TL: GREENPEACE NEWSLETTER (GP) CHLORINE-FREE Vol.2, No.1 Fall 1993 SO: GREENPEACE INTERNATIONAL (GP) DT: November, 1993 Keywords: environment greenpeace chlorine toxics us canada / Editor: Jay Palter Associate Editors: Yvette Ali, Joan D'Argo, Gail Martin, Bonnie Rice, Joe Thornton Contributing Writers: Niaz Dorry, Rick Hind, Mark Floegel For more information about Greenpeace's Chlorine-Free Campaign contact: Greenpeace Toronto Greenpeace Chicago 185 Spadina Ave., 6th Fl 1017 W. Jackson Toronto, ON M5T 2C6 Chicago, IL 60607 (416)345-8408 (312)666-3305 Greenpeace USA Greenpeace New Orleans 1436 U St. N.W. 802 S. Carrollton Ave. Washington, D.C. 20009 New Orleans, LA 70118 (202)462-1177 (504)861-0867 CONTENTS * Presumed Guilty: Phasing Out Organochlorines as a Class, by Joe Thornton * A License to Kill: Grassroots Activism Confronts Proctor and Gamble in Florida, by Gail Martin * Industry Study Backfires: Chlorine Phase-out is Feasible and Affordable, by Joe Thornton and Jay Palter * Breast Cancer: A Preventable Epidemic, by Joan D'Argo and Joe Thornton * Chlorine-Free News - Dioxin linked to Endometriosis in Rhesus Monkeys - Communities Resist WTI Incinerator - Architects Designing PVC-Free Future - As Chlorine Use Declines, Industry Expands PVC Production * Chlorine-Free Publications and Videos Presumed Guilty: Phasing Out Organochlorines as a Class by Joe Thornton -------------------------------------- A growing weight of evidence indicates that the global build-up of organochlorines poses a serious threat to the health of people, wildlife, and the larger ecosystem. On this basis, a diverse group of scientists, environmentalists, communities, and international bodies have called for a phase-out of the chlorine- based industrial processes that cause this pollution. The movement to phase-out chlorine parallels the rise of a broader critique of the way all persistent toxic substances are regulated. This critique views the current reactive approach -- the evaluation and control of individual chemicals using risk assessments, "acceptable" discharge limits, and pollution control and disposal technologies -- as fundamentally inadequate to deal with the thousands of toxic chemicals produced, used, and discharged into workplaces, communities, and the environment. In place of the reactive approach, a new framework has been advocated, based on: * The Precautionary Principle. Since we have very limited capacity to predict precisely the impact synthetic chemicals will have on health and the ecosystem, we should err on the side of caution. Practices that may cause harm should be avoided. * Zero discharge. The ecosystem's capacity to safely assimilate persistent toxic substances is zero, because these chemicals build up over time, eventually reaching levels that cause health and environmental harm. * Clean Production. End-of-pipe pollution control and disposal techniques primarily shift toxic chemicals from one medium, place, or form to another. Pollution is prevented only when production processes are reformulated to eliminate the use of toxic chemicals. These principles establish that industrial processes that produce persistent toxic substances must be phased-out, not simply "managed" or "regulated." But the principles do not clearly indicate how to apply the new framework to a universe of hundreds of thousands of toxic chemicals. Organochlorines provide a test-case for the application of the preventive framework. Addressing the threat posed by these chemicals demonstrates that the new approach can and must be applied, not to individual compounds, but to chemical classes and the industrial processes that produce them. INDUSTRY'S RESPONSE: ONE CHEMICAL AT A TIME When the call to phase-out chlorine first emerged in North America, the chemical industry reacted with press releases and statements that phasing out chlorine is an emotional, destructive idea, not based on "sound science," that would "shred the fabric of society." This year, the industry began a $5 million public relations campaign with the release of a report entitled "Scientific Principles for Evaluating the Potential for Adverse Effects from Chlorinated Organic Chemicals in the Environment." The new report, written for the Chlorine Institute by the Canadian consulting firm CanTox, argues that concerns about organochlorines must be addressed within the current regulatory framework. According to CanTox, since organochlorines vary in their chemical and biological behavior, they must be addressed only on a chemical-by-chemical basis. Risk assessments must be performed for each chemical; these assessments must then determine the appropriate pollution control and disposal methods to "ensure that environmental release rates of specific chemicals are maintained below those that would result in adverse effects." Evidence of large scale damage to human health and the environment should be considered valid only when scientists can prove "the specificity of the associations between specific chlorinated organic chemicals and reported adverse effects." Though the industry calls it "science-based," this reactive approach is based in outmoded science and a discredited policy framework. Five irrefutable facts about the chlorine industry and its products make the old, chemical-by-chemical approach unworkable, unscientific and unethical for dealing with this priority class of chemicals. 1. BUREAUCRACY: TOO MANY CHEMICALS CREATES REGULATORY GRIDLOCK The most basic reason that organochlorines cannot be evaluated and regulated one at a time is that there are simply too many of them. Of the estimated 80,000 synthetic chemicals in commerce, only 1 to 2 percent have been subject to basic hazard assessments. None have been subject to complete toxicity assessments that consider long-term reproductive, developmental, and immune system damage. Meanwhile, industry introduces thousands of new chemicals annually -- much faster than existing ones can be tested. And regulations lag even further behind the assessments. The same problem applies to organochlorines, an estimated 11,000 of which are in commerce. Basic hazard evaluations for just these "officially produced" organochlorines would take centuries. Thousands more organochlorines are formed as by- products in chlorine-based processes; the majority of these are unidentified and could not be assessed or regulated on a chemical-specific basis even if time and resources were adequate. 