When Industry Owns Labor
On August 11, 2017, I received and posted the ‘Fluorine Testing Results’ from a set of 2004 new, never-worn, structural turnout gear. We purchased the gear from a supplier who had used them as a model in his store.
The testing was performed by Professor of Physics, Dr Graham Peaslee at the University Notre Dame, Indiana. After 13 years it was suspected there could be no PFAS / Fluorine left on the gear. We were wrong. The Fluorine content was so high it had to be measured in ‘volume’ not the usual ppm standard.
The gear needs further testing to determine the actual content of PFOA and the precursors that break down to PFOA.
While the newer technology uses a short chain C-6 technology that is not PFOA, that same technology uses ‘precursors’ that break down to PFOA.
The problem we have is the industry refers to the content as ‘trace amounts’ a very subjective term. We need actual tested and confirmed content amounts. We need labels in your gear telling you what the chemical additives are and their tested content amount. The same manufacturers that advise ‘trace amounts’ make up the FEMSA, Fire and Emergency Manufacturers Services Association. They lobbied for and won the right to NOT place warning labels in your PPE. It is called ‘The Liability Bill’ and is proudly posted on their history page. https://www.femsa.org/whois_femsa/history/
During this time, DuPont knew it was being investigated for PFOA. So while the FEMSA supports many FF cancer research programs, it is silent on PFOA. The manufacturers DuPont/Honeywell sit on NFPA as voting members of #1971, while they are and were aware of the toxin PFOA, and while they were aware the European Union was removing it from your PPE. They were notified in 2006 by ECHA. Not once did they bring this subject up as a matter of concern. But Mr Grilliot, of Honeywell, did vehemently protest having warning labels in your gear while he served on NFPA 1971. I have that posted on my page as well. From NFPA 1971 ROP 1996 :
This issue came to light for Paul and I in 2016 hen it was learned that in Europe their fire industry was preparing to transition to non-PFOA
PPE.http://www.hemmingfire.com/.../PPE___Duty_of_Care_Forum... The European Chemical Agency or ECHA requires that by 2020 PPE must not have more than 25 ppb PFOA. This is higher than the 2 ppb ECHA wanted but manufacturers said it was impossible for them to work with those numbers. The manufacturers of PPE wanted to strike (derogate) FF PPE from the standards altogether. Essentially leaving FF gear out of the safety net ECHA set up. https://echa.europa.eu/.../61e81035-e0c5-44f5-94c5...
The media outlet Station Pride covered this story in 2017. ‘The Real Cancer in Your Gear’. https://www.firefighterclosecalls.com/the-real-cancer-in-your-gear/
The article had over 4,000 shares and barely any comments. The fleet was shocked at the accusation but curious.
Enter Robert Bilott
Attorney Robert Bilott is the environmental lawyer who exposed the toxins PFOA and PFOS that have been poising water systems in our towns where 3M and DuPont have made Kevlar and AFFF for decades.
https://www.nytimes.com/2016/01/10/magazine/the-lawyer-who-became-duponts-worst-nightmare.html and now the focus of feature film Dark Waters about Rob’s 20 year battle with DuPont fighting the shocking agenda of DuPont who omits, manipulates, and uses industry science to support their stance. https://www.documentcloud.org/documents/2289501-weinberg-memo.html
https://www.focusfeatures.com/dark-waters
This is Robert Bilott’s 194 page letter to the EPA, CDC, ATSDR, and US Attorney General. On September 5, 2017 he gave them 60 days to come up with testing and studies on behalf of ALL RESPONDERS who have been exposed to PFOA/gear and PFOS / FOAM. I’m not sure that he ever heard directly from any of them.
The reason for the concern of the amounts of PFOA on your gear is because it accumulates. It does not break down. This coating in/on gear has been degrading in your stations for years. We have no idea how much as manufacturers refuse to disclose amounts. It accumulates on your walls, surfaces, vents, in the areas you work, sleep, and eat.
In 2012, the REACH committee from the European Chemcial Agency/ECHA, declared PFOA had met criteria to be declared a PBT or ‘Persistent — Bioaccumulative — Toxic’. This is why we need numbers of what content of PFOA was used in our gear in past years. Because it never goes away. It accumulates. It is toxic.
https://enveurope.springeropen.com/…/10.1186/2190-4715-24-16
There have been many PAH studies. Even PAHs dust studies in your stations. There have not been any PFAS dust studies, even though biomonitoring studies show your PFOA serum 3 times higher than average. “From a yet unknown source”.
