How the Forever Lobbying Project collected and released 14,000 “PFAS papers”
By Stéphane Horel (Le Monde), Luc Martinon (freelance, Germany/France) and Leopold Salzenstein (Arena for Journalism in Europe), and edited by Craig Shaw (The Black Sea) and Himanshu Ojha (The Black Sea), 14 January 2025.
Over the course of a year-long investigation, the Forever Lobbying Project gathered a total of 14,331 documents on PFAS (per- and polyfluoroalkylated substances), constituting the world’s largest collection to date on “forever chemicals”.
The team decided to contribute to the development of knowledge about PFAS beyond the investigation and reporting by sharing this trove of documents with two US-based databases, the Industry Documents Library at the University of California, San Francisco (home of the famous “Tobacco Papers”) and Toxic Docs (Columbia University, New York, and City University of New York). In the UCSF database, the documents are filed under the Chemical Industry Documents Archive.
These documents are now available to everyone: the public, frontline communities around the world, researchers, regulators, governments, civil society organisations, and other journalists.
A third of the documents (4,796) were obtained through 184 Freedom of Information (FOI) requests made to public bodies at both EU and national levels across Europe. These documents shed light on an issue of high public interest and deserve to be seen by the public.
In addition, the team downloaded 3,393 attachments submitted to the European Chemicals Agency (ECHA) during a public consultation on the PFAS ‘restriction’ proposal filed under the European chemicals regulation REACH. These include impact assessments, risk management option analyses, position papers, and other lobbying materials submitted by companies and their trade associations.
Finally, 6,026 documents come either from the depths of the US Environmental Protection Agency (EPA) document repository or from litigation between the State of Minnesota and 3M.
But collecting the documents was not the most challenging part. Strict laws hindered the public’s right to be informed about these documents, and releasing the entire collection raised many issues.
“What we need now is clarity” (2025). (FOI artwork: Tarjei Leer-Salvesen for the Forever Lobbying Project, based on a DuPont document redacted by civil servants at the Swedish Chemicals Agency KEMI)
The real headache came from the fact that many of the documents contained personal data, i.e. e-mail addresses, telephone numbers, or physical addresses. In some instances, publication of personal data is prohibited in the European Union and the United States. And, in any case, the Forever Lobbying Project did not want to make this information public. One essential condition for releasing the collection was to redact the data.
Deleting all the information by hand would have taken too much time. As well as offering to host the documents, the Industry Documents Library at the University of California, San Francisco (UCSF) kindly put the Forever Lobbying Project in touch with an organisation that could help, Everlaw. The Everlaw for Good programme gave the team free access to a software package originally developed for the needs of lawyers in the United States, and used to automate this type of task. This work also required a great deal of human energy and time. It was carried out by data journalists Leopold Salzenstein and Luc Martinon, respectively, at Arena for Journalism in Europe and for the Forever Lobbying Project.
The whole team is very grateful to them, and to Rachel Taketa (UCSF), Kate Tasker (USCF), Jerry Markowitz, David Rosner and Merlin Chowkwanyun (Toxic Docs, respectively City University of New York and Columbia University, New York), and Everlaw for Good for contributing to make the 14,000 “PFAS papers” public.
The “PFAS papers” collection
° Forever Lobbying Project FOI requests
Documents: 3,583
Over the year 2024 alone, the team filed around 118 FOI requests in 16 countries (EU Member states, Norway, Switzerland, and the United Kingdom), asking for documents and records of physical, telephone, and video meetings (including notes, minutes, correspondence) about PFAS between public bodies (such as president and prime minister cabinets, government departments, competent authorities and agencies) and lobbying organisations and companies; and between public bodies and internal correspondence inside public bodies.
