The Scotchgard Papers
provided by Environmental Working Group
cotchgard coating is universally recognized as the magical substance that repels water and stains from clothes, carpets and furniture. Scotchgard ingredients belong to a family of fluorocarbon chemicals that degrade to form perfluorooctane sulfonate (PFOS). 3M has manufactured PFOS since 1948, and in 2000 was expected to produce more than 10 million pounds of the compound for use in Scotchgard products.
On May 16, 2000, 3M unexpectedly issued a vague, one-page press release announcing that it would phase out PFOS because of concerns over new data that the chemical had been detected broadly at extremely low levels in the environment and in people.
It looked like another environmentally responsible decision, but the truth behind the phaseout was anything but laudable. It is found in a mountain of documents on file at EPA's Washington headquarters. Almost no one outside 3M or the agency has ever read these documents - until now.
In 1997, 3M found PFOS in supposedly clean samples from blood banks all over the world. PFOS has since been detected in the blood of children, in Alaskan polar bears and in bald eagles from the Great Lakes. A 1999 3M study tentatively identified PFOS in the blood or liver of California sea lions, albatross, Caspian seals and cormorants. PFOS has been detected in bottle-nosed dolphins, harbor seals, northern fur seals, minks, turtles, albatross, otter, herring gulls, bald eagles and in the eggs of wild birds.
In their PFOS phaseout statement, 3M paints itself as a corporate hero, but on the same day 3M issued its terse press release, the EPA released a document of its own. It reported the widespread PFOS contamination of blood and noted that PFOS chemicals combine persistence, bioaccumulation and toxicity properties to an extraordinary degree.
The next day, 3M's Executive Vice President of Specialty Material Markets Charles Reich told the Washington Post that the discovery of PFOS in bloodbank supplies was a complete surprise. But the more than 1,000 documents in EPA's Administrative Record on Scotchgard show clearly that 3M knew its products were in the blood of the general population as early as 1976. 3M waited more than 20 years before agreeing - under threat of regulatory action by EPA - to remove this health hazard from the marketplace.
The company has done next to nothing to inform the public that the active ingredient in its product now universally contaminates the US population and will persist in our blood for years to come.
In 1979, 3M knew its Decatur, AL plant was dumping effluent with high organic fluoride levels into the Tennessee River. In 1997, the estimate of PFOS-related chemicals produced by the Decatur plant topped 1 million pounds. 3M tested for organic fluorines in workers' blood at least as early as 1976 and for PFOS in blood beginning in 1979.
When organic fluorine levels in workers' blood showed a steep increase beginning in about 1983, 3M medical staff reacted with alarm. [W]e must view this present trend with serious concern, they wrote. It is certainly possible that... exposure opportunities are providing a potential uptake of fluorochemicals that exceeds excretion capabilities of the body.
Then, in the summer of 1997, 3M found PFOS not only in workers' blood, but also in supposedly clean blood - samples from blood banks that were to be used as control samples to the workers' blood.
In a May 18, 2000 article in the New York Times, 3M's medical director was asked how PFOS gets into human blood. That's a very interesting question, he said. We can't say how it gets into anybody's blood.
In fact, 3M knew very well how PFOS could enter the human bloodstream.
3M knew that millions of pounds of Scotchgard had been sprayed on furniture, clothes and carpets. After the phaseout was announced, a 3M consultant published a report showing that an estimated 34 percent of the product expelled from the [Scotchgard] can is initially lost as waste to the air, where anyone could inhale it.
The 3M documents in the EPA file offer few specifics on products that contain PFOS. However, a manual for taking field samples of PFOS instructs technicians to prevent contamination of the samples by avoiding use of the following products that contained perfluorinated chemicals: PostIts, new clothing, water-resistant clothing, Tyvek suits, microwave popcorn, fast food, chicken sandwiches, french fries, pizza, bakery items, beverages, candy, cookies and candy bars.
