When did 3M know they were releasing PFAS into the environment?

No later than 1978.

One of the first waste samples I analyzed from 3M’s Decatur, Alabama PFAS facility ate through the metal can during transport from Alabama to St. Paul.  That was in 1998, twenty years after a previous generation of 3M scientists had conducted their own studies of the PFAS waste from Decatur and learned that 3M chemicals were entering the environment.

In 1998, my team and I used several analytical tools to characterize waste samples from 3M’s manufacturing facilities in the US and Europe.   The samples contained such high levels of PFAS we designated a separate sample preparation area in the lab and confined the analysis to a single analytical instrument to prevent contamination of other samples.  We also analyzed environmental samples surrounding the manufacturing facilities including Tennessee River water and soil collected from agricultural fields that had been treated with the sludge from the treatment plant.  Not surprisingly, we found plenty of PFAS there, too.

What was surprising was what I discovered in 2022 while reading through publicly-available historical documents from 3M: a previous generation of 3M scientists had completed much of the same characterization….two decades earlier.

A 1983 research proposal at 3M references data collected by 3M in 1978: “Preliminary field studies at Decatur demonstrated that the soil environmental compartment receives the highest concentration of fluorochemicals from the application of wastewater treatment sludge. A laboratory analysis showed sludge to contain 730 ppm of organic fluorine (11,12). In comparison, fluorochemicals entering the Tennessee River in wastewater effluent were present at 10.9 ppm organic fluorine, but the volume of the  effluent is 200 times that of the sludge (13).” [#1282]  In this excerpt, citations 11 and 12 (from 1978) reference PFAS levels in sludge and wastewater effluent, while citation 13, referencing the volume of effluent, is from 1982.  

That 1983 proposal continues: “Fluorochemicals have been produced at the Decatur plant for about thirty years. Since then, they have been entering the environment through landfilling of tars and other by-products, through water discharges, both before and after the installation of a modern wastewater treatment facility, through vapor discharges from manufacturing processes and wastewater aeration basins, and more recently through the field incorporation of wastewater sludge containing fluorochemicals." [#1282] 

The 1983 document provides this background as part of the justification to restart the environmental investigation of certain PFAS chemicals, especially as relates to waste leaving 3M’s PFAS manufacturing facilities.  The research proposal was sent to an executive in the Commercial Chemicals Division at 3M with a letter of support from the author’s manager, who emphasized the need to complete the proposed work to update and reassess the historical data. [#1284]  

A few months later, the author of the proposal wrote another document entitled “Questions and Answers on the Need for the Fate of Fluorochemicals Phase II Study.”  Presumably this document was crafted to address questions and concerns from the Commercial Chemicals Division including, “I can see doing health effects testing, but environmental, no one is really concerned about that.” [#1287]

A month later, the executive in the Commercial Chemicals Division responded formally to the proposal (copying the Vice President of the division), acknowledging that the proposed work, “could be of assistance in overcoming a simplistic tendency in regulatory and legislative channels to lump in one hazardous category all ‘halogenated organic compounds.’” [#1291]  However, approval was not given and the proposal was sent back for revision.  I can find no evidence in the public record that the “Phase II” proposal from 1983 was funded by 3M in that decade.  

Among other things, the unfunded 1983 proposal suggested experiments to understand how much of the “applied fluorochemical” from PFAS biosolids ended up in adjacent surface water reservoirs due to run off and how much was taken up by crops grown on the fields with PFAS-laden biosolids.  Forty years later, huge swaths of the country are dealing with decimation of agricultural resources and property due to PFAS contamination, to say nothing of PFAS-contaminated drinking water adjacent to the PFAS land applied sludge applications [e.g. LINK, LINK, LINK].  It’s clear that 3M’s decision not to fund this study in 1983 was an enormous missed opportunity for public and environmental health.  

In 1992, nearly 10 years later, another proposal, very similar to that presented in 1983 was offered again - the 1983 proposal, still undone, is appended to the 1992 proposal [#1372].  Again, with the exception of a few small studies tangentially related to the proposed work (e.g. LINK), I can find little evidence in the public record that work proposed in 1983 and again in 1992 was completed before my 1997 “discovery” of PFOS widespread in the blood of the general population.

The studies my team and I completed characterizing waste from 3M’s PFAS manufacturing facilities in 1998-1999 essentially confirmed the data reported in 1978, even though those scientists were using less sophisticated analytical tools. Twenty years apart, both groups confirmed there were high levels of PFAS in wastewater effluent from the manufacturing facility in Decatur, there were high levels of PFAS in the sludge that was being incorporated into soil and spread on fields, and PFAS was entering the river.  

In 1978-79 3M had data indicating their PFAS chemicals ( e.g. PFOS and PFOA) were persistent, bioaccumulative and toxic, and they knew these same chemicals were entering the environment and being spread on agricultural fields [e.g. #1282, #1284, #1144, #1083, #1174]. In the face of all that knowledge, 3M refused to invest in creating a more comprehensive dataset and did not share this information outside of 3M management.  [#1291] 

The work that I did characterizing the waste streams from 3M’s manufacturing facilities in 1998 was fascinating work for me, but old news for others at 3M including my boss, Dale Bacon.  As the executive who led the Environmental Lab for many years (including during my tenure), Mr. Bacon was engaged in the work in 1978, 1983, 1992 and 1998.  [e.g. #1198, #1284, #1496]  Mr. Bacon is one of 3M’s executive PFAS Secret Keepers, a group I’ll discuss in the next week or two.

How can you help me?

Please share this with people interested in PFAS and public health. Specifically, I’d like to reach communities who are dealing with PFAS contamination and trying to match their pollution reality against the narrative constructed by industry. Please spread the word!