What has the PFAS Foam Manufacturers Done To Educate the Public — Virtually Nothing

( I am publishing this document on behalf of a long-standing PFAS advocate and industry expert, he asks to remain nameless at this time ~ Diane)

ORIGINALLY PUBLISHED AUGUST 4, 2019.

1. In May 2000 3M announced it would leave the fluorinated surfactant market.

2. As detailed in the NFPA Foam Committee Notes from March 2001, which has been called the smoking gun of the PFAS issue, the military and manufacturers all knew there were serious health issues with the 8 Carbon AFFF. Virtually nothing was done to make end users aware of the fact that there was a health issue until firefighters started getting cancer and asking questions.

3. In May 2000 3M announced it would leave the fluorinated surfactant market.

4. In May 2001 the Fire Fighting Foam Coalition (FFFC) was formed in order to educate, inform and help persuade regulatory and legislative decision-makers that firefighting foams are a value-added component to any firefighting capability. The members of this coalition generate billions of dollars in sales each year. The FFFC is a not-for-profit trade association whose members are manufacturers, distributors and users of aqueous film-forming foam (Class B) firefighting agents and their chemical components. FFFC members have a financial interest in the outcome.

5. The FFFC, FluorCouncil and Amercian Chemical Council are all banded together to in order to influence legislation.

6. The FFFC immediately stepped up to assist the USEPA with its review of the fluorinated surfactant issue. I firmly believe that is why it took 16 years for the USEPA to actually come to a conclusion about C8 AFFF. I also believe that the FFFC, because of its involvement with the USEPA, was able to limit the investigation to just C8 AFFF because the manufacturers had transitioned to C6 AFFF shortly after the FFFC was formed. In an October 2003 memo, which has been widely circulated, Tom Cortina then a consultant for the FFFC and now Executive Director of the FFFC sent an email to all of the members of the FFFC confirming that they were able to limit the USEPA to only addressing the C8 AFFF.

7. During the hearings held by the legislature in Washington State, several individuals representing the fluorsurfactant industry said they could live with a ban on PFOS and PFOA. It is already banned. The USEPA stated goal under the EPA PFOA Stewardship Program, the eight major manufacturers of perfluorinated chemicals committed to work towards the elimination of PFOA, PFOA precursors, and related higher homologue (i.e., C8 or greater) perfluorinated chemicals by December 31, 2015. The EPA got it done by April 2017.

8. In May 2016, the FFFC issued its Best Practice Guidance for Use of Class B Firefighting Foams. The guide says that PFAS foam is safe as long as you follow the guide.

Is the C6 Replacement AFFF any safer?

1. With respect to C6, The Norwegian State Pollution Control Agency (SFT), which does not sell any firefighting chemicals, published an extremely important report on February 3, 2009 which showed (i) that C6-based fluorosurfactants are bioaccumulated by earthworms to a similar extent as PFOS and PFOA, (ii) that the predicted no-effect concentrations (PNEC) values for PFOS, PFOA and C6-based fluorosurfactants were similar within a factor of two, (iii) that local soil concentrations at sites that had used firefighting foams exceeded the PNEC, meaning that soil organisms were at risk, and (iv) shore-line sea snails had high levels of C6-based fluorosurfactants.

2. Based on the SFT, Dr. Roger A. Klein, MA, PhD, MB, BChir, CChem, FRSC, MIFireE concluded that “all fluorosurfactants, whether PFOS-based or fluorotelomer-based, produce very persistent long-lived fluorinated degradation products which are widely dispersed throughout the environment including isolated regions such as the Arctic not in obvious contact with these materials. Moreover, based on the Norwegian report, these degradation products may be similarly bioaccumulative and toxic in certain species low down in the food-chain, for example, earthworms. Unfortunately because these fluorinated materials are so environmentally persistent, that continued release into soil and groundwater, whether direct or indirect, will result in increasing concentrations as time passes resulting ultimately in the predicted no-effect concentration (PNEC) being exceeded thus putting organisms at risk. This will occur whether or not the fluorinated material is toxic or relatively non-toxic. The time taken even for relatively non-toxic compounds will also depend on the mass flow into groundwater. It is only a matter of time!” Dr. Klein is very sought after as a speaker with respect to PFAS.

