28 March 1999
To: 3M

I 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) and
methyl FOSE alcohol (CAS #24448-09-7).
Perfluorooctansefulfonate is the most insidious pollutant since PCB. It is probably more
damaging 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 with
PCB.
I have worked within the system to learn more about this chemical and to make the
company 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 that
my samples would be analyzed soon--never to see results. There are always excuses and
little is accomplished. I can illustrate with several examples.
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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 send
out for fate property and ecotoxicity testing. Finally I was provided with one that
apparently 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 concentration
of PFOS in menhaden fish meal. The 8e committee told me that they would like to
reconsider 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 not
done--not because there were technical problems, but because management did not
actually give the analysis high priority.
3M submitted a TSCA 8e last May. There is tremendous concern within EPA, the
country, 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 their
parents. This finding indicates a widespread environmental contamination and food
chain transfer and probable bioaccumulation and bio-magnification. This is a very
significant 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 but
omits 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 of
similar chemicals. It can also indicate if there is an unforeseen risk to certain biota or
via 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 see
it.
3M waited too long to tell customers about the widespread dispersal of PFOS in
people and the environment. We knew before May of 1998, yet 3M did not start
telling 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 the
customers 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 a
background, their risk assessments are inaccurate. Thus they can make inappropriate
business decisions and not realize that their use of PFOS precursors contributes to an
aggregate risk.
3M continues to make and sell these chemicals, though the company knows of an
ecological 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 the
company 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 is
used, the probability of harm exceeds 100,000%.
3M told those of us working on the fluorochemical project not to write down our
thoughts 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 are
taken 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 their
actions speak to different concerns than mine. I can no longer participate in the process
that 3M has established for the management of PFOS and precursors. For me it is
unethical to be concerned with markets, legal defensibility and image over environmental
safety.
Sincerely,
Rich Purdy

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