TL: PVC: AN ENVIRONMENTAL POISON SO: Greenpeace Australia DT: 1995 PVC AN ENVIRONMENTAL POISON The Chlorine Plastic ALTERNATIVES ACTION PAPER Page 1.0 EXECUTIVE SUMMARY.......................................................................... 3 3c industry 1.1 Brief outline of industry............................................................................. 4 1.2 PVC production 1.3 PVC disposal 1.4 PVC recycling 1.5 PVC disadvantages 2.0 Environmental impacts of PVC alternatives 2.1 Polyethylene / Polypropylene (PE / PP) 2.2 Polystyrene (PS) 2.3 Polyethylene Terephthalate (PET) 2.4 Polyurethane (PUR) 2.5 Aluminium 2.6 Synthetic rubbers 2.7 Vacuum impregnated and surface treated wood 3.0 Recommended alternative materials 4.0 Strategy to replace PVC 4.1 Plumbing / drainage 4.2 Electrical / electronics 4.3 Building / construction 4.4 Packaging 5.0 Impediments and resistances to the use of alternatives 5.1 Economic impediments 5.2 Building industry conservatism 5.3 Lack of information 6.0 Environment protection authority: industry regulations 7.0 PVC industry arguments 7.1 PVC properties 7.2 Energy 7.3 Occupational Health 7.4 Organochlorines 7.5 Accidents 7.6 Dioxins 7.7 Hydrochloric acid 7.8 Additives/Migration 7.9 Leachates 8.0 Recycling 8.0 Recommended actions 1.0 Executive Summary This Action Paper argues for the elimination of the chlorinated plastic, Polyvinyl Chloride (PVC), from the construction and conduct of the Sydney 2000 Olympic Games in response to the Environmental Guidelines, which proposed 'minimising and ideally avoiding the use of chlorine based products (organochlorines) such as PCB, PVC and chlorinated bleached paper.' The Paper urges the adoption of environmentally appropriate criteria for building material selection and their incorporation into the core of the design process. Full life cycle analysis and costing for construction materials and products and whole building projects, must be integrated into public and private corporate values. The 2000 Olympics present a golden opportunity to raise the environmental standards of the construction industry nationally and internationally. This Paper identifies the main disadvantages of PVC as follows: * environmental, health and occupational impacts due to persistent pollution during production of chlorine, EDC, VCM, PVC and its additives * subsidised electricity prices paid by the chlor-alkali industry * public health and environmental impacts from accidental fires and additional firefighting equipment costs and damages to public and private property. Smouldering PVC liberates deadly hydrochloric acid/dioxins which also damages property and equipment * environmental and health impacts from leachates and additives migration * cost of incinerator upgradings and maintenance * environmental and health impacts from incineration emissions and slag/ash waste disposal * cost of landfill space for this non-biodegradable product * cost of providing recycling services * PVC is a subsidised product where corporate private costs are externalised or dumped onto society. Incorporating this full cost, would cause PVC to lose its cost effectiveness. 1.1 Summary of Environmental Impacts of PVC Alternatives: Polyethylene/polypropylene (PE/PP) PE / PP are more environmentally appropriate plastics than PVC in terms of their: * reduced production of emissions * fewer problematic additives * reduced leaching potential * reduced potential for dioxin formation during combustion, due to the lack of chlorine and provided brominated / chlorinated flame retardants are excluded reduced technical problems / economic costs during recycling phase. Polystyrene (PS) As PS has no chlorine content and far less additives than PVC, and provided brominated / chlorinated flame retardants are excluded, it is environmentally a better plastic than PVC. Polyethylene terephalate (PET) As PET has no chlorine content and less additives than PVC, and provided brominated / chlorinated flame retardants are excluded, it is environmentally a better plastic than PVC. Polyurethane (PUR) The use of isocyanates in the manufacture of polyurethane result in considerable disadvantages in the work environment compared with PVC. When using PUR, environmental improvements will be obtained in waste management due to the absence of heavy metals and chlorine. However, those advantages are not sufficient to make it a better alternative. The available evidence indicates, that PUR can not be recommended as an environmentally acceptable PVC alternative. Aluminium Aluminium recycling is a highly developed industry and energy requirements are much lower than primary production. However, the recycling of aluminium used in the building industry, is negligible compared to the very high rates of aluminium can recycling. A Danish EPA report gave no endorsement to aluminium over PVC, claiming it was not possible to unequivocally rank one material before the other. Synthetic rubber alternatives Ethylene4 Propylene Diene (EPDM) is recommended by the Danish EPA as a PVC alternative. Polychloroprene (CR) and Styrene Butadine (SBR) are not recommended as PVC alternatives. Vacuum impregnated and surface treated woods Impregnated and surface treated wood, is assessed to have environmental advantages compared to PVC. However, there are major impacts associated with emissions if organotin compounds are used. There are currently, substitutes available for many PVC applications which are environmentally superior, with satisfactory performance standards. Industrial capital equipment costs required to switch from PVC to alternative materials, is relatively small compared to overall production costs. Manufacturers would readily move to substitute materials is they perceived a market for PVC alternatives. This demand could be created by internalising the currently externalised environmental costs of PVC. A strategy to replace PVC is outlined, concentrating on three market sectors, plumbing/drainage, electrical/electronics and building/construction, which account for over 80% of all PVC end-users. Figure 1 Problems of PVC at a Glance PRODUCTION Toxic Wastes of EDC / VCM Occupational Hazards Toxic Additives Accidental Spills / Leaks / Explosions Massive Energy Requirements / Greenhouse Gases TRANSPORTATION Accidental Spills / Leaks / Explosions USEAGE Toxic Outgassing/Sick Building Syndrome VCM / Dioxin Residues Accidental Fires (Hydrochloric Acid / Dioxins Additives Migration DISPOSAL Accidental Landfill Fires (Hydrochloric Acid / Dioxins) Incineration (Hydrochloric Acid / Dioxins / Heavy Metals) Landfill (Leachates) RECYCLING Need for Virgin PVC Additives Removal Problem Potential toxic by products (down cycling) Uneconomic Nature of Process 1.1 Brief outline of the PVC industry In 1912 a German patent was taken out for VCM made from acetylene and hydrochloric acid. Polymerisation of VCM was also developed. Commercial PVC production began in the 1930s and during the war many applications were discovered. Ethylene replaced acetylene and production boomed in the post-war era. Concurrent with these developments, the chlorine industry began commercial production early this century. During the First World War it was used as a poison gas. The production of chlorine and caustic soda, through the electrolysis of brine, is of central importance to the chemical industry. 60% of the world's chemical industry still uses chlor-alkali products, either directly or indirectly. 1 As chlorine production expanded rapidly during the post-war era, markets had to be found by the chemical industry. Globally, 40 million tonnes of chlorine are now produced annually and 50% is used to make plastics. Of this 20 million tonnes, 68% is used to make PVC, 22% to make Polyurethane (PUR) and 10% for other plastics. 2 PVC is thus the largest single use or 'sink' for global chlorine production. As various chlorine derivatives - chlorinated fluorocarbons (CFCs), chlorinated hydrocarbons (CHCs) and chlorine based bleaches have been assessed environmentally harmful and have been phased out, the market for chlorine has stabilised. The industry now promotes PVC as an "environmentally compatible application for chlorine." 3 PVC production in Australia began in 1950. It is currently produced by two transnational petrochemical corporations, ICI Australia Ltd at Laverton North, Victoria and Botany, New South Wales, and Auseon Limited at Altona, Victoria. ICI Botany currently operates Australia's only VCM plant, supplying feedstock to their PVC plant. Both ICI Laverton North and Auseon at Altona import VCM from North America. The VCM is transported by road, from the port facilities at Geelong, to these plants in western Melbourne. ICI currently produces 60,000 tonnes of PVC per annum at its Laverton North plant and 55,000 tonnes at its Botany plant. Auseon produces 65,000 tonnes at its Altona plant. Total Australian PVC production is therefore, approximately 180,000 tonnes per annum. PVC production is planned to increase to 240,000 tonnes with the completion of the new $43 million ICI plant at Laverton North in late 1996. (The existing Botany plant will then be closed). ICI will then produce 140,000 tonnes with Auseon producing 100,000 tonnes. The industry will require strong domestic growth and a massive export drive to market this production level. There is a probability of a post -1996 overcapacity of PVC production within Australia, as vast new Asian and Latin American plants come on-line (see Table 3) The Australian plastics industry includes over 3000 plastic product makers. The industry has a gross economic turnover exceeding $7 billion, employs over 61000 people, pays $0.8 billion in gross wages and salaries. 