Primary Source Report-TH

  1. Letter from R. Purdy to 3M re: Resignation

Minnesota Attorney General State’s Second Amended Exhibit List

Richard Purdy was an Environmental Specialist working for 3M until his public resignation in April 1999. His resignation letter, documented as evidence in the State of Minnesota’s lawsuit against 3M over PFAS contamination, will allow me to assert that 3M knew of the damaging effects of PFAS chemicals they produced and through negligence or malice, worked to delay the study and release of information pertaining to PFAS.

2. Fact Sheet PFOA & PFOS Drinking Water Health Advisories

EPA Website

This primary source is an EPA summary fact sheet of health effects and advisories pertaining to PFOA and PFOS, the most commonly studied chemicals in the PFAS family. Updated from their original 2009 PFAS health advisory, this new document will help me to definitely state that PFAS chemicals have significant negative health effects on the environment, animals, and people who are exposed to and consume the chemicals produced at the 3M Decatur plant.

3. 100,000 north Alabama customers advised not to drink water due to chemical contamination

This online news article from disseminates information to Alabamians of an advisory issued by the West Morgan East Lawrence Water and Sewer Authority that tells 100,000 customers not to drink their water over PFAS concerns. This article shows that the 3M Decatur plant’s use and production of PFAS chemicals had a tangible effect on the people who rely on the Tennessee River for drinking water and food sources such as bass and catfish.

Primary Source Analysis

  1. Richard Purdy’s Resignation Letter

Richard Purdy was an Environmental Specialist working for 3M until his resignation in April 1996 over his “disappointment in 3M’s handling of the environmental risks associated with the manufacture and use of perfluorinated sulfonates (PFOS)”. PFOS are chemicals in the PFAS family. In his resignation letter, which is documented as Exhibit 1001 in the State of Minnesota’s lawsuit against 3M over PFAS contamination, he bullets his concerns: 3M’s delay of testing PFOS samples, withholding, restricting, or omitting key information, and “waiting too long to tell customers about the widespread dispersal of PFOS in people and the environment”. Purdy’s resignation letter appears to document that in the years leading up to 1999, 3M knew about the adverse environmental and health risks associated with PFOS use and actively worked to keep the information obfuscated and behind closed doors until they discontinued using the product in 2000.

In his resignation letter, Purdy’s first bullet point addresses 3M’s historical reluctance to allow internal employees’ request for a risk assessment on PFOS. “For more than twenty years 3M’s ecotoxicologists have urged the company to allow testing to perform an ecological risk assessment on PFOS and similar chemicals. Since I have been assigned to the problem a year ago, the company has continued its hesitancy”. Secondary sources (The Scotch-Guard Papers) also reference the company’s knowledge of PFAS risks dating back to 1979. Further, Purdy mentions the finding of “PFOS in the blood of eaglets–eaglets still young enough that their only food consisted of fish caught in remote lakes by their parents. This finding indicates a widespread environmental contamination and food chain transfer and probable bioaccumulation and bio-magnification.” Instead of reporting this important distinction about the food chain that caused the eaglets’ exposure to PFOS, in a TSCA 8e filing to the EPA in May 1999 “3M chose to report simply that PFOS had been found in the blood of animals, which is true but omits the most significant information.” The third piece of evidence in his letter is that he claims “3M told those of us working on the fluorochemical project not to write down our thoughts or have email discussions on issues because of how our speculations could be viewed in a legal discovery process.” This is a serious claim that speaks to the attitude 3M maintains regarding past and ongoing issues with their products, which are central in my Decatur site as Purdy points out that “the chemicals the company is considering for replacement are just as stable and biologically available.”

