3M 2006 Annual Report Download - page 98

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complying with these laws and regulations, defending personal injury and property damage claims, and modifying its
business operations in light of its environmental responsibilities. In its effort to satisfy its environmental responsibilities
and comply with environmental laws and regulations, the Company has established, and periodically updates, policies
relating to environmental standards of performance for its operations worldwide.
Remediation: Under certain environmental laws, including the United States Comprehensive Environmental Response,
Compensation and Liability Act of 1980 and similar state laws, the Company may be jointly and severally liable, typically
with other companies, for the costs of environmental contamination at current or former facilities and at off-site locations.
The Company has identified numerous locations, most of which are in the United States, at which it may have some
liability. Please refer to the following section, "Accrued Liabilities and Insurance Receivables Related to Legal
Proceedings" for more information on this subject.
Regulatory Activities: As previously reported, the Company has been voluntarily cooperating with ongoing reviews by
local, state, national (primarily the U.S. Environmental Protection Agency (EPA)), and international agencies of possible
environmental and health effects of perfluorooctanyl compounds (perflurooctanoiFDFLGRU³3)2$´DQGSHUIOXRURRFWDQH
VXOIRQDWHRU³3)26´DQGUHODWHGFRPSRXQGV$VDUHVXOWRI its phase-out decision in May 2000, the Company no longer
manufactures perfluorooctanyl compounds except that a subsidiary recovers and reF\FOHV3)2$IRULQWHUQDOXVHLQ
production processes.
In January, 2006, the EPA announced a voluntary initiative under which eight companies, including the Company and
its subsidiary referenced above, would commit to reducHHPLVVLRQVDQGSURGXFWFRQWHQWRI3)2$E\E\
over levels in 2000, and to commit to working toward the HOLPLQDWLRQRI3)2$IURPHPLVVLRQVDQGSURGXFWVE\
The Company is well positioned to comply with these objectives in light of its phase out of perfluorooctanyl chemistry
LQ,Q2FWREHURIWKH&RPSDQ\VXEPLWWHGLWs initial report under this voluntary initiative.
,Q-DQXDU\WKH(3$LVVXHGDGUDIWULVNDVVHVVPHQWIRU3)2$DQGVXEPLWWHGLWIRUUHYLHZWRWKH(3$6FLHQFH
$GYLVRU\%RDUG7KH(3$GRFXPHQWH[SUHVVHVWKH(3$¶VSUHliminary assessment in terms of the margin of exposure
between the levels of that compound that cause adverse health effects in laboratory animals and the levels found in
human blood sera in the U.S. population. A panel convened by the Science Advisory Board issued a draft report in
-XQHDQGDUHYLVHGGUDIWLQ-DQXDU\7KH6FLHQFHAdvisory Board has conditionally approved the revised
draft of the panel, which among other things recoPPHQGHGWKDW(3$FODVVLI\3)2$XQGHUWKH(3$¶VKD]DUG
GHVFULSWRURI³OLNHO\WREHFDUFLQRJHQLFWRKXPDQV´7KHVHlection by the panel of this descriptor was based upon the
view that data from two studies show WKDW3)2$LVDPXOWLVLWHFDUFLQRJHQLQrats. The Company disagrees with this
classification since the panel did not consider other important data. The EPA is expected to make a final risk
assessment based on its work to date and additional data not considered by the Science Advisory Board. In January
WKH(3$VWDWHGWKDWWRGDWHLW³LVQRW aware of any studies specifically reODWLQJFXUUHQWOHYHOVRI3)2$H[SRVXUH
WRKXPDQKHDOWKHIIHFWV´
The EPA signed a Memorandum of Understanding with the Company and Dyneon LLC, a subsidiary of the Company, in
2FWREHUXQGHUZKLFKWKH&RPSDQ\LVPRQLWRULQJWKHSRWHQWLDOSUHVHQFHRI3)2$DWDQGDURXQGWKH&RPSDQ\¶V
manufacturing facility in Decatur, Alabama. Activities are in progress pursuant to this Memorandum of Understanding.
5HJXODWRU\DFWLYLWLHVFRQFHUQLQJ3)2$DQGRU3)26FRQWLQXHLQ(XURSHDQGHOVHZhere, and before certain international
bodies. These activities include gathering of exposure and use information, risk assessment, and consideration of
UHJXODWRU\DSSURDFKHV2Q2FWREHUWKH(XURSHDQ8Qion Parliament passed proposed restrictions on the
PDUNHWLQJDQGXVHRI3)267KH'LUHFWLYHZill go into force when the EC formally adopts and publishes the regulation.
2QFHSXEOLVKHG0HPEHU6WDWHVZLOOKDYHmonths to enact the Directive into national law. It is anticipated that the
Directive will become effective mid-2008.
The Company has been cooperating with the process to reviewZKHWKHU3)26PHHWVWKHFULWHULDXQGHUWKH3URWRFRO
IRU3HUVLVWHQW2UJDQLF3ROOXWDQWV323VProtocol"). This Protocol is part of an international treaty known as the
Convention on Long-Range Transboundary Air Pollution (LRTAP),Q'HFHPEHURIWKH([HFXWLYH%RG\
comprised of parties to the Protocol decided that the record generated under the Protocol review process was
VXIILFLHQWWRGHWHUPLQHWKDW3)26TXDOLILHVDVD323DQGWhat the review process should now proceed to a "Track B"
review focused on the economic impacts DQGRWKHUDVSHFWVRIDGGLQJ3)26WRWhe Protocol. The United States, which
has signed but not yet ratified this Protocol, indicated its disagreement with the Executive Body decision. In December
of 2006, the Executive Body decided that the Track B review should contiQXHDQGWKDWIXUWKHULQIRUPDWLRQLVUHTXLUHG
EHIRUHDGHFLVLRQRQZKHWKHUWRDGG3)26WRWKH3URWRFROVKRXOGEHPDGH3)26DOVRKDVEHHQQRPLQDWHGIRU
DGGLWLRQWRDQRWKHULQWHUQDWLRQDOWUHDW\IRFXVHGRQ323VNQRZn as the Stockholm Convention. A process to prepare a
ULVNSURILOHIRU3)26LVQRZSUoceeding under that Convention.
As previously reported, the Company and state agencies tested groundwater beneath three former waste disposal sites
in Washington County, Minnesota, used many years ago by the Company to dispose lawfully of waste containing
perfluoronated compounds. The test results show that water fromFHUWDLQPXQLFLSDOZHOOVLQ2DNGDOH0LQQHVRWDQHDUWZR
of the former disposal sites and some private wells in that YLFLQLW\LQ/DNH(OPR0LQQHVRWDFRQWDLQORZOHYHOVRI3)26
DQG3)2$WKDWLQVRPHFDVHVDUHVOLJKWO\DERYHJXLGHlines established by the Minnesota Department of Health