4 In 1992, 985,200 tonnes of plastic polymer resin was consumed in Australia, 280,300 tonnes was imported and 143,000 tonnes was exported. TABLE 2 Australian Polymer Consumption by Main Resin Type ('000 Tonnes) Tonnes Per Cent Tonnes Per Cent PVC 191.5 19.5 172.9 17.5 PP 111.0 11.3 135.5 13.7 HDPE 132.0 13.4 133.5 13.5 LDPE 159.0 16.2 116.0 11.8 PS 41.5 4.2 48.6 4.8 PU 49.3 5.0 40.7 4.1 Others 296.8 30.2 338.0 34.3 TOTALPolymer 981.1 100.0 985.2 100.0 Source: Plastics Institute of Australia In recent years, growth in the domestic consumption of plastic resins has stagnated (see Table 2). Domestic PVC resin consumption actually declined by almost 10% between 1988 and 1992. PVC accounted for 17.5% of all plastic resin consumption in Australia in 1992. This proportion has declined from 19.5% in 1988. Imports of PVC have also declined from 43,400 tonnes in 1989 to 12,000 tonnes in 1992 due to reduced demand and a successful anti-dumping action taken by local producers. In contrast the export of plastic products has increased rapidly in recent years, growing at an average annual rate of 32% from 1989 to 1993. 5 The plastic industry is a key sector of modern industrial economies, virtually all other manufacturing industries are downstream users of plastic products. Plastics have gained this central role in the last few decades, replacing alternative materials, mainly through cost effectiveness, often defined by ignoring negative externalities. The momentum of this process allows the plastics industry to claim that new developments in such areas as aerospace, telecommunications, computer technology and surgery, would not have been possible without plastics. There is scarce research information available concerning the displacement of employment (within industries supplying pre-plastic / traditional / alternative materials), due to the impact of the plastics revolution. The plastics industry is highly capital intensive with relatively low labour input. It could be assumed that the net effect has been to increase manufacturing sector unemployment. TABLE 4 Planned Vinyl Chloride Monomer (VCM) and Polyvinyl Chloride (PVC) Projects in Southeast Asia ('000 Tonnes) Country Amount China 440 PVC 220 VCM Indonesia 162 PVC 100 VCM Japan 300 VCM Malaysia 100 PVC 400 VCM Philippines 60 PVC Korea 160 PVC Taiwan 360 PVC 360 VCM Thailand 160 PVC 540 VCM Vietnam 92 PVC Others 77 PVC TOTAL 1,600 PVC 1,920 VCM Source: Asian Chemical News, volume 1 1.2 PVC production The raw materials of PVC are naphtha or natural gas liquids, salt, water and electrical power (see Diagram 3). Briefly, the production process is as follows: * Gas is made into ethylene * Salt is decomposed into chlorine and caustic soda by electrolysis * Caustic soda is used extensively in the production of aluminium / alternatives are currently available * Ethylene is combined with chlorine to produce ethylene dichloride (EDC) * EDC is processed into vinyl chloride monomer (VCM) * VCM is polymerised into PVC * PVC (57% chlorine / 43% hydrocarbons) * Additives give PVC a wide range of desired qualities (up to 50% of flexible PVC can be comprised of additives) DIAGRAM 3 PRODUCTION OF PVC - A COCKTAIL OF ENVIRONMENTAL POISONS 1.3 PVC disposal PVC in Australia is mostly disposed of in landfills. In other industrialised nations the trend is increasingly towards incineration as landfill space declines. PVC's durability and non-biodegradability is claimed by the industry to ensure stability of landfills. Thus landfill sites are often sealed within PVC membranes, in the belief that this prevents leakage. There is scarce research information available on the processes occurring in landfills. It is probable that corrosive liquids in the landfills will interact with PVC to liberate additives, especially plasticisers, which will leach into the groundwater.6 Groundwater and riverwater pollution are legacies of both industrial emissions and landfilled industrial and domestic wastes. A 1993 CSIRO report identified a major 'contaminant front' composed of a cocktail of different chemicals, including heavy metals such as cadmium and lead moving towards Port Phillip Bay, Victoria. This toxic plume originated in Melbourne's industrialised western suburbs and it was estimated to have the potential to contribute 4,000 tonnes of toxicant per year to the bay. 7 Additional toxic plumes with high chloirnated content have also been identified as resulting from previous chlorine industrial activities at the Dow Chemicals plant and Auseon's PVC plant at Altona. The ICI Botany Plant in Sydney a major producer chlorine and other chlorinated compounds, was found to contribute high levels of hexachlorobenzene (HCB) and chlorinated hydrocarbons (CHC) and mercury to Botany Bay. In a 1990 study mercury was detected in all biota samples, 7 out of 13 species tested exceeded the recommended NH&MRC guidelines of 0.5 mg/kg for shellfish for human consumption. The report also found that contamination was entering the marine environment through the discharge of contaminated groundwater. 8 These contamination problems will potentialy cost millions of dollars to rectify and clean up. Victoria's current policy of failing to separate domestic sewerage and toxic industrial waste, leads to serious environmental pollution of Port Phillip Bay. NSW has similar waste disposal policies and similar impacts occuring particulary in the marine environment. Highly toxic wastes associated with the production of PVC contaminate both industrial landfills and otherwise agriculturally useful domestic sewerage sludge. In Sydney massive reserves of (otherwise valuable) groundwater have been found to be polluted from industrial contamination and toxic landfills. Although PVC currently constitutes a small proportion of the total waste stream (0.7% EC average), 9 this amount will increase as the longer life PVC, used in the building industry, is replaced. Much of this older PVC contains cadmium and lead, additives which are now banned, but are still common in imported PVC. These additives can also be expected to ultimatly leach into the environment. As available landfill space declines, new landfill proposals are often in environmentally sensitive areas - such as the Hawkesbury / Nepean drainage system of Sydney's western suburbs. With these new developments there is an increasing risk of toxic leachates polluting ground and river water. Landfill disposal is a primitive technological solution. Into a hole goes a cocktail of chemicals, leaching is determined by variables like temperature, rainfall, soil type and the exact waste composition. Accidental fires are another hazard. Landfilling PVC is clearly not a satisfactory disposal solution. Incineration is an industrial combustion process designed to reduce unwanted materials to simple solid and gaseous residues. The primary goal is the total destruction of unwanted materials. High temperature incineration of wastes releases toxic chemicals to the environment via stack emissions of pollutant vapours and particles, fugitive emissions of unburned wastes, and discharge or disposal of combustion residue. In some cases these pollutants are more dangerous than the original wastes. Australia has a range of incinerators operating for the disposal of chlorinated industrial wastes, many of these have substantial emissions of hazardous and toxic substances. Australian industry still relies heavily on problematic incinerator technology. In 1992 Greenpeace commissioned stack testing of three Australian incinerators. Independent analysis recorded dioxin emission levels at least 20 times higher than recommended German standards. The Command Ltd. medical waste incinerator in Victoria had an average dioxin emission level some 200 times in excess of this standard (see Table 5). Table 5 Emissions for select Australia Incinerators German Emission Standards Mean Stack test TEQ Max Stack Test TEQ Number of samples n HARPERS LTD Dioxin 0.1 ng/m3 2.98 ng/m3 2.98 ng/mg 110 Mercury 0.05 mg/m3 0.9 mg/m3 1.2 mg/m3 211 Lead 0.05 mg/m3 3.9 mg/m3 6.6 mg/m3 2 COMMAND LTD Dioxin 0.1 ng/m3 20.91 ng/m3 75.93 ng/m3 312 Mercury 0.05 mg/m3 4.476 mg/m3 23.0 mg/m3 613 Lead 0.05 mg/m3 7.4 mg/m3 38.0 mg/m3 6 WAVERLY WOOLLAHRA Dixoin 0.1 ng/m3 2.56 ng/m3 3.83 ng/m3 214 PVC has been reported as being the largest single source of chlorine in hospital waste (medical waste) incinerators. Several reports have found a direct relationship between the amount of PVC in waste fed into an