In Europe they are discussing this issue as The Potential Transition to NON PFOA PPE. It is being spoken of in their symposiums. Ask yourselves why it is not mentioned in your symposiums.
http://www.hemmingfire.com/.../PPE___Duty_of_Care_Forum?fbclid=IwAR0Qm9bPHAMgrOBcffJRtODexICUNgJLcx3sARYfmhEmF2faP2RPyVF6Qas
Dr Roger Klein gives the best presentation on the subject.
http://hemmingfire.com/news/fullstory.php/aid/2660/PPE___Duty_of_Care_Forum_-_condensed.htm
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The IAFF 2017 Statement on PFOA leaves me very concerned. IMO this response acknowledges the health concerns but is a stand down approach and contradicts Resolution 34, as well as their previous statements that PFCs are found in your turnout gear:
See page 2 of this IAFF 2010/2011 PFC Fact Sheet under Toxic Exposure:
http://iaff.org/HS/SubstanceExposures/PDF/PFCs_FactSheet.pdf
As well as this 2015 IAFF Publication:
- pages 53–62: http://services.prod.iaff.org/ContentFile/Get/10183
The 2017 IAFF Statement on PFOA appears to acknowledge the health concerns yet does nothing to seek to investigate the PFC content in stations and FF serum.
. https://docs.wixstatic.com/.../fbe7dd...
In 2018 we held a conference call with Pat Morrison from IAFF. He heard our concerns and explained his reason for the IAFF statement. We were told he would be revising the statement. That never happened.
****** Results from 2004 new/never-worn Turnout Gear: ************
* FLUORINE TESTING RESULTS * On July 10th, 2017 Doctor Graham Peaslee, Professor of Physics at Notre Dame received the samples we sent him. The samples came from a ‘new, never worn’ set of 2004 gear I purchased that was used as a ‘model’ for a display. This study was done solely by Diane and Paul Cotter. This is not to be confused with the study currently being conducted on the 20 year span of turnout gear by Dr Peaslee. This was just the first initial ‘sample test’.
PLEASE UNDERSTAND, THESE NUMBERS ARE FOR A “total fluorine” measurement meaning, the next step is to test for PFOA specifically, by it self which Dr Peaslee describes that next process. What is now known, is that if after 14 years, if there were no fluorines present, there would be no PFOA as well, because there are fluorines, we now must test to see the PFOA amounts by itself. There are various types of fluorines, but, in my opinion, because we know that PFOA was used as per the statements of the manufacturers themselves we will find PFOA. How much? The next test will tell us.
Dear Diane,
Sorry for the slow response, but we ran your samples earlier this week (on Tuesday), and I have just looked through the results for four samples:
Left Under Arm firefighting suit FF-LUA
Moisture Barrier firefighting suit FF-MBTL
Right Sleeve by Cuff firefighting suit FF-RSC
Tail firefighting suit FF-T
The Moisture Barrier sample actually had two parts to it, a thin underlining fabric and the thicker outer layer. We labeled the thin fabric as MBTL2.
The results are pretty unambiguous…Everything except that thin underlining fabric was heavily fluorinated:
Sample counts/uC error ppm F Percent F
FF-LUA 24682 2472 10555 1.62
FF-MBTL 57530 5756 24603 3.77
FF-MTBL2 485 98 207 0.06
FF-RSC 20691 2073 8849 1.36
FF-T 18212 1826 7789 1.19
840 ppm F std 1964 128
We typically measure in parts-per-million, but these fabrics are so heavily fluorinated, they are better measured in percent fluorine content…each of the pieces contained between ~1 and ~4% fluorine (last column on right). This would typically indicate a very heavy treatment in PFAS chemicals to impart water and flame resistance to the fabric. We have seen values like this before, but typically only on fire-resistant fabrics.
We also looked at these fabrics yesterday with an X-ray Fluorescence unit, just to test for the presence of other flame retardants in the material, and we did not see any chlorinated nor brominated compounds nor heavy metals, so it looks like the flame-resistant properties of these materials are being given by fluorinated compounds alone…
I hope this information is useful to you. If you want to know which specific PFAS compounds are present in the fabrics (it can often be a mixture), then you would have to perform a chemical measurement using an instrument called Liquid-Chromotrography — Tandem Mass Spectrometry (LC-MS/MS). There are commercial companies that make these measurements (TestAmerica, for example), but they are complicated measurements and they typically charge several hundred dollars for a single analysis.
Please let me know if there is any other information I can provide for you….
GRAHAM
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I’ve lost count of the number of emails to the International Association of Firefighters on this issue. Their response rate is about 2%. If that.
In 2018 I reached out to Kathy Crosby Bell of Last Call Foundation to ask for help in funding a new project we were embarking on. It would be the first in the nation, the first in the world really. We would be studying the PFAS content in ‘new, never-worn’ turnout gear, we had the ability to acquire 20 years worth of new turnout gear, and, went so far as to match it with ‘decommissioned gear’ buy make and model and year !
