7/25/18 reply of Commander Kenney Fent of the CDC NIOSH with my response of 7/26/18 below:
Diane Cotter
Dear Diane Cotter:
Thank you for your email regarding perfluoroalkyl substance (PFAS) contamination in the fire service for career, volunteer, wildland, and military first responders. The National Institute for Occupational Safety and Health (NIOSH) is familiar with this concern and actively engaged in research on occupational exposure to these compounds and other persistent organic compounds. NIOSH is also part of a large network of federal agencies, including the Environmental Protection Agency (EPA) and Department of Defense (DOD) among others, evaluating the exposure and risk of a number of PFAS compounds including GenX chemicals (also a member of the PFAS family). NIOSH regularly communicates our applicable research findings to these other federal agencies with the goal of expanding our collective understanding of human exposure to PFAS and other persistent organic compounds.
As you may know, PFAS were used in multiple products in the United States, such as stain resistant and water repellant coatings on fabrics and textiles, including those used in the fire service. PFAS were also used as surfactants in the aqueous film forming foams (AFFF) that fire departments may use to suppress industrial fires, chemical fires, or other fires that are difficult to suppress with water. Because of the environmental persistence, bioaccumulation, and toxicity concerns, many PFAS compounds have been phased out in the United States. In many cases, shorter-chain fluorinated compounds are being used as replacements in the aforementioned products. These replacements are much less persistent in the environment and are typically short-lived in the human body. However, further toxicity research on these replacement chemicals is needed. Because AFFF foams have long shelf lives, some departments may still have legacy PFAS-containing AFFF foams in stock.
NIOSH is currently engaged in ongoing research studies to examine PFAS exposure in the fire service. In a 2015 collaborative study with the University of Illinois, where firefighters suppressed controlled residential fires, NIOSH collected blood from 36 U.S. firefighters for the analysis of PFAS compounds. The results from this study may provide an indication of the biological levels of PFAS among a select group of firefighters. Data from this study are still undergoing analysis, but we hope to publish the findings within the next year.
NIOSH is also working with the Universities of Miami and Arizona on a prospective firefighter cancer cohort study. As part of this study, samples of firefighter participants’ blood are being collected for PFAS analysis. One goal is to expand this cohort to include firefighters who are more likely to use or have used PFAS-containing AFFF foams, such as industrial firefighter trainers. This study is still in the early phases, so it will take some time to publish the results.
Page 2 — Diane Carter
NIOSH is also considering other studies focused on occupational exposure to PFAS, including GenX chemicals.
Your email raised concern regarding the carcinogenicity of PFAS compounds. There are many risk factors for cancer, including diet, physical fitness, and chemical exposures. Firefighters may be exposed to numerous combustion byproducts that are known human carcinogens, including polycyclic aromatic hydrocarbons (PAHs), benzene, formaldehyde, and vinyl chloride. Much of the research at NIOSH has focused on these known human carcinogens. It is currently unknown how PFAS-containing AFFF foams and firefighting textiles contributed to the systemic levels of PFAS in firefighters, and further, how these exposures then contributed to health outcomes. While studies certainly indicate that firefighters have an increased risk of certain types of cancer, linking these cancers to specific exposures is very difficult.
Generally, scientists can only provide evidence for causality, but can rarely provide proof of causality. It becomes even more difficult to provide evidence of causality when the exposure has changed substantially over time. Because some PFAS compounds have been phased out of a variety of products, including recent turnout gear ensembles, firefighters’ exposures may also be different today than decades ago. This is further compounded by the fact that firefighters could have PFAS exposures from combustion sources (depending on what is burning) or be exposed outside the workplace (depending on furniture, carpeting, etc. used in the home). Despite these complexities, we are fully dedicated to understanding firefighters’ exposures to all chemicals and identifying ways of minimizing those exposures and any related health effects.
Thank you for your concern and outreach on this important topic. Please be on the lookout for informative articles on firefighters’ exposures to PFAS and other persistent organic compounds as we publish findings from our research over the next few years. These results will also be shared broadly with the U.S. fire service organizations.
Sincerely,
Kenneth Fent, PhD, CIH
Research Industrial Hygienist
CDR, U.S. Public Health Service
National Institute for Occupational Safety
Dear Kenny,
With all due respect, this response does nothing to support a national protocol for the fire service. Every single fire station in the nation that trained with AFFF is at risk.
Every single fire station in the nation that houses PPE is at risk.
Every single fire fighter should have serum tested. Every single fire fighter should be included in the National PFAS Register.
I’m at a loss to understand why the alarm is not being sounded for the fire service here in the USA as it is in Australia, where their union has ordered the serum testing for all fire fighters?
Or why we are not conducting symposiums as is done in Europe to educate the fire service on the chemicals used in the making of theprotective ensembles. And the end of life disposal methods. We must have limits of PFAS chemicals in our gear now. Not in the future. As has been done in the EU by the demands of ECHA 25ppb PFOA in PPE and 1ppm precursors.
We must have labeling in our gear now on a national scale as has been instituted in Washington State. Notifying the fire fighter that the garment contains PFAS chemicals which are known to be endocrine disruptions.
The 385 page ECHA background document on PFAS goes into great discussion about fire fighters. Their occupational exposure from the gear via routes of exposure; dermal, ingestion, inhalation. From the gear.
These are all protocols we must provide now. Not in the future. You are the most respected man in the fire service Kenny. You and I have spoken on the phone about this issue. We spoke about the events in Europe and I sent you all of the material on their events.
This is not enough. We must have a plan now. Today. We know the chemicals are in the gear. The new PFAS may be even worse. We know they live in fire stations that have had gear degrading for decades. We know in the 80’s, 90’s, the fire service drilled using AFFF. If they drilled with AFFF in their own yards, they ARE at risk for water / soil contamination.
We need a national plan for the fire service. The testing and studies are wonderful and needed. But this is not a plan Kenny. We know they are occupational exposed. The new CDC PFAS Toxicological Profile states it.
We need a national fire service PFAS protocol.
Where do we turn now? If CDC is not going to do this? Who will put
this national project together?
Sincerely,
Diane Cotter
p.s. The ‘NIOSH’ photo used in the article is from this 1977 report: