MANUFACTURING DOUBT, 3M’s Ethical PFAS Debacle, Part III: Controlling the Narrative
3M Headquarters in Maplewood, Minnesota
Sociological researchers talk about Manufacturing Doubt when an industry or company promotes scientific uncertainty as a way to “alter or misrepresent knowable facts…to promote an agenda.” In considering this concept as applies to 3M and the now infamous global PFAS contamination perpetrated by the company, examples of manufacturing doubt seem prolific starting in 2000, when 3M’s role in global PFAS contamination became public knowledge via their announcement to exit the manufacturing of their C8 (perfluoroctanyl) chemistry. Subsequent release of internal documents as part of litigation between 3M and the Attorney General of the State of Minnesota provide an insider’s look at 3M’s reality versus the doubt they sought to spread to the public.
Controlling the Narrative in the Popular Press
In the May 16, 2000 press release 3M authored about the company’s decision to cease production of their C8 chemistry, Executive Vice President Chuck Reich said, “While this chemistry has been used effectively for more than 40 years and our products are safe, our decision to phase out production is based on our principles of responsible environmental management." This statement is simultaneously calming (“our products are safe”) and self-aggrandizing (“(3M’s) principles of responsible environmental management”). Amidst much discussion about 3M’s surprise announcement, the company statements continued to reassure the public about the lack of toxicity: “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.”
What the public didnt realize upon hearing Reich’s reassuring statement is that “all existing scientific knowledge” about the major contributor to PFAS contamination, PFOS, was held by 3M. Years earlier, when academic groups found evidence of PFAS in the blood of the general population and asked 3M for PFAS data so the academics could evaluate independently, 3M declined to disclose sufficient details to enable outside research. Although “all existing knowledge” implies exhaustive research, the reality was far less impressive.
On the same day as 3M’s public announcement, following extensive discussions with 3M, the EPA authored a memo to representatives of international agencies, summarizing the situation unfolding in St. Paul. Based on EPA’s review of 3M’s toxicology data, EPA wrote: “these chemicals are very persistent in the environment, have a strong tendency to accumulate in human and animal tissues and, based on recent information, could potentially pose a risk to human health and the environment over the long term.” In particular, EPA notes data in mice evidencing the role of PFOS toxicity in post-natal deaths and reproductive developmental effects, even in second generation offspring. EPA concludes, “(PFOS) thus appears to combine Persistence, Bioaccumulation and Toxicity properties to an extraordinary degree.” The EPA’s chilling judgment is at odds with 3M’s calming press release, more than half of which is devoted to promoting the company’s innovation.
Following both 3M’s and the EPA’s communications, there was debate about if 3M’s actions surrounding the phase-out of their C8 chemistry were voluntary or completed under pressure from EPA. Either way, 3M executives continued to trumpet the lack of toxicity of PFOS with absolute certainty: “This isn’t a health issue now and it won't be a health issue,” 3M’s Medical Director, Larry Zobel told the New York Times days after 3M’s announcement.
However, less than 3 months later, 3M sent a communication to EPA disclosing several violations in TSCA 8(e) reporting requirements and noting previously unreported and potentially concerning data on PFOS toxicity. The previously unshared studies included (in 3M’s own words):
Four acute toxicity studies…fall into the "moderate" toxicity category under EPA’s reporting guidance.
Two studies… appear potentially to meet EPA’s current reporting guidance due to the observation of effects identified in the guidance as being potential indicators of neurotoxicity.
Four studies…appear potentially to meet EPA’s current reporting guidance due to the observation of developmental effects.
The same letter also documents previously unsubmitted environmental data indicating widespread PFAS contamination of the food web (including in fish-eating birds and in wild fish processed into commercial animal feed) and another study indicating “high toxicity” in at least one test species in an environmental test.
In the same New York Times interview, about the likely source of PFAS in the general population, Zobel offered: “That’s a very interesting question. We can’t say how it gets into anybody’s blood.”
Zobel’s illusion of ignorance shared with the press is challenged by internal documents, dating back decades indicating that 3M understood that Scotchban, 3M’s grease resistant coating for food packaging, was likely a major source of PFOS exposure to the public.