incinerator and the amount of dioxin emitted. Several reports have found a direct relationship between the amount of PVC in waste fed into an incinerator and the amount of dioxin emitted.15 Reducing or eliminating PVC feed has been found to result in significant decreases in dioxin emissions.16 In Australia there is only one municipal waste incinerator in Waterloo, Sydney. It is planned to spend $44 million of public money to upgrade this to incorporate dry alkaline scrubbers, combined with either fabric filters or electrostatic precipitators, to reduce emissions by a factor of ten. 17 It is claimed these technological improvements would reduce dioxin emissions from 35.7ng (1989) to below 0.1ng/m3 , thus meeting the German environmental standard. However, it is unlikely that even with these improvements, that in operation, the incinerator will perform to these standards. Even at the reduced level, continued emissions in such a densely populated residential area are unsatisfactory. As Australian companies seem to be aiming to export an increasing amount of PVC, the waste disposal practises of other nations becomes a valid environmental concern. Dioxins and other products of incomplete combustion formed during incineration, are transported through the air streams around the world. In Europe, the technology of incineration is improving and flue gas cleansing systems will aim to achieve the 0.1ng/m3 standard by 1997. Whilst the industry now claims incinerators are 'dioxin sinks', the reality of waste disposal of increasingly toxic slag and flue gas residues is ignored as are the range of other products produced during incineration. Wastes such as bottom ash, filter ash and acid gas residues, are ultimately landfilled with all the potential for leachate problems. It could be assumed that landfill and incineration practises in the developing world fall far short of European and OECD environmental standards. However, even with the best incineration technology, real world conditions will often reduce these emission standards. Incinerators and landfills are the 'dirty end' of industry. Disposal of waste, either from industrial process, or at the end of a product's life cycle, are crucial to the maintenance of dirty production processes and poor consumer habits. Australia's waste disposal system is monitored and perpetuated by regulatory authorities which abdicate their responsibilities, often turning a blind eye to the resulting environmental impacts, 'just as long as the job gets done.' 1.4 PVC Recycling As PVC is a thermoplastic, recycling is technically possible. However, post-consumer, or real recycling, is extremely limited due to the vast range of additives, which give the plastic such a wide range of applications. It is difficult to sort the toxic chemical cocktail waste product resulting from various combinations of over 4,000 additives. PVC can not be compared to glass for example, where the only sorting is on the basis of colour. The 'chlorine circle' concept, where PVC is incinerated to produce hydrochloric acid and salt, breaks down due to the contamination of the waste salt with additives. Purifying this salt would be economically prohibitive, costing more than virgin PVC. Reflecting these technical and economic problems PVC is currently collected by only 18% of local councils. It generates an average price of $178 per tonne as compared to $494 per tonne for PET. 18 There is also a lack of markets for recycled PVC products, only clear PVC bottles and containers have been recycled to any extent. Unless the proportion of virgin PVC is very high, the process becomes, in reality 'down cycling' into a small range of relatively useless and potentially toxic products. In 1991 ICI developed Revinyl 30 for use in non-food grade bottles and flooring, pipes, fittings and general extrusions. This product is 30% recycled and 70% virgin PVC. In 1993 Cryogrind Australia, on behalf of Auseon, also began recycling clear PVC containers into stormwater pipes. Only 20% of this product is post-consumer resin. It is apparently encountering market resistance. Auseon also makes flooring tiles and moulded fittings. Cryogrind's 300 tonnes per annum constitutes a major proportion of the total PVC recycled in Australia. In 1992 only 0.2% of PVC was recycled. Even in the packaging sector, PVC recycling only reached 6% for juice and cordial bottles in 1993. 19 As part of the Australian and New Zealand Environmental and Conservation Council ( ANZECC ) target of achieving a 50% landfill waste reduction by the Year 2000, the National Plastics Recycling Plan has set a 1995 PVC target of 15% recycling of juice and cordial bottles. No target has been set for non-packaging PVC. It is likely that non-packaging PVC recycling will continue at very low rates. To reach the ANZECC target, poor recycling performers, such as PVC, should be phased out. 1.5 PVC Disadvantages The main disadvantages of PVC as a building material are as follows: Externalities The primary reason PVC has displaced alternatives over the last few decades is because the market price fails to incorporate negative environmental, health and economic externalities which include: Environmental, health and occupational impacts due to persistent pollution during production of chlorine, EDC, VCM, PVC and its additives Subsidised electricity prices paid by the chlor-alkali industry Public health and environmental impacts from accidental fires and additional firefighting equipment costs and damages to public and private property Environmental and health impacts from leachates and additives migration Cost of incinerator upgradings and maintenance Environmental and health impacts from incineration emissions and slag/ash waste disposal Cost of landfill space for this non-biodegradable product Cost of providing recycling services PVC is a subsidised product where corporate private costs are externalised or dumped onto society. Incorporating this full cost, would cause PVC to lose its cost effectiveness Durability Problems Over the longer term there have been durability problems in some applications, PVC's UV resistance has not been up to acceptable standards Particularly in harsh Australian conditions, brittleness, discolouration and breakages have resulted from external uses Smouldering Potential In accidental fires PVC smoulders, liberating deadly hydrochloric acid/dioxins which also damage property and equipment 2.0 Environmental Impacts of PVC alternatives 2.1 Polyethylene / polypropylene ( PE / PP ) The polyolefins, polyethylene (PE) and polypropylene (PP), are polymerised olefines (hydrocarbons with a carbon-carbon double bond). They are made from the alkenes, ethylene and propylene. PE and PP, together with polystyrene (PS) are the most obvious PVC alternatives. 20 Differences in the polymerisation process result in the different types of PE - Low Density Polyethylene (LDPE), Linear LDPE (LLDPE), Medium Density PE (MDPE), and High Density PE (HDPE). In its various forms, PE is the most common plastic in the world. There is high public awareness of PE as it dominates the food packaging sector and kerbside recycling services (for HDPE) are reasonably well developed. Building materials made from PE are tough, flexible, water impermeable, and have good chemical resistance. They do suffer from low tensile strength and have poor weathering qualities. 21 They are used mainly as moisture barriers, dampcourses, pipes and electrical insulation. In the building sector, PP is used in pipe fittings and is highly resistant to acids, alkalis and other destructive agents. PP produces excellent pipe joint weldings. The main environmental problems of PE / PP include: * Ethylene and propylene are highly flammable / explosive raw materials. * Compared to PVC, PE / PP production involves less occupational and environmental impacts. However, PE / PP process workers have reported a range of illnesses from nasal irritation, headaches, skin irritation, nausea, to colorectal cancer and 'meat wrappers asthma.'22 * PE / PP contains a range of additives - UV and heat stabilisers, anti-oxidants, anti-blocking agents, colorants, blowing agents and fillers. Flame retardants are also used as these plastics are highly flammable. * Flame retardant content can reach 40% and PE / PP can contain both brominated and chlorinated flame retardants, which are capable of giving off dioxins. * Heavy metals, such as lead powders, are used as fillers in PE / PP. Leaching of these additives in landfills is a potential problem. * When PE / PP is thermally degraded various volatile compounds are generated. 44 different organic compounds from PE have been identified. 