UNDONE SCIENCE, 3M’s PFAS Ethical Debacle, Part IIb: PFOS Environmental Contamination
An obvious indicator of PFOS waterway contamination, 3M waited 20 years before characterizing PFAS accumulation in fish. Photo by M. Andreasson.
In the 2018 peer-reviewed article, “Nonstick Science: Sixty years of research and (in) action on fluorinated compounds,” Richter et al (2018) define UNDONE SCIENCE as “areas of research that are of concern for…members of the public yet are not an area of focus for academic, government or industry researchers often due to deliberate or tacit avoidance.” The authors continue, “Institutional ignorance….can be intentional as when a company stops studying a topic because they do not want to find further cause for concern.” A review of 3M documents made public on the Attorney General of Minnesota’s website, demonstrates many ethical lapses at 3M. If you’d like to review the primary data cited, go to the AG’s website and check out the document numbers I’ve provided in [brackets] below. Within quotation marks, words italicized inside the parenthesis have been added by me for clarity.
The second example of 3M’s Ethical Debacle in Undone Science concerns 3M’s reluctance to investigate the widespread contamination of the environment with PFOS despite the understanding that the compound was extremely long-lived and actively being discharged into the environment. The dearth of relevant studies concerning PFOS in the environment at 3M follows a pattern remarkably similar to 3M’s unwillingness to conduct carcinogenicity studies to better gauge chronic effects of PFOS in humans.
By 1978, 3M knew that the “Decatur, Alabama plant effluent has high organic fluorine levels, 10.9ppm [1208].” A 1977 study inside 3M demonstrated that organic compounds bioaccumulate in fish [1138] and a study in 1979 concluded that “PFOS is completely resistant to degradation” in the environment by microbes, hydrolysis and photolysis [1179]. In a 1979 risk assessment conducted within 3M, scientists concluded testing results “(suggest) that the toxic action of FC-95 (PFOS) is cumulative [1198].” Even without consulting toxicity studies on mammals conducted at 3M, before 1980 it was well established that PFOS was being discharged into the environment, that it didn’t degrade at all once discharged and that it bioaccumulated in aquatic life.
Again, assuming that 3M’s legally mandated disclosures are complete, despite these three known and damning characteristics of PFOS, no chronic toxicity testing for PFOS on aquatic species was conducted. Nearly 15 years later, in 1992, a 3M Environmental Specialist encouraged the company to initiate more extensive testing, stating “These short-term tests aren’t intended to measure long-term effects like bioaccumulation and chronic toxicity [1208].” The calls from scientists within the company to pursue more comprehensive environmental studies continued in 1993: “Does the perfluorooctanesulfonate (PFOS) bioaccumulate? Is perfluorooctanesulfonate (PFOS) particularly toxic to any organism in the biosphere?....Does PFOS transfer in eggs? Do birds handle PFOS differently than mammals? …Is PFOS appearing in any of the common human foods (honey, fish, milk, liver & kidney, eggs, clams & oysters) [1408]?”
Within 3M, these questions remained unasked and unanswered.
Finally, in 1998 studies were conducted within 3M that evidenced widespread environmental contamination of PFOS, from fish to birds [1504]. 3M reported these results to the EPA in 1999 in the form of a TSCA 8(3) Supplemental Notice. In that notice, the company offered that “3M is in the process of implementing a more comprehensive program of sampling and analysis to quantify PFOS levels across a range of species, environmental media and geographic locations. These additional data will provide a fuller basis for characterizing the fate and distribution of PFOS and other FCs in biota and ecosystems [1588].” After over 20 years of scrupulously practicing Undone Science, in 1999, 3M finally decided to pursue answers to long avoided questions.
