TL: MYTHS OF THE CHLOROPHILE: Chlorine Phase-Out SO: Jay Palter, Greenpeace Canada (GP) DT: March 1994 Keywords: toxics chlorine bans greenpeace reports gp canada organochlorines risks drinking water diseases health / --------------- MYTHS OF THE CHLOROPHILE: Facts Supporting a Chlorine Phase-out by Jay Palter, et al.* March 1994 ------------------------------------- All over this planet, chlorine-based poisons are increasingly being identified as root causes of ecological destruction -- from ozone depletion, to food contamination, to immune failure and infertility in wildlife and humans. A growing number of public health, scientific and political bodies are calling for the phase-out of chlorine- based poisons and the industrial processes that create them. In the past two years, the American Public Health Association, the International Joint Commission on the Great Lakes, and four major international conventions have added their voices to the chorus of calls to phase out chlorine. In response, the chemical industry and other chlorophiles [1] can be heard repeating a series of myths -- about the chlorination of drinking water, naturally occurring toxins, chemical-by-chemical proof of harm as "good science", chlorine-based pulp bleaching and PVC plastic -- all in defense of maintaining the production of chlorine-based chemicals. In exposing and refuting the mythology of the chlorophile, it is clear that the chemical industry has utterly failed to offer compelling arguments for why an orderly economic transition away from chlorine chemistry should not occur. ------------------------- THE MYTH OF UNSAFE DRINKING WATER Phasing out chlorine means that public health will be threatened by waterborne diseases. The chlorophile claims that 20,000 people died of cholera after drinking water chlorination ceased in Peru. ------------------------ Chlorine-free advocates recommend the use of SAFE drinking water disinfection, NOT no disinfection, as the chemical industry implies. Hundreds of communities around the world (among them Paris, Amsterdam and Munich) are already providing safe, chlorine-free water using ultraviolet light, ozone, or filtration-based disinfection. The cholera epidemic in Peru was caused by the lack of proper sanitation, making any satisfactory purification of drinking water impossible [2]. In fact, one study of the cholera virus that caused the Peru epidemic found that it was resistant to chlorine disinfection [3]. Chlorinating drinking water replaces one type of serious public health problem with another. Instead of waterborne infectious diseases, chemically induced diseases such as cancer, birth defects, and other effects associated with chlorination by-products in our drinking water are harming public health. Increasingly, chlorination systems are neither regarded as practical nor effective for developing countries, particularly in rural settings. Chlorine may remain necessary only for episodes of emergency contamination. These would be far less common if developing nations were provided adequate resources to install infrastructures to provide safe, chlorine-free drinking water and to adequately treat sewage. Despite the existence of safe and effective alternatives, water chlorination only accounts for about one percent of total chlorine use and would not be at the top of any priority list for phasing out major polluting uses of chlorine. ----------------------------------- THE MYTH OF "NATURAL" DIOXIN AND OTHER INDUSTRIAL ORGANOCHLORINES Some studies have found as many as 1,500 organohalogens ("halogens" include chlorine, bromine, fluorine and iodine) are produced in nature. These and other "natural" sources of organochlorines, such as dioxin from wood-burning, are used by the chlorophile to justify the industrial generation and ecological effects of dioxin and all other organochlorines. ----------------------------------- A number of organochlorines are produced naturally, mostly by algae and fungi. However, only the simplest organochlorine --chloromethane -- is produced in significant quantities and Lovelock has suggested that this chemical is involved in the delicate regulation of the stratospheric ozone layer [4]. While far in excess of human-made quantities, naturally occurring chloromethane represents a minor contribution to total chlorine levels in the stratosphere. The two major ozone depleting substances are still the human-made CFC-11 and CFC-12 [5]. Other naturally occurring organochlorines are produced by organisms only in TINY quantities -- precisely because of their toxicity -- for use as natural pesticides, antibiotics, and chemical defenses. Most importantly, no organochlorines whatsoever are known to occur naturally in the tissues of people, mammals, terrestrial vertebrates and other higher species. Yet, hundreds of industrial organochlorines are now accumulating in our tissues [6]. Many dioxin sources characterized as "natural" or non- industrial, such as wood-burning, actually originate in the chemical industry. Dioxins and furans are almost completely absent in tissue samples from ancient Chilean mummies and Inuits -- people from cultures that did extensive indoor wood- burning and would have been highly exposed to wood smoke. If dioxin formation is associated with wood-burning today, it is related to extensive chlorinated pesticide use in modern forestry and global chlorine pollution