- 3M was aware as early as 1979 that PFOS & PFOA would bio-accumulate around their production site and, as internal documents show, knew about the toxicity of PFOS as well as PFOA by the mid 80s
- The company gradually stopped production as soon as environmental agencies caught on to it, priding itself for its environmentally friendly way of doing business
- The fact that concentrations of other, different, but similar compounds keep increasing is extremely concerning. If history is not to repeat itself, regulators and citizens must learn from the past
2020 marks the year that PFOA production is officially phased out in the European Union. What seems to be an achievement of regulators at first, is actually a decree in vain, since the chemical industry knew for many years this was coming. Behind the scenes, one finds a decade-long story of cover-ups and lies by the industry’s big players with the sole goal of protracting regulation and trading profits for environmental and public health. To commemorate the eventual phase-out in the EU and sound a note of future caution for regulators, this investigative post revisits the troubled legacy of two poly- and perfluorinated organic compounds (PFCs), namely Perfluorooctanesulfonic acid (PFOS) and Perfluoroctanoic acid (PFOA).
Over the last decades, reports on adverse health effects particularly of PFOS and PFOA made many headlines. Both compounds were not recognised as pollutants until the early 2000s and since then the full panoply of adverse effect on the environment and human health has surfaced and entered the public arena.
3M, a major producer of both compounds, rather surprisingly, announced in 2000 that after more than 40 years, it would phase out its production of PFOS in the United States by the end of 2002. The company claimed that their decision was ”based on […] principles of responsible environmental management.” Only a few years earlier, 3M had been presented the ‘Heroes of Chemistry’ award and the ‘Sustainable Development Award’ for their outstanding way of doing business in an environmentally friendly way. It was the next logical step since 3M seemed to be a company with environmental integrity.
The Cover Up
This is troubling because 3M was aware as early as 1979 that PFOS & PFOA would bio-accumulate around their production site. In 1983, it was proven to cause cancer in a rat study and in 1992 3M knew that ”10 years of employment at their PFOA production site would result in a three-fold increase in prostate cancer mortality.” Persons in charge were well aware of the toxicity of PFOS as well as PFOA for decades and only discovered their principles of responsible environmental management, once evidence of PFOS’s adverse health effects was overwhelming and after it had found a commercially viable alternative. PFOS and PFOA were used in a range of products, from scotchguard, packaging for candy, bakery items, beverages and fast food, paints, for post-its, other office appliances, all the way to (water-repellent) clothing. They also served as emulsifiers in the production of Teflon or other polymers and as coatings for a variety of products. These compounds were, and are still, likely to be present in the final product and every one of us will inject them in one way or another. However, with the phase-out and the shift to other compounds the overall exposure to PFOA and PFOS has decreased (Table 1). Exposure to PFOS in everyday life was essentially inevitable. Yet, after a study had discovered the compound in supposedly clean samples from blood banks that were used as controls for an internal study of 3M’s employees, Mr. Zobel, 3M’s medical director at the time, dared claiming ”We can’t say how it gets into anybody’s blood…”, while, at the same time, internal technical reports advised 3M field personnel not to use certain products in order to avoid contamination of samples with PFOS. Clearly, the company was aware of PFOS’s universal presence, how contamination would occur and to what extent it could jeopardize public health.
At the time of 3M’s first environmental coming of age in 2000, an internal memorandum of the Environmental Protection Agency (EPA) stated that ”PFOS is of significant concern on the basis of evidence of widespread human exposure and indications of toxicity. […] These chemicals combine persistence, bioaccumulation, and toxicity properties to an extraordinary degree.” Subsequently, 3M had little choice other than to phase out production with certain compounds such as PFOS on the EPA’s radar. Well aware of the problems around their C-8s, the company gradually stopped production as soon as environmental agencies caught on to it. In the US, this was in 2000. In Europe, 3M and its subsidiaries did not face PFOS regulation until 2006 and therefore, while knowing about the health effects of their effluent and that it would pollute soil, rivers and groundwater, and bio-accumulate in animals and humans, let their toxic waste flow freely. Luckily, in 2006, the EU’s regulation caught up and stopped PFOS production. 3M proceeded similarly with PFOA; while they stopped production in the US in 2002 and now pride themselves in being ahead of the EPA’s 2015 stewardship program goals to eliminate PFOA, they continued to produce the compound in Europe and other parts of the world, eagerly polluting water bodies. In most sites in the EU, 3M stopped producing PFOA by 2008, but it was only in 2017 that the European Union decided to entirely ban its production by 2020; a decree in vain since production in the EU phased out years ago and has largely stopped as of today.