2. CHEMISTRY: ORGANOCHLORINES ARE PRODUCED IN MIXTURES. Organochlorines cannot be regulated individually because they are never produced individually. Chlorine reacts quickly and indiscriminately with any carbon-based material. Processes based on chlorine result in the formation of complex organochlorine "soups" that cannot be precisely predicted or controlled. Hundreds or thousands of organochlorines are present in the effluents from bleached pulp mills, in the emissions of incinerators burning chlorine- containing wastes, and in the discharges from waste-water treatment plants using chlorine as a disinfectant. Even processes intended to produce single organochlorines actually produce complex mixtures containing hundreds or thousands of compounds. The manufacture of a simple organochlorine like vinyl chloride involves the production of large quantities of wastes that contain a broad spectrum of chlorinated by-products. These mixtures become even more complex when released to the environment. Some organochlorines can be partially metabolised or degraded in the environment, but the by-products are usually new organochlorines that are frequently more toxic or persistent. Regulations that consider only individual products cannot address the complex soups of organochlorines that are formed throughout the lifecycle of chlorine. For instance, although intentional manufacture of PCBs and hexachlorobenzene has been curtailed, these compounds continue to be accidentally manufactured and released as by-products of chemical manufacturing, paper bleaching, incineration, and other processes. Product-specific regulations do not address organochlorines that are never made intentionally, like the dioxins and furans. These compounds are formed throughout the entire spectrum of chlorine-based products and process. There are no uses of chlorine known not to produce these by-products at some point in their lifecycle -- during manufacture, use, or disposal. Eliminating the sources of dioxins and furans alone would require a broad phase-out of all chlorine-based processes. 3. BIOLOGY: ORGANOCHLORINES CAUSE HARM IN MIXTURES. Once these mixtures of organochlorines are released into the environment, the chemicals do not cause their effects on a one- by-one basis. Thus, the effects they cause cannot be predicted, evaluated or prevented in isolation, either. 177 organochlorines have already been identified in the fat, blood, breast milk, semen and breath of the general human population of the U.S. and Canada. 168 have been "unequivocally" identified in the Great Lakes ecosystem. Hundreds or thousands more are known to be present, but have not yet been identified. Each of these organochlorines can add to or multiply the toxic effects of the others. Many organochlorines can act together to produce synergistic suppression of the immune system. Organochlorines also interact with non-chlorinated chemicals and other causes of disease. Dioxin exposure increases the chance of getting cancer from chemicals found in cigarette smoke and auto exhaust. DDT promotes cancers initiated by radiation from x-rays, nuclear tests, or power plants. As a result, the effects of chemical mixtures cannot be predicted on a chemical-by chemical basis. The "safe" exposure levels derived from risk assessments on isolated substances never consider the effect of the chemical in the context of all the other exposures. The hazard posed by the total mixture is never acknowledged or addressed. It is unscientific, impractical and unethical to suggest, as the CanTox report does, that epidemiological evidence should be considered valid only if cause-effect linkages can be proven between "specific chlorinated organic chemicals and reported adverse effects." Ironically, the industry's idea of "good science" deliberately excludes the well-established reality of multiple chemical interactions. "Proving" causal linkages between individual chemicals and diseases is undermined because: i) everyone is exposed so there is no uncontaminated control group; ii) it is almost impossible to isolate one chemical from the myriad of contributing factors; and iii) subtle long-term health effects are very difficult to measure. Finally, the prove-harm approach reacts only after irreversible damage to the health of humans and the ecosystem has occurred. In effect, this approach uses people and wildlife as guinea pigs in a living laboratory. In the Great Lakes ecosystem, at least fourteen species high on the foodchain -- including humans -- are suffering epidemics of reproductive and developmental impairment that have been linked to persistent organochlorines. Despite the clear association of these effects with organochlorine exposure through the food chain, the effects are not entirely explained by the PCBs, dioxin, DDT and other chlorine-based pesticides known to play important roles. A similar picture emerges from the Baltic Sea, where large-scale effects on fish, wildlife, and ecosystem structure have been attributed to organochlorines, but cannot be entirely explained by individual compounds. CanTox's demand for proof of chemical-specific causal links will allow health damage to continue while a difficult, protracted, and ultimately impossible scientific endeavor continues. 4. ECONOMICS: INDUSTRY UNDERMINES CHEMICAL-BY-CHEMICAL REGULATIONS The chlorine industry's profits depend upon sales of chlorine and its co-product, caustic soda. If organochlorines are regulated one-by-one, the industry will shift the excess chlorine into other products and processes to maintain total sales. This economic logic will ensure that there is no net decrease in environmental loadings of organochlorines. Historically, the industry has succeeded with this strategy. When DDT was phased out, the organochlorine pesticide toxaphene was phased in. As the ozone-destroying CFCs have been phased- out, industry has substituted HCFCs, which are also chlorinated, persistent, and ozone-depleting. Now the industry has announced its plan to substitute HFCs when HCFCs are phased out over the next decade; HFCs are made from chlorinated feedstocks. Currently, the most important "sink" for excess chlorine is the plastic PVC, the only major chlorine use sector increasing in North America. As chlorine use in pulp and paper, solvents, and refrigerants declines, the industry is relying on PVC to take up the slack by continuing to expand into markets for traditional materials like wood, glass, cardboard, metal and ceramic. As PVC markets eventually become saturated in the northern nations, the industry intends to prevent declines in total chlorine use by increasing PVC consumption in southern developing nations. Massive growth in exports of PVC products, feedstocks, and production technology are planned for Latin America, the Pacific Rim, and the Middle East in coming years. 5. TECHNOLOGY: ASSESS ALTERNATIVES, NOT RISKS. The chemical-specific approach inevitably leads to an end- of-the-pipe focus. Discharge limits on specific chemicals are met using pollution control devices that shift discharges from one environmental medium to another. The focus on "acceptable" risks and discharges of individual chemicals takes for granted the continued use of polluting processes. The key question should be not "How much damage can we tolerate?" but "How little damage can we do?" When the focus shifts to chemical classes, however, and the processes and feedstocks that produce them, the availability of clean alternatives becomes a primary issue. The only way to prevent the production of organochlorines is to substitute alternative processes for ones that now rely on chlorine. Chlorine-free alternatives are available, practical, and proven effective. 