Submission to the Inquiry into the Management of Per and Polyfluoroalkyl Substances (PFAS) Contamination in and around Defence Bases 6 July 2018 Committee Secretary Joint Standing Committee on Foreign Affairs, Defence and Trade PO Box 6021 Parliament House Canberra ACT 2600 Via email: [email protected] Dear Committee Secretary We write to you with a submission to the Inquiry into the Management of Per- and Polyfluoroalkyl Substances (PFAS) Contamination In and Around Defence Bases on behalf of the Coalition Against PFAS. The Coalition Against PFAS (CAP) represents communities around Australia contaminated by PFAS chemicals. While European nations warn about the danger of even low-level PFAS exposure, and the United States has announced cleaning up PFAS contamination is a “national priority”, Australia continues to lag behind the world in confronting what is an escalating environmental and public health crisis. CAP is an initiative being led by representatives of Oakey, Williamtown and Katherine, three communities who have experienced PFAS contamination first hand, and who are now coming together to advance three key objectives: 1. To advocate for and connect impacted communities. More and more communities around Australia are discovering they have unwittingly been caught up in PFAS contamination emanating from Government airfields and other sites. 2. To act as a national voice on PFAS contamination. Given the dispersed and often regional locations of PFAS contamination the Commonwealth Government has too often been willing to downplay the issue as a few isolated cases. 3. To share information, highlighting locally what’s happening globally. Australia is well behind international developments and research on this important issue. This submission is based on facts, in particular the facts of what our communities have experienced and learned about PFAS contamination over the past three to four years. We believe that the Commonwealth Government, as both the representative body and the polluter, has failed to act decisively on this issue and failed to meet its responsibilities to its constituents. Those constituents are not just our damaged communities, but also the Australian public at large and Australia’s precious environmental resources. In our view, the facts are plain: 1. this contamination in our communities could have been avoided; 2. the contamination has not been remediated, and continues to spread every day; 3. the Government has refused to acknowledge its liability; 4. the Government has issued inconsistent, confusing and misleading advice; 5. the Government has ignored the Senate’s recommendation and the pleas of those people whose lives have been severely damaged to provide compensation or an exit route; and 6. all that has been achieved, as some of us approach our fifth Christmas living in contamination zones, is millions of dollars spent on consultants to write reports whilst the affected people are treated as mere guinea pigs taking part in an appalling science experiment. The Coalition Against PFAS 1 Submission to the Inquiry into the Management of Per and Polyfluoroalkyl Substances (PFAS) Contamination in and around Defence Bases These failures have resulted in a critical loss of confidence in not only the Department of Defence, but also other Federal and State agencies. Collectively, there has been a near total failure to take responsibility, which in turn has allowed this issue to grow into one of the largest environmental and public health issues ever to occur in Australia, putting lives and livelihoods in our communities at risk. We attach the Coalition Against PFAS’s submission to the Inquiry into the Management of Per- and Polyfluoroalkyl Substances (PFAS) Contamination In and Around Defence Bases, which documents our experience, and calls for urgent action, beginning with a full and public scrutiny of the issues by your Committee. Sincere regards Lindsay Clout Fullerton Cove, NSW President, Coalition Against PFAS Dianne Priddle Oakey, QLD Dr P J Spafford Katherine, NT The Coalition Against PFAS 2 Submission to the Inquiry into the Management of Per and Polyfluoroalkyl Substances (PFAS) Contamination in and around Defence Bases Submission to the Inquiry into the Management of Per- and Polyfluoroalkyl Substances (PFAS) Contamination In and Around Defence Bases The Coalition Against PFAS July 2018 Dated: 6 July 2018 The Coalition Against PFAS 3 Submission to the Inquiry into the Management of Per and Polyfluoroalkyl Substances (PFAS) Contamination in and around Defence Bases BACKGROUND PFAS contamination is not unique to Australia, and the present situation in Australia must, fundamentally, be understood in its historical and global context. Whilst CAP’s representatives are not scientific experts, our communities have been living with PFAS for three to four years, we conduct our own research, we take advice from scientific experts, and we talk to communities overseas who have experienced the same problems. For the benefit of the Committee, we begin our submission with some of the key background facts. PFAS Manufacture and Usage Between the late 1940s and early 2000s, various products containing per- and polyfluoroalkyl substances (PFAS) were manufactured and sold, including Aqueous Film Forming Foams (AFFF) used to fight fires. AFFF such as “3M Lightwater” (Lightwater) contains in particular perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), and to a lesser degree, perfluorooctanoic acid (PFOA). These abbreviations and terms will be used throughout this submission. PFAS are unnatural substances which are persistent once released into the environment, with a half life of around 70 years. There is scientific acceptance that PFAS are highly damaging to the environment, and are toxic to animals and marine life. In 2000, the OECD concluded that PFOS was “persistent, bioaccumulative and toxic to mammalian species”.1 PFAS are classified by the UN’s Stockholm Convention as persistent organic pollutants which are to be phased out globally. Whilst much of the debate around PFAS has focussed on the human health risk, it is important for this Committee and the Australian public to understand from the outset that the PFAS contamination plumes caused by AFFF usage across Australia are in each case disasters for the protection of this country’s environment and natural resources, including our most precious resource, water. Human health concerns about PFAS first began surfacing during the 1960s and 1970s in the USA. The chemicals are not supposed to be ingested in the human body, but once ingested they persist for between three to seven years and cause physical damage as they bind to organs such as the liver, they reduce the body’s immune system and thereby inhibit its ability to fight illness. In 1961, a DuPont internal memo reportedly concluded that PFOA (being used in its Teflon products) should be “handled with extreme care”, since a new study had found enlarged livers in rats and rabbits exposed to PFOA, which suggested the chemical was toxic.2 In 1976 PFAS were detected across blood banks in the USA.3 In 1978 immunotoxicity was discovered in a 3M laboratory study in which monkeys exposed to high levels of PFOA died.4 In 1993 a study of 3000 male 3M workers exposed to PFOA at the company’s factories identified a 3.3 fold increase in prostate cancer.5 However, following 1 https://www.oecd.org/env/ehs/risk-assessment/2382880.pdf 2 Mariah Blake, “Welcome to Beautiful Parkersburg, West Virginia”, Huffington Post 27 August 2015, https://highline.huffingtonpost.com/articles/en/welcome-to-beautiful-parkersburg/ 3 Taves DR & Ors, “Organic Fluorocompounds in human plasma – prevalence and characterization” – ACS Symposium Series, 1976 (28) 4 Goldenthal et al, “Final Report, Ninety Day Subacute Rhesus Monkey Toxicity Study”, International Research and Development Corporation Study No. 137-090. Monkeys were given 0, 3, 10, 30 and 100 mg/kg per day of PFOA. All monkeys at the 100 dosage and 3 out of 4 at the 30 dosage died. Adverse effects were noted in the adrenals, bone marrows, spleen and lymph nodes. The results of this study were not disclosed by 3M to the US EPA until 2000. 5 Gilliland F and Mandel J, “Mortality among employees of a perfluorooctanoic acid production plant”, J Occup Med 1993, 35(9) The Coalition Against PFAS 4 Submission to the Inquiry into the Management of Per and Polyfluoroalkyl Substances (PFAS) Contamination in and around Defence Bases lobbying by the American Chemical Council, the chemicals were exempted from the 1976 Toxic Substances Control Act. As a consequence, the manufacturers of these chemicals have never been required to prove that they are safe; instead, the burden of proving harm falls onto affected communities. In the Ohio River Valley in the USA, tens of thousands of citizens were unknowingly exposed to large quantities of PFOA (called “C-8” in the USA) released from DuPont’s Washington Works into the river and landfill sites. Those sites included Dry Run Creek, a landfill used by DuPont on the property of a farmer, Wilbur Tennant. Mr Tennant’s cattle experienced severe abnormalities in the herd (stringy tails, malformed hooves, giant lesions, green discolorations in their guts) and 153 cattle died. In 2000, a court order revealed the source of the contamination was PFOA, known as C8 in the USA. The Tennants’ case led to a settlement whereby DuPont funded a seven year, US$33m epidemiological study into the health of 69,000 residents by an independent panel of scientists. In 2011, the independent C8 Science panel concluded that PFOA was linked to at least six human diseases, and the US EPA subsequently set a combined drinking water advisory of 0.07 micrograms per liter (µg/L) on the basis that: “These studies indicate that exposure to PFOA and PFOS over certain levels may result in adverse health effects, including developmental effects to fetuses during pregnancy or to breastfed infants (e.g. low birth weight, accelerated puberty, skeletal variations), cancer (e.g.