3M knew that PFOS chemicals were used in packaging for an assortment of foods and that the compounds were readily absorbed through the digestive system into the blood.
PFOS chemicals - specifically formulated to repel oil, grease and water - proved useful as coatings for candy wrappers, fast-food boxes and bags for microwave popcorn. Other products that can contain PFOS include: window treatments, fabric wall coverings, decorative pillows, slipcovers, bedspreads and comforters, mattress pads, shower curtains, table linens, carpet and upholstery fabrics in cars and vans, outdoor furniture, leather clothing, footwear, accessories, photographic products, raincoats, sportswear, boat covers, backpacks, tents, shirts, pants, jackets, shoes, boots, gloves and handbags.
Cutting a deal
Less than three months before the phaseout announcement, 3M tried to cut a deal with the EPA. On March 7, 2000, 3M put forth its Fluorochemical Re-engineering Initiative in which the chemical would be kept on the market, but through continuous process improvement, 3M would attempt to reduce exposures to one-tenth the current levels.
3M's re-engineering proposal came close on the heels of a PFOS exposure study that found significant numbers of deaths in the first generation of offspring of exposed rats and other effects extending to the second generation. At high doses, all offspring in the first generation died within four days of birth. At a lower dose, many of the offspring of the second generation died. It is very unusual to see such second generation effects, wrote the director of EPA's Chemical Control Division.
All indications are that, up until the phaseout announcement, 3M was aggressively lobbying to use PFOS products as food additives. In January 1999, in the midst of the discovery of contaminated clean blood samples, 3M continued petitioning the FDA to allow PFOS chemicals to be used on microwave popcorn bags.
Under the Delaney clause of the Food Drug and Cosmetics Act, chemicals that cause cancer in animals cannot be used as food additives. A 1998 3M study reported that the PFOS should be regarded as a liver carcinogen in rats.
In April 2000, 3M submitted to EPA a study showing deaths of monkeys dosed at relatively low exposures. In the words of the 3M report: monkeys exhibited low food consumption, excessive salivation, labored breathing, hypoactivity, ataxia, hepatic vacuolization and hepatocellular hypertrophy, significant reductions in serum cholesterol levels, and death. One 3M study showed elevated PFOS levels in a group of children ages 6 to 12. But it was not until the 2000 phaseout announcement that 3M acted to withdraw the food additive uses of the chemical.
The public record does not contain details about discussions that might have occurred between 3M and EPA in the 70 days between 3M's re-engineering proposal and the public phaseout announcement.
The New York Times reported that EPA officials had forced 3M's hand: The EPA account differs from that of 3M, which said on Monday that it had voluntarily decided to stop making the chemical.... [A]gency officials said that if 3M had not acted, they would have taken steps to remove the product from the market.
DuPont and Teflon
The $2.5 billion fluoropolymer industry is now in the spotlight. Two other groups of PFOS-related compounds are under intense EPA scrutiny. One is a ubiquitous group of chemicals called telomers. The other is perfluorooctanoic acid (PFOA), which the EPA believes presents a different hazard, exposure and risk picture.
DuPont uses PFOA to produce Teflon fibers that form its famous nonstick coating. DuPont claims that the manufacturing process destroys the PFOA. But other perfluoro chemicals persist in the Teflon. A 3M document points to the potential for widespread distribution in the environment as this material is used by the Teflon coating industry, both domestically and internationally.
In lab studies, PFOA produced dose-related increases in liver, pancreas and cell tumors. A 1992 study of workers at 3M's Chemolite plant in Cottage Grove, MN, found that ten years of employment in PFOA production was associated with a significant threefold increase in prostate cancer mortality.
In documents dated May 16, 2000, 3M tried to avoid the subject of PFOA, claiming that perfluorooctanoic acid (PFOA) will be separately discussed with EPA. EPA had a different sense of what 3M had promised, saying that on May 16, 3M committed to ending production of PFOA. 3M, however, has made no public pledge to phase out PFOA.