27 pulp mills around the world are now producing high-quality, totally chlorine-free paper using oxygen- based bleaching or other methods. Dozens of European companies and municipalities have virtually eliminated the use of PVC in construction, flooring, automobiles, furniture, and packaging. Farmers around the world have achieved high yields and reduced expenses using organic farming methods instead of synthetic pesticides. Manufacturing firms and dry-cleaners are substituting chemical-free processes for chlorinated solvents. Even some chemical companies are using alternative processes to make chemicals that previously required chlorinated intermediates. Alternatives are available now for all major uses of chlorine. But their implementation in North America has been slowed by the current regulatory focus on individual chemicals and acceptable discharges. In the end, one of the best reasons to phase out chlorine is because we can. REVERSING THE BURDEN OF PROOF Current regulations are based on a "prove-harm" approach: individual chemicals are innocent until proven guilty. But the evidence does not support the presumption that organochlorines are harmless. For all the reasons discussed above, the prove- harm approach is unworkable, unscientific, and unethical. A new standard of proof is necessary; the burden of proof should not rest on those attempting to protect health and the environment. In many fields of law, a plaintiff has the burden of making a "prima facie" case: preliminary evidence must provide reason to believe the law was broken or an injury took place. Once the prima facie case is established, however, the burden of proof shifts, and the defendant must disprove the case. In civil rights law, for instance, this approach is frequently used when it is impractical or unreasonable to expect plaintiffs to provide incontrovertible proof of intentional discrimination. This method can be used to reverse the burden of proof in the environmental field, as well. Based on the following rationale for phasing out the class of chlorine-based products and processes, industry must accept the burden of proving that a process or product within that class does not result in the production and discharge of persistent toxic substances during its lifecycle. First, organochlorines dominate virtually every government list of priority environmental pollutants, typically accounting for over half of the chemicals of concern. Second, organochlorines tend to be persistent, bioaccumulative and/or toxic, more so than similar non- halogenated hydrocarbons. The same properties that make organochlorines effective industrial chemicals -- solubility in oils and fats, resistance to chemical and biological breakdown, and toxic, pesticidal or antibiotic action -- account for their environmental hazards. No organochlorines are known to be non-toxic. Third, the hazardous qualities of organochlorines are the rule, not the exception. Toxicity, persistence, and/or bioaccumulation are associated not only with dioxin, PCBs, and DDT but also with many short-chain solvents and monomers, longer- chain aliphatics, simple and complex aromatics, chlorinated acids, exotic by-products, and "new-generation" chlorinated pesticides like atrazine and alachlor. These compounds are also widespread in the ecosystem and the human population. Fourth, organochlorines in nature are overwhelmingly foreign and toxic to complex organisms. Although several hundred are produced in very small quantities by fungi and algae, only one organochlorine -- the simplest, methyl chloride -- is produced in large amounts. No organochlorines occur naturally in the tissues of humans, other mammals, or terrestrial vertebrates. Naturally occurring organochlorines function as natural pesticides, antibiotics, and chemical defenses, reinforcing the presumption that organochlorines are harmful to complex organisms. Fifth, because organochlorines are formed in complex mixtures, any organochlorine product is likely to result in the production of the most dangerous organochlorines at some point during its lifecycle. The burden of proof should be reversed for chlorine-based processes, not just individual products. The prima facie case does not argue that all organochlorines are equally toxic, persistent, or bioaccumulative. It does present a weight of evidence, however, that organochlorines tend to exhibit these qualities. It shows that it is likely that many of the thousands of organochlorines that have not yet been tested or identified will turn out to be toxic persistent, and/or bioaccumulative. It shows that all chlorine-based processes are likely to produce harmful substances -- on purpose, by accident, or both. CHLORINE PHASE-OUT: TEST CASE FOR PREVENTION The chlorine industry's plea for a chemical-by-chemical, risk-based approach to organochlorines is essentially a defense of the existing reactive regulatory system which has allowed the contamination to develop in the first place. The present system has served the chemical industry well and permitting its continued expansion by diverting public concern into a largely ineffective bureaucracy, excluding consideration of safer alternatives, and placing an impossible burden of proof on those who would curtail toxic chemical use. If the industry can ensure the survival of the current reactive framework, it can guarantee that any new policies for organochlorines will be piecemeal and ineffective. If, on the other hand, reformers can establish that the only way to address the health and environmental threat of organochlorines is to apply the principles of prevention to a broad class of chemicals and processes, a new framework will have been established. In this light, the chlorine phase-out emerges as a political and practical test-case for the scientists, workers, communities, and environmentalists who have advocated a broad prevention-based approach. Achieving a chlorine phase-out will establish that the precautionary framework can be applied and can work. It will then be possible to substitute Clean Production methods for the many other toxic chemicals and processes still to be addressed. "A LICENSE TO KILL" Grassroots Activism Confronts Proctor and Gamble in Florida by Gail Martin ----------------------------------------------------------- Proctor & Gamble (P&G) has been pouring chlorinated effluent into the Fenholloway River since 1954. The stagnant, black stream is known locally as the "Stinky River." "There's no bones about it. They have a license to kill," says Mark Thompson, a scientist with the Florida Marine Fisheries Commission, about P&G. (1) Florida is home to two of the three locations in the world known to have what Dr. Will Davis, an EPA scientist, calls "bearded ladies."