PLEASE ADD OCCUPATIONALLY EXPOSED FIRE SERVICE TO THE PEASE AFB PFAS CONCEPT PLAN.
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America's firefighters have been on the front line of PFOA/PFOS exposure since 1983 while using it in AFFF, being sprayed in our eyes, mouth, nose, wading in it, having it adhere to our PPE/personal protection ensembles/turnout gear, and exposing our families to this toxin after bringing home contaminated gear.
We were not aware how toxic this substance was.
We have just recently learned our turnout gear, or PPE has been impregnated with PFOA since 1999 (at least) to make our gear water repellent so that it meets the NFPA 1971 water resistance standards for firefighting. We were not made aware. We do not know how much. Only the chemical giants have that information. We sweat in this gear, our body temperature rises and our skin absorbs these toxins. We start our careers in our child bearing years. PFOA and PFOS are designated by California Prop65 as causing 'reproductive cancers'.
In 2006 the European Chemical Agency (ECHA) notified the chemical giants that they would be restricting PFOA in 'textiles'. One of those textiles is firefighter PPE. By 2012 PFOA was designated Substance of Very High Concern by the ECHA. Turnout gear manufacturers were made aware of the decision to restrict the amount of PFOA in turnout gear to 25ppb and 'precursors' to 1ppm.
As of today, January 18, 2018, they have not advised the US of this issue formally. While the manufacturers are discussing and teaching about the issue in Europe, they have not mentioned it here. They have only minimized the issue when it came up recently by way of a firefighting article here in the US. https://station-pride.com/2017/03/28/the-real-cancer-in-your-gear/
We are in a particularly high risk exposure setting as our gear has been degrading in our fire stations where we work, eat, sleep, since 1999.
The coating on our gear degrades in UV lighting, in many stations our gear is stored in open lighting next to the engines and trucks in our bays. There may be as many as 30 sets of gear in a station in one week. The gear is designed to be used for 5 years and 30 washings. Over the course of 20 years we have had thousands of sets of gear in our stations releasing particles of PFOA into our 'home'.
As of this date, there has not been a PFAS dust study done in our stations. Yet, biomonitoring has shown firefighters PFOA serum tested in ranges from 243 ng/mL to 423 ng/mL from a 'yet unknown source'. The 'DuPont Water Works' plant workers were high at 32 ng/mL.
Adding to this IDLH issue is the October 2, 2017 NH DES letter to every fire station in NH that of 6 of 7 New Hampshire fire stations water wells tested at 'elevated' levels of PFAS. https://www4.des.state.nh.us/nh-pfas-investigation/wp-content/uploads/2017/11/Fire_Department_H20Sample.pdf
Since September 5, 2017, Environmental Attorney Robert Bilott, along with C8 Science panel member Dr Paul A Brooks, and Fire Chief Jeffrey Hermes have demanded testing and studies of the EPA, CDC/ATSDR, and US Attorney General on behalf of all responders in the US due to their exposure from these areas. See letter here: https://www.documentcloud.org/documents/3988104-Firefighter-Letter.html
On January 16, 2018 Attorney Bilott did receive a reply from Patrick Breysee PhD CIH Dir ATSDR indicating the monies Attorney Bilott requested (7,000,000) from the recently found funds available, was not yet designated for FIREFIGHTERS.
We seek immediate support and decisiveness that these funds are designated for the front line, who while already at a very high risk for cancer., was unaware of the toxin in our PPE and the extent of the toxicity of PFAS in the AFFF.
The manufacturers were well awaare of the extent and danger of this toxin, yet chose to not issue the hazard in warning labels in our gear. They actually belong to a group called Fire and Emergency Manufacturers Association (FEMSA) THAT FOUGHT FOR, AND WON THE RIGHT, TO NOT PUT WARNING LABELS IN OUR GEAR. https://www.femsa.org/whois_femsa/history/
These same manufacturers sit at our NFPA standards committees deciding everything from the balance of a helmet to the width of reflective tape on our gear. Not once did they disclose this danger to us. These are very complicated drawn out committees, at any time a manufacturer could have provided a 'notice of concern'. They did not.
We cannot wait one more day for money to be found while we don gear that is coated in PFAS and use AFFF that may or may not be safe.
We have sacrificed enough, we have given enough of ourselves, we expect immediate action from each and every individual on this petition. We deserve nothing less. We have been kicked down the road long enough in this ruse of deception and omission of the toxic hazards of PFAS from the manufactures that provide our PPE and AFFF. Charge this back on them if need be. The PPE industry alone in the USA is over 5 billion dollars.
On August 11, 2017, we received the test results of NEW, NEVER WORN 2004 turnout gear. We had it tested to determine if there could still be PFOA in the gear after 13 years. The testing was performed by Professor of Physics, Graham Peaslee, Notre Dame, IN. Here are his results:
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....
