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Occupational Firefighter Concerns on PFAS: What Do Dockers® Pants and the Precautionary Principle Have to Do With Firefighting Foams and Firefighters?
Fluorinated firefighting foams were transitioned from long chain to short chain PFAS due to the US EPA Stewardship Program. "In 2006, EPA invited eight major leading companies in the PFAS industry to join in a global stewardship program."1 This change was initiated due to increasing concerns about PFAS contamination and health issues connected to PFAS.
PFAS occur in more products than just firefighting foams. Between 2012-2015 when many industries transitioned from using C8 to C6 PFAS in their products, many decided not to do so based upon the precautionary principle. Levi Strauss & Co. issued a case study on their decision to not change over to C6 production in May 2016. This was done to avoid introducing a regrettable substitution by identifying substances of concern following a six-step program that the company had set up.2
The company reported:
"Short chain PFCs" are not currently regulated and do not have a mandatory classification under the EU's classification and labelling (CLP) Regulation. But the evidence that long-chain PFCs, such as perfluorooctonoic acid (PFOA) and perfluorooctanesulfonate acid (PFOS) are harmful to human health and the environment is well documented, according to Levi Strauss.
Furthermore, Levi Strauss says "although there is much less available data to demonstrate it the theory held by certain sectors in the science and NGO communities is that the molecular structure between short-chain and long-chain PFCs is so similar that short-chain PFCs may also be persistent, bioaccumulative and toxic (PBT)." In line with the precautionary principle, the company made the decision to replace the substance of concern with a PFC-free alternative.
The primary focus was to make sure the alternative chemical did not turn out to be a 'regrettable substitution,' and subsequently be identified as just as hazardous as the chemical it was trying to replace. Of particular importance were PBT and carcinogenic endpoints, because they were the endpoints of concern in long-chain PFCs that it was seeking to replace."3
Levi is known worldwide for their clothing, a brand of denim jeans and Dockers(R), employing 15,800 people internationally.4 "Dockers main European market is Spain, which covers 50% of its business in the continent. France, Turkey and Spain represent 80% of sales in Europe."5 As of 2016, Levi Strauss Signature jeans were sold in 110 countries.6
In addition to Levi Strauss & Co., IKEA, Crate & Barrel and 50 other US companies declined to go with the 'new' C6 technology and decided corporately to obtain safer replacement items for their finished products.7
Using short chain compounds in firefighting foams requires using a greater amount of perfluorinated chemicals than the older, long chain foam products. Dr. Linda Birnbaum, recently retired director of the National Institute of Health / National Institute of Environmental Health Sciences (NIH/NIEHS), downplayed the difference in GenX and PFOA toxicity stating: "Every PFAS that has been studied is causing problems." GenX is C6.8 Image Copyright: Foam Exposure Committee. Attorney Robert Bilott published Exposure in 2019 about his efforts working on PFAS for over 20 years. The movie "Dark Waters" made the Cincinnati attorney famous. Mr. Bilott is currently representing Belleview McVille, Ohio Fire Chief Jeff Hermes in a class action lawsuit. Chief Hermes blames his 2016 cancer diagnosis on PFAS in ﬁreﬁghting foams. He had joined the US Air Force in 1983. The case is not just about ﬁreﬁghters but would allow the 97% of Americans who have PFAS in their blood to obtain testing.
In the US, the NIH/NIEHS agency funds scientific research into PFAS chemicals. "Even if they have a shorter half-life, if it has a half-life of 30 days, it's going to build up in your body," Dr. Birnbaum explained. She further reported: _"… lack of biological persistence does NOT mean lack of toxicity, particularly for chemicals like PFAS that may have consistent daily exposures_."9 In other words, just because a toxic substance is in the body a shorter amount of time, it does not necessarily mean it is to be considered any less toxic, especially if the exposure is through daily intake of contaminated drinking water.
The precautionary principle uses criteria to assess all potential risk. Risk management is a key component of the assessment process. The US Fire Administration states:
"Risk management is increasingly seen in many occupations as a proactive approach to mitigating potential injury risks. However, research on implementing safety interventions in the fire service is limited. Recently, a team of researchers set out to see how a risk management approach might be successfully implemented by firefighters.
A key principle of the approach was that the firefighters themselves identified the risks and developed solutions to mitigate them. Proactive risk management is required by regulation in the United Kingdom's fire service. Although not required in the United States, the research team believed that even a voluntary implementation would bring great benefit."10
The National Fire Protection Association (NFPA) is responsible for setting fire service regulations in the US. The organization has historically avoided addressing firefighter occupational exposure and toxicity in firefighting standards. In the meantime, restrictions are being set state by state by the department of natural resources or environmental quality, legal actions and insurance constraints instead of being fire service directed.
Fortunately, there are commercially available fluorine-free foams that meet fire testing performance criteria. Fire chiefs are constantly involved in problem resolution to provide their departments with safer products that can accomplish the job. By choosing a fluorine-free firefighting foam that has been fire tested by a third party, the decision will protect firefighters and downgradient community water supplies.
