers exposed to our chemicals within the distribution chain.

Product Volumes and Use Patterns: Combines 3M product detail with the exposure routes to provide a summary of total business exposure by product type. * , **

oooi04 102 Apparel and Leather Fluorochemical Use, Distribution And Release Overview Table of Contents I. Chemical Names II. Situation Analysis A. Business Definition B. Global Polymers C. Key Markets and End Uses D. Application Methods E. Customer Location Maps III. Exposure Information  Apparel A.. Distribution Chain B. Points of Contact C. 3M Fluorochemical Exposure Information D. Waste Stream/ Recycle Characterization E. Product Volumes and Use Patterns IV. Exposure Information  Leather A. Distribution Chain B. Points of Contact C. 3M Fluorochemical Exposure Information D. Waste Stream/ Recycle Characterization E. Product Volumes and Use Patterns Chemical Names The following is a list of Chemical Abstract Services (CAS) names and numbers for individual products. The following information is presented:

Generic Code: Indicates an internal 3M designation of the product( s).

CAS Number: Indicates the Chemical Abstracts Services number( s) of fluorochemicals contained within each product.

Chemical Name (complete CAS name or IUPAC names if CAS name does not exist): Indicates the Chemical Abstracts Services name( s) of fluorochemicals contained within each product.

Chemical Class: Indicates a shortened, generic chemical name.

000106 104 Chemical Names .

Generic Code CAS Number Chemical Name (complete GAS name or IUPAC name If GAS name does not exist) Chemical Class Apparel AP 1 , AP 5 AP 1 , AP 5 AP 1 , AP 5 AP 2 AP 3 AP 3 AP 3 AP 4, AP 5 Chemical Names I Generic Code CAS Number Chemical Name (complete CAS name or IUPAC name if CAS name does not exist) Chemical Class AP 6 AP 7 AP 6 AP 9 Leather FO 1 FO 2, FO 3, FO 4 FO 5, LE 3 FO 6 FO 7 FO 7 Chemical Names .

Generic Code CAS Number Chemical Name (complete CAS name or IUPAC name if CAS name does not exist) Chemical Class FO 7 FO 7 FO 7 FO 8 LE 1 LE 2 LE 4 . Apparel and Leather Fluorochemical Use, Distribution, and Release Overview II. Situation Analysis A. Business Detition Sale of fluorochernicals for application on fabrics and leather used to manufacture garments, footwear, accessories and other non garment functional fabrics.

Direct Customers:

. l . . . . .

extlle MrllsKorrurusslon Flnlshers that use fluorochemicals to provide oil and water repellency to enhance the functional performance of the fabric produced.

. m . . Tannenes/ Fmlshers that use fluorochemicals to enhance functional petiormance as above and/ or serve as a processing aid in the conversion of raw leather.

8 cal Formulators that use fluorochemicals as ingredients for the textile and leather care, dry clean and fatliquor industries.

m . . al Da that resell products to end users and may do quality testing repackaging and/ or lab tech service work.

Global Business Sjze:

108 000i10 Global Polymers This chart outlines the nine polymers used in the Apparel and Leather Markets product portfolio which features 19 different products. The polymers are divided into major product categories: Repellent, Stain Release, Leather and Formulators.

The following information is provided for each polymer: the chemical components that make up the polymer, and the total fluorochemical pounds sold in 1997 for each. Volume information is provided relative to the other polymers in the product category, and relative to the total pounds sold in the Apparel and Leather Markets. The geographic breakout, US vs. outside the US is also provided. Global Polymers W JO)

Chemistry Sub Total: Polymers AP 1 AP 4 AI' 9 Al' 7 AI' 6 Al' 5 AP 8 AP 2 LE 4 LE 2 LE 1 LE 3 Sub Total:

Sub Total: m* m FO 8 FO 4, FO 7 FO 6 FO 7 FO 5 FO 1 FO 2 FO 3 1 utm I I I I I 000113  121 C. Major Markets and End Uses This chart provides detail about the major markets that each of the four Apparel and Leather product lines goes to. This includes typical end uses and the major substrate types where 3M fluorochemicals are used. Information about relative size of the 3M product lines is also shown.

This information was developed using the market knowledge of 3M employees involved with these products.