In 1998, following a discussion about the metabolic pathways associated with various components of Scotchban, 3M toxicologist John Buttenhoff noted among other areas of investigation to be considered, “sources of exposure other than Scotchban,” an indication that Scotchban was already established within 3M as the primary source of PFAS exposure and that other sources could be identified.
Zobel’s evasive response to the New York Times in 2000 also follows evidence of significant work inside 3M to fully quantitate the transfer for PFAS compounds from Scotchban-coated paper to food during normal consumer use. 3M had sufficient confidence in Scotchban as a significant source of exposure of PFAS to the general population that, in 1998, they prepared for disclosure communication with the Center for Food Safety and Applied Nutrition at FDA, with particular emphasis on microwave popcorn as an example of a product of concern. Both of these examples preceded Zobel’s assertion of source uncertainty to the press by more than 2 years.
Controlling the Narrative in the Technical Literature
In another example of 3M’s attempt to manufacture doubt and control the narrative around PFAS, consider a letter from the editor of the peer-reviewed journal, Toxicological Sciences rejecting publication of 3M’s submitted manuscript on a study of the toxicity of PFOS in monkeys. In that letter, dated March 2, 2001, one technical reviewer’s criticisms of 3M’s submitted work was scathing and demonstrate 3M’s incomplete disclosure as a means of creating doubt about the significance of PFOS toxicity:
The authors also need to explain more fully why effects in the low and mid dose groups were not considered significant. Cholesterol and hormone levels were affected in a dose-dependent manner in both sexes. Statistically significant effects were seen at the mid dose and, in some cases, at the low dose. These are clearly dose-related….Finally, in describing the adverse effects of PFOS as reversible, the authors seem to have forgotten that two high-dose animals died on test.
The same reviewer notes: “While I realize that all the details of a subchronic study cannot be included in a journal article, I cannot recall ever seeing the phrase ‘data not shown’ so many times in one paper, and there are numerous instances where it was omitted.”
As in the mainstream press, within the technical literature, 3M’s lack of transparency documenting negative physiological effects of PFAS aligns with the intention of prompting a benign narrative for the presence of PFOS in humans.
Others have documented the various ways 3M employed an external “technical expert” to control the scientific narrative surrounding global contamination of the food web. Professor John Giesy obfuscated payments from 3M, rejected for publication technical articles that were problematic for 3M, tried to exert control on regional PFAS science, allowed 3M to anonymously review and suggest changes to submitted technical papers, and shared confidential copies of other researchers’ work with 3M, asking for the company’s guidance on if he should reject or accept papers.
Although Giesy and his coauthor are credited with being the first to document global distribution of PFOS in 2001, the sample data cited in his peer-reviewed publication were prepared, analyzed and summarized by 3M using the same method, instrumentation and laboratory personnel employed to support all PFAS tissue data, reported and unreported, collected 1997-2000. Despite 3M’s extensive contributions to producing these data and writing significant sections of the manuscript (note the replication of some text in the Materials and Methods section of Giesy’s publication and of that published by 3M months earlier), the only reference to 3M’s contributions is in the Acknowledgements section of the paper: “This research is supported by a grant from the 3M Company, St. Paul, MN.”
As 3M did with the “discovery” work completed on PFOS in the sera of the general population in 1997, by attributing significant discoveries to outside researchers, 3M created an illusion of separation between the company and the disturbing data…a feigned “how could we have known” innocence. In addition to providing Giesy with all the tissue data included in his publication, 3M decided on the timing of the publication to best serve the interests of 3M. Reich noted, “Dr. Giesy’s work is done under contract to 3M and therefore the work is only publishable if and when we agree. I understand Dr. Giesy’s urgency to be first to publish…. but this can’t dictate our timelines”. By allowing Giesy to take full credit for creation and publication of a comprehensive dataset indicating widespread global PFAS contamination, 3M contributed to the false perception of the independence of the external researcher. This positioning was so successful that Geisy was launched into the public position of technical expertise, providing him with unearned influence and control over the developing technical narrative of PFOS as a global environmental contaminant.