(1) Dr. Davis documented female mosquitofish which have taken on male characteristics, and vice versa. These fish have been found downstream from two chlorine-bleaching pulp mills -- Champion Paper near Pensacola and Proctor & Gamble in Taylor County.(2) Joy Towles Cummings, leader of the grassroots group Help Our Polluted Environment (HOPE) in Taylor County, Florida, has been documenting the ecological destruction wrought by three decades of P&G's dumping. So far, she and HOPE have exposed: * the USEPA DOES NOT regulate P&G's discharge for the entire 22 mile length of the Fenholloway River; * documentation of a 25 square mile seagrass die-off where the river meets the Gulf of Mexico; * a state warning against consuming ANY amount of river fish due to dioxin (for which the state still has not posted warning signs); * a settlement pond that is still used by P&G is located over a sinkhole which continually releases wastes directly into the local groundwater supply. In July 1991, HOPE members received confirmation of what they feared most. The Florida environmental agency and health department finally admitted that P&G's discharge had contaminated the groundwater supply. Since most local people rely on private drinking water wells in this rural area, groundwater contamination means drinking water contamination. The state agencies urged people living within two miles of the river not to drink their water. The media attention that followed revealed that P&G had long suspected the contamination. They had a long-standing practice of drilling new wells for county residents who complained about their bad water, along with supplying bottled water to many homes where safe wells no longer existed. Further, it was revealed that while P&G management staff had been drinking bottled water since 1986, mill workers were drinking contaminated water until August 1991. BACKLASH: BLAMING THE MESSENGER Accompanying the revelations about P&G's negligence, the backlash against HOPE members intensified. At the September 1991 EPA public hearing on the contamination, many of the P&G supporters wore orange hunting vests and hats, while others wore the orange ribbons distributed at the door. Some supporters said this was to symbolize hunting the environmentalists. In April 1992, the hostility turned violent. One evening, three men wearing masks docked at the Fenholloway Fish Camp, a routine HOPE meeting place in an isolated area surrounded by swamp and woods. Though it was unusual, on that night one of the camp operators was there alone. The men stabbed, raped and burned her with a cigar. They then poured polluted river water into her wounds and said, "Now you'll have something to sue us about. We're going to pay a visit to Joy next." The Florida Department of Law Enforcement recently dropped its investigation of the case. No arrests were ever made. Blaming the messenger is still the rule in Taylor County, though HOPE has not relented. Joy Towles Cummings says of the incidents, "We didn't know that it would turn out like this when we organized, but we're glad we called ourselves HOPE. We're determined to continue until Proctor & Gamble is cleaned up, and we'll do so out of hope, not fear." ACTION AND HOPE HOPE has taken numerous actions to highlight the problem, culminating in a November 1992 HOPE and Greenpeace action to block P&G's chlorine shipments for a day. In an appeal to the workers, leaflets were distributed during shift changes. Workers and activists were subjected to the intimidation tactics of P&G who videotaped the leafleting. A thumbs-up signal was given to those who refused a leaflet; the camera focused in on those who merely took a leaflet. Following the lead of thousands of plaintiffs suing Georgia- Pacific and International Paper in Mississippi, HOPE members and hundreds of other residents have also filed lawsuits against P&G. Three of the approximately ten thousand Mississippi cases have already been decided. In one case, a jury decided that Georgia-Pacific committed chemical trespass and damaged property, awarding over $1 million to a downstream landowner.(3) In another case, the jury awarded over $3 million to two landowners for nuisance and emotional distress. This ruling set a precedent in that plaintiffs did not have to prove that they had cancer, or dioxin in their bloodstream, or link either to the mill, but that they suffered emotional distress from factors such as fear of cancer.(4) While the Mississippi cases are under appeal, similar citizen lawsuits are moving forward in Texas, North Carolina, Alabama, and Pensacola, Florida. REGULATORY FAILURE The USEPA's regulatory response has been negligible, at best. In September 1991, the USEPA and Proctor & Gamble announced they would study the problem for two years. (The study is already behind schedule.) The company advocates piping the waste 22 miles directly to the Gulf of Mexico. No serious consideration has been given to totally eliminating chlorine, even though that would enable the company to implement a closed-loop system. HOPE believes the only way P&G can operate safely in Taylor County is with a closed-loop system which would eliminate the contamination of groundwater with organochlorines and other toxins, along with reducing its 50 million gallon per day use of Florida's scarce water supply. P&G publicly denies that it is possible to eliminate chlorine in a kraft mill making its products. (Alternately, company officials deny even using chlorine.) In fact, the P&G mill uses three stages of chlorine dioxide in its disposable diaper pulp line, while its rayon pulp line (used to make products such as tampons) still uses elemental chlorine. In Europe, many kraft mills are currently are using totally chlorine-free processes to make the same products as P&G, as well as paper-grade chlorine-free products. In Sweden, Stora Cell and Korsnas use oxygen and hydrogen peroxide to bleach totally chlorine-free diaper-grade kraft pulp, while the Lenzig AG of Austria has purchased a rayon mill in Tennessee which will use totally chlorine-free rayon pulp from Brazil. HOPE COMES TO WASHINGTON P&G still has a license to kill. The Fenholloway River still receives 50 million gallons of contaminated wastewater each day. While the State of Florida and the USEPA remain silent, HOPE is escalating its community action. HOPE is taking its grassroots chlorine-free campaign to Washington and the new USEPA Administrator Carol Browner. On MONDAY SEPTEMBER 20, HOPE and activists attending the Environmental Health Network conference