23 Two of these compounds, formaldehyde and acetaldehyde, are listed as carcinogenic by the Danish Labour Inspection Service. * As PE / PP is highly flammable, during combustion carbon monoxide, carbon dioxide and polycyclic aromatic hydrocarbons are given off. If flame retardants are present - highly corrosive acids are formed, but in smaller amounts than PVC. Recycling rates for milk bottles (HDPE) reached 31% in 1993. HDPE can be recycled into pipes, toys, traffic barrier cones, crates, garbage cans and signs. Government interventions, such as the South Australian Container Deposit Legislation / recycling program, have created a pro-recycling environment in which firms such as Riblock Australia have developed high quality, innovative and cost competitive applications for recycled HDPE. The 1992 LDPE recycling rate was only 0.6% and the PP rate was 0.2%. 24 However, with less additives than PVC, recycling is more economically feasible. Recycled uses include agricultural and building film, pipes, crates, drainage channels, septic tanks, grease traps, compost bins and drinking troughs. PE / PP are more environmentally appropriate plastics than PVC in terms of their: * reduced production of emissions * fewer problematic additives * reduced leaching potential * reduced potential for dioxin formation during combustion, due to the lack of chlorine and provided brominated / chlorinated flame retardants are excluded * reduced technical problems / economic costs during recycling phase 2.2 Polystyrene (PS) As a building material PS is widely used for foamed insulation. It is also hard, rigid and transparent and brittle, with low heat resistance. Its weathering performance is poor. 25 Different polymerisation processes result in different PS grades: * general purpose (crystal) - clear and brittle * high impact polystyrene (HIPS) - copolymer added (polybutactine) gives extra strength * expandable polystyrene bead (EPS) - blowing agent added for insulation / impact resistance Raw materials used in the production of PS include: * benzene * ethylbenzene * styrene * butadiene Additives used in PS include: * UV stabilisers * anti-oxidants * flame retardants * anti-static agents * plasticisers - including DEHP / DEHA * fillers In the production of PS the main occupational / environmental impacts include: * air emissions of styrene have been recorded near plants and in ground/river water * IARC (1987) assessed styrene as carcinogenic in animals, with insufficient evidence for human carcinogenic effect 26 * butadiene has been assessed as carcinogenic by the Danish Labour Inspection Service * environmentally - styrene, benzene and ethylbenzene are of low ecotoxicity and they are not bioaccumulative * brominated / chlorinated compounds are used as flame retardants in PS foam * foam blowing agents may also contain ozone destroying CFC's * Combustion of PS will liberate the following compounds: * styrene monomer * ethylbenzene * benzene * acetylene * carbon monoxide * carbon dioxide * presence of flame retardants results in hydrogen chloride and dioxins - only 0.1% of PS has such flame retardants 27 According to the Danish Labour Inspection Service, carcinogenic styrene oxide, is emitted during thermal decomposition. Landfilling low density EPS consumes a lot of space. Waste disposal problems for PS, have led to U.S. restrictions as a food packaging material in states like Oregon. The problem of PS additives leaching is largely unresearched and unknown. Although technically it can be recycled, Australian PS recycling rates are poor - only 1.4% in 1992. (19) Research is currently trying to convert PS into protein for animal foodstuffs and ultimately, human consumption. Stabilisers, plasticisers and flame retardants could prove to be a meal-time problem. EPS can potentially be re-compacted back into PS. As PS has no chlorine content and far less additives than PVC, and provided brominated / chlorinated flame retardants are excluded, it is environmentally a better plastic than PVC. 2.3 Polyethylene terephthalate (PET) PET is a thermoplastic polymer made from ethylene glycol and terephthalate. Two types of PET exist, the transparent, amorphous type (A-PET) and a whitish, crystalline type (C-PET). PET can contain the following additives: * UV stabilisers * flame retardants * pigments * anti-oxidants * anti-statics There are occupational health impacts associated with PET production. Workers handling pigments, catalysts, phthalates, nickel, hexamethylene diamine, etc. could expect to have some probability of increased cancer rates. 28 However, there is almost no information available on these PET production related impacts. Migration of additives has only been studied by one of the major PET producers, ICI, who assessed it to be of an 'acceptable' level. (21)- During combustion, carbon monoxide, carbon dioxide, hydrocarbons, additives and heavy metals will be liberated. Incineration flue gasses and slag waste will be contaminated. In landfills any additives will also leach out of PET. The PET recycling rate of 19% (1992) is the highest (resin type) rate achieved by the plastics industry. (22) Recyclate can also be 100% pure recycled PET, without the need for virgin plastic. However, the high recycling rate is due to kerbside bottle collections and almost no recycling of non-bottle PET is done. This most recyclable of plastics should also be compared with South Australian glass bottle recycling rates of 95%, with Container Deposit Legislation. (23) As PET has no chlorine content and less additives than PVC, and provided brominated / chlorinated flame retardants are excluded, it is environ- mentally a better plastic than PVC. 2.4 Polyurethane (PUR) In the production of PUR and its intermediate products 11% of total world chlorine production is consumed. (24) Common uses for PUR include insulation, furniture seating, artificial leather, tarpaulins, flexible tubings and carpet underlay. PUR is produced by a reaction with isocyanates, a polyester or polyether resin and a blowing agent. Thermoplastic polyurethane (TPUR) is formed by linking polyester / polyether, diphenylmethane diisocyanate and glycol. PUR raw materials and intermediate products include: * toulene diamines (TDA) * phosgene (produced during thermal degradation of chlorine containing materials) * propylene chlorohydrin * amines * additives * methylene chloride * CFC gases (CFC 11) * halogenated flame retardants * pigments PUR production materials have been linked to several occupational and health impacts, including heart diseases, asthma, and reduced sperm quality. (25) PUR combustion liberates the following compounds: * carbon monoxide * carbon dioxide * monomeric isocyanates * amines * toluidines * nitrogen oxides * hydrogen cyanide * propane * benzene * hydrogen chloride * dioxins Dioxins and other halogenated compounds will only be produced if halogenated flame retardants are present. PUR foam insulation can slowly thermally degrade and liberate monomeric isocyanate. While flexible PUR recycling is technically possible there is effectively no post-consumer PUR recycling in Australia. In landfills, PUR ester foams have been observed to degrade, generating leachates and CFCs. (26) Briefly, PUR's main environmental impacts result from: * isocyanates * CFC blowing agents * halogenated flame retardants * production emissions to workers * chlorine requirements of intermediate products TPUs are assessed as an environmentally better type of PUR as no CFCs and less isocyanates are used. Due to PUR's problematic production processes and additives, the Danish Environmental Protection Agency concluded that: " isocyanates result in considerable disadvantages in the work environment compared with PVC. When using PUR, environmental improvements will be obtained in waste management due to the absence of heavy metals and chlorine. However, those advantages are not sufficient to make it a better alternative." (27) The available evidence indicates, that PUR can not be recommended as an environmentally acceptable PVC alternative. 2.5 Aluminium The main raw materials for aluminium are: * bauxite * electrode carbon * natrium hydroxide * chalk Australia is the world's main exporter of bauxite. Aluminium was first produced in 1886. After World War Two, it made a great impact on the building industry, competing with traditional materials. It now has a wide range of uses, in glazed door and window frames, roofing and cladding materials, light structures, rainwater goods and decorative finishes. Through the processes of anodising, electrolytically bonding of colour finishes and improving strength through alloying, aluminium's applications have been greatly extended. The production of aluminium is an energy intensive industry. Aluminium hydroxide is formed by crystallisation, through the 'Bayer Process' where bauxite is dissolved in nitrium hydroxide. Aluminium is then separated by electrolysis at approximately 950-9700C, the aluminium hydroxide having been melted to oxide then mixed with aluminium fluoride. (28) Aluminium's properties which have proved so appropriate in the building industry include: * corrosion resistance * light weight * high strength to weight ratio * malleability * conductivity The main environmental and occupational health impacts of aluminium are: * 'red mud' - bauxite waste by-products * electrolysis of aluminium oxide - huge energy demand / greenhouse impacts * occupational asthma - aluminosis and other respiratory diseases from aluminium dust inhalation * dialysis dementia / encephalopathy - from accumulation of aluminium in the brain in people with weakened kidneys * Alzheimer's disease - where victims have 2-5 times as much aluminium in the brain's grey matter as normal, ageing people. No direct relationship has yet been proven, but aluminium is a recognised nervous system toxicant * potential for accidents and explosions during production processes * potential for leachates of landfilled aluminium ions polluting ground water * carcinogenic impacts from PAH compounds * occupational problems related to magnetic and electrical fields * fluoride vapours * incineration impacts of burning aluminium include temperature control problems which could result in increased dioxin emissions. Aluminium recycling is a highly developed industry and energy requirements are much lower than primary production. However, the recycling of aluminium used in the building industry, is negligible compared to the very high rates of aluminium can recycling. In conclusion, the Danish EPA gave no endorsement to aluminium over PVC. "When comparing aluminium with PVC it is not possible to unequivocally rank one material before the other." 