Whereas contamination from products is fairly easy to deal with by switching to different chemicals, environmental pollution, and hence, in parts, bio-accumulation, can take decades or more to get rid of. Through irresponsible effluent management of many industrial and military sites PFOA and PFOS were discharged into waters and soils without prior treatment for many years. The consequence in many places is contaminated drinking water. Australia, over the last few years, woke up to the reality that many aquifers are contaminated from 3M’s so-called ’Light water’ which was used in firefighting and by the military for exercises. Similar situations are playing out in Germany, where more than 100000 people near a 3M production site are estimated to be at risk of harboring up to 20 times the recommended PFOA-levels in their blood serum from the consumption of publicly delivered groundwater and general exposure through aerial deposition. The first author of this blog is one of them. PFOS and PFOA are still leaching through the soil, will end up in aquifers eventually and are going to sustain the problem for several decades. In the respective area in Germany, for example, PFOA levels in groundwater are expected to peak around the year 2030 and will remain of concern for the next 50 years. Up to this day, approximately 100000 tons of PFOS and about 8000 tons of PFOA have been produced worldwide and it is unclear what amount has ended up in the environment and at what risks of exposure different populations or ecosystems are.
Knowingly polluting many places and jeopardizing public health, 3M and other manufacturers behaved incredibly irresponsibly and, rightfully so, now face many lawsuits. While 3M phased out early, which was nothing but a foresighted early exit strategy to escape part of the public blame and legal issues to come, other companies did not. DuPont, for example, only stopped PFOA and PFOS production in 2013 and settled more than 3000 lawsuits in early 2017, but still denies any wrongdoing. This may be legally correct since there was no regulation in place in many countries, but it is a morally wrong and incredibly irresponsible behavior absent of any integrity. Supposedly, 3M and alike have entirely phased out production of PFOS and PFOA as of today, since PFOS was added to the Stockholm Convention on Persistent Organic Pollutants in 2009 and both PFOS and PFOA are under intense scrutiny of environmental agencies. For the most part, the industry has substituted the production of C-8s with shorter chained alternatives such as perfluorobutanesulfonic acid (PFBS) or functionalised perfluoropolyethers such as ADONA. Although it has been shown that they are equally bio-accumulative, a much shorter half-life significantly reduces the overall concentrations in tissue and therefore its toxicity towards fish, birds, and invertebrates. It remains to be seen if this is confirmed in further studies across organisms. However, the fact that concentrations of other, different, but similar compounds keep increasing is extremely concerning (see Figure 1). PFNA and PFDA, for example, also seem to have adverse health effects such as ”toxic effects on lymphoid organs and T-Cell and innate immune cell homeostasis”. Why the use of these other harmful compounds is not regulated in a similar way remains unclear at this point. If history is not to repeat itself, regulators must learn from the past and take efforts to closely monitor how ongoing exposure to and levels of potentially harmful compounds evolve and explore how these can be minimised and mitigated.
The way forward
While it is clear that PFOS and PFOA levels are decreasing in many places, other compounds may be equally harmful and with all the attention on PFOS and PFOA risk slipping under the radar of environmental and public health authorities. Eliminating PFOS and PFOA is an important achievement, and luckily regulation was set in place in many countries, albeit too late. It may well be, even though studies are inconclusive on the effect of single PFCs, that the continued and combined exposure to PFCs such as PFOS and PFOA plays a major role in the cancer epidemic that we see today. Unfortunately, it will take time, decades, to clean up the pollution in many places. The decade-long residence time of certain PFCs in groundwater systems is especially troubling. At the same time, the compounds that replaced C-8s in production have not been studied excessively enough to assume that they are entirely unharmful to the environment. They have already been detected in the environment and on locally grown products; and adverse health effects may occur only after continuous long-term exposure.
Ultimately, the responsibility lies with the regulatory bodies and environmental agencies of each country. In the long run, continuous monitoring should be the basis of not exposing consumers to possibly harmful compounds. Mainland Europe prides itself a lot on its ’precautionary principle’ when it comes to avoiding environmental damage, i.e., any environmental damage or negative health outcomes through human activity shall be avoided or at least minimised. Germany took this one step further and often tries in vain to act according to the so-called ’Vorsichtsprinzip’, which best translates as a principle of conservation or prudence. That means that a certain practice or product will not be allowed for sale or execution until it is proven to be unharmful to the environment and health. Opposed to this stands the ’scientific principle’, i.e. without scientifically proofing environmental damages or negative health outcomes, a product or practice cannot be regulated. The latter is the prominent way of conduct in the anglo-Saxon world. Both approaches have their advantages and disadvantages, but for the sake of the health of their citizens and their already exhausted water bodies, affluent western societies in particular should be able to afford acting along principles of precaution. Otherwise, continuous exposure of entire populations to harmful products such as PFOA and PFOS will undoubtedly repeat itself. Costs of postponing product launches for some years are virtually zero compared to what is necessary to mitigate the environmental damages and treat the diseases that compounds such as PFOA and PFOS can cause. Such products must be extensively studied and tested before they are allowed on the market and breaches or cover-ups by market participants must be vigorously prosecuted.