Selected Statements, Studies and Reports

Return to PFOS / PFOA Index Page

NOTE: The interest of the FAN Pesticide Project in this issue is directly related to the fact that several PFOS and PFOA chemicals were used as "inerts" in pesticides. However, most, but not all, have been deleted from use since 2001. The so-called "inerts" are used in pesticides and can account for as much as 99%, or more, of a pesticidal formulation. US EPA's policy is to allow the public information only on the "active substance" and to deny the public the names of the chemicals used as "inerts" in specific pesticide products -- even though the majority of inerts are toxic and biologically active.

• See the molecular structure for some of these chemicals

PFOA. February 2006. In an article in Environmental Science & Technology called The Weinberg Proposal, a 5-page letter was made publicly available from the international consultant firm called the The Weinberg Group Inc. to DuPont. The letter is a proposal to DuPont to manage their corporate strategy on the maelstrom surrounding PFOA to DuPont's advantage. This is indeed a very rare look at the strategies of managing a polluters image to the polluters advantage. For example, P. Terrance Gaffney, Esq., of The Weinberg Group wrotet:

... For over two decades, clients have repeatedly communicated to us that of all the services we provide, the most valued is our ability to provide an overall science-based defense strategy. This strategy can be applied to litigatlon, regulatory, or legislative problems that cause a particular product to be under pressure. Specifically, during the initial phase of our engagement by a client, we will hamess, focus, and involve the scientific and intellectual capital of our company with one goal in mind -creating the outcome our client desires....
Read full letter.

PFOS-PFOA. February 2006. Investigation of perfluorochemical (PFC) contamination in Minnesota. Phase One. Report to Senate Environmental Committee. By Fardin Oliaei, Don Kriens and Katrina Kessler.

PFOA. January 20, 2006. Review of EPA's Draft Risk Assessment of Potential Human Health Effects Associated with PFOA and Its Salts. US EPA Science Advisory Board.

PFOS- PFOA. January 13, 2005. Results of survey on production and use of PFOS, PFAS and PFOA, related substances and products/mixtures containing these substances. ENV/JM/MONO(2005)1. Organisation for Economic Co-operation and Development. OECD Environment, Health and Safety Publications. Series on Risk Management No. 19.

PFOS-PFOA. Jan 4, 2005. Draft Risk Assessment of the potential human health effects associated with exposure to perfluorooctanoic acid and its salts. US EPA Office of Pollution Prevention and Toxics, Risk Assessment Division. (132 pages)

PFOS. Oct 2004 (release date). Environmental Risk Evaluation Report: Perfluorooctanesulphonate (PFOS). by D Brooke, A Footitt, T A Nwaogu. Research Contractor: Building Research Establishment Ltd., Risk and Policy Analysts Ltd. Report produced by the UK Environment Agency's Science Group. (96 pages)

PFOS. Sept 2004. Proposal for Regulations on PFOS-Related Substances. Partial Regulatory Impact Assessment. Prepared for the UK Department for Environment, Food and Rural Affairs (DEFRA). Chemicals and GM Policy Division by Risk & Policy Analysts Ltd. in association with BRE Environment. Project: J454/PFOS RRS. (39 pages)

PFOS. Aug 2004. Perfluorooctane Sulphonate. Risk Reduction Strategy and Analysis of Advantages and Drawbacks. Final Report. Prepared for Department for Environment, Food and Rural Affairs and the Environment Agency for England and Wales. (266 pages)

PFOA. Aug 1, 2003. Perfluorooctanoic Acid. Physiochemical Properties and Environmental Fate Data. Submitted to US EPA from Michael A. Santoro, Director, Environmental Health Safety and Regulatory Affairs, 3M; and George H. Millet, Director - Quality, Environmental, Health & Safety, Dyneon LLC, 3M Company. Federal Register Docket No. OPPT-2003-0012-0164

