DuPont 2008 Annual Report Download - page 46

Item 7. Management’s Discussion and Analysis of Financial Condition and
Results of Operations, continued
equipment, weather-resistant/breathable apparel and non-stick cookware. Fluorotelomers are used to make soil,
stain and grease repellants for paper, apparel, upholstery and carpets as well as firefighting foams and coatings.
A form of PFOA (collectively, perfluorooctanoic acid and its salts, including the ammonium salt) is used as a
processing agent to manufacture fluoropolymer resins and dispersions. For over 50 years, DuPont purchased its
PFOA needs from a third party, but beginning in the fall of 2002, it began producing PFOA to support the
manufacture of fluoropolymer resins and dispersions. PFOA is not used in the manufacture of fluorotelomers;
however, it is an unintended by-product present at trace levels in some fluorotelomer-based products.
DuPont Performance Elastomers, LLC (DPE) uses PFOA in the manufacture of raw materials to manufacture
Kalrez»perfluoroelastomer parts. PFOA is also used in the manufacture of some fluoroelastomers marketed by
DPE under the Viton»trademark. The wholly owned subsidiary is a part of the Performance Materials segment.
PFOA is bio-persistent and has been detected at very low levels in the blood of the general population. As a result,
the EPA initiated a process to enhance its understanding of the sources of PFOA in the environment and the
pathways through which human exposure to PFOA is occurring. In 2005, the EPA issued a draft risk assessment on
PFOA stating that cancer data for PFOA may be best described as “suggestive evidence of carcinogenicity, but not
sufficient to assess human carcinogenic potential” under the EPA’s Guidelines for Carcinogen Risk Assessment. At
the EPA’s request, the Science Advisory Board (SAB) reviewed and commented on the scientific soundness of this
assessment. In its May 2006 report, the SAB set forth the view, based on laboratory studies in rats, that the human
carcinogenic potential of PFOA is more consistent with the Guideline’s descriptor of “likely to be carcinogenic.”
However, the report stated that additional data should be considered before the EPA finalizes its risk assessment of
PFOA. The EPA has acknowledged that it will consider additional data, including new research and testing, and has
indicated that another SAB review will be sought after the EPA makes its risk assessment. DuPont disputes the
cancer classification recommended in the SAB report. Although the EPA has stated that there remains considerable
scientific uncertainty regarding potential risks associated with PFOA, it also stated that it does not believe that there
is any reason for consumers to stop using any products because of concerns about PFOA.
DuPont respects the EPA’s position raising questions about exposure routes and the potential toxicity of PFOA and
DuPont and other companies have outlined plans to continue research, emission reduction and product stewardship
activities to help address the EPA’s questions. In January 2006, DuPont pledged its commitment to the EPA’s
2010/15 PFOA Stewardship Program. The EPA program asks participants (1) to commit to achieve, no later than
2010, a 95 percent reduction in both facility emissions and product content levels of PFOA, PFOA precursors and
related higher homologue chemicals and (2) to commit to working toward the elimination of PFOA, PFOA precursors
and related higher homologue chemicals from emissions and products by no later than 2015. In October 2008, (for
the year 2007), DuPont reported to the EPA that it had achieved a 98 percent reduction of PFOA emissions in
U.S. manufacturing facilities. The company achieved about a 97 percent reduction in global manufacturing
emissions, exceeding the EPA’s 2010 objective. DuPont will work individually and with others in the industry to
inform EPA’s regulatory counterparts in the European Union, Canada, China and Japan about these activities and
PFOA in general, including emissions reductions from DuPont’s facilities, reformulation of the company’s
fluoropolymer dispersions and new manufacturing processes for fluorotelomers products.
In February 2007, DuPont announced its planned commitment to no longer make, use or buy PFOA by 2015 or
sooner if possible. DuPont has developed PFOA replacement technology and successfully used this technology in
its global manufacturing facilities to produce test materials for all major fluoropolymer product lines. DuPont has
begun to supply fluoropolymer products made without PFOA to customers for testing in their processes, and is
working to obtain the appropriate regulatory approvals for this technology.
In the meantime, DuPont introduced Echelon
TM
technology which reduces PFOA content by 99 percent in aqueous
fluoropolymer dispersion products. DuPont has now converted customers representing over 95 percent of the sales
volume for these products to the newly formulated Echelon
TM
technology. In the first quarter 2008, DuPont
introduced its next generation fluorotelomer products. The products are marketed as DuPont
TM
Capstone
TM
products for use in home furnishings, fire fighting foam, fluorosurfactants, and leather goods. Additional
products will be introduced for paper packaging, textiles, and other end use markets pending appropriate
regulatory approvals.
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Part II