Ignorance and Misdirection: a corporate strategy for avoiding PFAS accountability
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This blog post is available here: LINK on Substack at Kris Hansen’s PFAS Journal LINK. Or you can read the text here.
Ignorance and Misdirection: a corporate strategy for avoiding PFAS accountability
And a new vocabulary word: AGNOTOLOGY
AGNOTOLOGY. According to Dr. Robert Proctor who co-coined the term, agnotology is the study of deliberate, culturally induced ignorance and doubt. Definitely a word whose time has come. However, as historians and sociologists will tell you, agnotology is not a new concept. There’s a rich analytical discipline focused on how industries (and other entities, of course) use doubt, ignorance and uncertainty to protect their products and thus, protect their profits.
Proctor talks about the different constructs of ignorance, one of which he describes as being “a deliberately engineered and strategic ploy.” Ignorance is a strategy. When 3M claims they didnt know that their chemical was in the blood of the general population or globally distributed in the environment, or that they didnt know their PFAS had chronic health effects, how do we evaluate their claims of ignorance? Is their ignorance innocent and something they worked tirelessly to address as soon as they became aware of the risk? Is their ignorance feigned, with their own unsettling data protected and unshared? (Unseen Science). Does their ignorance exist because documented knowledge leads to accountability and thus experimental evaluation is intentionally avoided by the accountable? (Undone Science). Agnotology teaches us that “we didnt know” and “we couldnt have known” can be tactical strategies employed to maintain the status quo and avoid taking action.
As an example, consider statements made by two 3M executives, both with PhDs in Chemistry and both one-time Vice Presidents of 3M’s Specialty Chemical Division: Dr. Larry Krough (1975) and Dr. Charles Reich (2000).
In November 1975, Dr. Krough documented to other executives and to 3M’s Corporate Responsibility Committee that 3M scientists had matched 3M’s chemical, PFOS, to the organic fluorine compound isolated by academic researchers from samples of blood from blood banks. [#1145]
In May 2000, nearly 25 years later, Dr. Reich noted to the Washington Post, “It was a complete surprise that [PFOS] was in the blood bank supplies.”
Even without considering the 25 years of research 3M invested in various initiatives including programs like “Fluorochemicals in Blood” and “Determination and Characterization of Trace Fluorochemicals in the Environment” [e.g. #1148, #1166,#1989, #1408, #2534], Reich’s proclaimed ignorance needs interrogation.
“It was a complete surprise” is not an explanation we should accept from a PhD chemist and business leader of a science- and engineering-corporation that confronted that “surprise” 25 years earlier. [#1118, #2771]
In the face of Reich’s dubious proclamation, the critical question that needs explaining is WHY didnt you know?
During the same week in 2000 that Reich expressed his shock at the presence of PFOS in blood bank supplies, 3M’s Medical Director, Dr. Larry Zobel insisted, ''We can't say how it gets into anybody's blood.'' [LINK] As with Reich, Zobel’s proclaimed ignorance is inconsistent with 3M’s 25 year history of research.
Starting in 1975, academic researchers proposed the organic fluorine contaminating the blood of the general population was linked to 3M’s PFOS-based products [e.g. #1121]. By 1980, 3M had conducted their own studies documenting high levels of their persistent, bioaccumulative and toxic chemicals being discharged into rivers, incorporated into biosludge and spread on agricultural fields [LINK]. Twenty years before Zobel’s claim of ignorance relating to the source of human exposure, 3M scientists had determined that the chemistries associated with 3M’s PFAS-based food packaging and 3M’s PFAS-based textile protection products were metabolized to PFOS [#1166].
In a 1998 document specifically created “At the direction of Larry Zobel, MD,” 3M toxicologist Dr. John Buttenhoff, noted about PFOS : “Potential for human and environmental exposure, direct or indirect, is high.” [#1489]
In subsequent posts, I’ll employ agnotology to evaluate 3M’s claims about their historical analytical capabilities relative to PFAS. In this post, I will offer a few quick reminders related to the intentional production of ignorance and doubt that come up often when I’m reviewing industry documents on PFAS and when I’m thinking about the costs (e.g. public & environmental health costs; water/natural resource remediation) associated with global PFAS contamination.
