How 3M avoided taking That Obvious Next Step
Photo by Carl Bohacek©
Please LINK to this article in my substack [Kris Hansen’s PFAS Journal]. You can subscribe (for free) and receive new content directly to your email. You can also read the text here.
How 3M avoided That Obvious Next Step - Ignorance as a Strategy, Part I
In the press, and presumably in courtrooms, 3M has claimed ignorance as a defense for exposing the public and the environment to persistent, bioaccumulative and toxic chemicals for decades. In May 2000, a 3M executive VP noted: “It was a complete surprise that it [PFOS] was in the blood bank supplies.” [LINK]
Evaluating this executive defense requires examining both the science of measuring PFAS (analytical chemistry!) and the science of ignorance (agnotology!) and how 3M wove them together. Ultimately, I’ll unpack this in 3 parts.
The background you need is this: Three academic researchers, Guy, Taves & Brey (Guy et al) approached 3M in 1975 to say they had conducted an Organic Fluorine Analysis (OFA) and their data indicated that industrially-produced organic fluorine appeared to be contaminating the blood of the general public in the US. Guy et al had done a lot of work to figure out what the organic fluorine compound was but without some information from PFAS producers, they couldnt be sure. They thought, however, the compound came from products like Scotchgard; using a tool called fluorine nuclear magnetic resonance spectroscopy (F/NMR) they described features of the compound that matched PFOS. The researchers asked for specific information from 3M to confirm the identity of the compound they found. Although 3M had ready access to the requested information, after “plead(ing) ignorance” [#1118], the company chose not to share meaningful data about PFOS with the researchers then or ever. And so, PFOS went unnamed as the contaminant (and likely carcinogen) in the blood of the US public for nearly 25 years, only to return, as a “complete surprise,” apparently, to a 3M executive in 2000. [e.g. #1118, #2593, #2771, #1121,#1123, #1144, #2534]
What happened within 3M after those first conversations with Guy et al in 1975 was a careful dance of testing and not testing.
Part I, 1975-1983: OFA + F/NMR + gas chromatography (GC)
In 1975, 3M could have confirmed the presence of PFOS as the major component of organic fluorine in the blood of Americans. Further, using analytical tools available within 3M, by 1980, 3M had data indicating that PFOS was persistent, bioaccumulative and toxic and was entering the environment via waste water, sludge and agricultural soil.
By October of 1975, 3M had every detail of Guy et als experiment and methods [e.g. #1121] for measuring levels of organic fluorine in human blood and for isolating and characterizing the specific compound.
Upon learning of Guy et als findings, the obvious next step would have been for 3M to immediately repeat the academic group’s experiment. 3M could have characterized blood samples from more donors or from donors in different cities in the US if they were critical of Guy et al’s chosen demographic. Given the analytical resources and expertise available within 3M, the company could have repeated the study as early as 1975. However, as far as we can tell, 3M did not take that obvious next step.
Instead, 3M chose to refine the method Guy et al. used for the quantitative OFA in human blood. Although 3M didnt publish this improved method until 1978 [LINK], the team within 3M was using their new OFA method as early as February 1976, just months after connecting with Guy et al. 3M immediately confirmed the general data collected by Guy et al.: approximately 30 parts per billion (ppb) of organic fluorine was present in samples of blood purchased from US blood blanks [e.g. #1145, #1144].
Having confirmed the accuracy of the first part of the academics’ data, the obvious next step was to isolate the organic fluorine via Guy et al’s method and analyze it using F/NMR. 3M possessed the same F/NMR as Guy et al. and had a scientist expert in the analysis [e.g. #1123, #1145]. However, as far as we can tell, 3M did not take that obvious next step.
And yet, 3M did apply the powerful analytical combination of OFA and F/NMR to drive many significant studies and conclusions related to PFOS, none of which they shared with Guy et al. or in the technical literature. For example, 3M showed that rats fed the PFAS component of 3M’s food packing product (Scotchban) showed high levels of organic fluorine in their blood, which 3M then identified as PFOS [e.g. #1133, #1166]. 3M demonstrated that their PFAS-workers in Decatur, AL had very high levels of organic fluorine in their blood (3M’s F/NMR analysis then showed it was PFOS), while in Cottage Grove, MN, the high organic fluorine levels in 3M workers’ blood were attributed to PFOA. In both cases, 3M determined that the PFAS was retained in the workers’ blood for a long time. [e.g. #1145, #1144, #1146].
Although 3M routinely used OFA and F/NMR to solve some important questions about PFOS and PFOA, they chose not to apply this powerful combination to identify the PFAS compound in the blood of the general population.
In light of 3M’s apparent analytical expertise applied to some questions while simultaneously maintaining a complete lack of curiosity and skill for addressing the question of public exposure, Robert Proctor’s words on agnotology resonate: “...ignorance should not be viewed as a simple omission or gap, but rather as an active production. Ignorance can be an actively engineered part of a deliberate plan.” [LINK]
Already in possession of sufficient analytical tools and expertise to verify that PFOS was the major PFAS component present in the general public in the 1970s, 3M developed a third analytical tool: a series of complimentary detectors coupled to gas chromatography (GC). These detectors could be used alone or together to identify and measure low-levels of both PFOS and PFOA in blood and other matrices. The GC methods provided more compound specificity than the OFA method and were more sensitive than the F/NMR method.
