Comment submitted by Diane Cotter

PFOA ~ aka The Firefighter Serial Killer Aside from IARC's designation as a known carcinogen, and in addition to the occupation of firefighting being 'carcinogenic', I submit my comment as to the role of PFOA and the largest intentional occupational poisoning known to mankind. Firstly, the EPA has no designation over the production of turnout gear, the most fluorinated textile known to man. Only manufacturers knew of the chemical polluting the rivers and waterways of the nation during the making of the essential use textiles. Simultaneously, only a pinky swear mandated transparency via an EPA/industry marriage. PFOA was used in staggering amounts as a DWR coating for essential use PPE of firefighters. Names like 'Super Shelltite', would give no hint of the carcinogen in the coating. In 2014 Lt Paul Cotter was diagnosed with cancer, ending his 28 year firefighting career and compelling me, his wife, by providence, to orchestrate a novel study with Dr. Graham Peaslee and members of the firefighting community. What we discovered was shocking. PFOA and other PFAS were present in all three layers of gear. PFOA levels were of great concern as industry swore 'if' PFOA were there it would be 'trace amounts'. https://cen.acs.org/environment/persistent-pollutants/Protective-gear-expose-firefighters-PFAS/98/i26 In 2018 I gave my first public speech on this saga at the first PFAS community engagement in Exeter, NH where Dr. Peter Grevatt and Administrator Dunn heard for the first time of the staggering amounts of PFOA in turnout gear. Dr. Grevatt exclaimed to an ally, "we missed the gear, we never knew".. (paraphrasing). The parties that did know about PFOA, and precursors that form PFOA, would be industry itself, who were also immersed in a stunning conglomerate cartel of firefighting organizations and safety institutions. Prior to the release of the June 2020 Peaslee study, industry began its five year war to obfuscate the science on PFOA in turnout gear by enforcing its long established hold within the fire fighters union and safety standards orgs and events. When firefighters questioned industry or union leadership they were advised there was no concern. Letters were sent to municipalities across the nation from gear makers who explained they had questioned Dupont and were advised there was no PFOA in the gear. The 2020 study proved otherwise. Upon release of the Peaslee study, industry doubled down its hold on ensnared allies; under then General President Harold Schaitberger the International Association of Firefighters claimed the role as the conscripting authority for the billion dollar PPE industry, now faced with a horrific scandal. https://www.fireengineering.com/wp-content/uploads/2020/09/pfoa-lion.pdf In 2020 the IAFF's science panel ascribe that the new 'short chain' PFAS used to replace PFOA it once denied was even used, was, and I quote, "too big to pass through the skin - it's like tennis balls and volley balls". Taken directly from the words of Lion Gear's non-peer-reviewed science study by Exponent; https://www.youtube.com/watch?v=-MaKd6XC_60 Simultaneously, under ECHA, these same gear manufacturers were openly discussing the use of PFOA C6 chemistry in turnout gear in Europe. In the early 2000's firefighter cancer began to surpass heart disease as the number one killer of firefighters. DWR coatings with PFOA and other PFAS (as one never gets just PFOA it is always joined by family) began in early 1980's. https://www.ewg.org/research/timeline-forever-chemicals-and-firefighters The discovery of PFOA in turnout gear would then lead to one major manufactures to switch to C6 chemistry, proclaiming the new C6 chemistry is, and I quote, "ten times less toxic". Massachusetts and other states have enacted mountainous bipartisan PFAS free gear legislation, as this is what firefighters fought for and chose, with industry now delivering alternatives. Municipalities are now purchasing PFAS free gear for firefighters who demanded it and won. But without EPA holding industry to the NFPA standards firefighters fought for and paid for with their lives, industry can, and will, use the 'essential use' dogma of PFOA and PFOS - a fallacy proven by the American firefighter whose entire firefighting ensemble is 'essential use'. Respectfully, It did take time to right the course of the toxic turnout gear scandal. From the release of The Real Cancer In Your Gear of March 2017, to the massive lawsuits now in the works for firefighter cancer personal injury, along with the RICO lawsuit in Butte-Silver Bow MT to outfit the nation with PFAS free turnout gear, it took eight years to overcome captured institutions and industry who put profit over America's bravest. https://www.courthousenews.com/wp-content/uploads/2026/07/montana-pfas-amended-complaint.pdf Reference: https://childrenshealthdefense.org/defender/rfk-jr-podcast-diane-cotter-firefighter-cancer-pfas-forever-chemicals/