From: Robina Suwol
Date: 05 Apr 2003
Remote Name: 188.8.131.52
Policy memo from Environmental Working Group (EWG)
EPA Issues Powerful Indictment Of Chemical in Teflon
Government Scientists Find Blood of U.S. Population Is Contaminated At Levels That Could Cause Harm
EWG Concludes That Health Risks Are Even Higher Than Agency Believes
A draft risk assessment from the U.S. EPA has concluded that PFOA, a critical component of Teflon production, and a chemical found in scores of consumer products from clothes to stain repellents, food packaging and cosmetics, presents unacceptably high developmental and reproductive risks to humans. Based on powerful results from animal reproduction studies, and a comparison of blood levels in the affected animals with blood levels in people, EPA scientists conclude that children with the highest measured blood levels of PFOA have less than one tenth the protection, or less than one tenth the margin of safety, than the level the agency considers to be safe. In EPA parlance, the margin of exposure for these children is just 7, when it should normally be 100
(EPA pg 51).
EWGs preliminary review of the EPA risk assessment and other studies conducted by industry indicates that some children already have blood levels of PFOA at or above the levels that cause serious toxicity in laboratory studies.
Both EPAs and EWGs analyses conclude that current PFOA exposures in children are well above safe levels.
The EPA risk assessment is the result of an internal priority review of PFOA prompted by unexpected toxicological and bioaccumulation discoveries(EPA pg 5) with respect to the entire family of perfluorinated chemicals, particularly PFOS (perfluorooctane sulfonates), the active ingredient in Scotchgard, which was forced off the market by EPA in 2000. PFOS has many similar chemical and toxic properties to PFOA. Neither compound breaks down in the environment, both kill newborn rats at doses that have no effects on the mothers (dams), and both cause a variety of cancers and other toxic effects.
According to EPA scientists, PFOA causes ?significant increases in treatment related deaths?(EPA pg 35) in newborn animals at doses that did not affect the mothers, and a range of serious changes in the weight of various organs, including the brain (decrease), prostate (decrease), liver (increase), thymus (decrease), and kidneys (increase in lower dose groups, decrease in high dose group) (EPA pg 36). The deaths of a significant number of rat pups within 2 to 4 days after birth in experiments in which the mother was exposed is highly unusual, and raises grave concerns about the toxicity of PFOA to people.
There is also evidence of birth defects in humans from PFOA-exposed workers. Although the draft risk assessment says that ?reproductive outcomes have not been examined? in people, in 1981 DuPont monitored the pregnancies of seven women employed at its Teflon plant in Parkersburg, West Virginia. According to an internal DuPont document made public through litigation, two of these seven women gave birth to babies with birth defects - one an "unconfirmed" eye and tear duct defect, and one a
nostril and eye defect. That same year, DuPont reassigned 50 women at the plant to reduce PFOA exposure.
PFOA also causes tumors in at least 4 different organs in animal tests, and has been associated with statistically significant increases in prostate cancer death and incidence in PFOA plant workers in two separate studies (EPA pg 17-23). Animal data strongly support the evidence that PFOA causes prostate cancer in humans, but the EPA has yet to evaluate those risks.
Concerns about the hazards of PFOA are heightened by the widespread exposure and near-universal contamination of the human population with the chemical at levels similar to those that cause organ weight changes and other indicators of toxicity in laboratory animals. PFOA is present in the blood of more than 90 percent of the population of the United States, and levels in some people in the general population are as high as levels found in some PFOA factory workers. According to the EPA document, DuPont and other manufacturers do not know the primary sources of these exposures, or why some exposures in the general population are so high. The EPA concludes: It is not known what the environmental concentrations of APFO (PFOA) are or the pathways of human exposure to the general population.
Two factors, however, help to explain the situation. First, PFOA is infinitely persistent in the environment. It never breaks down, as opposed to other long- lived pollutants like PCBs and DDT, which have half lives measured in decades. In addition, other major classes of chemicals, in particular a group known as the telomer alchohols, break down into PFOA. This means that if PFOA itself were banned today, the levels in the global environment, wildlife and people could substantially increase, probably for decades. The total amount of PFOA generated by DuPont and other companies will remain in the environment, and will circulate through the biosphere and through the blood of the human race, indefinitely.
This brewing crisis represents a stunning breakdown of the regulatory system for toxic chemicals. PFOA and related chemicals have been widely used in consumer products for a half century, but it was not until the past several years that scientists at the EPA had any data that indicated these levels of risk. Why? Because industry is not required to conduct health and safety tests on industrial chemicals like PFOA and PFOS as a condition of their sale and use, no matter how widely those chemicals are utilized in industrial or consumer products. This absence of real regulatory authority over the chemical industry means that EPAs authority is largely limited to requests for data from chemical manufacturers after contamination presents a crisis, as is the case with