The Inside Story
3M and Scotchgard: How safe is PFOS?
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Compare the company's spin on dangers and the phaseout of PFOS chemistry with the conclusions drawn by EPA and the facts revealed by their internal documents.
According to 3M "All existing scientific knowledge indicates that the presence of these materials at these very low levels does not pose a human health or environmental risk."
According to 3M "Preliminary data indicated . . . that PFOS is of significant concern on the basis of evidence of widespread human exposure and indications of toxicity . . . EPA's preliminary risk assessment indicates potentially unacceptable margins of exposure for workers and possibly the general population."
The EPA memo said PFOS accumulates heavily in humans and animals, and in humans has a relatively long half-life in the body, which is why the Agency declared that it "combine[s] persistence, bioaccumulation, and toxicity properties to an extraordinary degree." (view entire document)
Current theory holds that PFOS interrupts the body's ability to produce cholesterol, a necessary building block of nearly every system in the body. In the May 16, 2000 memo, EPA describes the potentially grave aspects of PFOS toxicity as follows:
"The proposed mechanism... affects reproductive outcomes in litter bearing animals due to its inhibitory effect on a burst of cholesterol biosynthesis in the critical period just before birth. The proposed mechanism would, if demonstrated, have broad implications for and present significant potential concerns for humans and environmental organisms." (view entire document)
Persistence and the Phaseout
3M's one-page phaseout press release vaguely claims: "Sophisticated testing capabilities - some developed in only the last few years - show that this persistent compound, like other materials in the environment, can be detected broadly at extremely low levels in the environment . . . " (view entire document) The implication is that 3M just recently discovered these chemicals in the environemnt, but in fact 3M knew by the late 1970s that perfluorinated chemicals could be found in wildlife and humans.
In 1979, 3M caught four fish from the Tennessee River near its plant in Decatur, Alabama, and analyzed them for fluorochemicals. 3M's discussion of the results reveals that even then, the company was fully aware of the ability of fluorochemicals to bioaccumulate in wildlife and people: "Fluorochemicals bioaccumulate in fatty tissue, and since more fatty tissue is present in the larger fish, more fluorochemicals would be expected." (view entire document) The company acquired this knowledge during a period when the dangers of persistent pollutants like PCBs and DDT were receiving great attention, but 3M did not follow up on these findings and PFOS received little attention from regulators.
A May 2000 recapitulation of the 1979 study and verification analyses conducted on the same samples recites a litany of problems associated with both the original work and the follow-up work. The problems are so severe that 3M concludes that "no reliable conclusions can be derived from this study." (view entire document) But the public record finds no indication that 3M conducted follow-up studies on game fish or other species in the Tennessee River, even though other laboratory studies showed compelling evidence that perfluoro chemicals could bioconcentrate. (view entire document)
Even after 3M learned about the broad contamination of the environment with PFOS in 1997, the company still characterized the 1970s fish data as "highly questionable" and failed to disclose the data to the EPA. (view entire document) A 1993 review of company bioaccumulation studies finds that "These papers make an excellent example of how a little knowledge can be dangerous." (view entire document)
Apparently 3M would prefer no knowledge. 3M's internal documents show that another 20 years passed before the company made any significant effort to collect additional data on organic fluorine levels in wildlife. It is true that subsequent studies revealed much more about the extent and nature of bioaccumulation. But 3M's failure to tell the EPA about the 1970s studies either then or during the initial phaseout process reveals a company reluctant to come clean.
Twenty years later the result is nearly universal contamination of wildlife by PFOS. A sampling of the astounding array of species in whose blood or tissues PFOS has been detected includes polar bears, bottle-nosed dolphins, California sea lions, harbor seals, northern fur seals, Caspian seals, minks, turtles, albatross, cormorants, otter, herring gulls, and bald eagles. PFOS is also found in the egg yolks of wild birds. (view entire document)
last updated: march.27.2009