Diane Cotter
5 min readJan 18, 2019

My January 16, 2019 Stakeholder Statement at MassDEP PFAS MRL Petition by Toxics Action Center and Conservation Law Fund.

Good Morning,

I’m Diane Cotter, and I advocate for firefighters PFAS exposures.

Regarding AFFF: October 2nd, 2017 the NH DES sent every fire station in the NH a letter advising them to test their water, as recent findings showed 6 of 7 stations tested elevated for PFOA/PFOS. This was an accidental discovery brought on by construction next to a fire station. Soil samples required by nearby building construction discovered high levels of PFOA at the firehouse.


There are 58,000 fire stations in the USA. It would be wise to test every station.

Yesterday I was told by a 30 year Massachusetts firefighter that years ago they would wash the walls of the station with AFFF, wash their turnout gear, their trucks, and bring their gear home for wives to wash. Then, they would discharg their tanks in the nearby reservoir.

We applaud the Mass initiative to collect old AFFF to be disposed of properly and ask that this program continue.

Today I’m here to talk to you about the staggering amounts of PFAS used in the manufacturing of firefighter turnout gear. Textiles make up over 30% of the fluoro-industry footprint.

It was not the manufacturers of our gear, or NFPA, OSHA, CDC, EPA, or ACC that made this discovery and notified us. It was the diagnosis of my firefighter husband’s career ending cancer that led to this discovery.

Searching for information on chemicals used in manufacturing of gear was hopeless. Manufacturers cited propriety CBI. These same manufactures are immersed in every aspect of firefighter cancer research, prevention, and outreach. But they will not discuss the chemicals used in the gear.

I went to the extreme length of purchasing ‘new never-worn’ turnout gear, with the hopes of finding a scientist who would be willing to test it for us. And I found him, I found Profess of Physics, Graham Peaslee of Notre Dame University. He relayed the initial fluorine results were so high in fluorine the amounts had to be read in ‘volume’ not the usual ppb/ppm. Further testing would reveal PFOA thousands of times higher than the new MRL, as well as PFNA, PFDA, and PFHxS…

PFOA causes testicular cancer. PFOA is the number one cancer in the fire service. DuPont is a manufacturer of our gear. DuPont knew in 1992 PFOA causes testicular cancer. DuPont has never told us about the PFOA in turnout gear.

Professor Peaslee is now testing 20 years worth of new, never-worn turnout gear. We are funding this research through private fundraising, car washes, bake-sales, and grants given by Boston’s own Last Call Foundation Honoring Fire Fighter Michael Kennedy, as well as Fire Maul Tools of Chicago. Professor Peaslee is working pro-bono. It’s the commercial testing that is extremely expensive.

Please allow me to read this brief explanation of concern from the Professor:


Professor, I’ve requested to give a oral statement tomorrow at this event and wish to shed light on the amount of long chain PFAS in the PPE degrading in landfills for years…


Diane, we don’t know how much of the PFAS coating in a jacket will degrade into PFOA, and how much will degrade into other PFAS unfortunately. I do know the timescale on textiles like turnout gear will be on the order of a decade or two before it all decomposes. And I do know from literature (attached) that the majority of clothing will decay in PFOA compared to other PFAS…maybe 50–60% will end up as PFOA. This leads to a scary amount of PFOA in a typical landfill leachate.

So to get you something more concrete, I went back to the measurement of the new turnout gears, that had 116 ppm of PFOA that was readily available from the material on the jacket. I am guessing 95+ % remain on the jacket, but this was what would come off immediately if you soaked the jacket in water for a couple days. I went to the internet and looked up how much material is in a men’s jacket, and it is about 3 yards x 45 in wide fabric or 1620 inches squared. Then I weighed a piece of jacket fabric in my lab from Boston FD, and I calculate about 730 g of fabric per jacket. (This is under 2 lbs, which seem a little light, but there is a lt of reinforced cloth and buckles on a typical jacket that probaly gives it a few more pounds, but no more PFAS.) If there are 730 g of fabric per jacket and there are 116 ppm PFOA per gram, then you end with about 85 mg of free PFOA per jacket. This may not seem like much, but if you tossed two jackets into an Olympic-sized swimming pool (with 660,000 gallons of water), this amount of PFOA would exceed the 70 parts per trillion EPA standard for drinking water! This is without decaying in a landfill 20 years. Imagining pants are about the same as a jacket, that means one set of new turnout gear tossed into water would produce enough waste PFOA to contaminate a full-sized swimming pool. Then if you let it decay in a landfill for 10–20 years you would probably get enough PFOA to contaminate 100 times that much…but the exact ratio of PFOA to to other PFAS isn’t known in decaying fabric, and the total amount of fluorochemicals applied to the clothing isn’t known exactly by anybody but manufacturers, so it will be hard to say whether it is 100x or 500x. But the bottom line is that these heavily treated textiles will contaminate 300,000 gallons of water per item readily, and maybe 100 times that over a couple of decades in the landfill…which is a lot of water.

There are some assumptions in here…but this is why I am concerned about the end-of-life disposal of turnout gear…like carpets they represent a significant source of PFAS for a few generations to come.


From Diane;

A few comments to consider. Gear is replaced every 5 to 10 years. The NFPA standard is every 10 years (with more frequent use some will be replaced sooner). NFPA annex recommends 2 sets of gear for every firefighter. There are 1.5 million firefighters in the USA. There are approximately 15,000 firefighters in Massachusetts. Our best guess is the chemicals began their use in turnout gear in the 80’s or 90’s. We’re not exactly sure.

We are now told by our manufactures that C6 is now used in place of C8. But the manufacturers didn’t tell us that PFOA was in our old gear to begin with. We have a trust issue here.

For the protection of the health of the citizens of the Commonwealth, and for the protection of the citizens who may be forced to pick up remediation costs, we ask that PFAS be classed as a group.

Thank you.



Diane Cotter

A very private individual who fell into a very public rabbit hole of epic proportions. I call it the #greatestdeceptionever - really, EVER.