RE: Sept. 14, 2022, Fire Engineering Webcast – “Firefighting PPE Evaluations: From Need to Selection”
Dear Chief Bobby Halton:
Thank you for the opportunity to respond to the above-mentioned webcast. Although we, at the International Association of Fire Fighters (IAFF), found some comments made immediately troubling, we were unable to address them sooner, since we have been in Colorado Springs from Sept. 14-18 to prepare for, and subsequently conduct, the 2022 Fallen Fire Fighter Memorial Ceremony. Sadly, 469 names for the years 2019 and 2020 were added to our Memorial Wall and the trend of having three out of every four line of duty deaths resulting from occupational cancer has unfortunately continued.
- IAFF, Metro Chiefs Advise Members of Adverse Health Risks Linked to Firefighter Turnout Gear
- Statement from IAFF General President Edward A. Kelly on PFAS Lawsuits Filed
- Humpday Hangout: Research Update on ‘Forever Chemicals’
- Researcher Responds to Claims About PFAS, Firefighter PPE
Now that the honoring of our brothers and sisters who have made the ultimate sacrifice has been dutifully carried out, we shall continue our efforts to preserve and improve upon the health, safety, and wellbeing of the 331,000-plus members that have entrusted us with that responsibility.
To that end, the IAFF categorically opposes the position taken by your webcast guest, San Antonio Fire Department retired Lt. Jim Reidy, in reference that PFAS/PFOA (hereinafter referred to as PFAS) in turnout gear are not dangerous. The comments, inferences, and analyses made regarding the safety of PFAS in this webeast are not rooted in contemporary, peer-reviewed science. Nearly every day more evidence arises proving that the entire family of PFAS (12,000-plus, according to the EPA) is harmful to human health and the environment. Consequently, the statements made and the references given in the webcast with respect to PFAS within turnout gear simply do not reflect the wealth of credible, peer-reviewed, scientific evidence to the contrary which the medical and research communities, as well as the IAFF, stand behind.
I will now proceed to address some of the-specific comments made by retired Lt. Reidy:
Minute 36, slide titled: “Hazard Assessment of Fluorochemicals Present on Firefighter Gear [by] Cody Patrick Zane (2020)”
The slide starts with, “Ultimately, it was determined that firefighters have minimal risk of exposure to PFCs from their gear.”
Rebuttal:
In 2020, Cody Patrick Zane was a North Carolina State University graduate student. The quote above was _from Mr. Zane’s dissertation which happened to not be supported by his overseeing professor, Dr. R. Bryan Ormond, Ph.D. In fact, Professor Ormond has stated the following, in an email correspondence dated, March 10, 2021, between him and Cpt. Sean Mitchell, IAFF Local 2509: ,
- From the start his [Zane’s] work was limited in scope to only looking at what we could potentially detect on unused gear to focus on anything that was from the manufacturing of the suits. It was also limited to the gear that we had saved up in the lab from previous projects.
- We also ran into issues trying to get the other PFAS chemicals measured because of instrument availability, and then COVID hit and we basically lost most of his samples.
- So the work was more on the pilot scale to see how some of the methods worked and how to go about the measurements. The student had to finish up during the summer, so we weren’t able to continue with his work.
- You are also right that this work doesn’t prove anything on its own and it isn’t yet peer-reviewed. The only reason it is available to view is because all of the graduate students’final thesis[sic]/dissertations are made available through our library.
Minute 37, slide titled: “Research and Independent Testing Shows Firefighter’s Turnout Gear Remains Safe Despite Claims By Paul Chrostowski, Ph.D., QEP”
Quote from the slide: “… too often uninformed critics and environmental activists have inaccurately used them to raise alarms about the protectiye turnout gear used by firefighters throughout the United States.”
Rebuttal:
The slide also states: “He [Dr. Chrostowski] is a consultant to Lion [a turnout gear manufacturer].” It shall be left up to the readers to decide if the write-up of an industry paid consultant is enough to quell any concerns they may have with respect to PFAS. It is also very important to note that this is an article and not a scientific study. To my knowledge, Dr. Chrostowski has neither authored a single publication about PFAS, nor has he been cited in any PFAS-related work. Notwithstanding, his article refutes internationally known academics with dozens of PFAS-specific peer-reviewed scientific research publications that have been cited just as many times by other experts. His article in FirefighterNation was deemed so inaccurate, Dr. Graham Peaslee, Ph.D., renowned Notre Dame University’s experimental nuclear physicist and PFAS researcher—who is not paid by the industry—wrote a lengthy rebuttal. Readers are encouraged to view Dr.