3M, Dupont, Chenmours, Daikin, Solvay…We still havent seen all of the data
According to former MN Attorney General, Lori Swanson, in the course of litigation, 3M was forced to turn over more than 27 million pages of documents to the prosecution [LINK]. Thanks to the State of MN and the Forever Pollution Project, some of these documents are publicly available. Most are not. We can evaluate the DISCLOSED documents to better understand what 3M knew and when they knew it, but the vast majority of 3M documents related to PFAS remain protected, safe from our scrutiny. The disclosure protection afforded 3M (and other chemical companies) continues to allow the corporation to dictate the public narrative about some aspects of the PFAS public health crisis. Data is being intentionally withheld from us.
Pretending a little bit of PFAS doesnt matter
Often, people try to define *part per billion* in a way that downplays the significance of that amount. For example, the “Communication Plan” 3M crafted in May 2000 before publicly sharing the information that their chemicals were present in the blood of the general population at about 50 ppb notes: “Part per Billion (perspective)...One cent in $10,000,00” . The “perspective”, emphasised throughout the communication plan by repeated use of phrases like "extremely small amounts” and “very low levels” when describing PFAS contamination, reinforces the notion that parts per billion is a negligible, nearly meaningless, amount. [#2781]
While it may be true that 50 cents is trivial to a multi-millionaire, 50ppb of fentanyl in human blood is generally lethal. Chemical toxins and pocket change are not comparable when it comes to public health.
Chronic versus Acute Toxicity
Generally, something that is ACUTELY toxic makes you sick immediately: you eat a rotten clam and throw up in a couple of hours [LINK]. Rotten clams have acute toxicity. PFAS like PFOS and PFOA are not ACUTELY toxic, at least not at the levels to which we are exposed in our daily lives. Drinking a glass of water with 4 ppb of PFOA will not make you throw up or even give you a stomach ache because 4 ppb of PFOA is not ACUTELY toxic. However, a childhood spent drinking water with 4 ppb of PFOA may give you cancer [LINK], lower your immune response to disease, or raise your cholesterol to dangerous levels [LINK]. PFOS and PFOA have CHRONIC toxicity. A chemical that has CHRONIC toxicity can cause harmful effects as a result of long-term or repeated exposure, even if the exposure is a small amount. Some PFAS are toxic; not all are acutely toxic. PFOA and PFOS are examples of PFAS demonstrated to have chronic toxicity.
3M has done lots of studies evaluating the acute toxicity of PFOS and PFOA; these studies are not risky for the company as they generally show no effects at low levels. However, despite the fact that 3M knew PFOS was persistent and bioaccumulative in humans, prior to 1998, the company didnt conduct any studies evaluating the chronic toxicity of PFOS. As a senior-level toxicologist at 3M noted in 1979 (!!), “Because of the apparent persistence of these fluorochemicals in the body, the most important question remains possible long term effects.” [#1199] A similar observation was offered by a senior environmental scientist at 3M in 1992: "It should be kept in mind that the acute toxicity tests for which the greatest amount of data exists are usually a few days in duration and do not reveal long-term effects such as bioaccumulation or chronic toxicity." [#1372]
Both 3M and Dupont knew that the real public health risk associated with PFOS and PFOA was the potential for CHRONIC toxicity [e.g. LINK, #1124, #1408, #1212, #1204]. By not studying these chronic health effects, or studying them but not reporting results publicly for scientific evaluation, 3M and Dupont were using ignorance as a strategy.
The chemical industry’s continued use of ignorance as an excuse for decades of damage to public health and the environment is a deceitful and multi-dimensional strategy to be challenged. Fifty years after the academic researchers alerted 3M to PFAS contamination in the blood of the general public [e.g. #1118], the chemical industry continues to use ignorance to avoid accountability for PFAS contamination.
In response to allegations Chemours has been violating the Clean Water Act for five years, on August 7, 2025, a US judge ordered the company to stop discharging PFAS into the Ohio River from their facility in Parkersburg, West Virginia. According to the judges ruling:
Because the harm is hard to quantify, Defendant [Chemours] argues that an injunction is not available to the Plaintiff. Defendant’s argument posits a dangerous premise: exposure to a harmful pollutant like HFPO-DA [a PFAS] is acceptable on some average, despite many permit violations, and the purpose of the Clean Water Act. Under this theory, a plaintiff exposed to concentrations of HFPO-DA has no recourse until she develops a serious illness. This theory of irreparable harm cannot be.
As per Dr. Proctor: “Ignorance can be an actively engineered part of a deliberate plan.” [LINK]