By 1979, 3M could measure 1.5 ppb of PFOA and 400 ppb of PFOS in blood [e.g. LINK, LINK] using their GC methods. Although publicly available documents show detectability of PFOS to 400 ppb, this measurement was demonstrated by 3M using a very small volume of donor blood (about 20 drops).
The obvious next step would have been to follow very standard analytical techniques designed to concentrate samples and improve the sensitivity of the PFOS analysis, using 5 or 10 times as much blood (still, a small volume - about as much as a doc takes to test your cholesterol). 3M could have used a modified version of their existing method to detect PFOS at 75-100ppb or even lower.
Had 3M concentrated the blood samples and applied their method to those individuals in the general population with the highest levels of organic fluorine in their blood, they would have confirmed PFOS as the major PFAS in the blood of individual donors from the general population, ratifying the conclusion they could have drawn from their OFA and F/NMR data in 1975. [LINK] However, as far as we can tell, 3M did not take that obvious next step.
3M continued to develop PFAS analytical methods and by 1983, 3M scientists:
Demonstrated that PFOS and PFOA were entering the environment via 3M sludge, effluent and soil [e.g. LINK, #1282].
Demonstrated that a 3M-produced PFAS in consumer products and known metabolic precursor to PFOS, bioconcentrated in fish and mammals [e.g. #1185, #2563, #1208, #1251, LINK]
Supported 3M toxicity studies [e.g. LINK], including the 90-day subacute studies in monkeys and rats and acute toxicity studies on aquatic species, all of which demonstrated toxic effects from PFOS [e.g. #1181, #1199, #1282].
3M even had time to use their analytical tools to characterize two studies on the breakdown of Dupont’s PFAS chemistry (a competitive product to 3M’s Scotchgard). In 1981, 3M scientists demonstrated that a PFAS component of Dupont’s textile protection product breaks down to PFOA. [LINK] 3M used a variation on that method to provide an even more detailed analysis of Dupont’s product in 1983. [LINK] While secreting their analytical methods and data concerning PFOS within the company, 3M published methods and data for Dupont’s products in the technical literature.
(Think it’s peculiar that 3M spent so much time characterizing and publishing the breakdown of a competitor’s product while keeping quiet about PFOS and PFOS-based products? Me too. My thoughts on why are HERE).
Dr. Don Hagen and Dr. Richard Newmark are two of the handful of 3M scientists whose names appear repeatedly on publicly available PFAS documents from the 1970s and early 1980s. Both Hagen and Newmark achieved 3M’s highest rank for scientists and both were inducted into 3M’s scientific honor society. Both also had access to samples of PFOS and PFOA and all existing information on the chemical and physical properties. Both enjoyed open and honest communication with the technical leaders from the Specialty Chemical business, perks NOT available to Guy et al. [e.g. #1123,#2593, #1144]
It is inconceivable that the top analytical chemists at one of the world’s largest science- and engineering companies would not have taken the obvious next step had they been asked, allowed, or chosen to do so. It is inconceivable that analytical chemists who demonstrated such a high level of technical expertise in characterising 3M samples and competitive products could not have replicated or modified existing, published methods to identify PFOS in the blood of the general population. The inconsistent application of scientific exploration demonstrated by 3M evokes a return to agnotology.
Social scientists discuss Forbidden Knowledge as “knowledge considered too sensitive, dangerous or taboo to produce.” They suggest that, in trying to understand what motivates scientists to produce knowledge, it is equally important to recognize why they avoid producing knowledge in other areas. That is, what data IS produced (and why) should be evaluated equally with what data IS NOT produced (and why not). 3M’s reluctance to take the obvious next step in PFOS-confirmation bought the company at least 25 years of PFAS-funded profits while surreptitiously exposing the public to a knowable risk.
Between 1975-1983, 3M devoted significant scientific and executive leadership resources to study various iterations of a “Fluorochemicals in the Blood” program [e.g. #1145, #1146, #1148, #1989]. 3M characterized metabolites from their PFOS-based products, looked at consumer exposure [e.g. #1166 ], supported PFAS toxicity studies and characterized a variety of PFAS in environmental matrices [LINK]. 3M analytical chemists developed and published some very innovative and sophisticated analytical methods for characterizing persistent breakdown products from competitors’ PFAS chemistries [LINK].
All that executive involvement, technical expertise, and corporate resource and yet, on numerous occasions, 3M did not take the obvious next step to repeat or refine Guy et al’s original experiment. An experiment that would have confirmed, no later than 1976, that PFOS was widely and indisputably present in the blood of the general population.
Personally, I wonder if Hagen and Newmark were pressured, like I was, to avoid generation of data that would hold the corporation accountable. Or did the scientists independently decide not to take the obvious next step, to preserve their livelihood or as a quest for approval and promotion. Either way, we’re not to know. Hagen passed away several years ago and Newmark, apparently, has forgotten the whole PFAS Era at 3M [LINK].
Forgotten Knowledge. Forbidden Knowledge.