112 00011L4 0 .d Apparel and Leather Fluorochemical Use, Distribution, and Release Overview Major Markets and End Uses Product 1 Estimated Volume Line I Market outerwear activewear dress clothing uniforms technical textiles other uniforms workwear casual clothing dress clothing footwear garment accessories upholstery textile & leather care dry cleaners fatliquor supplies End Use raincoats skiwear, golfwear suits, slacks jackets, slacks awnings, boat covers, protective clothing tents, backpacks, etc. shirts, pants, jackets shirts, pants shirts, pants shirts shoes, boots leather jackets, gloves, handbags, etc. chairs, sofas, etc. aerosols, shoe creams, polishes rainwear/ outerwear waterproof leather Typical Substrate poly / cotton polyester, nylon wool, p01y/ w001 wool, poly/ wool acrylics, poly/ cottons, other nylon, polyester, other cotton, poly/ cotton cotton, polylcotton cotton, poly/ cotton cotton, poly/ cotton pigskin, bovine pigskin, bovine, sheep, goat bovine, deer sheep D. Application Methods  Apparel Fabrics The following chart presents the methods of applying fluorochemical in this market segment. The percentages represent the mix of these methods based on fluorochemical volumes used. s D. Application Methods  Leather Tanneries The following chart presents the methods of applying fluorochemical in tbis market segment. The percentages represent the mix of these methods based on fluorochemical volumes used.

OOOli8 116 117

000119 .

, .

118 000120 119 000121 120 000122 III. Exposure Information  Apparel A. Distribution Chain This diagram represents the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used. This distribution chain represents the typical use of the product line; not every product will go through each step. This information is based on 3M internal lcnowledge of the marketplace. Distribution Chain Apparel 3M Mill Mfg Retail + Consumer + Dry Cleaner 0 0 A 4 E PC w ..; r + Formulator B. Points of Contact The Points of Contact diagram details the path the product takes within the distribution chain starting with the arrival of 3M product at the 3M customer. This information was compiled from 3M internal knowledge of the marketplace based on 3M technical service/ sales visits and general information from the customer interactions.

 `* 124 000126  .._._ I_. Points of Contact at Textile IMill Apparel Loading Dock MidDrug Room I bP@ +HoldingArca_, Returned cteaning to 3M Production Line + I I I +

Pad I I * +

Foam coating I I Tenter Frame Dryer I *

I Mechanical Processing Napping, Calendering etc.

4 Roll Sizing J (Fabric Scraps) I 1 r 1 Finishing 1 Points of Contact at Manufacture   Apparel Post cuing `r +

Pressing/ Steaming 4 I 126 Points of Contact at Dry Cieaner Apparel Dry Cleaner I jMil/ .

I Spray Application/ Dry in Closed system I Dry Clothing Pressed or Steamed 127 Cb 000129  000130 i :' 128 C. 3M F'luorochemical Exposure Information From the Points of Contact flow chart, each step in the customer use process is isolated. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an `XI".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during used.

Estimated Exposure Time: Indicates the amount of time that workers potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure..

Open or Closed System: Open system: is defined as one that allows workers to come in direct contact with 3M fluorochemical. Closed system: is defined as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochernical.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Information was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

*. B oool. 31 129 Exposure Information Apparel Most Likely Route of Estimated Exposure T Number of Workers Estimated Exposure Time Physical Form I 4 hrlday for 1 <50days/ year = Low 1 4hrslday for 50 I Open or Closed System Comments Point of Contact _

I Product dried on yarr Product dried on yarr Product dried on yarr X Product dried on yarr x x lOOdays/ yr = Medium Liquid Solid ( >la> o4d;:; t%, gh 1 Textile Mill InQestlon Dermal Inhalation (per plant)

I I I XI I 1 X 1 X X 1 2 1 2 Low incidence Rate.

1 III x x I I 1 3 I I 1 per x x machine 2 at oven X l 3 x x 1 3 1 per x x machine 2 at oven X 1 2 X 1 2 x x 1 3 X I I 1 2 Formulation & Development Work Low X Closed system X no/ very little potentia exposure. X Low X High X I High X I Exhaustion on Yarn I ~~ Knitting High I ' X I I Finishing High I I High I Exposure Information Apparel Most Likely Route of Estimated Estimated Point of Contact Exposure Number of Exposure Time Physical Form Open or Comments Workers cl hrlday for Closed System c50dayslyear = Low Whrslday for 50

hgeEtiOn Dermal Inhalation (per plant) loodays'yr = Medium >4hrslday for L' squid Solid Aerosol Vapor Open Closed MOOdaysIyr = Hlgh Mechanical Finishing (napping, calandering etc.) 2 per x x machine How many High x x X machines?

Roll Sizing X 1 per machine High X X QC Lab (Fabric) X l 2 Low X X Inventory (Fabric) 1 Low X X Loading Dock (Fabric) 1 Low X X Garment Manufacture  Pretreated Create Garment X >25 High x x X Post Curing l 3 Low X x x Pressing/ Steaming x x >25 Low X x x Packaging and Shipping X 3 5 Low X X s I I Exposure Information Apparel .

Most Likely Route of Estimated Estimated Point of Contact Number of Exposure Time Physical Form Open or Exposure Closed System Comments Workers <l hrlday for <50days/ year = Low Mhrsiday for 50

Ingestion Dermal Inhalation (per plant) `OWaWr = Medium >lhrslday for L' squid Solid Aerosol Vapor Open Closed >I OOdays/ yr = High Dry Cleaners Mix X l 2 Medium X X spray Application No/ very little potential Closed 1 2 Medium X X X exposure  closed Pressing/ system.