UPDATE **** JANUARY 29, 2018 ****
TESTING RESULTS CONFIRM PFOA PRESENT IN EXCESSIVE AMOUNTS IN 2004, NEW/NEVER-WORN STRUCTURAL PPE, SEE LINK FROM PROFESSOR OF PHYSICS AT NOTRE DAME, GRAHAM PEASLEE:
I have some LC-MS/MS results from an academic lab that I trust...they took the four pieces of clothing you sent me and took a small piece of each and rinsed it three times in heated methanol, and analyzed the rinse for the presence of 78 different PFAS. We know from previous textile work that this only will get some small fraction of what is adhered to the fabrics, but it will identify what is there. The results look something like this:
Item PFBA PFHxA PFHpA PFOA PFNA PFDA PFTeDA FHUEA
Right Sleeve <LOQ 14 <LOQ <LOD 121 66 <LOD <LOD
Left Under Arm <LOQ <LOD 13 116 74 57 <LOD <LOD
Moisture barrier <LOQ <LOD <LOD 41 <LOD 25 <LOD <LOD
Tail <LOQ <LOD 14 <LOD 84 28 30 <LOD
Envelope 46 109 <LOD <LOD <LOD <LOD <LOD 40
A quick explanation...these are the 7 diffferent PFAS that showed up above level of detection (LOD), or above level of quantification (LOQ). The PFBA are C4 acids, the PFHxA are C6 acids, the PFHpA are C7 acids, the PFOA are C8 acids, the PFNA are C9 acids, and the PFDA are C10 acids, and the last one is a C11 acid.
The first four rows are your four fabric samples with concentrations in ppb, and the last sample is the brown envelope in which the samples were shipped, so it is possible it contained some short-chained PFAS that might have contaminated the right sleeve sample. If you want to send these to a commercial lab at some point, you will want to put them in individual ziploc bags.
In summary, there are C8, C9 and C10 PFAS found on each garment, but less on the moisture barrier. These are "long-chain" PFAS, and the majority seems to be heavier than PFOA, although there is certainly PFOA present. Combined with the PIGE results which showed high levels of F present, and a methanol rinse that only removes a small fraction for analysis I would guess there is plenty of these long-chain PFAS applied to these garment samples.
The lab also did a GC/MS test for volatile PFAS, and found only volatile PFAS on the Tail sample, but with fairly high concentrations: 6:2 FTOH (120 ng/g), 8:2 FTOH (3600 ng/g), and 10:2 FTOH (1300 ng/g) (with all other analytes below detection.)
The fact that both the GC and LC/MS data are indicating C8 and C10 in the samples helps confirm the long-chain observation. To my knowledge, this type of long-chain PFAS chemistry is not typically used in textiles these days...so it is unusual to see them in samples.
I trust these data, and you are can share these results with your colleagues - but if you want to go further with the data in a court of law or elsewhere, you would have to have a commercial lab confirm these results...and that is pricey I know, but now you know what to look for at least. Armed with this information I bet you can start asking who used these long-chain PFAS commercially in fire-resistant clothing.
I wish you luck in your investigation. Sorry this took so long, but all the labs are very busy these days.
from Diane : What is important to note here, is that this testing will only remove a fraction of the actual content in the fabric. So that fraction, was 5 times the ECHA limit of 25 ppb PFOA. 5 times.... just that fraction.. what were we wearing? What are we wearing?
***** BOMBSHELL **** 2.20.2018 ********
IN 1992.. DuPont's own scientists found PFOA CAUSES *** YES, CAUSES *** TESTICULAR CANCER. THE NUMBER ONE CANCER IN THE FIRE SERVICE. THEY KNEW WE WEAR THIS GEAR NEXT TO OUR REPRODUCTIVE ORGANS FOR HOURS AT A TIME OVER YEARS AND YEARS... THEY HAVE SAID NOTHING.... EXCEPT TO FOCUS ON THE PRODUCTS OF COMBUSTION..
READ PAGE 29: THIS IS A DuPONT SHAREHOLDERS DOCUMENT. YOU, THE END USER WERE LEFT OUT......
In addition to causing testicular tumors, PFOA causes many other effects on the male reproductive system,
including increased size of the testes, epididymides and seminal vesicles, and decreased prostate in rats
[2, 6]. In the female, PFOA causes mammary tumors and cellular effects on the ovary .
Senators, Congresspersons, please, we must have your immediate attention. We have been poisoned by the companies that have a huge money stake in every aspect of the fire service.
We need water testing in our stations, dust studies in our stations, new technology that does not require PFAS and precursors for coatings that will form PFOA to meet our NFPA Standards, we need serum testing to follow us thorough our careers.
We sacrifice enough.
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