PFOA Stewardship Program Reporting Guidance
- Explanation of Suggested Reporting Forms
- Minimizing CBI Claims
- Explanation of the Term "Product"
- Amendments, Clarifications to Guidance
On October 11, 2006, EPA issued the PFOA Stewardship Program Reporting Guidance (PDF)(34 pp., 254 KB About PDF) as suggested guidance to companies participating in the voluntary 2010/15 PFOA Stewardship Program. The guidance provides a consistent approach to reporting emissions and product content information. The guidance applies to both the baseline year report due on October 31, 2006, and the subsequent annual progress reports due in October of each following year.
In addition to reporting baseline year information in October 2006, companies were encouraged to submit a simultaneous initial progress report to capture reductions in emissions and product content that have already been achieved since the baseline year.
The guidance document is based on a reporting form originally used in the Use and Exposure Information Project (UEIP), which was developed in the 1990's through a collaborative effort between industry representatives and EPA's Office of Pollution Prevention and Toxics (OPPT). That form was designed specifically to minimize the need for submitters to assert Toxic Substances Control Act (TSCA) Confidential Business Information (CBI) claims, and has been used successfully for more than a decade by some of the companies currently involved in the PFOA Stewardship Program. The original UEIP form was modified to make it more closely suit the objectives of the PFOA Stewardship Program. Read more information on the original UEIP.
Explanation of Suggested Reporting Forms
The guidance document provides two sets of suggested reporting forms:
- A summary table, which is intended to be used on the EPA Website to allow easy public access to the essential information; and
- A more extensive form, which is intended to provide sufficient detail to back up the summary table.
The suggested summary table is designed to aggregate the information included within the Stewardship Program goals for each company. It provides a way for each company to report progress on achieving the targeted reductions for their U.S. and global operations in:
- Facility emissions to all media; and
- Product content of PFOA, PFOA precursors, and higher homologue chemicals
The more detailed reporting form is designed to provide sufficient facility- and product-specific information for EPA to understand the source of the aggregated information in the summary table.
Minimizing CBI Claims
Given the public nature of the PFOA Stewardship Program, companies are encouraged to minimize CBI claims in completing the forms, but to ensure the inclusion of sufficient detail for EPA analysis.
Explanation of the Term “Product”
The term "product," used in connection with the "product content" parameter of the PFOA Stewardship Program, refers to basic fluorochemical substances or mixtures that are manufactured by the eight fluoropolymer and telomer companies participating in the program.
For example, the chemical substance polytetrafluoroethylene may be sold as a commercial chemical product in the form of a solid or as a diluted aqueous dispersion. Other fluoropolymers, fluorotelomer-based polymers, and telomer monomers that are in commerce would be included in the definition of "product" because they are commercial chemical substances. These would include, for example, substances sold to formulators as constituents for incorporation into other formulated products such as inks, paints, cleaners, and surface treatment applications for carpets, textiles, leather, and paper.
The final formulations themselves and the articles to which they may be applied --such as cookware, carpet, textiles, and paper --would not be included in the definition of "product" for the purpose of reporting under the PFOA Stewardship Program. These formulations and products are produced by other companies beyond the scope of the Program. However, as participating companies reduce the content of PFOA and related chemicals in their products, formulations and articles made using those products will also contain less PFOA.
Amendments, Clarifications to the Guidance
- Reporting Guidance Clarifications for the Progress Reports, September 7, 2007
- Additional Clarifications on Reporting Guidance, (PDF), October 26, 2006 (with revised reporting forms) (22 pp., 136 KB, About PDF)
- Clarifications on Reporting Guidance, October 20, 2006