2.6 Synthetic rubbers The Danish EPA assessed three synthetic rubbers as being the most relevant as PVC substitutes: * Ethylene Propylene Diene (EPDM) - mainly used in roofing * Polychloroprene (CR) - mainly used for cables, tables and tarpaulins * Styrene Butadiene (SBR) - mainly a roofing material * These rubber compounds were assessed in terms of vulcanising method and choice of additives. The following selections were assessed: * EPDM vulcanised with organic peroxides, without antioxidants * CR with sulfur and vulcanisation with zinc oxide, amomatic amines as antioxidants * SBR vulcanised with sulfur and substituted phenols as antioxidants The following table outlines the main environmental impacts associated with these rubber compounds: TABLE 6 SYNTHETIC RUBBER ALTERNATIVES EPDM CR SBR Raw Materials EthylenePropyleneEthylidene Norbonene Hexane Butadiene Chlorine (40%) Styrene Butadiene Additives Wide range of common additives including: - vulcanisers- retarders- antioxidants- plasticisers (inc. DEHP) - fillers- pigments Occupational Health Impacts - Risk of fires- nausea- muscular atrophy- testicular atrophy (rats)- leukaemia (workers) from benzene - mutations/ chromosomal aberations (rats)- central nervous depression-lymphocytes/chromosom -al aberations (workers)- (critical) genotoxicity- increased lung and skin cancers (workers)- liver illnesses (workers) - spontaneous abortions- nervous system injuries Environmental Impacts no information available could also effect people living near rubber factories (similar to PVC impacts) Combustion no hazardous emissions hydrogen chloridedioxins sulfur dioxidenitrogen oxides Recycling not possible due to chemical reactions during vulcanisation Table 6 identifies the common issues of toxic vulcanising compounds and additives. There is a lack of information available on the resulting environmental and occupational health impacts. Many of these toxic compounds are used in PVC manufacture. EPDM is recommended by the Danish EPA as a PVC alternative. CR and SBR are not recommended as PVC alternatives. 2.7 Vacuum Impregnated and Surface Treated Wood The Danish EPA assessed the environmental suitability of chemically treated, laminated timber (nordic pine and spruce) compared to PVC. Wood is a renewable resource, tree production uses no fossil fuels and produces no greenhouse gases. Managed plantations can regrow the consumed timber during the expected, 20 year life of window frames. Wood dust was previously considered non-hazardous. Now it is assessed to cause asthma, rhinitis and allergies. Hardwood dust is carcinogenic and softwood dust is a suspected carcinogen according to the Danish Labour Inspection Service. (29) Sawmills are very high accident work environments. The chemical constituents of timber are as follows: * cellulose 45-60% * hemicellulose 15-20% * lignin 25-30% * plus resins, oils, tannin, alkaloids, etc. Window frames are the main PVC substituting product. 90% of window frames are vacuum impregnated in pressurised closed tanks. Laminated timber has good strength, corrosion (in salty and acidic environments) and fire resistance. Trees are firstly cut into laminas and wood profiles are made by pasting these together with adhesives. This wood is then impregnated with various toxic chemical compounds. Often chromium / arsenic are used in vacuum impregnating processes. The Danish EPA assessed vacuum impregnation using the following compounds: * White spirit solvent (neurotoxic) * Tributyltin naphthenate (TBTN) * Bis (tributyltin) oxide (TBTO) * Dichlofluanid These impregnation agents are used at the rate of 30 kg/m3 of wood. White spirit solvent has over 45 aliphatic and aromatic hydrocarbons. They cause nausea, irreversible central nervous effects and are possible carcinogens. The biocide, Tributyltin (an organic compound) forms dioxins during combustion. When used in recreational boats, in antifouling paints, it is bioaccumulative and very toxic to marine organisms. Several species of European oysters have been effected by this toxin. In Australia its marine uses have been banned. Dichlorofluranid is both mutagenic and carcinogenic. The vacuum impregnating process also results in the emissions of solvents, ammonia, formaldehyde and free monomers. Painting of wooden window frames results in hazardous waste spills and sluge. Wood can not be recycled as glass is, but there is growing demand for recycled timber from demolished buildings. Chemicals can be leached out of landfilled, treated wood, into the groundwater. Impregnated and surface treated wood, is assessed to have environmental advantages compared to PVC. However, there are major impacts associated with emissions if organotin compounds are used. 3.0 Recommended alternative materials Table 7 Alternative construction materials PVC product Substitution material Drawbacks of PVC when compared to its substitutes Windows wood (pine, larch; fir, spruce, beech), aluminium iron furniture breaks off, warping and discolouration may occur under sunlight Flooring Ceramic tiles; wood, parquetry, linoleum, rubber, stoneware tiles, cork, sisal, hemp, terrazzo (venetian wash), polyolefine plasticiser evaporation, no moisture permeability, not repairable after damage and discolouration Walls brickwork, pebble dash, wood, gypsum plaster board temperature variations may cause material to come off; aesthetics, room climate Wallpaper paper wallpaper with protective coating on acrylate base, ceramic tiles plasticiser evaporation, aesthetic appeal Facades, curtain walls plaster, wood poor durability, aesthetic appeal Roll joints and hand rails wood, metal plasticiser evaporation Furniture wood, metal not repairable, plasticiser evaporation (e.g. in artificial leather) Blinds, shutters aluminium, wood; wooden shutters, textile blinds inside, etc. not as durable, PVC shutters usually turn brittle after 10 to 15 years Weather / draught strips for doors and windows rubber poor durability because it turns brittle and insulating characteristics disappear Sewage pipes concrete, earthenware, stoneware, polyethylene pipes more marked abrasion Sanitary installations e.g. pipes, pipe castings earthenware pipes, stoneware, steel, cast iron, copper pipes, polyethylene pipes increased abrasion, lower stability than steel, cast iron, limited section lengths, lower elasticity than other plastics Electrical installations plastics heavy dioxin formation in the case of fire Roof sheeting plastics, bitumen sheeting expansion problems, plasticiser migration Packaging Reusable packaging, cardboard, wood, other plastics disposal problems, heavy dioxin formation in the case of fire 4.0 Strategy to replace PVC An effective PVC replacement strategy must take into account where the use of alternatives would be most effective in terms of respective end-uses. The following table indicates that the main end-uses for PVC includes the five categories of Plumbing, Electrical / Electronics, Building / Construction, Packaging and Transportation - which accounts for more than 80% of all PVC usage. TABLE 8 AUSTRALIAN PVC End- Uses 1992 ('000 Tonnes) End-Use Tonnes Per-Cent Plumbing 92,800 53.7 Electrical / Electronics 33,700 19.5 Building / Construction 12,100 7.0 Packaging 10,700 6.2 Transportation 6,100 3.5 Other 17,500 10.1 Total 172,900 100.0 Source: Plastics Institute of AustraliaIn several minor end-use categories, such as kitchenware, materials handling, toys / sporting goods / leisure and recreation, and footwear, PVC usage is declining and is apparently being replaced by other plastics for commercial reasons. Only electrical/electronics end-use category records a substantial increase. 