This was an extraordinary effort. No fire service institution is involved.
Meet the committee : Discovering the ‘Chemical Additives’ aka Coatings in your Turnout Gear :::
As sets of bunker gear began arriving in the halls of Notre Dame Physics Lab, Dr Peaslee’s students loved seeing the gear and had great fun with the sets of gear. However, it would soon be learned that the new gear was so laden with PFAS, that Dr Peaslee had his students don protective gloves when handling the new turnout gear. Imagine if the fleet of 1.4 million were warned the PFAS was so prevalent in their new gear, that they should handle it with gloves? They are not warned.
April 2019:
Here is the latest warning from industry, to which a quote from the IAFF is given. This is from Lion Manufacturing who references their own study that is not public. But you may call if you have questions:
In this pdf is a statement attributed to the International Association of Firefighters.
What is the industry saying?
The IAFF has reviewed the science and stated that “it is unlikely that PFOA is present in any significant concentrations in uncontaminated new or recently US manufactured turnout gear” and that “even if present on outer shell treatments or within the moisture barrier of legacy turnout gear the exposure contribution from any such PFOA content is likely to be minimal since volatilization from the manufactured product would be required.”
Why should we believe this statement? Where is the proof? Who did the report? Why can’t we see the report?
I’d like you all to call Andy Schwarz at Lion and ask about that study. Who performed the study? What was the method used? Was it peer reviewed? Why won’t it be shared publicly? If you have further questions, please contact Andrew Schwartz at Aschwartz@lionprotects.com or 937.415–2913.
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In March of 2019, my group arranged a conference call with fire service leaders, (many of who were quick to discount my fears, and wrote numerous articles to support that the coatings were not the problem), in order to prepare them for the ‘preliminary results’ of Dr Peaslee’s study. We felt the results were so shocking that we didn’t want the leaders to learn via articles, and wanted them to have the opportunity to ask Dr Peaslee himself any questions.
We had a great response as almost all of the 40 leaders invited were able to attend. On that call were members of IAFF, Pat Morrison, Larry Petrick (since retired). Dr Peaslee explained that he found PFOA in all but one item in his 20 year span of new PPE. It was on a 2017 moisture barrier. Dr Peaslee explained he found a precursor that forms PFOA in hours to days, that he is concerned about dust inhalation, and hand to mouth exposure. His published paper will be released upon peer review. But, at least these leaders knew of his concerns.
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In the following months the PFAS hearings on Capitol Hill began to ramp up with ferocity. On September 10, 2019 in the House Oversight Committee the hearing “The Devil They Knew” was conducted with two panels:
Panel 1. Robert Bilott ; Partner Taft Stettinius & Hollister LLP, Lori Swanson
Former Attorney General State of Minnesota, Matthew Hardin (minority witness)Commonwealth Attorney Greene County, Virginia
Panel 2. Denise R. RutherfordSenior Vice President of Corporate Affairs
The 3M Company, Paul Kirsch President of Fluoroproducts The Chemours Company, Daryl Roberts, Chief Operations & Engineering Officer
DuPont de Nemours, Inc.
The nail in the coffin for the fire service comes at this point right here when Rep Debbie Wasserman Schultz asks DuPont, 3M, Chemours what they plan to do for compensation for firefighters and veterans. Warning. Difficult to watch.
https://twitter.com/i/status/1171558101197176833
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3 Weeks prior to the House Oversight Hearing, 3M, DuPont and other PFAS deniers were the sponsors of the IAFF Cancer Summit. As they have been doing for years.
https://redmondems.iaff.org/registered-exhibitors-and-sponsors
In this January 2020 video the IAFF continues to misrepresent the dialogue and is as culpable as DuPont and Lion who omit they know that PFOA is forming on your turnout gear. They are telling the fleet we need more studies, what they are not doing is sounding the alarm. They are not using the Precautionary Principle. They are not telling you to not handle your PPE when they know there is PFOA on it. They say in this video that only AFFF is the cause of PFAS absorption. THAT IS A PECULIAR STATEMENT. https://www.youtube.com/watch?v=6LvjSkU3OgY
They want to know about PFAS as a Product of Combustion. That’s fine. But while you are waiting on that, you have lost 4 years of mitigation while IAFF is dragging its feet in this issue. I’m not interested in the POC aspect. We know PFAS exists in homes on carpets and Teflon pans. I’m only interested in getting the science to you that we know already exists, that you are not being warned about, that IAFF is walking back. So that you can mitigate from the moment you purchase your gear.
Yes. I know Joe Hill is upside down. I think he’d be turning in his grave if he saw that industry now owns labor.
Diane Cotter
Your Turnout Gear and PFOA
2.1.2020