Belgium
Documents: 1190
Ministry of Agriculture (Federal Public Services)
Economie Bruxelles
Ministry of Economy (Federal Public Services)
Ministry of Environment (Brussels)
Federal Ministry of Environment (cabinet)
Federal Public Service Public Health, Food Chain Safety and Environment
Ministry of Environment (Walloon region) (cabinet)
Prime Minister’s cabinet
Czech Republic
Documents: 33
Ministry of environment
Denmark
Documents: 51
Ministry of Economy
Ministry of Environment
Finland
Documents: 14
Safety and Chemical Agency (Tukes)
France
Documents: 93
Ministry of the Environment
Ministry of the Economy
Presidency (Elysée)
Prime Minister’s cabinet (Matignon)
Germany
Documents: 112 (unreleased)
Ministry of the Economy (Hesse)
Ministry of the Environment (Bavaria)
Ministry of the Economy (Bavaria)
Ministry of the Environment (BMUV) (Germany)
Ministry of the Economy (BMWK) (Germany)
Italy
Documents: 46
Ministry of Industry
Regional Environmental Protection Agency (ARPA)
Netherlands
Documents: 271
National Institute for Public Health and the Environment (RIVM)
Ministry of infrastructure and water management
Norway
Documents: 88
Ministry of Climate and Environment
Norwegian Environment Agency
Sweden
Documents: 343
Prime Minister’s cabinet
Ministry of Climate and Enterprise
Swedish Chemicals Agency (KEMI)
Switzerland
Documents: 57
Federal Office of Public Health (BAG)
Federal Food Safety and Veterinary Office (BLV)
United Kingdom
Documents: 396
Department for Environment, Food and Rural Affairs (Defra)
Department for Business and Trade
Environment Agency
Natural Resources Wales
Scottish EPA (SEPA)
Treasury
EIR Jersey
Drinking Water Inspectorate
° Forever Pollution Project FOI requests
Documents: 600
In 2022, 600 documents were collected thanks to 4 FOI requests filed to EU institutions.
DG ENV | Directorate-General for Environment, EU Commission – 52 documents
DG GROW | Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission – 76 documents
European Chemicals Agency (ECHA) – 447 documents
European Food Safety Authority (EFSA) on Solvay’s ClPFPECAs and C6O4 – 25 documents
° 2023 public consultation on the PFAS “Universal restriction”
Documents: 3,393
From 22 March to 26 September 2023, the European Chemicals Agency (ECHA) organised a public consultation on the PFAS “Universal restriction” proposal under the European chemicals regulation REACH and received a historical record of 5,642 contributions, representing more than 100,000 pages. The Forever Lobbying Project collected 3,393 public attachments to contributions that were not classified as confidential by the submitters.
° Corporate Europe Observatory FOI requests on PFAS 2023-2024
Over the year 2024, Corporate Europe Observatory, a watchdog organisation that monitors lobbying activity in Brussels, filed and shared a total of 66 FOI requests to the European institutions, representing 701 documents, with the journalists of the Forever Lobbying Project.
The FOI requests covered the following EU institutions:
- Council of the European Union
- Sec Gen | Secretarial General of the EU Commission
- DG AGRI | Directorate-General for Agriculture and Rural Development, EU Commission
- DG CLIMA | Directorate General for Climate Action, EU Commission
- DG CNECT | Directorate-General for Communications Networks, Content and Technology, EU Commission
- DG COMP | Directorate-General for Competition, EU Commission
- DG DEFIS | Directorate-General for Defence Industry and Space, EU Commission
- DG ENERGY |Directorate-General for Energy, EU Commission
- DG ENV | Directorate-General for Environment, EU Commission
- DG GROW |Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission
- DG MOVE | Directorate-General for Mobility and Transport, EU Commission
- DG RTD | Directorate-General for Research and Innovation, EU Commission
- European Chemicals Agency (ECHA)
- DG SANTE | Directorate-General for Health and Food Safety, EU Commission
- DG TRADE | Directorate General for Trade, EU Commission
- DG JRC | Directorate General Joint Research Centre, EU Commission
- Permanent representations to the European Union of Belgium, Denmark, Lithuania, Netherlands, Romania, Sweden
° Earlier Corporate Europe Observatory FOI requests on the online platform Ask the EU
Documents: 512
– On the EU Chemical Strategy for Sustainability (2022)
- DG ENV | Directorate-General for Environment, EU Commission
- DG GROW |Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission
- DG SANTE | Directorate-General for Health and Food Safety, EU Commission
– On the REACH regulation (2022-2023)
- Sec Gen | Secretarial General of the EU Commission
- DG ENV | Directorate-General for Environment, EU Commission
- DG GROW |Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission
– On the Essential Use Concept and Generic approach to risk management (GRA) (2023)
- DG ENV | Directorate-General for Environment, EU Commission
- DG GROW |Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission
° Other Ask the EU FOI requests
The Forever Lobbying Project collected documents obtained over the past years by several organisations and newsrooms through FOI requests on PFAS and the EU Chemicals strategy for sustainability through the online platform Ask the EU, which are publicly available.