"The International Pollutants Elimination Network (IPEN) is a global network of public interest organizations improving chemical policies and raising public awareness to ensure that hazardous substances are no longer produced, used, or disposed of in ways that harm human health and the environment."11 According to an IPEN expert panel review, occupational exposure of firefighters to PFAS is concerning and could be significant. Elevated blood levels are found in both younger firefighters and longer-serving personnel who could have been exposed to older AFFFs.
"It would appear that a significant exposure pathway could occur during routine activities such as equipment maintenance and clean-out as well as during foam concentrate transfer from bulk containers to appliances." Significant exposure to foam concentrates can occur "through inhalation, ingestion or skin absorption of aerosols and splashes as well as the possibility of skin absorption when handling contaminated equipment…"12
According to IPEN: "The penetration of these fluorosurfactants into groundwater, even through solid concrete airport aprons, let alone the direct discharge into ground, rivers, and the ocean has far reaching effects, even into the food chain where bioconcentration makes the situation even worse…."13 More recent exposures to firefighters could result from contaminated training areas where PFAS residues from previously used legacy foams could be reconstituted.
Attorney Robert Bilott reported on a July 31, 1980 DuPont PFOA communication meeting memorandum that stated PFAS "toxicity varied depending on the pathway: orally, it was claimed to be "slightly toxic"; with skin exposure, "slight to moderately toxic"; and inhaled it was "highly toxic.""14
The Wisconsin Department of Natural Resources (DNR) tested actual firefighting foam samples for PFAS at Starkweather Creek in Madison during October 2019. The location is just south of the Dane County Regional Airport and Truax Air National Guard Field. The foam test samples measured between 80,000 and 92,000 parts per trillion (ppt) of PFOS while the surface water measurements tested at 400 ppt of PFOS.15 These test amounts are considered extremely high. USEPA lifetime drinking water health advisories for PFOA and PFOS together are 70 ppt.16
In response to these and other alarming findings, the DNR requested a statewide report on usage of PFAS-containing firefighting foams through a voluntary survey for fire departments which was scheduled to end March 17, 2020. "The survey will help with collection and disposal efforts throughout Wisconsin."17
"All PFAS-containing foams have the potential to create an adverse environmental impact if released into the environment, particularly if the foam solutions reach drinking water sources, groundwater or surface waters. Knowing where this foam is will help us ensure that the environment is protected from its damaging effects," according to Department of Natural Resources (DNR) Secretary Preston D. Cole of Wisconsin.18 Image Copyright: Foam Exposure Committee. The long delayed Toxicological Proﬁle for Perﬂuoroalkyls ﬁnally was issued in June 2018. This was the government report where ﬁreﬁghters became aware that they were expected to be occupationally exposed to PFAS
The US Agency for Toxic Substances and Disease Registry (ATSDR) issued a long delayed draft paper on PFAS in June 2018. They reported: "Individuals who perform jobs that require frequent contact with perfluoroalkyl-containing products, such as individuals who install and treat carpets or firefighters, are expected to have occupational exposure to these substances."19 [emphasis added]
Through FireRescue1, it was reported:
"IPEN scientists concluded a PFAS study revealing that there is "unequivocal evidence" that firefighters using chemicals containing PFAS to fight fires have high levels of toxic chemicals in their blood."
"Firefighters can be exposed to PFHxS and other PFAS chemicals from firefighting foam, exposure from contaminated PPE, managing PFAS foam wastes and contaminated fire stations.
"Unfortunately, the alternatives to PFOA and PFOS have the same health risks. The Environmental Protection Agency and the Centers for Disease Control and Prevention performed an analysis and linked substitutes for PFOA and PFOS, such as Gen-X and PFBS, with serious health problems."20
Examples of health effects linked to some PFAS include:
- Increased chance of thyroid disease
- Decreased immune response
- Increased cholesterol levels
- Increased chance of cancer, especially kidney and testicular cancers21
With growing concerns about occupational exposure and contaminated drinking water supplies from PFAS, limiting discharge of these toxic substances should be considered for the environment and to protect individuals, especially firefighters.
Fluorine-free foams are the solution to this toxic issue since they have been proven acceptable worldwide and are considered safer for firefighters. According to the New York Rochester Institute of Technology (RIT): "There is no regulation preventing the use of fluorine-free foams by non-military users, including firefighting training centers, chemical manufacturers, oil refineries, and others."24
- The New York RIT report listed over 90 fluorine-free foams from 22 manufacturers. These were "identified and tabulated with relevant data, including product and manufacturer name, country, performance specifications met, product application, product description, and the Chemical Abstracts Service (CAS) Registry Number, name, and percent of disclosed ingredients in the product."25
- "The main source of product information was manufacturer websites.26
There are shortcomings with ingredient disclosures and safety data sheets for firefighting foam products. In order to help fire officers make solid decisions, the Foam Exposure Committee wanted to narrow and prove out the fluorine-free foams that a fire department could safely use. The Committee was able to obtain a cross section of foam products presently used in the fire service. Testing was performed for total fluorine on each firefighting sample obtained.