will deliver their chlorine-free message to Carol Browner and the USEPA. -------- box --------- For more information on the Environmental Health Network Conference (September 17-19, Holiday Inn, Bethesda, MD), call (804)424-1162. Conference attendees are encouraged to stay and deliver the chlorine phase-out message to the USEPA on Monday September 20. ----------------------- For Further Information: Joy Towles Cummings, HOPE, P.O. Box 327, Salem, FL 32356 (904)584-4544 Gail Martin, Greenpeace, 802 S. Carrollton, New Orleans, LA 70118 (504)861-0867 Citizen Lawsuit Information, Dioxin Litigation Team P.O. Box 2072, 802 Main Street, Hattiesburg, MS 39401 (601)544-0631 Linda King, Environmental Health Network Great Bridge Station, P.O. Box 16267, Chesapeake, VA 23328 (804)424-1162 David Ludder, Legal Environmental Assistance Foundation 1115 N. Gadsden, Tallahassee, FL 32303 (904)681-2591 References: (1) Hauserman, Julie. "Florida's Forgotten River," Tallahassee Democrat, Tallahassee, Fla., March 17, 1991. (2) Davis, William & Bortone, Stephen. "Effects of Kraft Mill Effluent on the Sexuality of Fishes: An Environmental Early Warning," in Colborn, T. & Clement, C. (eds.) Chemically Induced Alterations in Sexual and Functional Development: The Wildlife/Human Connection, Princeton Scientific Pub., 1992; pp.113-27. (3) Maples, Nancy Jo. "Mill Loses $1 Million Dioxin Suit," Pascagoula Press Register, Pascagoula, Miss., October 28, 1990. (4) Hannaford, Jim. "Property Owners Awarded $3.2 Million in Dioxin Trial," Sun Herald, Gulfport, Miss., February 1, 1992. INDUSTRY STUDY BACKFIRES: Chlorine Phase-out is Feasible and Affordable by Joe Thornton and Jay Palter --------------------------------------------- The chemical industry has launched its first major counterattack against a growing movement of environmentalists, communities, scientists, and others calling for a phase-out of industrial uses of chlorine and chlorine-based chemicals. The attack takes the form of a report, written by Charles River Associates (CRA) for the Chlorine Institute, which presents alternatives for all uses of chlorine and estimates the costs associated with each. (1) According to the industry, the CRA report demonstrates that phasing out chlorine would devastate the economies of the U.S. and Canada, with costs of a total phase-out estimated at $102 billion annually. However, a more careful view of the information presented in the report actually supports the feasibility of eliminating chlorine. First, the CRA report moves the chlorine debate to a new level by acknowledging that alternatives are available for all uses of chlorine. That the chlorine industry has admitted the existence of substitutes for all of its products is of great importance. Instead of arguing that it is impossible for our society to kick its chlorine addiction, the industry is now arguing merely that it will cost too much money. Second, the report's calculations suggest that phasing out virtually all the chlorine used in North America may not be so expensive after all. According to CRA's estimates, a few sectors that use only small amounts of chlorine, such as pharmaceuticals, account for the bulk of the cost of the phase-out. Most of the chlorine could be eliminated for a much lower price. While CRA estimates the annual costs of a total phase-out at $102 billion, eliminating 95 percent of chlorine use would cost only $20 billion. When compared with other expenses -- such as the $75-150 billion in annual health care costs attributed to the effects of persistent toxic substances(2) -- the transition to a chlorine-free society appears to be a reasonable and productive investment in our future. This makes a well-planned chlorine phase-out program seem far less daunting. Large use sectors for which alternatives are most readily available and affordable -- i.e., PVC, pulp and paper, solvents, etc. -- represent logical first steps. Third, the actual cost of phasing out chlorine would be far less than CRA estimates. The report drastically overestimates the cost of chlorine substitutes in a number of major sectors by ignoring the real-world economic benefits of chlorine-free technologies. For instance, the National Academy of Sciences(3) has affirmed that farmers who eliminate their use of synthetic pesticides increase their yields, lower their production costs, and have access to burgeoning markets for organic foods. CRA ignores this evidence and assumes that phasing-out chlorine-related pesticides would cause a drastic decline in North American food production that would cost $24 billion per year. CRA also estimates high costs to phase out chlorinated solvents, but many industries have already adopted cleaner production processes and reaped financial benefits by eliminating the costs of purchasing, controlling and disposing of the chemicals, as well as the associated costs of regulatory compliance, liability, compensation, and remediation.(4) CRA also ignores long-term economic benefits. For instance, the European and North American pulp mills that have invested in totally chlorine-free production are now in the strongest positions to deal with the markets, regulations, and cost-saving opportunities of the coming decade. In its treatment of the effects of a chlorine phase-out on employment, the report fails to acknowledge that eliminating chlorine in user industries means changing production processes, not eliminating them. In some industries, like agriculture and dry cleaning, chlorine-free processes actually substitute labor for chemicals, creating more jobs. And as chlorine-based products like PVC are phased out, industries that manufacture chlorine-free materials will expand, generating new jobs. Finally, CRA estimates a one-time $67 billion investment in chlorine-free retooling, yet is silent on the employment opportunities associated with the transition itself. A chlorine-free economy would offer more jobs, not fewer, in a more sustainable framework. Of course, this is little comfort for the workers who are currently employed making chlorine and related chemicals. Clearly, the burden of the transition to a non-toxic economy should not fall on the shoulders of workers and communities. Programs to offer income protection, education, training, re-investment and re-development opportunities for displaced workers and communities must be integral parts of the chlorine phase-out. CRA ignores this opportunity. In sum, the CRA report supports the view that a well-planned phase-out of the chlorine industry over the next 10-20 years is both technically possible and economically feasible. The next step is for interested parties -- including workers and communities -- to begin to plan timelines, financing and worker and community assistance programs so that an effective and equitable transition to a chlorine-free economy can proceed. ------------ B O X ------------------ COMPARING COSTS Project Estimated Cost ___________________________________________________________ Cost to phase-out 100 percent $102 billion/yr of chlorine use, U.S. and Canada (1) Cost to phase-out 95 percent $20 billion/yr of chlorine use, U.S. and Canada (1) Health care costs for effects of $75-150 billion/yr persistent toxic substances -- U.S. and Ontario (2) U.S. industry expenditures on end-of-pipe $90 billion/yr pollution control (5) U.S. military budget $300 billion/yr U.S. savings & loan bail-out $500 billion (total) Clean-up of toxic and radioactive $500 billion to waste dumps in U.S. (6) $1.2 trillion Direct and tax subsidies for fossil fuels $53 billion/yr and nuclear power, U.S. government (7) ----------------------------------------------------------- References: (1) Charles River Associates. Assessment of the Economic Benefits of Chlor-Alkali Chemicals to the United States and Canadian Economies. Report and media summary. Washington D.C.: The Chlorine Institute, April 1993. (2) International Joint Commission, Virtual Elimination Task Force, Draft Final Report, March 31, 1993; p.3-7. (3) National Research Council, Committee on the Role of Alternative Farming Methods in Modern Production Agriculture. Alternative Agriculture Washington, D.C.: National Academy Press, 1989. (4) See, for instance, U.S. Office of Technology Assessment. Serious Reduction of Hazardous Waste. Washington: D.C., 1986. (5) W. Reilly, U.S. EPA Administrator. Quoted in Bureau of National Affairs Environment Watch, October 15, 1990. (6) M. Russell, University of Tennessee, quoted in H. Hebert, "Toxic Clean-up." Associated Press, December 10, 1991. (7) Lent, T. Energy for Employment. Washington, DC: Greenpeace, USA 1992. Data from H. Lovins and A. Lovins, Rocky Mountain Institute. Breast Cancer: A Preventable Epidemic by Joan D'Argo and Joe Thornton ------------------------------- Two years after Rachel Carson wrote her groundbreaking book, Silent Spring, she died of breast cancer. Three decades later, pollution of the global environment and our bodies has grown more severe. Breast cancer is now the leading cause of death for women between the ages of 40 and 55 in North America. GRIM STATISTICS Breast cancer rates have risen steadily since the dawn of the chemical age. From 1940 to 1982, breast cancer rates increased by 1.2 percent each year. Alarmingly, from 1980 to 1987, the number of breast cancer cases reported in the U.S. rose by 32 percent. Fifty years ago, one in 20 women got breast cancer. Today, a woman has a one-in-eight chance of getting breast cancer during her lifetime. Breast cancer incidence is growing rapidly in virtually all of the world's industrialized countries. In 1980, 560,000 women died of breast cancer worldwide. By the year 2000, that figure is expected to double. PERSONAL OR ENVIRONMENTAL CAUSES What is the cause of this cancer epidemic? As far back as 1964, the World Health Organization stated that 80 percent of cancers were due to human-made carcinogens. Yet we are told repeatedly by the powerful "cancer establishment" that breast cancer is caused by personal choices and family histories. On the environmental causes of breast cancer, the Cancer Society, National Cancer Institutes, and other research and treatment institutions -- most of which are partially funded and strongly influenced by the chemical and pharmaceutical industries -- are silent. A disturbing silence in light of the fact that personal risk factors like family history, reproductive choices and eating a fatty diet account for only 20 to 30 percent of all cases of breast cancer. The vast majority of breast cancer cases -- 70 to 80 percent -- are not attributable to personal risk factors. It is in these cases that the scientific evidence points to what breast cancer activists have suspected all along: breast cancer is an environmental disease. THE CHLORINE CONNECTION Chlorine-based industrial poisons -- known as organochlorines -- can now be found everywhere on the planet. Because they tend to resist degradation and accumulate in the fatty tissues of living things, hundreds of organochlorines contaminate our bodies and have been detected in our fat, blood, mother's milk, semen, and breath. Once in the body, organochlorines have been shown to cause cancer -- some linked directly to breast cancer -- by creating genetic mutations, disrupting natural controls in cell growth and division, and suppressing the immune system. And many organochlorines can mimic or interfere with the body's natural sex hormones -- including estrogen, a well-recognized breast cancer risk factor. Greenpeace's report, "Breast Cancer and the Environment: The Chlorine Connection," documents the following: * Women exposed to higher-than-normal levels of organochlorines in the workplace have very high rates of breast cancer. * Women with breast cancer tend to have higher levels of organochlorines in their breast tissues than women who do not have breast cancer. * For decades, breast cancer rates and organochlorine pesticide contamination in Israel were among the worst in the world. Following an aggressive phase-out program for several chlorine-based pesticides in the mid-1970s, contamination dropped quickly to the levels found in other countries. Breast cancer rates dropped as well over the next decade, especially among younger women. In addition to organochlorines, radioactive fallout from above-ground nuclear testing, exposure to other toxic chemicals, and hormones added to meat and dairy products may also contribute to skyrocketing breast cancer cases. FIRST STEP TO PREVENTION: A CHLORINE PHASE-OUT Over the last 20 years, a few organochlorines have been banned or restricted. But thousands are still being produced, and thousands more -- like dioxin -- continue to be produced unintentionally whenever chlorine is used. Links to breast cancer and other diseases adds weight to the growing calls to phase out organochlorines as a group, with chlorine -- the chemical building block of them all -- specifically targeted for elimination. Alternatives are already available for all major uses of chlorine. Though the evidence is not scientifically conclusive, it is strong enough to warrant a precautionary approach: if we are to win the battle against breast cancer, steps must be taken now toward the elimination of organochlorines. Resources for Further Action: Chlorine, Human Health and the Environment: The Breast Cancer Warning, A Greenpeace Report by Joe Thornton. Send $10 to: Greenpeace, 1017 West Jackson Blvd., Chicago, IL 60607. Endorse "A Woman's Cancer Agenda". For more information contact the Women's Community Cancer Project, c/o The Women's Center, 46 Pleasant St., Cambridge, MA 02139; (617)354-9888. 