4.1 Plumbing / Drainage At 53.7%, the plumbing sector constitutes the largest end-use of PVC. If substitutes could replace PVC in this sector, over half of the PVC produced in Australia would not be required. These alternatives are available and many were used long before PVC. They include concrete, earthenware, stoneware, steel, cast iron and copper. Alternative plastics include PE-X (cross linked polyethylene), HDPE and PP. PVC underground and sewage systems can be replaced by concrete, nodular graphite iron and earthenware pipes. These materials have a longer service life than PVC but they are 20 - 30% more expensive. However, the materials cost is of less importance in underground ductwork, since the earthwork (excavating, laying ducts, etc.) accounts for the largest share of total costs. In Denmark the EPA has assessed PE and clay sewage pipes as both technically and financially viable PVC alternatives. European communities which have replaced PVC with substitute materials often find these are more durable and thus cost effective in the longer term. In Denmark, the city of Nyborg reported that the PVC main sewage pipe had turned as brittle as glass and required frequent replacement. HDPE sewage duct systems can be laid straight from rollers, an advantage in terms of ease of workmanship and time saving. As PVC pipes come in shorter lengths, they require more joints and have more leakage potential. HDPE pipes are more flexible and shock resistant. The price of HDPE pipes can be 20-40% lower than comparable PVC products. There are still a number of fittings and accessories that are only available in PVC. Discharge pipes are usually made from HDPE, PP or cast iron. The pressure resistance qualities of these materials is superior to PVC. Pressurised water delivery pipes are usually made from PE-X, steel, copper or HDPE. PVC is not suitable due to its greater potential to fragment under external impacts. For road construction, concrete pipes better satisfy strength requirements. Gutters and downpipes are usually made from galvanised steel or zincalum. PVC gutters become brittle when exposed to extreme cold or heat. Metal guttering has a longer service life. Although building supply firms usually only stock PVC and galvanised steel pipes, there are some local and foreign firms producing alternatives. They include James Hardie Pipelines (PE), Riblock of South Australia (HDPE) and Akatherm / Netherlands (HDPE and PP). 4.2 Electrical / Electronics The most difficult area of substitution is electrical insulation. PVC dominates this sector. Approximately 95% of all electrical insulation in Australia is PVC. Many local firms only carry PVC insulated cables. Price differentials range from 30% higher for rubber to 200 - 300% higher for teflon. Alternative plastics are also more expensive than PVC. In many instances, acceptable substitutes for PVC cables, wiring conduits, plugs, sockets and other small electrical accessories are not yet available. In Europe environmental authorities have concluded that firms will need a research and development phase of one to five years to replace PVC in these areas. Alternative materials include PE, ethylene-vinylacetate copolymer, polyamide, teflon, silicone and thermoplastic elastomers. Cables and conduits made of these materials are actually of superior quality. The European experience has been that alternative prices decrease significantly, when these materials become subject to mass demand. This has already occurred in those areas where PVC has been banned. It should also be noted that the higher costs of substitutes will not have a large impact on the over-all project budget. Much of the electrical cable sold in Australia is imported. The research and development of halogen-free / technically suitable substitute materials is predominantly occurring in Europe. Given the timescale, importation of these products would appear to be the only way to supply Olympic projects and comply with the Environmental Guidelines. 4.3 Building / Construction In this end-use category - PVC is widely used internally for floor and wall coverings, shutters and blinds, draft excluders, damp proof courses and vapour barriers. There have been durability problems with PVC due to the intensity of the Australian sunlight. This has limited the role of PVC in windows, guttering and other external uses. The main areas where PVC can be substituted include: Flooring There are many alternative flooring materials, but PVC usually has considerable cost advantage. These alternatives include cork, timber tiles, rubber, linoleum, parquety, sisal hemp, coconut fibre and polyolefine plastics. They are all available from local suppliers. Linoleum is the most cost competitive and has good antistatic and sound insulation characteristics. It is however, more susceptible to denting and moisture. An Australian firm has developed a polyolefine-based plastic flooring which compares well against PVC. Wall Coverings Alternatives to PVC foam wallpaper include painting or paper wallpaper. With PVC wallpaper there is a possibility of plasticisers and other additives evaporating into the air. Ceramic tiles are appropriate for kitchens and cafeterias. Wood, gypsum and plasterboard are all suitable alternatives. Draft Excluders Aluminium / rubber draft excluders are cost effective alternatives to PVC excluders which have displayed poor durability. Wood / rubber draft excluders are also available but at a higher price. Damp Proof Courses Aluminium / Bitumen and alternative plastic damp proof courses are locally available and are cost effective. In conclusion the Danish EPA estimated that 60-70% of the PVC production used in building and construction could be substituted within a three year period. Where required, product development would take up to five years. The assumption that alternative materials would mean reduced technical / durability standards has been disproved through the experience of several towns and cities which have now recorded satisfactory track records with PVC substitutes. Even maintenance costs have proved to be lower. (REFFERENCE) 4.4 Packaging PVC use in the packaging sector is currently declining. PVC blow moulded bottles are under competitive market pressure from PET which has comparable or superior qualities and cost advantages. PET has a relatively high recycling rate. Problems associated with the migration of plasticisers should immediately prohibit PVC's future role in food packaging. Overseas research has linked dioxin formation to the incineration of chlorinated compounds such as PVC. This strongly warrants the prohibition of PVC's short life end-uses, such as packaging. Other plastic and non-plastic materials are more environmentally friendly and have less potential for harmful health impacts. In general packaging PVC should be replaced by reusable materials, other plastics, cardboard and wood. 5.0 Impediments and resistances to the use of alternatives 5.1 Economic Impediments Nationally and internationally, there is a massive capital commitment to PVC. Much of this technology can only be used to produce PVC. A PVC plant cannot be converted to produce other polymers. A PVC phase out would close these plants and threaten at least a few hundred jobs. Downline, through the PVC product industry, there would be extensive re-tooling, re-skilling and reinvestment required. However, these costs are relatively small compared to overall production costs. New commercial opportunities would be created for firms like ICI which currently produces a wide range of polymers, including LDPE, LLDPE and PP in much greater volumes than PVC. Demand for these plastics would increase upon PVC's demise. There is a need for tax reforms and incentives to get this process moving. National retraining programs should be established to reduce trade union resistance to such industrial reforms. The full life cycle cost of PVC should be incorporated into its market price. PVC's poor recycling record should be reflected in the waste disposal component of this price. Eco-taxes should be levied on chlorine production's massive greenhouse impacts and these electricity rates should not be subsidised. Insurance premiums should reflect the damages resulting from PVC fires. Removing PVC's cost advantages would be an important step towards achieving a phase out. 5.2 Building Industry Conservatism In discussions with building industry representatives, the main attractions of PVC are price effectiveness and a proven track record. These ensure its role in an economically sensitive and competitive industry. A generation of building industry personnel are largely unfamiliar at working with PVC alternatives. While PVC has established supply networks, there could be concern about the reliability of alternatives supply. The building industry's entrenched conservatism and legal sanctions encourages developers and architects to avoid experimentation in unfamiliar or different materials. There must be strong financial incentives, scientifically backed arguments and ultimately, restrictions against PVC. The environmental and economic viability of PVC alternatives must be conveyed to the industry. 