PFOA. Aug 1, 2003. Submission of Monitoring Data Pursuant to the 3M LOI dated March 13, 2003 and APFO Users LOI dated March 14, 2003. Letter to US EPA from Michael A. Santoro, Director, Environmental Health Safety and Regulatory Affairs. 3M. Federal Register Docket No. OPPT-2003-0012-0163

PFOS-PFOA. April 10, 2003. Preliminary Risk Assessment of the Developmental Toxicity Associated with Exposure to Perfluorooctanoic Acid and its Salts. US EPA, Office of Pollution Prevention and Toxics, Risk Assessment Division. (63 pages)

PFOA. March 13, 2003. Environmental, Health and Safety Measures Relating to Perfluorooctanoic Acid and its Salts (PFOA). Letter to US EPA from Dr. Larry Wendling, VP, Performance Materials Division, 3M Company (9 pages). Federal Register Docket OPPT-2003-0012-0007

PFOS-PFOA. Nov 21, 2002 report: Hazard Assessment of Perfluorooctane Sulfonate (PFOS) and its Salts. Organisation for Economic Co-operation and Development (OECD). 362 pages. ENV/JM/RD(2002)17/FINAL.

PFOS-PFOA. March 1, 2000. Sulfornated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects. Prepared by 3M. This report is part of Federal Register Docket [OPPT-2002-0043] for US EPA's Dec 9, 2002, Final Rule on Perfluoroalkyl Sulfonates; Significant New Use Rule.

3M. February 5, 1999. The Science of Organic Fluorochemistry 12 pages.

Newspaper articles and Documents related to the Class Action lawsuit in Ohio on the contamination of drinking water with the PFOA Ammonium Perfluorooctanoate (commonly called C8). The C8 contamination originated from DuPont's Washington Works facility in Wood County, West Virginia

The Environmental Working Group (EWG) has been actively engaged in the PFOA issue.
They published the first comprehensive report on Perfluroinated Chemicals that includes a
searchable database to hundreds of documents.

Federal Register Entries. This is the public record of US EPA's statements and reguatory actions on PFOS and PFOA.

Abstracts on PFOS and PFOA for the following years:

See also:

Timeline for PFOS and PFOA chemicals

Molecular formulas of some PFOS - PFOA substances

List of PFOA - PFOS chemicals to be regulated by US EPA as identified in Federal Registers

TIMELINE: Selected Statements, Studies and Reports

3M January 21, 1999

Federal Register

Docket No. 0PPT-2002-0043-0007

Perfluorooctane Sulfonate: Current Summary of Human Sera, Health and Toxicology Data.

129 pages

3M February 5, 1999

Federal Register

Docket No. 0PPT-2002-0043-0006

The Science of Organic Fluorochemistry

12 pages

3M May 26, 1999

Federal Register

Docket No. 0PPT-2002-0043-0008

Fluorochemical Use, Distribution and Release Overview

347 pages

3M March 1, 2000

Federal Register

Docket No. 0PPT-2002-0043-0005

Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects.

51 pages

3M April 12, 2000 Study prepared for 3M

26-Week Capsule Toxicity Study with Perfluorooctane Sulfonic Acid Potassium Salt (PFOS; T-6295) in Cynomolgus Monkeys. Draft Report. COVANCE STUDY NUMBER 6329-223 VOLUME I of11

Author: Peter J. Thomford, PhD Study
Completion Date: To be determined
Testing Facility: Covance Laboratories Inc. 330 1 Kinsman Boulevard Madison, Wisconsin 53704-2595
Laboratory Study Identification: Covance 6329-223
Sponsor Study Identification: 3M Study NO. T-6295.7

30 pages

3M May 10, 2000 3M Environmental Laboratory

COMPOSITE ANALYTICAL LABORATORY REPORT ON THE Quantitative Analysis of Fluorochemicals in Environmental Samples. REPORT NO. FACT GEN-021, GEN-024, GEN-030, GEN-033 LRNW2491, W2845, W3197, EOO-1386

12 pages.