1 in 3: Women With Cancer Confront An Epidemic, Edited by Judy Brady. Cleis Press, 1991. Confronting Cancer, Constructing Change: New Perspectives on Women and Cancer, Edited by Midge Stocker, Third Side Press, 1993. The Cancer Industry, by Ralph Moss, Paragon House, New York, 1989. The Cancer Journals, by Audre Lorde, Ann Lute Books, San Francisco, 1980. Dioxin linked to Endometriosis in Rhesus Monkeys by Barbara Mains ------------------------------------------------ Results of a new study point to a direct correlation between chronic exposure to dioxin and an increase in incidence and severity of endometriosis in rhesus monkeys. These findings add further disturbing evidence that dioxin may function as an endocrine disruptor. WHAT IS ENDOMETRIOSIS? Endometriosis is a common disease of the female reproductive organs. It affects at least 5.5 million women in Canada and the U.S., and millions more around the world. Its cause remains unknown and there is no cure. The disease is characterized by the growth of endometrial cells (the cells forming the membrane lining of the womb) at sites outside the uterus. These cells respond to ovarian hormones by bleeding periodically, and can form bands of scar tissue that constrict the pelvic organs. The most common symptoms of endometriosis are painful menstruation and pain with sexual activity. It is also associated with infertility. Frequently a chronic disease, endometriosis exacts a heavy toll upon the productivity and well-being of women. Interventions to control the disease constitute a substantial burden upon the health care system. Sadly, endometriosis remains among the leading cause of hysterectomy in North America. RHESUS MONKEY RESEARCH In 1992, the Endometriosis Association learned of a unique rhesus colony of 24 female monkeys. The monkeys were part of a chronic toxicology study evaluating the long-term effects of exposure to dioxin (2,3,7,8-TCDD). Endometriosis occurs spontaneously in menstruating species, including rhesus monkeys. The forms of the disease exhibited by these species appear to be similar to its manifestations in humans. In the 15-year study, three groups (high dose = 25 ppt; low dose = 5 ppt; control = no dose) of monkeys were exposed to dioxin in their feed. The animals exposed to dioxin exhibited reproductive abnormalities, including spontaneous abortion and still births. Many of the dioxin-exposed animals exhibited symptoms similar to the human disease at the onset of menstruation, including anorexia and behaviour consistent with pain. The results of the study, expected to be published later this year, indicate that: * Chronic exposure to dioxin was directly correlated with an increase incidence of endometriosis in the rhesus monkeys. * The severity of the disease was positively correlated with the daily and cumulative dose of dioxin administered. For Further Information, Contact: Mary Lou Ballweg Barbara Mains Executive Director Director of Canadian Projects Endometriosis Association Endometriosis Association 8585 N. 76th Place 74 Plateau Cres. Milwaukee, WI 53223 Don Mills, ON M3C 1M8 Tel. (414)355-2200 Tel. (416)651-2419 Fax. (414)355-6065 ----------------------------------- Communities Resist WTI Incinerator by Niaz Dorry and Rick Hind ---------------------------------- The battle to stop the Swiss-owned Waste Technologies Industries (WTI), the world's largest and stupidest toxic waste incinerator located in East Liverpool, Ohio, continues to rage. In April 1993, representatives from the Ohio Valley communities joined Greenpeace in the "Put People First, Not Polluters" bus tour. The Greenpeace bus stopped at over 25 communities across the U.S. fighting existing or proposed sites of hazardous waste incinerators. The tour culminated in Washington on May 17. Citizens fighting toxic waste incinerators from across the country chained themselves to a mock incinerator parked in front of the White House, demanding that the new administration keep their promise to stop WTI and implement a national moratorium on new burners. Fifty-three activists were arrested. On July 14, anti-incinerator activists took their battle to the Swiss embassy in Washington. After a busload of children from East Liverpool were refused a meeting with the President, they joined their parents at the Swiss embassy. The parents surrounded the school bus and refused to leave. Twenty-three activists were arrested. A letter was delivered to the Swiss ambassador requesting that the Swiss government employ whatever legal means it could to stop this illegal facility from polluting their community. Following the May protest in Washington, the USEPA announced an 18-month moratorium on incinerators and a shift in policies regulating burners and industrial furnaces (BIFs). However, the "freeze" does not appear to affect most of the new facilities currently in the permitting process. A real moratorium, the "Pollution Prevention and Incineration Alternatives Act" (H.R. 2488) authored by Representative Bill Richardson (D-NM) was recently introduced in the U.S. Congress and now has over 60 co-sponsors. The bill requires a four-year "time-out" on new garbage incinerators and sets strict conditions for any new hazardous or garbage incinerators, including new recycling requirements and toxic use reduction that would render new incinerators unnecessary. It also establishes a 1.5 mile buffer zone between schools and hospitals and protection from the disproportionate siting of incinerators in minority and low income communities. WHAT YOU CAN DO: * Urge your Representative to co-sponsor H.R. 2488, The "Pollution Prevention and Incineration Alternatives Act," authored by Rep. Bill Richardson (D-NM). * Call or write President Clinton tell him to keep his promise to stop WTI and start an incineration moratorium. The White House, Washington, DC 20050 (202)456-1414. --------------------------------------------------------- AS CHLORINE USE DECLINES, INDUSTRY EXPANDS PVC PRODUCTION by Gail Martin and Jay Palter --------------------------------------------------------- Products and processes using chlorine are in decline -- CFCs are being banned, chlorinated solvents are being phased out, and the amount of chlorine used for pulp bleaching is dropping. As chlorine uses are phased out, the chlorine industry creates "sinks" into which they dump excess chlorine. PVC, or polyvinyl chloride plastic, is the preferred industry "sink" for chlorine and its production is increasing as all other uses of chlorine decline. PVC accounts for one-fifth of plastics consumption and is the largest use of chlorine worldwide. Its entire lifecycle -- production, use and disposal -- results in environmental contamination with organochlorines and other toxins added to PVC products. In Europe, these problems have prompted major manufacturers and governments, including 100 local authorities in Germany alone, to phase-out PVC use. [See Greenpeace factpack "PVC: Toxic Waste in Disguise".] In