of forests. According to one scientific review, "In ancient human tissue, frozen over 100 years ago, as in silt samples from lakes corresponding to time periods associated with less-chlorinated synthetic chemicals, very little if any chlorinated dioxins or dibenzofurans can be detected, suggesting that most chlorinated dioxins found at present are relatively new and derive from other chlorinated synthetic chemicals." [7] Attempts to date to ascribe sources to the high levels of dioxin found in the environment usually account for only around 10 percent of dioxin, primarily from combustion sources. [8] Table 1 lists known industrial sources of dioxin that are often omitted from dioxin source inventories. Despite the chemical industry's attempts to "naturalize" their poisons, the global build-up of organochlorine pollutants in the environment and the food chain appears as a recent phenomenon caused by the rise of industrial chlorine chemistry in the twentieth century. --------------------------------------------------------- TABLE 1 -- KNOWN INDUSTRIAL SOURCES OF DIOXIN * Production of chlorine by mercury cell * Production of vinyl chloride monomer * Processes involving chlorophenols * Processes involving pentachlorophenol * Production of organochlorine pesticides (2,4-D, 2,4,5-T, lindane) * Processes involving aromatic organochlorines * Processes involving aliphatic organochlorines * Production, use and incineration of PCBs * Chlorine-based pulp bleaching processes * Magnesium smelting * Nickel smelting * Scrap metal smelting * Steel smelting * Copper wire recycling * Dry cleaning processes using perchloroethylene ---------------------------------------------------------- -------------------------------------------- THE MYTH THAT CHEMICAL-BY-CHEMICAL PROOF OF HARM IS "GOOD SCIENCE" Chlorophiles claim that phasing out chlorine-based chemicals as a class is unwarranted since only individual "bad actor" compounds may pose a problem (if any exists). CanTox Consultants, working for the U.S. Chlorine Institute, have presented four so-called "scientific principles", asserting this position: 1. It is unscientific to regulate organochlorines as a class because each compound has specific chemical and biological behavior. 2. Each chemical has a no-effect threshold. 3. Organisms can accommodate and detoxify low doses of toxic chemicals. 4. Causal linkages between individual chemicals and health effects must be plausible and specifically proven for each compound. [9] -------------------------------------------- Responding to each of the four CanTox "principles," Dr. David Ozonoff, Environmental Health Department chairperson at the Boston University School of Public Health, has summarized: "Even on cursory examination, we can see that these so-called principles are either empty of meaning or amount only to assertions, not principles." [10] 1. While it is obvious that each chemical is different, there are several good reasons -- that are more relevant to preventive environmental and public health policy -- for treating organochlorine poisons as a class. First, this class of chemicals tends to be persistent, toxic, and/or bioaccumulative. "This is not a generally benign set of compounds with a few bad actors, but a problematic group, from the public health point of view," according to Ozonoff. Second, most of the thousands of chlorinated chemicals in commerce have not been adequately tested. Since we know that there is a high probability that untested members of this class will turn out to pose a hazard to public health, there is good scientific reason to consider organochlorines harmful until proven safe. On this basis, the American Public Health Association has recommended that this class of compounds be phased out, with individual exceptions to be made upon proof of safety. [11] Third, organochlorines are produced in complex mixtures in virtually all processes that involve chlorine. Preventing the production of chlorine and its use in processes that create organochlorines is more effective than trying to control each chemical individually. 2. The CanTox assertion of a "no-effect" threshold is simply incorrect. It is generally accepted by the scientific community that there is no determinable threshold for carcinogens. Biological mechanisms like normal cell division amplify genetic damage. This is also a factor with birth defects, immune system damage and nervous system effects. During sensitive periods of development, tiny exposures to organochlorines can cause hormonal disruptions that trigger a cascade of biological effects. Scientists working on USEPA's dioxin reassessment have recently concluded that there does not appear to be any safe dose for dioxin. [12] Even if individual chemicals did have a threshold, the cumulative exposure to hundreds of compounds -- each below its "safe" level -- can combine to cause an effect. Thus, the existence of thresholds has little practical value for preventive environmental regulations or health protection. 3. Another assertion of doubtful validity is the claim that organisms can safely accommodate and detoxify toxic chemicals. "While we do indeed have detoxifying mechanisms, we also know that often it is these very mechanisms which are the root of the trouble, as when a detoxifying mechanism actually changes a non-carcinogen to a carcinogen," according to Ozonoff. Further, the body has no known method for effectively detoxifying dioxin. 