Steaming of Dry x x l 2 Medium X x x Clothing Consumer Consumer X X X Product dried on fabric I 0 0 D. Waste Stream/ Recycle Information  Apparel An approximation of the actual disposition of the chemical after it arrives at a customer site is given below. No exact values are known.

Waste chemical in liquid form as received that ends up in the sewer: Apparel e. g. Product adhering to inside of drum Spills Unused application mix Miscellaneous Percent of chemical poundage sold that ends up on waste yardage of fabric/ leather:

e. g. Second quality fabric/ leather Color samples Lab samples Cutting scraps that are recycled or landf2led Total percent of chemical poundage sold that ends up as waste or on waste goods:

000135 133   E. Product Volumes and Use Patterns This summary is based on individual products. It is a description of the application, chemistry, use pattern, exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which exposure was assessed. The route of exposure, the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following definitions apply: Process: use of fluorochemical containing product in another product. Application: use of fluorochemical containing product to treat a substrate End Use: use of treated substrate Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold in 1997. (M= lOOO)

Chemistxy: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

Amount of Fluorochernical Present: The fluorochemical concentration in process or end use.

% Residuals: Sum total of concentration of the mixture of fluorochemicals that are unreacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used; food, industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Environmental Fate: Identifies the most likely disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information.

134 Product Volumes and Use Patterns Global Product Portfolio .

ADDare Volume ES&

Application Sold 1997 mated % Product Process or (Ibs fluoro Resid Most Likely Route of Code End Use chemical) Chemlslty uals Use Pattern Exposure Environmental Fate Comments AP 8 Application X X x x Pad applied AP 8 End Use x x x x x x AP 1 Application X X x x Pad applied AP 1 End Use c m x x x x Product Volumes and Use Patterns Global Product Portfolio _ Aware1 dost Likely Route o ExDosure T T f EsU lated 91 Reskl uals Volume Sold 1997 Ibs fluoro chemlcal1 4ppllcation Jrocess or End Use Product Code I AP 2 AP 2 G ul c C C FO 2 FO 2 lttern Environmental Fate Comments Pad applied 4ppllcation X X X X End Use X X X X X 4ppliCaUOfl End Us x Product Volumes and Use Patterns Global Product Portfolio .

ADDare!

nest Likely Route 01 r h l Volume Sold 1997 :Ibs fluoro chemical) Esti Wed % Resid uals Product Code . 3roc8ss or End Use Use I X I X X ttern ironer ltal F X Chemistry Comments posui .e 4pplication Pad applied AP 3 AP 3 EnU Use X X X x X X x X AP 4 AP 4 AP 5 Ap 5 4ppllcatlon End Use 4pplication End Use X X Product Volumes and Use Patterns Global Product Portfolio _

lost Likely Route of EsU

ated % Volume iold 1997 bs fluor@ hhemical) 4ppllcaUon ?roc8ss or End Use `roduct Code Use Pattern ~ ltal F;

X Comments pow ronm 4P 6 4pplicaUon Pad applied 4P4 End Use X X X X Application AP 7 X AP 7 End Use X X X IV. Exposure Information  Leather 000141 139 A. Distribution Chain This diagram represents the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used. This distribution chain represents the typical use of the product line; not every product will go through each step. This information is based on 3M internal knowledge of the marketplace.

140 Distribution Chain 3M b Tannery b M fg b Retail b Consumer A A A I L I I I I b Formulator B. Points of Contact The Points of Contact diagram details the path the product takes within the distribution chain starting with the arrival of 3M product at the 3M customer. This information was compiled fi om 3M internal knowledge of the marketplace based on 3M technical service/ sales visits and general information from the customer interactions.

l 142 Points of Contact at Tannery Leather Loading Dock Retanning Application by Drum Setting Out Drying Stretch/ Condition /F C Application by Roller Coat, Spray or Chemical Milling / Plating/ F? j 000145 Points of Contact at Manufacture Leather Cut & Sew 000146 144 C. 3M Fluorochemical Exposure Information From the Points of Contact flow chart, each step in the customer use process is isolated.. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an `x".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during used.

Estimated Exposure Time: Indicates the amount of time that workers potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure.

Open or Closed System: Open system: is defined as one that allows workers to come in direct contact with 3M fluorochemical. Closed system: is detined as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochemical.

Comments: Provides additional descriptive information.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Information was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

n .' c 145 S Exposure information Leather .

Tsyte Of / ;sf) Ex;;;;"

<50dayslyear = Low 14hrsIday for 50

Ingestion Dermal Inhalation (per plant) 100days'yr = Mediurr >4hrslday for MOOdays/ yr = High . d.  Physical Form Open or Closed System Liquid Solid Aerosol Vapor Open Closed Comments innery X X Low incidence Rate. Loading Dock (Spills) QC Lab Formulation & Development Work X X l 2 l 2 Inventory (Chemical)

Mix Retanning  Application by Drum Setting Out Drying `tretch/ Condition l 2 Low X Closed system X no/ very little potential X 1 2 Medium High X exposure. X x x 1 2 Medium High X X x x X l 2 Medium High X x x X 1 2 Medium High X x x X l 2 Medium High X X Exposure Information Leather '

Estimated Exposure Time 4 hrlday for 1 Physical` Form 4Odayslyear = Low l rlhrs/ day for 50 t Open or Closed Systen Closet f T T n Estimated Number 01 Workers (per plant) Most Likely Route of Exposure Point of Contact Comments C II Ihalation Dermal x X Solid Aerosol Vapor Open x X X X X 1 2 1 2 Medium High X X 1 2 Medium High I 1 2 Medium High I / I .  Garment, Accessory, Shoe or Uphc X ~ X x x X X jlstety Manufacture Buffing/ Sanding C Application by Roller Coat, Spray or Chemical Milling Plating/ Embossina Semi closed spray X application X Sorting/ Measuring/ Wrapping/ Shipping X X X Medium High x x X I Wrapping and 1 Medium High X X X X Product dried on leather X Consumers 1 4 * D. Waste Stream/ Recycle Information  Leather An approximation of the actual disposition of the chemical after it arrives at a customer site is given below. No exact values are lu~ own.

Waste chemical iu liquid form as received that ends up in the sewer: Leather e. g. Product adhering to inside of drum Spills Unused application mix Miscellaneous Percent of chemical poundage sold that ends up on waste yardage of fabric/ leather:

e. g. Second quality fabric/ leather Color samples Lab samples Cutting scraps that are recycled or landfilled Total percent of chemical poundage sold that ends up as waste or on waste goods:

148 000150 E. Product Volumes and Use Patterns This summary is based on individual products. It is a description of the application, chemistry, use pattern, exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which exposure was assessed. The route of exposure, the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following definitions apply: Process: use of fluorochemical containing product in another product. Application: use of fluorochemical containing product to treat a substrate End Use: use of treated substrate Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold in 1997. (M= lOOO)

Chemistry: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

Amount of Fluorochemical Present: The fluorochemical concentration in process or end use.

% Residuals: Sum total of concentration of the mixture of fluorochemicals that are unreacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used; food, industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of expokure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Environmental Fate: Identifies the most likely disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information.

** .

E 149 000151 Product Code LE 4 LE 4 LE 2 LE 2 LE 1 z LE 1 LE 3 LE 3 Application Process 01 End Use Application End Use Application End Use . .

End Use End Use Volume Sold 1997 (Ibs fluoro chemical) Product Volumes and Use Patterns Global Product Portfolio . Leather I I I Most Likely Route of I Indust Com

Food rial martial Use Pattern 1 Environmental Fate hlQeS

Uon Landfill X X X X X X X X X X X X X X Comments Primary applilcation 1; by drum, material ma be roll or spray applied In a closed system.

Primary applilcation ii by spray.

l Application Product Process or Code End Use I I Volume Sold 1997 [lbs fluoro chemical) Chemistry Product Volumes and Use Patterns Global Product Portfolio ' Leather ES&

mated % Resid uals Use Pattern Most Likely Route of EXDOSUre Environmental Fate 1 Comments Product COdI3 Volume Volume Esli Esli Application Sold 1997 Application Sold 1997 matacl% matacl% Process or (Ibs fluoro Process or (Ibs fluoro Resid Resid End Use chemical) Chamlstry End Use chemical) Chamistry uals uals I FO 6 Process FO 6 End Use Product Volumes and Use Patterns Global Product Portfolio . Leather Food Route ofI 3M Aftermarket Application and Retail Consumer Business FLUOROCHEMICAL USE, DISTRIBUTION AND RELEASE OVERVIEW RETAIL MARKETS PRODUCTS COMMERCIAL MARKETS PRODUCTS Aftermarket Application and Retail Consumer Business Foreword This report is a comprehensive look at exposure to 3M's fluorochemicals in the Aftermarket Application and Retail Consumer businesses. It attempts to answer the following questions:

+ What products are customers exposed to? + Where does exposure happen? + What type of exposure is it?

Use of 3M fluorochemicals in the Aftermarket Application and Retail Consumer markets is complex and global. Markets served are highly fragmented and involve a number of 3M fluorochemical products that are used as ingredients in end use 3M formulations. The 3M formulations are used by 3M customers to treat various substrates such as carpets, floors, upholstery, apparel.