April 1993, Greenpeace released a report on PVC production entitled "Dioxin Factories". Based on new data from four European plants, the report showed that PVC feedstock production resulted in dioxin and other organochlorine emissions that ranked among the largest sources known. (The feedstocks, ethylene dichloride (EDC) and vinyl chloride monomer (VCM), are precursors to PVC and both highly toxic and carcinogenic.) While the European PVC industry is facing phase-out campaigns and set-backs on its expansion plans, the PVC industry in the U.S. is planning massive expansions. Recent articles in ChemicalWeek report expansions totalling at least 940 million lbs/year of PVC and 1 billion lbs/year of EDC in the U.S., already the world's largest PVC producer. Even with a sluggish economy, PVC demand in the U.S. grew by 12 percent in 1992. With the economy and housing starts on an upswing, the industry is expecting an even higher demand for PVC in 1993 and beyond. Most U.S. companies are planning or beginning expansions this year and into 1994. Though the information reported concentrates on PVC expansions, EDC and VCM expansions would likely follow suit. Notably absent from the following list of known expansions are industry leaders Dow, PPG and Oxymar. ------------------------ c h a r t -------------------------- KNOWN U.S. PVC INDUSTRY EXPANSIONS: BFGoodrich: 300 million lbs/yr PVC Borden Chemical & Plastics: Expansions under consideration Formosa: 850 million lbs/yr PVC added Georgia-Gulf: 240 million lbs/yr PVC Shintech: 375 million lbs/yr PVC added OxyChem: 1 billion lbs/year EDC(2) 100 million lbs/year PVC possible new PVC unit Vista Chemical: 300 million lbs/year VCM expansion may follow Westlake: Undisclosed PVC expansion plans Acquiring PVC pipe plants Sources: (1) Unless noted otherwise, all information from: Hunter, David. "PVC Makers Study Expansions to meet Demand Growth," CHEMICALWEEK, February 10, 1993. (2) Wood, Andrew. "U.S. Derivatives Expansions Raise Question of Ethylene Supply," CHEMICALWEEK, March 10, 1993 ------------------------------------ Architects Designing PVC-Free Future by Bonnie Rice ------------------------------------- Architects are uniquely positioned to play a key role in sustainable development. Their choice of design and materials can have serious long-term implications for the sustainability of the planet. In June 1993, thousands of architects from around the world gathered in Chicago at the "Designing for a Sustainable Future" conference, hosted by American and international architecture associations. Greenpeace participated in the conference to educate architects about the environmental and human health impacts of using PVC (polyvinyl chloride) plastic, one of the most common materials used in construction today. "PVC: The Hidden Costs," a new Greenpeace video that premiered at the conference, highlights why several visionary European designers, planners and developers are spearheading the PVC-free construction movement: * High levels of ultra-toxic dioxins and other chlorinated poisons are formed in the production of the raw materials used to manufacture PVC; * Additives used in the production of PVC products (eg., flooring) off-gas into the air, contributing to Sick Building Syndrome; * Incineration or accidental burning of PVC produces dioxins and other dangerous organochlorine compounds; landfilling of PVC can result in groundwater and soil contamination due to leaching of PVC additives. Building and decorating materials account for over 60 percent of PVC use. Window frames, pipes, flooring, roof sheeting, electrical insulation, wall coverings and window blinds made from PVC contribute to the global burden of toxic pollution. As documented in the video, safer materials such as concrete, wood, ceramics, metal and rubber can be substituted for all major uses of PVC in construction. A 1990 Danish study found that 60 percent of PVC building materials can be replaced within a three-year period, and the remainder within five years. Already, over 100 communities in Europe have banned or are phasing out the use of PVC in public buildings, due to the health and environmental risks of this unnecessary, toxic plastic. For copies of the videotape, "PVC: The Hidden Costs," contact Greenpeace (919)828-5202. RECENT CHLORINE-FREE PUBLICATIONS AND VIDEOS: Greenpeace Publications * PVC: "Dioxin Factories: A Study of the Creation and Discharge of Dioxins and other Organochlorines from the Production of PVC," April 1993. "PVC: Toxic Waste in Disguise," 1992. "Alternatives to PVC Products," (partial translation of Greenpeace Austria report) 1993. * Incineration: "Hazardous Waste Incineration: Impacts on Agriculture," February 1993. * Chlorine and Breast Cancer: "Chlorine, the Environment and Human Health: The Breast Cancer Warning, October 1993. * Chlorine Phase-Out Economics: "Transition Planning for the Chlorine Phase-Out: Economic Benefits, Costs and Opportunities," October 1993. GREENPEACE VIDEOS: Chlorine-Free Video #1 -- "The Global Chlorine Crisis." Chlorine-Free Video #2 -- "Breaking the Chlorine Trap", presentation by Barry Commoner (transcripts also available). Chlorine-Free Video #3 -- "Alternatives to Industrial Uses of Chlorine," presentation by Jay Palter and Joe Thornton. "PVC: The Hidden Costs" -- Alternatives to PVC building materials. OTHER ARTICLES: * Numerous articles have been published by the general media and in trade publications that are useful for understanding the key issues in the chlorine debate. "Concerns Broaden over Chlorine and Chlorinated Hydrocarbons,"by Bette Hileman, CHEMICAL AND ENGINEERING NEWS (April 19, 1993), pp. 11-20. "Chlorine," by Richard Lazenby, EARTHKEEPER Magazine (June/July 1993) pp. 28-33. "The Crusade Against Chlorine," by Ivan Amato, SCIENCE Vol.261 (9 July 1993), pp.152-4. "Is Chlorine Killing the Great Lakes/Sunset for Chlorine?" by David Moberg, E Magazine (August, 1993), Vol. IV, No. 4, pp. 26-31. "Chlorine: What Agendas? What Issues? What Options?" by Elisabeth Kirschner with David Hunter, CHEMICAL WEEK (3 Nov 1993). * Some of the current articles focusing on the breast cancer and its connection to organochlorines include: "The Environmental Link to Breast Cancer," by Liane Clorfene-Casten, MS. Magazine (May/June 1993), Vol. III, No. 6. "The Profits of Misery -- Breast Cancer and the Environment: How the chemical industry profits from an epidemic it may be causing," by Monte Paulsen, DETROIT METRO TIMES (May 1993). [Reprinted as "The Politics of Cancer," in UTNE READER (Nov/Dec 1993), pp.81-90.] * The problems of the incineration of PVC products and other waste composed of chlorinated compounds which have the potential to produce dioxins: "Hazardous Waste Incineration Presents Legal and Technical Challenges," by David Hanson, CHEMICAL AND ENGINEERING NEWS (March 29, 1993), pp. 7-14. ENDS