3. In May 2015 journal Environmental Health Perspectives published a document known as the Madrid Statement, signed by more than 200 scientists from 38 countries. The statement highlights the potential harm of both old and new PFAS chemicals.

4. The FFFC/FluroCouncil/American Chemical Council point out that PFAS is rarely found in blood serum, so it is safe. In September 2017 Philippe Grandjean, MD, DMSc., provided an expert’s report on behalf of Minnesota in the lawsuit that the State of Minnesota brought against 3M.

Basically, the manufacturers of PFAS products are stating that there isn’t an issue with blood serum measurements, so our products are safe and the scientific community is saying that although there isn’t an apparent issue with blood serum, there is an issue with certain organs (lungs and kidneys mentioned specifically). In my opinion, narrow testing that avoids the organs would seem to generate a misleading result.

This is from part of Dr. Grandjean’s expert report.

QUOTE

Also, the correlation between PFC chain length and half-life is not absolute in that, for example, the six-carbon chain (C6) PFHxS has one of the longest half-lives, while eight-carbon chain (C8) PFCs such as PFOA and PFOS have somewhat shorter half-lives.

Certain scientists, particularly industry-affiliated scientists, have assumed that short-chain PFCs such as PFBA have lower or no toxicity based on PFBA’s short apparent elimination half-life in blood serum. However, a recent study shows that PFBA is retained significantly in human kidneys and lungs, rather than blood. In this autopsy study, PFCs were measured in different organs. Short-chain PFCs are barely detectable by standard LC-MS techniques in blood serum, but in human body organs PFBA showed the highest concentrations in human lung tissue, and PFBA also was the predominant PFC in human kidneys. Thus, the fact that PFBA appears in lower concentrations in blood than the longer-chain PFCs is probably misleading as to its toxicity. Rather, given that PFBA is known to accumulate in the kidney and the lung, it is reasonable to assume that PFBA exposures likely contribute to target organ effects, especially in kidneys. PFHxS is retained in several organs, including the brain. Animal studies already have begun to bear this out, as I discuss below. The short-chain PFCs, moreover, are equally as bio-persistent as the long-chain PFCs, in that they are synthetically made, are not found in nature, and do not degrade. The molecular structure of PFBA and other short-chain PFCs also are highly similar to the structure of long-chain PFCs, particularly at the end group of the chain. Given the similar structure of PFBA and other short-chain PFCs to more-studied PFCs, particularly at the end group of the chain, and their equal bio-persistence, and given the adverse human health effects that have been shown as to PFOA and PFOS, many in the scientific community have called for short-chain PFCs to be assumed to be, and treated as, equally risky. In their Madrid Statement, this large group of scientists in the field concluded: “While some shorter-chain fluorinated alternatives seem to be less bioaccumulative, they are still as environmentally persistent as long-chain substances or have persistent degradation products. Thus, a switch to short-chain and other fluorinated alternatives may not reduce the amounts of PFCs in the environment. In addition, because some of the shorter-chain PFCs are less effective, larger quantities may be needed to provide the same performance.” These colleagues also noted that, “While many fluorinated alternatives are being marketed, little information is publicly available on their chemical structures, properties, uses, and toxicological profiles” .In an accompanying editorial to the Madrid Statement which I co-authored with Dr. Linda Birnbaum, Director of the National Institute of Environmental Health Sciences, we emphasize concern about the “potential risks of the short-chain” PFCs, and call for studies especially regarding low-dose endocrine disruption and immunotoxicity. In response to these statements by academic researchers, the industry FluoroCouncil agreed to much of the content, but stated that “the short-chain PFAS substances studied to date are not expected to harm human health or the environment,” as they “are eliminated more rapidly from the body and are less toxic than long-chain substances”. While that may be true for blood serum, short-chain substances like PFBA clearly linger in certain organs, as already mentioned, and the potential risks of these compounds are in no way clear. They therefore clearly cannot be considered “safe” at this point.

END QUOTE

Philippe Grandjean, MD, DMSc., (The Harvard T.H. Chan School of Public Health) is one of the foremost experts on health effects of these chemicals (PFAS). His studies have looked at long term effects of perfluorinated chemicals on the immune systems of exposed children. He explains it takes years to pass the chemicals out of your system.

Are There Sufficient Alternatives?

