3M's commitment to PFAS stewardship: regulations and litigation

Regulation & Litigation

Regulation

  • Science-based policymaking can help improve lives

    3M supports science-based regulation that is based on the best available science and established processes, including for PFAS. 

    This can help provide needed certainty for manufacturers and companies who rely on PFAS in critical industries, like medical devices and aerospace, while helping people better understand how and why PFAS are regulated. 


  • PFAS Policy Priorities

    Effective public policy that supports strong and healthy communities, access to critical products and economic competitiveness must be informed by a broad range of factors. These include:

Foundation in rigorous science

Science is core to 3M’s mission of improving every life. It also informs our public policy and regulatory engagement on PFAS. While the science behind PFAS can be complex and continues to evolve, science must be at the forefront of providing answers and solutions. Things to consider include:

    • Policymakers must take into account the weight of scientific evidence when making decisions. Policymakers should base decisions on the body of rigorous, reliable science on PFAS rather than individual studies.
    • Policymakers should also follow established scientific methodologies and ensure validated testing methods are available to help ensure companies and others in the regulated community can use data to show compliance with regulations.
    • 3M works continuously improve our operations and reduce our environmental footprint. We often use our scientific expertise in PFAS to make these very actions possible.
    • To learn more about Health Science, click here
    • PFAS are used by a broad range of customers and industries worldwide to make innovative products, including personal protective equipment, life-saving medical devices, and low-emission vehicles possible. Some PFAS are critical to the manufacture of high-end computer chips and electrical component cooling systems that provide significant reductions of energy consumption yielding significant reductions in Greenhouse Gas emissions. Regulatory action must account for these important applications.
    • Policymakers should also take into account how, if at all, people and the environment could be exposed to PFAS through the use of these materials.
    • Many PFAS have differing properties related to factors like mobility or bioaccumulation, which are important considerations for sound public policy.
    • Because PFAS refers to a broad category of compounds that encompasses thousands of materials with distinct, and widely varying properties, profiles, and uses, treating them as a single group or class is not scientifically sound or appropriate.
    • 3M supports a rigorous, science-based dialogue and review among regulators, academic researchers, manufacturers, and others to determine how these materials could potentially be grouped in a scientifically sound way.

Results-oriented Approaches for Communities

Our scientific knowledge of PFAS chemistries has and continues to evolve. 3M is committed to working collaboratively with communities to answer questions about current and past PFAS use and determine a path forward.

    • 3M has committed to appropriate PFAS remediation at locations where we manufactured or disposed of these materials.
    • Policies that address PFAS remediation should prioritize a science-based approach informed by a thorough understanding of environmental data, such as the assessed risk of the PFAS in the environment, potential exposure pathways, and the costs and benefits. These policies should also provide time to gather and analyze this data.
    • We continuously invest in research and development to find new and better ways to serve our customers, including those seeking PFAS-free solutions. Meeting those needs where possible can benefit our customers and position our enterprise for the future. In many applications, no suitable technical and/or economically feasible alternative is available to meet our customers’ needs.
    • 3M has voluntarily committed to install state-of-the-art control technologies for PFAS discharges at our manufacturing facilities globally. As part of our global environmental goals, 3M has committed to investing $1B for initiatives including waste reduction and pollution control programs, reductions in water usage, and the treatment of wastewater that returns higher quality water to the environment after its use in manufacturing operations.
    • As we do so, we and other companies need cooperation from authorities to establish reasonable transition periods and legal frameworks grounded in science.

Collaborative development using established processes

PFAS are used by a wide variety of critical global industries to make products people rely on every day. It is important to consider many viewpoints and work together to craft policies that reflect these broad uses in modern products. Factors to consider include:

    • 3M welcomes opportunities to work with authorities at all levels of government globally, including legislators and regulatory officials, to identify a collaborative path forward.
    • We believe that including a broad range of perspectives throughout the policymaking process – including from industry, academics, nongovernmental organizations, and others – can promote more effective solutions for communities.
    • Global stakeholders share their perspective on proposed environmental and manufacturing policies to help inform sound decision making.
    • Regulators should engage thoughtfully with those comments to help balance the needs and goals of public entities, communities and industry and demonstrate clear benefits for the cost of new or expanded regulation.

Engagement with Regulatory Processes

3M regularly provides information about PFAS regulatory topics and submits comments as we seek to engage with local, national and international bodies. 

To learn more about specific comment submissions, please contact us.

Learn About PFAS Drinking Water Advisory Levels

  • In the United States, there are currently no federal drinking water regulatory limits for PFAS compounds. The U.S. EPA is in the process of setting federal drinking water regulatory limits for PFOA and PFOS. What is currently in place is a federal, non-enforceable drinking water lifetime advisory level of 70 parts per trillion (ppt) for PFOA and PFOS (combined), which was established under the Obama Administration in 2016. According to EPA, this LHA provides a significant margin of protection for people over an entire lifetime of drinking water from a single source. 

    In the absence of federal regulatory limits, some states have set or have begun the process of setting their own limits based upon varying factors. Though approaches and assumptions vary, they are typically based on animal studies, which use theoretical modeling to extrapolate a proposed limit.

    3M supports establishing science-based drinking water limits for PFAS like PFOS and PFOA under the Safe Drinking Water Act, which could help prevent the confusion that a state-by-state patchwork of limits could create. These limits should be based on rigorous science and follow established rulemaking processes.

    Existing national drinking water advisory levels vary globally. For instance, Canada advises levels at 600 ppt and 200 ppt for PFOS and PFOA, respectively. Australia’s levels are 70 ppt and 560 ppt, and the United Kingdom recommends 300 ppt and 1,000 ppt for PFOS and PFOA. The levels are meant to consider a lifetime of drinking water consumption, and they are designed to provide a large margin of protection. 

    3M is committed to working with the U.S. EPA, state regulatory agencies, community groups and elected officials to help collaboratively share our knowledge and address this issue.
     

PFOA and PFOS advisory ranges (ppt) as of may 2019 for some countries and U.S. states

Common PFAS questions answered

  • 3M's commitment to PFAS stewardship
    What are PFAS?

    PFAS stands for a broad group of perfluoroalkyl and polyfluoroalkyl substances. The group contains several categories and classes of durable chemicals and materials with properties that included oil, water, temperature, chemical and fire resistance, as well as electrical insulating properties.

  • history of PFAS compounds (PFOS and PFOA) at 3M
    Where did PFAS come from?

    Processes to commercially produce PFAS were first developed in the 1940s. In the 1950s, 3M began manufacturing PFOA and PFOS, two types of PFAS, for product applications because of their ability to repel water, protect surfaces, resist heat and many other useful properties.

  • 3M's commitment to PFAS stewardship: health science
    What does the science say?

    While some research has indicated possible associations with certain biomarkers or health outcomes in people for PFOA and PFOS, results across studies examining these endpoints have found either inconsistent or conflicting observations and do not show causation. 3M and other leading experts around the world continue to research PFAS to look for potential health issues.


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