3M Announcement of phasing out chemicals May 16, 2000

3M Press Release

PFOS - 3M today announced it is phasing out of the perfluorooctanyl chemistry used to produce certain repellents and surfactant products.
... These include many Scotchguard products, such as soil, oil and water repellent products; coatings used for oil and grease resistance on paper packaging; fire-fighting foams; and specialty components for other products. 3M said it plans to substantially phase out production by the end of the year... "Our decision anticipates increasing attention to the appropriate use and management of persistent materials," said Dr. Charles Reich, executive vice president, Specialty Material Markets.... Sophisticated testing capabilities - some developed in only the last few years -- show that this persistent compound, like other materials in the environment, can be detected broadly at extremely low levels in the environment and in people. All existing scientific knowledge indicastes that the presence of these materials at these very low levels does not pose a human health or environmental risk...
Ref: 3M phasing out some of its specialy materials. 3M press release,

Statement by US EPA May 16, 2000 Charles Auer's statement

Statement by: Charles Auer, USEPA, Director, Chemical Control Division Office of Pollution Prevention and Toxics. EPA OPPT.

PFOS - According to US EPA: "PFOS accumulates to a high degree in humans and animals. It has an estimated half-life of 4 years in humans. It thus appears to combine Persistence, Bioaccumulation, and Toxicity properties to an extraordinary degree."

3M Letter July 7, 2000

Federal Register

Docket No. 0PPT-2002-0043-0009

3M. Phase-out Plan for POSF-Based Products. Letter from William Weppner (3M) to Charles Auer (US EPA)

11 pages
3M July 13, 2000 3M New Data on Half-Life of Perfluorochemicals in Serum
US EPA. August 31, 2000

Federal Register

Docket No. 0PPT-2002-0043-0010

Hazard Assessment and Biomonitoring Data on Perfluorooctane Sulfonate - PFOS, with cover memo from Jennifer Seed, EPA OPPT to Charles Auer, EPA OPPT

30 Pages

Paper August 2002 Presented at Dioxin 2002 Conference, Barcelona, Spain.

PFOS - The first environmental survey of Perfluorooctane Sulfonate and related compounds in Japan. Authors: Sachi Taniyasu (1), Kurunthachalam Kannan (2), Yuichi Horii (1) and Nobuyoshi Yamashita (1)

(1) National Institute of Advanced Industrial Science and Technology (AIST), EMTECH, 16-1, Onogawa, Tsukuba, Ibaraki 305-8569 JAPAN
(2) National Food Safety and Toxicology Center, Michigan State University, East Lansing, Michigan, US

US EPA Report Nov 4, 2002


Office of Pollution, Prevention
and Toxics

PFOA -Revised Draft Hazard Assessment of Perfluorooctanoic Acid and its Salts.
This is a preliminary assessment of the potential hazards to human health and the environment associated with exposure to perfluorooctanoic acid (PFOA) and its salts. The majority of the toxicology information is for ammonium perfluorooctanoic acid (APFO). This assessment includes a review of the studies that were available as of October, 2002.

PFOA is primarily used as a reactive intermediate, while its salts are used as processing aids in the production of fluoropolymers and fluoroelastomers and in other surfactant uses... Groundwater samples taken near fire-training areas that used fire-fighting foams containing perfluorinated surfactants had elevated PFOA concentrations many years after the foam use. This demonstrates the following:

(1) PFOA either existed in--or was formed via degradation of-- the surfactants,
(2) PFOA or its precursors migrate through the soil, and
(3) PFOA persists in groundwater.

A retrospective cohort mortality study demonstrated a weak, although statistically significant association between prostate cancer mortality and employment duration in the chemical facility of a plant that manufactures PFOA. However, in a recent update to this study in which more specific exposure measures were used, a significant association for prostate cancer was not observed. In a morbidity study, workers with the highest PFOA exposures for the longest durations sought care more often for prostate cancer treatment than workers with lower exposures.