Peaslee’s “Researcher Responds to Claims About PFAS, Firefighter PPE” posted on Oct. 5, 2020, to gain further insight as to the validity of the comments made by Dr. Chrostowski.
Minute 37, slide titled: “Disposition of Fluorine on New Firefighter Turnout Gear [by] Derek J. Muensterman, Ivan A. Titaley, Graham F. Peaslee, [et al] (emphasis added)” From the Abstract shown in the slide:
- The outer layer, moisture barrier, and thermal layers of the turnout gear all yielded measured concentrations of volatile PFAs that exceeded nonvolatile PFAS concentrations.
- New turnout gear should be examined as a potential source of firefighter occupational exposure to nonvolatile and volatile PFASs in future assessments.
Rebuttal:
Unneeded. As you can see in the quotes above, this slide actually counters the point that the webcast segment was trying to make.
Minute 37, slide titled: “IAFF Turnout Gear, and PFOA 2017 (3 pages of 7)”
Retired Lt. Reidy stated that”… and the IAFF also had a position paper in 2017, …”.
Rebuttal:
3 selected pages from a 7-page, limited IAFF statement made 5 years ago based on the known facts and science in 2017 are irrelevant in 2022, given the myriad of PFAS-related scientific knowledge gained since then about the toxicity, carcinogenicity, immunotoxicity, as well as endocrine and metabolic derangements caused by PFAS, all of which are common knowledge today.
Moreover, these are other currently proven, peer reviewed, and accepted PFAS facts:
- PFAS is a toxicant, carcinogen, immunotoxin, and hormonal disruptor
- PFAS off-gasses and is inhaled
- PFAS volatilizes and is ingested
- PFAS is absorbed through the skin
- PFAS is in present in all 3 layers of turnout gear
- PFAS is shed from turnout gear
- Occupationally acquired cancer is the number 1 killer of firefighters. 348 brothers and sisters that went on the wall this past Saturday were killed by cancer.
- The International Agency for Research on Cancer reclassified the occupation of fire fighter as Group 1, Known Human Carcinogen. PFAS is one such carcinogen.
- PFAS is so toxic that on June 15, 2022, the EPA decreased the acceptable water health advisory levels for PFOA to 0.004 parts per trillion (ppt) and for PFOS to 0.02 ppt. To put in context, this means essentially zero.
In closing, retired Lt. Reidy is correct in that there is no research that proves that PFAS in the outer shell or the moisture barrier of turnout gear has been proven to directly cause cancer. Anybody that knows anything about research would know the impossibility of designing such a study, given the unethical considerations of exposing humans to known carcinogens. Similarly, there is no study that proves the benefit of jumping out of a flying aircraft with a parachute versus without one. In the study titled: Parachute use to prevent death and major trauma related to gravitational challenge: systematic review of randomized controlled trials,the authors could not find any volunteers for the parachute-less cohort. The lack of such volunteers perfectly exemplifies what is known in science as the precautionary principle, which states: where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason to continue the potentially harmful or lethal practice of—in these instances—jumping out of an aircraft without a parachute or to continue to unnecessarily expose fire fighters to PFAS. Anyone that does not believe in the tenet of the precautionary principle or neglects to infer the obvious when it comes to PFAS—in turnout gear or from anywhere else—is failing to serve the population they are trying to protect. As a medical doctor who is sworn to do no harm and as the first-ever chief medical officer of the IAFF, I steadfastly and wholeheartedly stand by the statements I have presented.
-·Again, thank you for the opportunity to advocate for the health, safety, and wellbeing of our 331,000-plus brother and sister fire fighters.
Danny Whu, MD, MPH
Board Certified in Preventive Medicine and Public Health
Chief Medical Officer, International Association of Fire Fighters
Sr. Physician Medical Team Manager, FEMA Urban Search & Rescue, FL Task Force-1 Division Chief of Fire, Rescue & EMS Operations (ret.), Miami-Dade Fire Rescue Dept. Assistant Director (ret.), Miami-Dade County Office of Emergency Management Deputy Incident Commander (ret.), Miami-Dade County Emergency Operations Center Proud Member of IAFF Local 1403 for over 32 years