- Chemical Watch on the Interservice consultation on the EU Chemical strategy for sustainability (2020)
- InfluenceMap on CEFIC and the Secretariat General of the European Commission (2021)
- Investigative Reporting Project Italy (IRPI) on PFAS
- DG CLIMA | Directorate General for Climate Action, EU Commission (2017-2021)
- DG ENV | Directorate-General for Environment, EU Commission (2011-2021)
- DG GROW |Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, EU Commission (2011-2021)
- DG SANTE | Directorate-General for Health and Food Safety, EU Commission (2017-2021)
- DG JRC | Directorate General Joint Research Centre, EU Commission (2017-2021)
° US Environmental Protection Agency Docket “AR-226”
Documents: 5,302
The US Environmental Protection Agency (EPA) opened “docket AR-226” in 2003 to collect documents relating to Perfluoorooctanoic Acid (PFOA) and Fluorinated Telomers (“Request for Comment, Solicitation of Interested Parties for Enforceable Consent Agreement Development, and Notice of Public Meeting”), mostly internal documents from the PFAS manufacturers 3M and DuPont. Until now, the 5,302 documents of “docket AR-226” were available only by request from the US EPA.
The PFAS Project Lab helped the Forever Lobbying Project obtain the comprehensive collection from the US EPA, including its index, which made it possible to identify and tag each document. They are made public and easily searchable by docket number for the first time. Docket AR-226 is a joint collection of the Forever Pollution Project and Toxic Docs, an online repository of “previously classified documents on industrial poisons” based at Columbia University and the City University of New York. The Toxic Docs database includes all documents cited in Sharon Lerner’s pioneering reporting on PFAS for The Intercept: The Teflon Toxin and Bad Chemistry.
° State of Minnesota vs 3M
Documents: 724
On 20 December 2010, the State of Minnesota (US) filed a lawsuit against 3M in Hennepin County District Court (case 27-CV-10-28862) seeking payment for damages caused to natural and ecological resources by 3M’s disposal of PFAS. The Forever Pollution Project collected the documents publicly released by the Office of the Attorney General. The collection includes the original complaints and answers filed in the case.
The list of documents can be seen here (using a VPN from outside the US):
- 14 documents.
- 710 out of 777 documents were retrieved. Dead links, paywalled articles and YouTube videos were not included. One document (Plaintiff no 2758) was not uploaded because it is a 10,000+ page document of hand-written research results.
° External links
The Industry Documents Library of the University of California in San Francisco (UCSF) includes 39 key documents dating from 1961 to 2006, featured in the 2018 film “The Devil We Know“. This collection was gathered through litigation discovery by Robert Bilott, the attorney who first successfully sued DuPont over PFAS.
The documents were analysed in a 2023 paper titled “The Devil they Knew: Chemical Documents Analysis of Industry Influence on PFAS Science” by Nadia Gaber (University of California, San Francisco, US), Lisa Bero (University of Colorado Anschutz Medical Campus, US), Tracey J. Woodruff (University of California, San Francisco, US).