Overview of the Peer Consultation Process
PURPOSE
The 3M Company and Dyneon LLC (the Companies) have prepared three Assessment documents as part of a PFOA Site-Related Environmental Assessment Program:
- Data Assessment
- Screening Level Exposure Assessment
- Future Data Needs Assessment
The purpose of these documents is to answer the following question:
“Are current PFOA environmental releases and sources of those environmental releases from the Site and the presence of PFOA in environmental media on and around the Site sufficiently understood so that pathways of migration and exposure to PFOA associated with that Site are adequately characterized and assessed on a screening level basis?” (EPA, 2004)
The purpose of the peer consultation process is “to provide a forum for scientists and relevant experts from various stakeholder groups to exchange views on the Companies’ Assessments, and in particular on the recommended data needs, and to provide these views to a third party contractor” (EPA, 2004).
ROLE OF THE INDEPENDENT THIRD PARTY
Menzie-Cura is implementing and administering the responsibilities of the independent third party in the peer consultation. These responsibilities include:
- Developing procedures for the peer consultation process, including procedures to avoid conflict of interest for the peer consultation group members;
- Ensuring public access to information pertaining to the process;
- Identifying and selecting members of the peer consultation group;
- Identifying and managing any conflict of interest and bias issues;
- Reviewing the three Assessment documents for administrative completeness;
- Developing questions to clarify the Charge to the peer consultation group;
- Organizing and facilitating a meeting of the peer consultation group; and,
- Drafting and finalizing a meeting report.
ROLE OF THE PEER CONSULTATION GROUP
The peer consultation group is composed of scientific experts from various stakeholder groups. The peer consultation group will review the three reports generated by the Companies and provide comments in light of the following Charge in Section V.A.1 of the Memorandum of Understanding between the United States Environmental Protection Agency (EPA) and the Companies:
“Are current PFOA environmental releases and sources of those environmental releases from the Site and the presence of PFOA in environmental media on and around the Site sufficiently understood so that pathways of migration and exposure to PFOA associated with that Site are adequately characterized and assessed on a screening level basis?” (EPA, 2004)
The group members will also complete the following tasks:
- Submit preliminary written comments and questions based on their review of the Assessment documents;
- Participate in a conference call to discuss preliminary comments and questions;
- Participate in a meeting in Decatur, Alabama and provide a list of data needs by the end of the meeting; and,
- Review the draft Meeting Report for accuracy and provide editorial assistance to complete the Final Meeting Report.
Each peer consultation group member will provide his or her own personal scientific opinions, not those of their employers or other entities with which they are associated. Group members are offered an honorarium for their time spent participating in the peer consultation process.
PUBLIC PARTICIPATION
Interested stakeholders and members of the public are invited to propose nominees for the peer consultation group. Also, peer consultation group meetings and deliberations will be open to the public. Interested parties can provide brief written comments addressing scientific and technical matters two weeks prior to the peer consultation group meeting or make oral statements (scheduled in advance and limited to 3-5 minutes) at the meeting. Menzie-Cura will prepare a final report on the peer consultation process that includes a summary of the significant written and verbal comments from interested parties and will submit the report to the Companies and to EPA.
Information and documents relevant to the process, and announcements regarding opportunities for interested parties to participate in the peer consultation process are available at this web site.