6.3 Lack of Information The lack of awareness of PVC's negative environmental effects is also an impediment to the acceptance of alternatives. This lack of information extends from developers, architects, engineers, planners, builders, trades workers, into government departments, trade unions and even environmentalists. In this information vacuum the Chlorine/PVC industry has the resources and the economic and political power to influence this debate. These industries are fighting for their own survival. In the U.S. they have recently formed powerful lobby groups, financed with millions of dollars. In Australia prominent politicians, from both major parties, retire into senior positions within the plastics industry. The merging of corporate and political power is thus almost complete. Getting the facts through to the building industry, the political system and the public, is an urgent priority. There should be building industry teach-ins, to inform of the full impacts of PVC and the environmental advantages of the full range of PVC alternatives. As in European countries, a comprehensive handbook, or teaching kit, with video/facts sheets, should be distributed at the local and state level. The establishment of an environmentally sustainable building advisory centre should be considered. A PVC alternatives / environmentally sustainable building materials marketing show, could well be held at the 2000 Games site. A database of alternative materials and suppliers should be made available to the building industry. It should be stressed that a chlorine free future is not a radical, green demand, but rather, the way the world must go in order to survive. 6.0 Environment protection authority: industry regulations Emissions from VCM / PVC production plants are controlled by the respective state Environment Protection Authorities (EPAs). The NSW EPA has responsibility to issue the licence which permits ICI's Botany plant to operate. ICI plans to phase out PVC production at this plant over the next two years as it concentrates production at its existing and planned facilities near Melbourne. VCM will still be produced at the Botany plant. The NSW EPA controls emissions of EDC / VCM, and other toxins under the Clean Air Act 1961 and the Clean Water Act 1970. Currently, chlorine emissions from ICI's Botany plant are restricted to 0.2 g/m3 (66ppm) from the chlorine plant and 40ppm from the more recent hydrochloric acid plant. The company is required to record emission levels and retain this information for a minimum of three months. These records can be checked by the EPA. There are currently no legislated dioxin emission controls in Australia.The licence also gives basic instructions on the cleaning of chemical spills and leakages within the plant. The NSW EPA is currently considering concepts such as Load Based Licensing, where the ability of the environment to cope with emissions is assessed and 'loads' allocated to industry. Such a system has been applied to certain industries like coal mining in the Hunter Valley, where an environmentally acceptable 'load' has been selected and 'salt discharge quotas' allocated. River monitoring ensures the quotas are not exceeded. However, the scientific information concerning chlorinated emissions is increasingly indicating that only zero levels are acceptable due to their environmental persistence and bioaccumulativity. (31) In the Sydney Waste Disposal Area the NSW EPA is responsible for industrial PVC waste disposal into controlled landfills. Post-domestic PVC waste is landfilled with ordinary municipal waste. Such tips outside Sydney, are usually controlled by local councils. The NSW EPA is currently considering life cycle costing, where the waste generator pays and the real price of landfill is reflected in waste disposal charges. In some European countries increased waste disposal costs have effectively priced PVC, with its poor recycling track record, out of consideration for most building industry purposes. The Federal EPA is also formulating new waste disposal policies in order to meet the ANZECC target of 50% waste reduction by the year 2000. At both the Federal and State levels there is, currently, an unwillingness to push life cycle costing/polluter pays principles beyond the conceptual phase. The NSW EPA's encouragement of 'cleaner production' will not remove chlorinated compounds from the waste stream, recycling efforts will be undermined and pollution will increase. The position of the NSW EPA contrasts with several European and U.S. environmental authorities which are critical of the production, use and disposal phases of PVC. Although the NSW EPA claims to support the application of the precautionary principle - it does not accept that the threat of PVC is serious and likely to cause irreversible environmental damage. To protect human health and the environment, zero emission standards should be adopted for dioxins. Australia's environmental protection authorities must urgently adopt both full life cycle costing and clean production principles. They should also adopt the precautionary principle, rather than giving chemicals the legal rights of people, their use and production must be restricted until they are proven to be environmentally benign. Such action would reconfirm their responsibilities towards environmental protection and human rights rather than corporate capital maximisation. 7.0 PVC Industry Arguments With the emergence of a global anti-chlorine movement in recent years, the chemical industry has reacted as if fighting for its survival. Industry arguments can be grouped around the following major issues: 7.1 PVC Properties The industry promotes the previously discussed beneficial properties of PVC which have allowed it to dominate certain markets. It is claimed that alternatives cannot be found which perform to standard, without great economic cost. In the U.S., Chlorine Institute funded research has priced a PVC phase out at U.S. $6.9 billion. This amount is disputed by Greenpeace. 7.2 Energy Industry claim: "PVC is one of the most environmentally friendly polymers in use today...(it) requires little energy to create, and is made primarily from salt." (ICI Document 1991) "Considering all the energy costs associated with PVC - production of chlorine, ethylene, the huge amounts of chemical additives, and the energy costs associated with waste disposal and emission neutralisation - PVC is as or more energy intensive than chlorine-free plastics." (Greenpeace) 7.3 Occupational Health The industry claims that production emissions/leakages are low enough to be of an 'acceptable' level - they satisfy legal requirements and measures are being taken to reduce then even further, as the community dictates. VCM health impacts, for example, are recognised: "In the early 1970s it was discovered that prolonged exposure to very high concentrations of VCM could result in...liver cancer. All plants currently in operation employ designs which ensure that the workforce is protected against this." (Norsk Hydro) However, it has been noted that health impacts extend beyond process workers and that: "...angiosarcoma of the liver has been seen in persons living in the vicinity of VCM plants." (Danish EPA 1991) 7.4 Organochlorines The industry accepts that certain organochlorines are toxic and environmentally persistent, however, they reject a chlorine phase out because: "Most chlorinated organic chemicals can now, and in the future, be used without adverse effects." (C & E News Nov. 1994) The American Chemical Society sees: "no reason for singling out such an extensive group of chemicals for study and, in fact, is concerned about the harm that a comprehensive study of chlorine would generate." The Great Lakes IJC (U.S./Canada) replies that: "(we) cannot afford to take a chemical-by-chemical approach to testing chlorinated organics, (it) would take millennia to accomplish...it is prudent, sensible, and indeed necessary to treat these substances as a class rather than as a series of isolated, individual chemicals." (C & E News Nov. 1994) 7.5 Accidents "In regard to transportation, the vinyl industry...operates at very high safety standards. In 44 years of PVC manufacture in Australia. There has not been one single accident involving the transportation of VCM, the basic raw material for PVC." (Michael MacKellar PIA CE 1994) "Almost 800 tonnes of VCM were released through accidental releases between 1977-89 by the B.F. Goodridge / Auseon LImited plant in Altona." ( Greenpeace 1994) 7.6 Dioxins The industry promotes the belief that incineration is safe and the burning of ordinary waste (containing wood or salt, etc.) also produces dioxins. The proportion of dioxins resulting from PVC is thus of no real significance. "In well designed and efficient incinerators, the release of toxic gases can be effectively controlled." (PIA) "Research has not discovered any connection between the PVC content of refuse and the quantity of dioxins formed." (Norsk Hydro) "Research has demonstrated that the combustion of organic matter together with matter containing chlorine, will normally lead to the formation of a small quantity of dioxins. It is therefore assumed that the incineration of