4. Requiring proof that an individual chemical has harmed human health before preventive action can be taken is unscientific, unethical and contrary to the principles of public health, such as the primacy of disease prevention. Since we are exposed to thousands of toxins that cause additive or multiplicative effects on human health, there is no way for epidemiologists to trace health effects back to an individual chemical. The link between organochlorines and widespread harm is highly plausible, since these chemicals are known to cause a wide range of health effects in both animals and humans, including genetic mutations, hormonal disruptions, metabolic changes, cancer, birth defects, developmental abnormalities, behavioural dysfunction, and immune suppression. ------------------------ THE MYTH THAT CHLORINE-BASED BLEACHING IS "SAFE" Paper industry officials claim that wastewater from pulp mills bleaching without chlorine is as toxic to fish as pollution from mills that use chlorine, based on a Canadian studies which used elevated levels of a fish liver enzyme (EROD) as an indicator of toxicity. Chlorophiles use these studies to claim that the toxic effects of pulp mill effluent on fish are not caused by organochlorine discharges (some postulate instead a mystery substance, Chemical X, as the culprit) and that efforts to eliminate chlorine from pulp mills is misdirected. ------------------------ It is well known that organochlorines are not the only toxic compounds in pulp mill effluent, but that fact in no way minimizes the hazards of organochlorines. In fact, the Canadian researchers acknowledge that damage to fish and other aquatic species is most severe from mills using large amounts of chlorine and less severe when chlorine is reduced, while the Swedish Environment/Cellulose Project makes very clear that damage is least severe when no chlorine is used at all. [13] The Canadian data in no way alleviates the need to phase- out all chlorine use in the paper industry for several reasons. First, ecological concern surrounding chlorine-based bleaching in pulp mills is based a large body of scientific evidence linking the resulting organochlorine pollution and reproductive, developmental, immunological, and hormonal toxicity in wildlife and humans. The Canadian study does not address these effects and, hence, in no way undermines the need to prevent organochlorine formation by eliminating chlorine-based bleaching. Second, the EROD fish liver enzyme is a highly variable indicator of ecological effects that responds to many factors other than chemical stimuli, i.e., changes in water temperature or the reproductive condition of a fish. [14] Using EROD comparisons to draw sweeping conclusions about chemical toxicity are indefensible in the absence of controls on all other EROD-related factors. Third, in some of the experiments, researchers manipulated pulp mill effluents to remove the most toxic chemicals (low molecular weight portion), testing instead with the less toxic (high molecular weight portion) of mill effluents. Over time in the environment, however, these large molecules are transformed into more toxic, lower-weight molecules. Using the least toxic fraction of organochlorine effluents as a basis to conclude that the entire effluent is non-toxic is clearly indefensible. Finally and most significantly, the Canadian data confirms that pulp mills generate toxic effluents, including organochlorines, that can only be eliminated by designing mills that discharge no effluent. Eliminating chlorine -- which is highly corrosive to piping -- is a necessary first step toward "closed-loop" pulp mill technology. -------------------- THE MYTH OF PVC Chlorophiles claim that PVC (polyvinyl chloride) conserves energy and resources and is recyclable. They claim that PVC does not increase dioxin emissions from municipal waste incinerators and PVC fires do not generate more dioxins than wood or fuel fire residues. - ------------------- One-third of the world's total production of chlorine is used to make PVC. PVC is composed of ethylene, a non-renewable petroleum derivative, and up to 60 percent chlorine. PVC products serve an important function for the chemical industry; they act as a "sink" for dumping the excess chlorine that results from the electrolytic production of caustic soda from salt. Both chlorine and ethylene production are extremely energy intensive. For instance, chlorine production alone accounts for one quarter of all the energy consumed by the German chemical industry (or two percent of the total national energy demand). Energy costs make up as much as 75 percent of the fixed costs of producing chlorine. [15] Thousands of toxic and energy intensive additives are also required to render PVC pliable, stable, or resistant to degradation. PVC is harmful to the environment during its production and use, in cases of fires, and because numerous toxic additives are used to give PVC specific physical properties. [16] A recent study by the Tellus Institute concluded that the environmental impacts associated with the PVC lifecycle are more severe than those associated with any other packaging material. [17] Other lifecycle analyses recommend alternatives to many PVC applications including such as window frames, floorings, cable/wire coverings, cars and furniture. Only by ignoring