1. Virtually all of the FFFC/FluroCouncil/American Chemical Council members that manufacture AFFF also manufacture a non-fluorinated chemical that is capable of extinguishing a Class “B” fire. New York State DEC commissioned a study, released in December 2018, that identified 100+ PFAS free potential substitutes for AFFF

2. As background, AFFF was developed for, and is very good at extinguishing one type of fire — pooled, two-dimensional Class “B” fires. Class “B” fires are rarely nicely pooled fires.

3. The specification for AFFF states “requirements for aqueous film-forming foam (AFFF) liquid concentrate fire extinguishing agents consisting of fluorocarbon surfactants and other compounds, as required, to conform to this specification”. When an RFP is issued for AFFF or Mil Spec AFFF, non-fluorinated fire fighting chemicals cannot bid.

4. The AFFF test makes no sense in the real world. There are 2 performance tests. One is a twenty-eight-square-foot fire test using 10 gallons of unleaded gasoline and the second is a fifty-square-foot fire test using 15 gallons of unleaded gasoline. These tests are conducted in perfect conditions.

5. Michael White, the Legislative Liaison with the Washington State Council of Fire Fighters testified that AFFF is tested in a level pan in an ideal setting but fires in the real world are never like the pan fire and AFFF does not work when it is not a flat, pooled fire.

6. Grant Nelson, a lobbyist for the American Chemical Council/FluroCouncil (same as Fire Fighting Foam Coalition) stated on numerous occasions that AFFF is the most effective chemical out there but they could live with the C8 AFFF being banned.

7. Mitch Hulbert (Solberg) stated although Solberg has a non-fluorinated Class “B” chemical, it isn’t as effective as AFFF. Again, as stated above all of these manufacturer’s have non-fluorinated Class “B” chemicals.

8. Frank Bateman spoke. He has been with 3M, Williams Hazard/Boots and Coots and now teaches firefighting at Texas A&M and other places. He gave examples of 3 fires that only AFFF could have put out. Interestingly, if you listen to his testimony regarding the Denver Airport fire, he stated that AFFF was used to get near the “spraying fire” and a dry chemical was then used to extinguish the fire. Mr. Bateman’s own testimony confirms that AFFF is not effective on anything but a flat, pooled fire.

9. Mr. Grant, Mr. Hulbert and Mr. Bateman all stated that “best practices” training would fix everything. Interestingly, although all of these manufacturers knew there was an issue 20+ years ago, they only came up with a Best Practice Guidance for Use of Class B Firefighting Foams in May 2016. Mitch Hulbert was in attendance at the NFPA Foam Committee meeting in 2001 when the AFFF issue blew up. Mr. Bateman was with 3M. They knew about the problems.

What about the performance of Fluorine Free Class “B” fire fighting foam?

The Colorado State House Bill 19–1279 under SECTION 1. Legislative declaration states:

(d) PFAS chemicals are not necessary to put out high temperature fires. Major airports like London Heathrow have successfully used fluorine-free Class B firefighting foams for years, including to combat active fires. Washington state will ban the sale of Class B firefighting foams with intentionally added PFAS chemicals for residential fires in 2020.

IPEN, which is a global group of experts has a panel that is seeking to ban all PFAS from firefighting foam. The panel prepared a document for the Stockholm Convention 9thConference of the Parties held a few weeks ago. The following is on page 27 of the document:

A comprehensive list of known end-users of fluorine-free firefighting (F3) foams was given in the IPEN White Paper presented at the UN Stockholm Convention POPS Review Committee meeting in Rome in September 2018. This list is reproduced below.

All of the 27 major Australian airports have transitioned to fluorine-free firefighting (F3) foams, as have the following major hub airport’s: Dubai, Dortmund, Stuttgart, London Heathrow, Gatwick, Edinburgh, Manchester, London City, Leeds-Brad- ford, Copenhagen, and Auckland, and elsewhere in Europe such as Billund, Guernsey, Bristol, Black- pool, Köln-Bonn. Private sector companies using F3 foams include: BP, ExxonMobil, Total, Caltex, Gazprom, Statoil, BHP Billiton, Bayern Oil, 3M, BASF, Chemours, AkzoNobel, Stena Line, Pfizer, Lilly, Weifa, JO Tankers, and ODFJEL. In the oil and gas sector, F3 foams are being used extensively, with Statoil in Norway having transitioned to F3 foams throughout all of its operations. Some military users, including the Danish and Norwegian Armed forces, have moved to F3 foams.