Sources Lnforrnation for this report was developed soIely from internal 3M sources. These include:

+ Knowledge of product handling and use practices from field sales and technical personnel + Best estimates of end use applications from known customer activities. + Internal sales reports + Knowledge of worldwide activities (where applicable) by St Paul based personnel How To Read This ReDort Situation Analysis: Provides background on business and products.

Distribution Chain and Points of Contact: Follows the path of a 3M fluorochemical in a 3M end use product from the manufacturing process, where applicable, through the distribution chain to final end user and its end use mode. Objective is to identity ail significant points of contact with 3M fluorochemicals  from arrival on customer's loading dock through product usage and disposal.

Exposure Information: Attempts to quantify type and length of exposure and number of workers exposed to 3M fluorochemicals within the distribution chain.

Product Volumes and Use Patterns: **

Combines 3M product detail with the exposure routes to provide a summary of total business exposure by product type.

000156 154 Aftermarket Application and Retail Consumer Business Retail Market Products TABLE OF CONTENTS Fluorochemical Identities Chart Situation Analysis Distribution Chain & Points of Contact FC Exposure Information Summary FC Exposure Information Charts Product Volumes & Use Patterns Summary Product Volumes & Use Patterns Chart 155 FLUOROCHEMICAL IDENTITIES CHART RETAIL MARKETS PRODUCTS GENERIC CAS CODE NUMBER CAS NAME FC CHEMISTRY NAME K 1, HC 2, I w 3. AA l. I I I I I AA 2 .I I 1 I I HC 4 HC 5, AA 3 . Aftermarket Application and Retail Consumer Business RETAIL MARKET PRODUCTS Situation Analysis BUSINESS DEFINITION Home treatment of upholstery, carpet, auto interiors and apparel by individual retail consumers.

KEY PRODUCTS Aerosol can spray cleaners and protectors for home use  cleaners for fabric, upholstery, carpet; protectors for fabric, upholstery, carpet, leather. All products in this category are manufactured by independent, non 3M manufacturing facilities under contract with 3M.

KEY MARKETS Grocery, club, hardware, auto parts stores.

KEY CUSTOMERS Individual retail consumers.

INTENDED USE Occasional home use on carpets, upholstery, apparel, auto interiors, shoes and boots.

EXPECTED USE Home use. Fabric protector  two cans per year per product user. Other products  one can or less per year per product user.

157 Aftermarket Application and Retail Consumer Business Retail Markets Products Distribution Chain and Points of Contact The following information describes the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used.

The distribution chain for the Retail Markets Products is not complex. Product is shipped from the manufacturer to the retailer with the possibility of one or more warehousing steps in between. During distribution, the product is in sealed aerosol cans. No significant exposure to the 3M product is anticipated during distribution. No charts are provided for the distribution chain.

The following charts provide points of like& contact with the 3M fluorochemical and fluorochemical containing product during manufacture and customer use.

* This information was compiled from 3M internal knowledge of the manufacturing process and marketplace based on 3M technical service/ sales visits and general information from customer interactions.

158 Staging LG Area Receiving Dock + Warehouse I 1 Weigh Drum Station Disposal * QA f Charge Rinsate Sample Mix Tank Disposal c I 1 A Sample Ship to Customer 000161 159 RETAIL MARKETS PRODUCTS HC 1, HC 4 APPLICATION d Purchase product 1 ?I Arrange furniture or clothing for treatment Spray on furniture, carpet or clothing Arrange furniture or clothing for drying Let treated article dry I 1 Use treated article p 160 000162 0 RETAIL MARKETS PRODUCTS HC 2, HC 3 APPLICATION  Purchase product v Store product for fku e use V Spray on furniture, carpet or clothing I Wipe onto fabric 1 J Let treated 1 to loosen soil 1 L I article dry 161 C? @00163 RETAIL MARKETS PRODUCTS HC 5 APPLICATION fl Purchase product ]

Store product for future use V Spray on shoes, other leather items Use treated article Arrange treated article for drying Let treated article dry .

* 162 000164 RETAIL MARKETS PRODUCTS AA l, AA 3 APPLICATION Purchase product Store product for f& m e use  Open car doors, windows <

V Spray onto car interior +

Let car interior dry V Use car 163 000165 RETAIL MARKETS PRODUCTS AA 2 APPLICATION p Purchas; product 1 1 Let car interior dry 1 + l Use car 164 Aftermarket Application and Retail Consumer Business Retail Markets Products 3M Fluorochemical Exposure Information Summary Based on the Distribution Chain/ Points of Contact flow chart, each principal step in the manufacture and customer use process is isolated. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern. Use pattern includes steps in manufacture and end use application by the retail consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure at each point of contact  ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during use. During end use application, "number of workers" represents number of occupants of residence present during and after product use.