organochlorine emissions in PVC production, toxic additives in PVC products, and pollution from PVC disposal can PVC appear "environmentally friendly." Only a tiny fraction of the total PVC waste stream is recycled into material for the same original use. Chemical additives found in the wide range PVC products complicates PVC recycling schemes. Many so-called recycling schemes are more aptly termed "down-cycling," since the resulting material can only used for low-grade applications. Plastics recyclers are increasingly opposing PVC packaging since it is easily mistaken for other plastics and contaminates existing recycling operations. Burning PVC causes large emissions of dioxins, furans, and many other organochlorine compounds. According to the USEPA, "The formation of dioxins is generally understood to occur as a result of burning organic material with chlorine- containing material." [18] Testing data from numerous accidental fires in Europe and North America confirm that PVC fires result in dioxin contamination and release large amounts of highly corrosive hydrochloric acid. In response to all of the hazards associated with PVC, over 150 European communities have declared PVC-free building policies. The German Federal Office of the Environment is recommending substitution of PVC in all areas susceptible to fires because of the hazards. [19] Alternatives for virtually all uses of PVC are presently available. [20] Traditional materials which are renewable, reusable, recyclable and less energy intensive, such as sustainably harvested wood, glass, paper, ceramics and metal are often the best alternatives. In some cases, eliminating uses altogether is the most environmentally sound option. ------------------ * Background materials for this article were originally compiled by T. Belazzi with extensive input by R. Stringer, P. Johnston, W. van der Naald, J. Thornton, M. Knapp, M. Floegel, M. Besieux and M. Krautter. --------------------- NOTES: 1. "Chlorophile" designates one with a vested interest in chlorine's continued production and widespread use. 2. "Evaluacion Del Rol de la chloraciondel agua de bebida en la propagacion y control de la epidemia de colera en Peru," written by OACA (Oficina de Assesoria y Consultoria Ambiental), DIGESA (Direccion General de Salud Ambiental) and the Peruvian University Cayetano Heredia. 3. Rice, E.W. et al., "Chlorine and survival of 'rugose' Vibrio cholerae" (letter). The Lancet, No. 8821, Vol. 340, Sept 19, 1992, p.740. 4. Lovelock, J., "Natural Halocarbons in the air and in the sea." Nature 256:193-4, July 1975. 5. Simmonds, P.G., et al., Atmos. Environ. 27A(9), 1397-1407, 1993. 6. See Vallentyne, J., "Testimony and submission before the Alberta-Pacific Environmental Impact Assessment Review Board. Edmonton, Alberta. December 1, 1989." Reprinted by Greenpeace as "The Case for Phasing Out Organohalogens". See also International Joint Commission, Science Advisory Board Report. Windsor, Ontario, 1989. 7. Schechter, A., "Dioxins in humans and the environment." Biological basis for Risk Assessment of Dioxins and Related Compounds. Banbury Report 35:169-212, 1992. 8. See Harrad, S.J. and Jones, K.C., "Dioxins at large." Chemistry in Britain, Dec. 1992: 1110-1112. See also Travis, C.C. and Hattemer-Frey, H.A., "Human exposure to dioxin." Sci. Tot. Environ. 104: 97-127. 9. CanTox Inc., "Scientific Principles for Evaluating the Potential for Adverse Effects from Chlorinated Organic Chemicals in the Environment." May 7, 1993. 10. All quotations in this section are from Ozonoff, D., "Taking the Handle off the Chlorine Pump." Remarks at the Public Health Forum, Boston University School of Public Health. October 5, 1993. Reprinted by Greenpeace. 11. "Recognizing and Addressing the Environmental and Occupational Health Problems Posed by Chlorinated Organic Chemicals." American Public Health Association, October 1993. 12. Portier, et al., Fund. and Applied Toxicology 20:48-56. 13. See Carey, J. et al. (unpublished). "Recent Canadian Studies of the Physiological Effects of Pulp Mill Effluent on Fish." Canada Centre for Inland Waters, P.O.Box 5050, 867 Lakeshore Rd., Burlington, Ont. L7R 4A6. See also Sodergren, A., et al. Bleached Pulp Mill Effluents: Composition, fate and effects in the Baltic Sea. Swedish Environmental Protection Agency Report #4047, pp.54-57. 14. Jiminez, B.D., et al., "Hepatic Enzymes as Biomarkers: Interpreting the effects of Environmental, Physiological and Toxicological Variables," in McCarthy, J.F et al., Biomarkers of Environmental Contamination. Lewis Publishers, pp.123-142, 1990. 15. Household and Personal Products Industry. February 1993 p.22. 16. Federal Office of the Environment, Germany, "Environmental Damage by PVC -- An Overview," Berlin, June 1992. Translation available from Greenpeace. 17. Ackerman, F., et al., The Tellus Institute Packaging Study. Boston: The Tellus Institute, 1992. 18. National Dioxin Survey: Tier 4: Combustion Sources. U.S. Environmental Protection Agency, 1986. 19. Impacts on the Environment from the Manufacture, Use, Disposal and Substitution of PVC. German Federal/State Commission on Environmental Chemicals. Duesseldorf, Sept. 1992. Translation available from Greenpeace. 20. See Alternatives to PVC Products (selected chapters from "PVC Phase-Outs by Local Communities," Greenpeace Austria, 1992. Translation available from Greenpeace. END