No one has addressed the firefighters' exposures to PFAS. Because of foam's dispersive nature, PFAS containing foam cannot be properly contained and it will contaminate drinking water. This will affect the public the fire service is attempting to protect and serve. The choice of firefighting foam can be made at the fire chief level but the fire officer needs more complete information which the Foam Exposure Committee will be able to provide with their testing.
- Case Study on Phase out of Short-Chain C6 Perfluorinated Chemicals (PFCs) from Apparel, Levi Strauss & Co., May 2016, https://chemical-watch.s3.amazonaws.com/downloads/Levi-article.pdf
- Dockers reclaims the throne of casualwear: Levi Strauss relaunches brand and accelerates in Europe, Iria P. Gestal / F.T. Ngo BII, Fe 12, 2020, https://www.themds.com/companies/dockers-reclaim-the-throne-of-casualwear-levi-strauss-relaunches-brand-and-accelerates-in-europe.html
- Short-chain Fluorinated Replacements: Myths versus Facts, Green Science Policy Institute, June 2018, https://greensciencepolicy.org/wp-content/uploads/2018/06/Myths-vs.-Facts-June-2018.pdf
- Clean Cape Fear, Frequently Asked Questions, https://www.cleancapefear.org/q-a/
- Using a risk management approach to reduce firefighter injuries, Nov 28, 2017, https://www.usfa.fema.gov/current_events/112817.html
- IPEN 2019, White Paper for the Stockholm Convention Persistent Organic Pollutants Review Committee (POPRC-15) Perfluorohexane Sulfonate (PFHxS)-Socio-Economic Impact, Exposure, and the Precautionary Principle, https://ipen.org/sites/default/files/documents/pfhxs_socio-economic_impact_final_oct.2019.pdf
- Fluorine-free Firefighting Foams (3F) Viable Alternatives to Fluorinated Aqueous Film-Forming Foams (AFFF) IPEN, Stockholm Convention, POPRC-14, Rome, September, 2018, https://ipen.org/sites/default/files/documents/IPEN_F3_Position_Paper_POPRC-14_12September2018d.pdf
- Exposure, Robert Bilott, Simon & Schuster, Inc., 2019, p. 174
- DNR: High levels of PFAS in foam from Starkweather Creek; mayor calls tests 'concerning,' _Wisconsin State Journal_, Chris Hubbuch, Dec 20, 2019, https://madison.com/wsj/news/local/environment/dnr-high-levels-of-pfas-in-foam-from-starkweather-creek/article_048ba3b0-3afd-5ef2-8fa7-e921edc7fd66.html
- DNR Asking Wisconsin Fire Departments To Report Use Of PFAS-Containing Firefighting Foam, B. Arbuckle, Feb 6, 2020, https://dnr.wi.gov/news/releases/article/?id=5038)
- ATSDR Toxicological Profile for Perfluoroalkyls, Draft for Public Comment, June 2018, https://www.atsdr.cdc.gov/toxprofiles/tp200.pdf, p. 557
- FireRescue1, Oct 1, 2019, https://www.firerescue1.com/research/articles/study-high-pfas-blood-levels-in-firefighters-EmPdska6GbwYoaxG/
- PFAS Exposure and Your Health, 4/2019, https://www.michigan.gov/documents/pfasresponse/2019-4-23_PFAS_Exposure_and_Your_Health_-_APPROVED_WEB_653460_7.pdf
- Wolverine Worldwide Blood Testing and Potential PFAS Exposure, Dec 7, 2017, https://wearewolverine.com/2017/12/07/blood-testing-and-potential-pfas-exposure/
- PFAS, An Overview on the Science and Guidance for Clinicians on Per- and Polyfluoroalkyls Substances, (PFAS), 12/6/2019, https://www.atsdr.cdc.gov/pfas/docs/ATSDR_PFAS_ClinicalGuidance_12202019.pdf
- New York State Pollution Prevention Institute, Rochester Institute of Technology, Kate Winnebeck, 2018 and 2019, http://theic2.org/article/download-pdf/file_name/Per_and_Polyfluorinated_Substances_in_Firefighting_Foam_040919.pdf, p.12 & 34
- ibid, page 10
- ibid, page 22
Foam Exposure Committee Mission Statement: To reduce firefighter / first responder exposures to perfluorinated chemicals used in firefighting foams in order to protect their health and lives. We will determine which firefighting products contain PFAS and those that are fluorine-free firefighting foams. First responders should have immediate access to safer fluorine-free firefighting foams.
The committee was formed of two retired fire chiefs and two former firefighters all of whom are presently involved in the firefighting foam industry, equipment and fire apparatus and a fire chief's widow.
Foam Exposure Committee:
- Bill Hutchins (Arizona Fire Apparatus)
- Dion LeMieux (Haven South LLC)
- Rick Nickeson (R. Nickeson Enterprises)
- Vicki Quint (Quint LLC)
- Rick Rochford (Environmental Response Solutions LLC)