Estimated Exposure Time: Indicates the amount of time that workers/ end users potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure.

Open or Closed System: Indicates open/ closed status of product at time of handling as follows: Ooen system is defined as one that allows workers to come in direct contact with 3M fluorochemical. Examples of open systems are mixing kettles, open drums and bottles. Closed system is defined as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochemical. Examples of closed systems are sealed drums and filled aerosol containers.

Comments: Provides additional descriptive information.

Disposal: Indicates most likely method of disposal of the end use product  landfill, recycling or incineration. All end use products represented in these charts are packaged in aerosol cans. Disposal into the waterways or sewer system is not expected.

This information is based on 3M internal knowledge and best estimates on how customers handle 3M fluorochemical products. Information was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

165 000167 3Y FLUOROCHEMICAL EXPOSURE INFORMATION RETAIL MARKETS PRODUCTS PRODUCT = l c 1 Point of Contact (MostL ~hvsical Form I Ownor IComments I I ikely Exposure Route( s) Estimated I ' Number of bsure Time I Closed Svstam I I Closed containers.

CHARGING 1 x 1 MIXING I I x 1 6 I I 3 4 x 1 I I 1 x 1 QA SAMPLING I Y I x j J x 1 Same set of people Y I I I I " for these four jobs APPLICATION: 1 I I I I I I DURING I I I I I I I APPLlCATlON byuser X X X 1 0.02 2 X X X byothersin house X X Assumes 2.5 per 1.5 0 0 X X family I AFTER I I I I I I I I I I I APPLICATION  by user X X 1 ? 2 X X  by others in house X X 1.5 Touching carpet ? 2 X X I Touching carpet 3M FLUOROCHEMICAL EXPOSURE INFORMATION RETAIL MARKETS PRODUCTS Point of Contact 1 Most Likely Expc PRODUCT = HC 2 Phvsical Form I Ooenor IComments I I I . I Closed System I I APPLICAllON byuser X X 1 7 2 X X  by others in house X X 1.5 ? Touching wt catpet 2 X X Touching wet carpet AFTER DRYING 2.5 ? ? X I Physical contact; dust I I I DISPOSAL LANDFILL RECYCUNG INCINERATION 1 I X X X X X X X 000169 167 3M FLUOROCHEMICAL EXPOSURE INFORMATION RETAIL MARKETS PRODUCTS [Point of Contact PRODUCT = HC 3 1 Most Likely Exposure Route( s) 1 Estimated I Estimats 1 Physical Form I Openor IComments I 1 Number ofI Expsure Time 1 Cl& d System I I APPUCATION: DURING APPLICATION  bv user X X X 1 0.03 1 X X X Assumes 2.5 Far  by others in house X X 1.5 0 0 X X family IMMEDIATELY AFTER APPLICATI ION I ! r X X 1 ? 2 X X Moving wat furniture?  by others in house X X 1.5 7 2 X X I 1 XU FLUOROCHEMI~ L ~POSURE INFORMATION RRAIL WWJWB PRODUCTS PRODUCT = HC 4 AFTER DRYING Physical contact; dust LANDFILL 7 ? X X X RECYCLING ? ? X x INCINERATION ? ? I x I x I I I I oooim I 169 3M ~u10wckwdlCAL EXPOSURE INFORMATION RETAlL MARKETS PRODUCTS .

Point of Contact PRODUCT = HC4 Most Likely Exposure Route( s) Estimated Estimate Physical Form Open or Comments Number of Exposure Time Closed System I I I ] Cl , I ; 1 f I I I I ' <l 1 ] x 1 1 :: Closed containers.

3 I2 14 IX1 I I I I Y Spill response only, I . . .  CAPPIN, PACKAGINb , I I WAFSHOUF ' I I SHIPPING CONSUMER APPLICATION: DURING I I I I I I I I I 1 I I I APPUCATION byuser X X X 1 0.02 1 X X X  by others in house Assumes 2.5 per X X I .5 0 0 X X I family IMMEDIATELY AFTER APPLICATION  by user X Touching wet X 1 ? 2 X X surface?  by others in house X X 1.5 ? 2 X X AFI ER DRYlNG 2.5 ? ? X Physical contact DISPOSAL LANDFILL X X X RECYCLING , X X INClNERATlON ] X X 170 3M FLIJOROCHEMICAL EXPOSURE INFORMATION RETAIL MARKETS PRODUCTS PRODUCT = M 1 surface; assume 2.5 171 IMMEDIATELY AFTER oLs I LANDFILL X X X RECYCLING I X X INCINERATION X X 3~ FUJOROCHEMICAU EXPOSURE lNFORMAllON RErblLwRKErsPwDucTs 0001xi L 173 _ Aftemarket Application and Retail Consumer Business Retail Markets Products Product Volumes and Use Patterns Summary This summary is based on individual products. It is a description of the application, chemistry, use pattern exposure and environmental fate.