2. EPA PFAS Health Advisory Fact Sheet

This source is an EPA summary fact sheet of health effects and advisories pertaining to PFOA and PFOS, the most commonly produced and studied chemicals in the PFAS family. The EPA updated their health advisories from the original in 2009 because “the science has evolved since then and EPA is now replacing the 2009 provisional advisories with new, lifetime health advisories.” These new lifetime advisories definitively place PFAS chemicals into a class of substances harmful to humans and the environment, show that the initial research prior to 2016 was incomplete or insufficient (also bringing into question new research on replacement chemicals in the PFAS family), and bring specific attention to water contamination from PFAS facilities like the 3M Decatur plant on the Tennessee River.

Foremost, the health effects of consuming water contaminated from PFOS and PFOA are clearly stated in the fact sheet. “These studies indicate that exposure to PFOA and PFOS over certain levels may result in adverse health effects, including developmental effects to fetuses during pregnancy or to breastfed infants (e.g., low birth weight, accelerated puberty, skeletal variations), cancer (e.g., testicular, kidney), liver effects (e.g., tissue damage), immune effects (e.g., antibody production and immunity), thyroid effects and other effects (e.g., cholesterol changes).” This is a stark contrast to the limited findings in the 2009 advisory. These health effects may pertain to a large percentage of the population, even those not directly near a manufacturing facility, as “scientists have found PFOA and PFOS in the blood of nearly all the people they tested, but these studies show that the levels of PFOA and PFOS in blood have been decreasing.” The EPA attributes this to PFAS in food and consumer products, but specifically point out the additional risk from being in close proximity to a site such as the 3M Decatur plant. “…drinking water can be an additional source in the small percentage of communities where these chemicals have contaminated water supplies. Such contamination is typically localized and associated with a specific facility, for example, an industrial facility where these chemicals were produced or used to manufacture other products or an airfield at which they were used for firefighting.” This evidence magnifies the environmental crisis created along the Tennessee River in Alabama and will be considered for further scrutiny in my paper.

3. – 100,000 People advised not to drink water

This article from originates shortly after the updated EPA PFOS advisory described in Primary Source 2. In response to the EPA health advisory, the West Morgan East Lawrence Water and Sewer Authority advised 100,000 customers not to drink their water over PFAS contamination. This article shows that the environment and peoples on or near the Tennessee River in Decatur were directly exposed to PFAS chemicals, had their access to safe drinking water restricted for up to four months, and further shows 3M’s continued dismissive and uncaring attitude toward the ecological problems they were at least partially responsible for.

After the EPA health advisory regarding PFOS and PFOA (PFAS family chemicals), testing showed that “eight water systems in Alabama had combined concentration of PFOA and PFOS greater than the new 70 parts per trillion advisory threshold.” “Only West Morgan East Lawrence and West Lawrence remain on the advisory list.” Both of the remaining water sources that were over EPA guidelines for PFOS and PFOA levels are drawn from the Tennessee River in the vicinity of the 3M Decatur plant. As a result, “The West Morgan East Lawrence Water and Sewer Authority has advised the approximately 100,000 people served by their water system not to drink tap water until further notice due to potentially hazardous levels of chemical contaminants PFOA and PFOS.” This large population would have to rely on another water source for up to four months while an engineer developed a temporary filter system. “That temporary filter is expected to be completed in September at a cost of around $4 million.” The article cites the EPA in stating that newborns who are breast feeding and those who have formula mixed with tap water are particularly at risk from PFAS health effects. Though these specific chemicals were not produced after 2002 in Decatur, their bio-persistence, the fact that advisories against drinking the water were not issued until 2016, and the continued contamination from other PFAS chemicals open the door to a large time-frame in which many Alabamians could have suffered negative health consequences from PFAS consumption. 3M responded to the water advisory with a dismissive comment. “3M’s activities in connection with these materials were not only fully permitted but entirely appropriate … In any event, we believe the claims against 3M – and recent actions taken by the water authority – are based upon the mistaken belief that the mere presence of these chemicals equals harm.” This attitude is reflected in Richard Purdy’s resignation letter over 7 years ago and seems to directly contradict the EPAs 2016 health advisory.