107 pages

OECD Report  Nov 21, 2002 Organisation for Economic Co-operation and Development (OECD)

PFOS - Hazard Assessment of Perfluorooctane Sulfonate (PFOS) and its Salts

362 page report. ENV/JM/RD(2002)17/FINAL. Organisation for Economic Co-operation and Development (OECD)

Newspaper March 29, 2003 New York Times PFOA - Ammonium perfluorooctanoate. Chemical might pose health risk to younger women and girls.
Newspaper Feb 16, 2003 The Columbus Dispatch (Ohio)

Industry memos show DUPONT knew for decades that a chemical used to make Teflon is polluting workers and neighbors by Michael Hawthorne

US EPA Report April 10, 2003

Office of Pollution Prevention and Toxics

PFOA - Preliminary Risk Assessment of the Developmental Toxicity associated with Exposure to Perfluorooctanoic Acid and its Salts.

63 pages. Also available at

Federal Register April 16, 2003 US EPA Perfluorooctanoic Acid (PFOA), Fluorinated Telomers; Request for Comment, Solicitation of Interested Parties for Enforceable Consent Agreement Development, and Notice of Public Meeting. Docket Number OPPT-2003-0012
TV Investigative report Nov 14, 2003 Transcript of ABC-TV "20/20" program SAFE OR SORRY? NEW EVIDENCE REVEALS DANGERS OF TEFLON. By: Brian Ross
Article Dec 16, 2003 Environmental Health Perspectives Another Fast-Food Fear, by Scott Fields
Article Jan 24, 2004 Science News Perfluorinated sources: factories outside, consumer products inside? by Rebecca Renner.
"The levels of some volatile compounds that break down to perfluorooctane sulfonate (PFOS) inside North American homes are about 100 times higher than those of outdoor levels, according to the first indoor measurements of three perfluorinated sulfonamides, which are published in research recently posted to ES&T’s Research ASAP website... Many treatment products consist of fluorocarbons linked to a group that can polymerize and thus bind to the carpet. In the past, it has been assumed that this linkage would effectively sequester the fluorocarbons from the environment. However, a small percentage of the fluorinated treatment product lacks the polymerizing linkage. As a result, free chemicals may be left in the carpet fibers after treatment. Stock hypothesizes that these volatiles could be an important source of PFOS and PFOA in the environment. In addition, breakdown processes in homes may even release the chemically bound precursors."
US EPA March 4, 2004

Federal Register

Docket No.

Longitudinal Study of Young Children's Exposures in their Homes to Selected Pesticides, Phthalates, Brominated Flame Retardants, and Perfluorinated Chemicals (A Children's Environmental Exposure Research Study--CHEERS).

Abstract: The U.S. EPA's Office of Research and Development's National Exposure Research Laboratory proposes to conduct a two-year longitudinal field measurement study of young children's (aged 0 to 3 years) potential exposures to current-use pesticides and selected phthalates, polybrominated diphenyl ethers, and perfluorinated compounds that may be found in residential environments. The study will be conducted in Duval County, Jacksonville, Florida over a two-year period from 2004 to 2006. Sixty young children will be recruited into this study in two cohorts: (1) infants recruited into the study soon after birth, and, (2) children recruited into the study at approximately 12 months of age. ...

Part A: Supporting Statement - EPA ICR Number: 2126.01 - 61 pages
From Table 2:
• Of 16 pesticides included in this study, 4 are fluorinated:
Bifenthrin, Fipronil, lamda-Cyhalothrin, and Cyfluthrin I, II, III, IV, total
• Perfluorinated chemicals:
Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS)

From Table 3: List of chemicals to be analyzed in biological media:
• one is fluorinated: 4-fluoro-3-phenoxybenzoic acid
Perfluorooctanoic acid/Perfluorooctane sulfonate





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