PVC will normally also result in their formation." (Norsk Hydro) In contrast the regulatory view is becoming clearer: "PVC is the most significant individual source of chlorine in municipal waste..." (Danish EPA 1991) "When 70-100% of the bio-waste is removed from the waste stream, a direct correlation between PVC content in the remainder and dioxin formation is found." (Leiden Univ. Study 1993 for Dutch Environment Ministry) "The primary known source of dioxins in the environment is the incineration of chlorine-containing compounds." (U.S. EPA 1994) 7.7 Hydrochloric Acid "Compared to the quantities of CO generated during a fire, hydrochloric acid does not constitute any particular health hazard." (Hydro) "The hydrochloric acid given off during fires also reacts with the many additives present in PVC, creating even greater volumes of toxic fumes...One of the best documented cases is that of the Beverly Hills Supper Fire Club of 1977...161 people died without any direct involvement with the flames...these deaths were a direct result of the presence of PVC." (D.N. Wallace - Journal of Combustion Toxicology 1981) 7.8 Additives/Migration "Where the use of PVC in medical equipment is concerned it is known that DEHP migrates into the blood from plastic blood packs. Research has established that this does not constitute a medical problem. On the contrary migration can turn out to be a medical benefit since it can inhibit the breaking down of the red blood cells." (Norsk Hydro) 7.9 Leachates "PVC helps to stabilise the fill for land reclamation...does not release undesirable contaminants into underground water supplies." (PIA) "PVC is supposed to be degraded in landfills...resulting in the release of phthalic acid esters, heavy metals, and other additives." (Danish EPA) 8.0 Recycling The industry argues that PVC recycling rates are low because 80% of the usage is long-life and little is used in packaging. Recycling will increase as building materials recycling becomes more common. "The fact that it is now recyclable means the environmental loop is complete." (ICI 1991) "In reality recycling is negligible, despite the fact that the PVC Industry feels itself under intense pressure to prove the recyclability of chlorine-containing plastic." (Greenpeace 1992) 8.0 Recommended Actions 8.1 The NSW Government must immediately establish an interdepartmental working party to select environmentally appropriate PVC alternatives for the Olympics. is specified for an Olympic building project, the Developer / architect must justify its use and why alternatives were not used. The cost ineffectiveness of PVC alternatives should not be an acceptable justification. Where the Environmental Guidelines are broken there must be accountability and the feedback should be used to remedy these problems. if they are seriously committed to clean production and a sustainable future. 8.2 In line with the U.S. Government, the Federal and State Governments must set up immediately, a task force to comprehensively assess the use, environmental and health impacts of chlorine and chlorinated compounds and products in Australia. The safety and availability of substitutes must be assessed, phase-out time frame for the chlorine industry will be reached. 8.3 Within 12 months the taskforce should collect all current information on usage and environmental health impacts of chlorine and chlorinated compounds. 8.4 Within 24 months the Federal and State Governments must review the information collected by the task force and develop a national and state strategy for the phase out and substitution of chlorine and chlorinated compounds and products. 8.5 The Federal Government and State Governments must urgently set up detailed toxic release inventories to catalogue organochlorine emissions to air, land and water. This information must be publicly available. 8.6 Priority phase out sectors for chlorine and chlorinated compounds would include pulp and paper, solvents, dry cleaning and chlorinated pesticides 8.5 Timelines to sunset other, secondary chlorine sectors should be established based upon the quantity of chlorine used and the availability of alternatives. These include chlorinated intermediates used to produce isocynates and propylene oxide, chlorine used to produce titanium dioxide and in waste water disinfection. Together with the priority sectors these uses consume 60-70% of all chlorine. 8.6 The Federal Government should institute an eco-tax on the chlor-alkali process and on imports of chlorine-containing products and alkali produced through the chlor-alkali process. Chlor-alkali plants should no longer be allowed to purchase government subsidised electric power. 8.7 Chlorine Tax revenue should be held in a fund to aid the transition to a chlorine free society. The fund should be used to research and develop economically viable alternatives and for easing dislocations to affected workers and communities, particularly those associated with chemical manufacturing. A multi-stakeholder group should be established to help set the policy of the fund. 8.8 That all Australian Governments set a zero target for the discharge of dioxins into the environment and timetables to achieve dioxin elimination. 8.9 The Federal Government consider an immediate, provisional phase out on the use of PVC food packaging, due to problems of additives migration into foodstuffs. 9.0 In view of the current waste management crisis, the NSW Government should evaluate materials with low recycling rates and determine the imposition of eco-taxes which reflect their waste disposal and environmental impacts. 9.1 All NSW Government departments must be required to purchase a minimum percentage of recycled materials - paper, plastics, metals, etc. - to generate markets for recycled materials. 9.2 Polyurethane (PUR) cannot be recommended as a PVC alternative due to high chlorine usage during production of intermediate products, chlorinated additives and problematic production emissions. 9.3 Building materials which require chlorinated additives or solvents in their production processes are not desirable PVC alternatives. Endnotes 1 Norsk Hydro., PVC in Products and as Waste - Environmental Aspects., Norsk Hydro Company Report., 1991, Oslo, p.7 2 ibid., p8 3 Plastics Industry Association., The Plastics Industry in New South Wales, Perfomance and Staregic Opportunities, Strategic Industry Research and Anlysis., 1990., p7 4 ibid., p.9 5 Danish Environmental Protection Agency., PVC and Alternative Materials., 1993., Copenhagen., pp97-98. 6 Opcit., Norsk Hydro., p33 7 HydroTechnology Pty Ltd., Groundwater Nutrient & Toxicant Inputs to Port Phillip Bay., Technical Report No 13., CSIRO Port Phillip Bay Study., Melbourne., December 1993 8 AG Environmental Engineers in association with Woodward-Clyde Consultants (USA). ICI Botany Environmental Survey: Stage I Preliminary Investigations. State Pollution Control Commission May 1990. 9 Winder, C., Health Effects of Emissions from Municipal Solid Waste Incinerators., Aus Tox Report., Sydney., 1993., pp2-3 10 Dioxin sample taken EML Air Pty Ltd, December 1992 11 Metal samples taken by EML Air Pty Ltd, April 1992, March 1993, in Sinclair Knight & Partners Pty Ltd, Harpers Pty Ltd, Environmental Audit Coburg Site, December 1993 12 Dioxin samples taken EML Air Pty Ltd, September 1991 13 Metal samples taken by EML Air Pty Ltd, November 199, January 1992, December 1992, 1993. 14 Samples taken 17 and 19 October 1990 by DSIR Chemistry in conjunction with SPCC Air Branch, in Buckland, S. & Taucher, J. The Analysis of Polchlorinated Dibenzo-P-Dioxins (PCDD's) and Dibensofurans (PCDF's) for Waverly Woolahra process Plant, DSIR Chemistry, NZ, January 1991 15 Ozvacic, V. et. al., Biomedical Waste Incinerator Testing programe, Chemosphere, Vol 201, 1990, pp 1801-1808. Danish EPA. Miljoministeriet Miljostyrelsen, PVC and Alternative Materials (English Translation), Copenhagen 1993. Also found in Allsopp, Opcit, p34 16 J. Boerekamps-Kanters & Louw, R., Final Report of the RUL-VROM project: GFT, PVC,, Afvalverbranding en `Dioxine' (Green Waste Fraction, PVC, Waste Incineration and Dixoins), Centre for Chemistry and the Environment. department of Chemistry of the University of Leiden, the Netherlands, report No CCESRS 93-09, 1993. Also found in Allsopp, Opcit 17 Bureau of Industrial Economics, Plastics Recycling: Economic Issues and Implications, Research Report 61, Australia Government Publish Service., Canberra., 1994., p.41 18 ibid., p.27 19 opcit., Dansih EPA., pp 101-121 20 ibid., pp.110-112 21 opcit., Bureau of Industrial Econmics., p22 22 Ward-Harvey, K., Fundamental Building Materials, Sakoga Pty Ltd is association with the Royal Institute of Architects, Ambassador Press, Sydney, 1984, p97 23 opcit., Dansih EPA., p145 24 opcit., Bureau of Industrial Econmics.,p22 25 opcit., Dansih EPA., p160 26 opcit., Bureau of Industrial Econmics.,p22 27 Industry Commission., Recycling., Volume II: Recycling of Products, Report 6., Australian Government Publishing Service., Canberra, 1991., pp205-207 28 opcit., Dansih EPA., p28 1