Product Code: Generic product description.

Application, Process or End Use: The perspective from which information was assessed. The route of exposure, the concentration of fluorochemical, the use pattern and the environmental fate may vary with application process or end use  products can be used for more than one application. Generally the following definitions apply: Process: use of fluorochemical containing product in manufacture of another product; may include dilution prior to commercial distribution. Application: use of fluorochemical containing product to treat a substrate; may include product dilution by end user. End Use: use of treated substrate .

Volume FC Solids Sold in 1997: Pounds of fluorochemical solids sold per product in 1997 expressed in thousands (000). FC solids less than 1000 lb are indicated by approximate pounds displayed inside parentheses ().

Chemistry: Generic description of fluorochemical ingredients. Full chemical names are listed at the beginning of this section.

Amount of Fluorochemical Present: The fluorochemical concentration present in product during process or end use.

% Residuals: Sum total of concentration of the mixture of fluorochemicals that are unreacted or partially reacted starting materials or intermediates.

Use Pattern: Indicates the major sector where product is used; food, industrial, commercial, and consumer.

Most Likely Route of Exposure: Identifies three potential routes of exposure; ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Environmental Fate: Identifies the most likely disposal route for the product; landfill, incineration, waste water treatment, and directly to water.

Comments: Provides additional descriptive information.

0001'76 174 Manufacture HC 1 Process APP End HC 2 HC 3 APP * .

End APP End HC 4 App Product Volumes and Use Patterns Product Volumes and Use Patterns Retall Markets Products Retall Markets Products Volume FC Amount Solids FC Residuals Sold FC Chemistry Present in product Most Use Pattern Likely Route( s) of Exposure Environmental Fate Comments 1997 W8S. b (000 lb) (w(% of (wt% of pdl) Food lllatld cm cagvw W& f lrhaladon Ingesdm Trerbnml landlill. Small percal X X X I X X X X X spent containers typically end up in 7 landlill. Small percal X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X  X. X X X X X X X X X X X x  X X X X X X Aftermarket Application and Retail Consumer Business End of Retail Markets Products Section 0001"/ 8 176  Aftermarket Application and Retail Consumer Business Commercial Markets Products TABLE OF CONTENTS Fluorochemical Identities Chart Situation Analysis Distribution Chain & Points of Contact FC Exposure Information Summary FC Exposure Information Charts Product Volumes & Use Patterns Summary Product Volumes & Use Patterns Chart 177 FLUOROCHEMlCAL IDENTITIES CHART COMMERCIAL MARKETS PRODUCTS GENERIC CAS CODE NUMBER CAS NAME FC CHEMISTRY NAME CC l, cc 2 HC 6 PC I, PC 2 Aftermarket Application and Retail Consumer Business COMMERCIAL MARKETS PRODUCTS Situation Analysis BUSINESS DEFINITION Commercial Markets Products have two distinct product categories:

A) Cleaning and protection of commercial building and residential upholstery and carpet with 3M products by professional applicators. Cleaning and maintenance of floors, walls and other hard surfaces in commercial buildings by professional staff such as in house custodians and independent contract cleaners.

B) Treatment of consumer and professional film negatives by commercial photo processing facilities.

KEY PRODUCTS A) 3M protectors and cleaner/ protectors for commercial building and residential carpets and upholstery manufactured as liquids intended for spray application. (Hard surface cleaning products are not considered in the following sections because use of fluorochemicais in the formulations is at a very low level  perhaps 0.1% of the formulation or less  and because similar products and use patterns are considered in other market sections of this 3M assessment report.)

B) Liquid photocurable coating for film negatives. Cured, durable coating provides scratch and soivent protection for photographic film negatives.

KEY MARKETS A) Janitorial supply, professional supply houses B) Commercial film processing facilities KEY CUSTOMERS A) Furniture retailers, building maintenance personnel, professional residential carpet cleaning services B) Individual retail consumers (photo negatives) and commercial/ professional photographers.

INTENDED USE A) Treatment of carpet and upholstery for ultimate use in commercial buildings and residences B) Machine applied and cured (closed system) in a very thin coating on fihn negatives at commercial film processing fbcilities.

EXPECTED USE PATTERN A) Liquid water based products applied using low pressure or paint type spray apparatus. Articles are treated at the customer residence, in commercial buildings, or ir `he furniture retailers establishment.

i3) Film protector is applied by commercial applicators only. commercial and retail consumers. Cured, dry, treated fi'", is handled by 000181 0 179 __,.. .  Aftermarket Application and Retail Consumer Business Commercial Markets Products Distribution Chain and Points of Contact The following information describes the path the 3M product takes from the time it leaves 3M to its ultimate end use. It represents an overview of the significant points where the 3M product may be handled and used.

