28 March 1999
To: 3MI resign my position as Environmental Specialist effective 6 April 1999. My resignation
is prompted by my profound disappointment in 3M’s handling of the environmental risks
associated with the manufacture and use of perfluorinated sulfonates (PFOS)(CAS#29081-56-9) and its precursors~ such as ethyl FOSE alcohol (CAS #1691-99-2) andmethyl FOSE alcohol (CAS #24448-09-7).
Perfluorooctansefulfonate is the most insidious pollutant since PCB. It is probably moredamaging than PCB because it does not degrade, whereas PCB does; it is more toxic to wildlife;
and its sink in the environment appears to be biota and not soil and sediment, as is the case withPCB.
I have worked within the system to learn more about this chemical and to make thecompany aware of the dangers associated with its continued use. But I have continually
met roadblocks, delays, and indecision. For weeks on end I have received assurances thatmy samples would be analyzed soon--never to see results. There are always excuses andlittle is accomplished. I can illustrate with several examples.
¯¯¯¯For more than twenty years 3M; s ecotoxicologists have urged the company to allow
testing to perform an ecological risk assessment on PFOS and similar chemicals.
Since I have been assigned to the problem a year ago, the company has continued its
hesitancy.
Over a period of seven months I made frequent requests that ecological risk
consultants be hired to help me plan toxicky testing, environmental sampling,chemical fate studies, and ecological risk procedure. I still have not received
authorization even to bring people in to interview-.
I requested, very frequently, over a nine-month period, a sample of chemical to sendout for fate property and ecotoxicity testing. Finally I was provided with one thatapparently the division had had all along.
I put together a pioneer risk assessment on PFOS that indicated a greater than 100%
probability of harm to sea mammals, based on preliminary data on the concentrationof PFOS in menhaden fish meal. The 8e committee told me that they would like toreconsider the assessment aider wc had a validated value for fishrncal. That analysis
was given high priority by the committee. After three months the analysis is still notdone--not because there were technical problems, but because management did notactually give the analysis high priority.
3M submitted a TSCA 8e last May. There is tremendous concern within EPA, thecountry, and the world about persistent bioaccumulative chemicals such as PFOS.
Just before that submission we found PFOS in the blood &eaglets--eaglets still
young enough that their only food consisted offish caught in remote lakes by theirparents. This finding indicates a widespread environmental contamination and foodchain transfer and probable bioaccumulation and bio-magnification. This is a verysignificant finding that the 8e reporting rule was created to collect. 3M chose to

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report simply that PFOS had been found in the blood of animals, which is true butomits the most significant information.
One of our customers, Griffin, has data on some of our chemicals. They developed
this data for pesticide registration purposes. I started regularly asking for permission
to visit Griffin and view the data last May. Their data can help us plan our studies ofsimilar chemicals. It can also indicate if there is an unforeseen risk to certain biota orvia certain exposure pathways. It was ten months before I was allowed to visit
Griffin, at which time I did not get to see the data. I have to return another time to seeit.
3M waited too long to tell customers about the widespread dispersal of PFOS inpeople and the environment. We knew before May of 1998, yet 3M did not starttelling customers until January of 1999. I felt guilty about this and told customers I
personally knew earlier. Still, it was not as early as it should have been. I kept
waiting for 3M to do its duty, as I was continually assured that it would. Some of thecustomers have done risk assessments on the PFOS precursor they use. They assume
there is not a background in the environment and in wildlife. Since there is abackground, their risk assessments are inaccurate. Thus they can make inappropriate
business decisions and not realize that their use of PFOS precursors contributes to anaggregate risk.
3M continues to make and sell these chemicals, though the company knows of anecological risk assessment I did that indicates there is a better than 100% probability
that perfluorooctansulfonate is biomagnifying in the food chain and harming sea
mammals. This chemical is more stable than ninny rocks. And the chemicals thecompany is considering for replacement are just as stable and biologically available.
The risk assessment I performed was simple, and not worst case. If worst case isused, the probability of harm exceeds 100,000%.
3M told those of us working on the fluorochemical project not to write down ourthoughts or have email discussions on issues because of how our speculations could
be viewed in a legal discovery process. This has s~mied intellectual development on
the issue, and stifled discussion on the serious ethical implications of decisions
I have worked to the best of my ability within the system to see that the right actions aretaken on behalf of the environment. At almost every step, I have been assured that action
will be taken--yet I see slow or no results. I am told the company is concerned, but theiractions speak to different concerns than mine. I can no longer participate in the processthat 3M has established for the management of PFOS and precursors. For me it isunethical to be concerned with markets, legal defensibility and image over environmental
safety.
Sincerely,Rich Purdy

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