The distribution chain for the Commercial Markets Products is not complex. In general, product is shipped from the manufacturer to the distributor who sells to the end user. One or more warehousing steps may be involved. During distribution, the product is in sealed containers. In two instances, 3M product is reformulated to end use formulation or let down from concentrate to end use concentration in the distribution process. No charts are provided for the distribution chain. Reformulation and let down are considered in the points of contact charts.

The following charts provide points of likely contact with the 3M fluorochemical and fluorochemical containing product during manufacture and customer use.

This information was compiled from 3M internal knowledge of the manufacturing process and marketplace based on 3M technical service/ sales visits and general information from customer interactions.

.

180 000182 1 COMMERCIAL MARKETS PRODUCTS 1 CC l, CC 2, HC 6 MANUFACTURE Warehouse ( Receiving Dock r staging Area Weigh Station I + Drum Disposal w Charge Rinsate Mix Tank Disposal V + QA f Adjust pH, Sample solids I I 1 Package 1 1 Warehouse 1 7 Ship to Customer 000183 181 COMMERCIAL MARKETS PRODUCTS CC 1 MANUFACTURE (Via Formulator)

J(

Formulation Area Dilute with water. Add chelator, fragrance. +

OK I Adjust batch pH 4 QA Sample l Test for pH Package cc 1  Warehouse Dilute prior to use by 1 applicator 182 COMMERCIAL MARKETS PRODUCTS PC 2 Manufacture (Via Formulator)

Warehouse 4 PC 1 Rec'd fi om 3M 1 Staging Area Drum Disposal Charge QA I Mix Tank I Rinsate Sample 4 Disposal I r I water i Fill, Package PC 2 Reject Disposal ship to Customer #

183 COMMERCIAL MARKETS PRODUCTS CC 1 APPLICATION CC 1 diluted in warehouse; truck tanks filled Transport to customer residence Spray on furniture, carpet JI Reposition furniture for drying +

Let treated article dry I 1 I .

184 COMMERCIAL MARKETS PRODUCTS PC 2 APPLICATION Warehouse f  PC 2 received I I I I +

i Retailer i i Ship to furniture warehouse retailers I I I Unpackage furniture; prepare for treatment ~~

Spray booth ( ) or Enclosed area; no ceiling; ( ) or 1 Designated area; no enclosure Move furniture 1 sprayers )

p Ship to customer k 1 .

Customer uses Customer picks treated article up tiiture 185 COMMERCIAL &lARKETS PRODUCTS HC 6 APPLICATION 1 Store in facility k

1 HC 6 Rec'd from 3M Pour portion into machine reservoir (multiple fills from one container) I i Container disposal + Clean equipment 1 Coated film sent to customer Disposal 1 186 Aftermarket Application and Retail Consumer Business Commercial Markets Products 3M Fluorochemical Exposure Information Summary Based on the Distribution Chain/ Points of Contact information, each principal step in the manufacture and customer use processes are isolated. All information is based on the use and handling of 3M fluorochemicals, materials containing 3M fluorochemicals and articles treated with 3M fluorochemicals. The following information is presented:

Point of Contact: Describes individual steps in the use pattern. Use pattern includes steps in product manufacture and end use application by the professional applicator.

Most Likely Route of Exposure: Identifies three potential routes of exposure at each point of contact  ingestion, dermal, and inhalation. Marks the most likely route of exposure with an "X".

Estimated Number of Workers: Indicates the number of workers who may have potential for exposure during use. During end use application, "number of workers" represents number of occupants of residence present during and a. fler product use as well as the professional applicator.

Estimated Exposure Time: Indicates the amount of time that manufacture workers/ end users potentially may be exposed during use.

Physical Form: Indicates the physical state (liquid, solid, aerosol, or vapor) of the product at time of exposure.

Open or Closed System: Indicates open/ closed status of product at time of handling as follows: Open system is defined as one that allows workers to come in direct contact with 3M fluorochemical. Examples of open systems are mixing kettles, open drums and bottles. Closed system is defined as one that, under normal conditions, does not allow workers to come in direct contact with 3M fluorochemical. Examples of closed systems are sealed drums and filled sealed containers.

Comments: Provides additional descriptive information.

Disposal: Indicates most likely method of disposal of the end use product  sewer, landfill, recycling or incineration.

This information is based on 3M internal knowledge and best estima& s on how &stomers handle 3M fluorochemical products. Information was compiled from available 3M sources including sales, technical service, marketing and regulatory expertise.

000189 187 3M RUOR~ HEMICAL DCPOSIJ~ INFOFthlATlON COMMERCIAL MARKETS PRODUCTS PRODUCT = ccl. CC. 2 I Estimated I I I I I  tv applicator X  by others in houee X 1 Cl X X Moving wet fumMe7 Walking/ touching wet 2 4 X x SUrfaCe?