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This resolution was passed by the Midway, Texas, High School TPTA and
sent to the full delegate body of the
Texas PTA Board of Directors for consideration at the November 1995
convention.
Midway High School Dioxin Resolution
Whereas, Dioxin, the most toxic substance created by humans, is formed as an accidental by-product in
numerous industrial processes involving chlorine.
Whereas, Dioxin is persistent in the environment, food chain,
and in our bodies.
Whereas, Dioxin is a by-product of waste incineration containing
chlorine, chemical and plastics
manufacturing, paper and pulp bleaching, burning hazardous wastes in cement.
Whereas, Dioxin is cross generational, passing from mother to
child through the placenta, and via mother's
milk.
Whereas, the creation of Dioxin is an avoidable hazard creating
numerous adverse health effects such as
cancer, hormonal disruption, infertility, impaired child development,
suppression of the immune system,
endometriosis, and diabetes.
Whereas, children bear the highest exposures, current levels of
dioxin in the bodies of the general population
are already in the range at which health effects are known to occur in
laboratory animals, according to EPA.
Whereas, some communities are subject to even greater exposures
and health risks because of disproportionate
siting of polluting facilities in minority communities.
Whereas, wildlife are now suffering severe effects on
reproduction and development.
Therefore, be it resolved that Midway High School PTA supports
legislation and actions that decrease, phase-out and eliminate the
creation, release and exposure of dioxins.
Be it further resolved that MHS PTA supports the use of
alternative processes, technologies, and products that
avoid exposure to Dioxin, especially those that are chlorine-free.
Be it further resolved that this Dioxin Resolution is of state
and national significance and shall be forwarded to
Texas PTA and National PTA for consideration.
October 11, 1995
Board Members
Texas Parent Teacher Association
Dear Board member.
It has recently been brought to my attention that the Texas PTA Will be
considering two
environmental resolutions at the upcoming Convention in Austin on
November 10-12.
I have some concerns about the factual representations made in these
resolutions. I have made
two extensive studies on the topics of chlorine/dioxin and hazardous
waste incineration. For
your information I have prepared two one-page summaries addressing the
resolutions which
hopefully will provide you with objective information based on sound science.
Along with the two summaries, I have included an abbreviated summary of
my larger chlorine
study, titled ''Chlorine: What are the Facts." I would be pleased to
make available copies of both
of the full reports, INSIGHTS:Chlorine In Perspective, and INSIGHTS:
Incineration of
Hazardous Waste, at your request.
Thank you very much for your cooperation. Please feel free to call me at
(409) 845-3372 if you
have any questions or need any additiooai information.
Sincerely,
Charles D. Holland
President, TIACT
and Professor Emeritus
Texas A&M University
Statement on Cement Kilns
A careful review of the resolution shows many of the premises to be
inaccurate and misleading,
Here are the facts about the use of waste-derived fuels in the operation
of cement plants.
1. Only one plant in Texas is in the permitting process for a
waste-derived fuel program.
2. The amount of waste-derived fuel that can be used by that
facility is less than half the amount specified in the resolution.
3. The use of waste-derived fuel by cement kilns has been
proven safe by state and federal studies.
4. There are no schools "immediately downwind from the plant",
as stated in the resolution. Furthermore, that community's
Superintendent of Schools is on record as approving the program.
5. The Texas environmental agencies and the Texas Department
of Health have found no adverse health or environmental effects
connected to the burning of waste-derived fuels at the referenced
facility.
6. Industrial resource recovery programs in Texas have not
increased air pollution.
7. Cement Kiln Dust (CKD) is non-hazardous. Regular testing
of CKD generated in Texas has shown that it does not leach unsafe levels
of any hazardous substances.
8. Cement plants use ignitable waste as fuel in manufacturing
cement, and the high temperature of around 4,000 degrees F used in
this process results in an organic destruction and removal efficiency
of 99.9999%.
9. There are no more risks in transporting ignitable wastes
than in transporting other flammable liquids like gasoline.
10. Hundreds of tests have shown there's no leaching of unsafe
levels of metals from cement produced while using waste-derived fuel.
11. The EPA has concluded, after studying the issue, that cement
produced while using waste-derived fuel does not require warning
labels since it is not appreciably different from any other cement.
12. Neither the process of producing cement using waste-derived
fuels, or the cement product represent a threat to the children of Texas.
13. There is substantial evidence ftom numerous studies that the
use of waste-derived fuel in manufacturing is safe.
In summary, since numerous studies have shown the use of waste-derived
fuel to be safe, and no
scientific evidence exists connecting the process with any negative
effects, the resolution is
inappropriate and should be rejected. The Texas Institute for the
Advancement of Chemical
Technology would be pleased to provide the Texas PTA with additional
information or
assistance in helping the organization understand this important, but
complex issue.
Statement On Chlorine and Dioxins
The Texas Institute for the Advancement of Technology concurs
with the Midway High
School Dioxin Resolution goal of reducing human exposure to dioxins,
however, as a scientific
organization that has studied the dioxin issue, we must disagree with
most, if not all, of the
premises outlined in the resolution. So does a significant portion of the
science community. In
addition, the Institute has serious concerns about the PTA's proposed
rnethod of achieving this
laudable goal of reducing dioxin exposure: namely, to "phase out and
eliminate the use of
chlorine in industrial processes."
Eliminating the chlorine industry and products of chlorine
chemistry will not solve the dioxin
problem or reduce dioxin levels in any meaningful amount. There are
natural sources of dioxin, such as
volcanoes and forest fires, and research conducted by credible,
scientific organizations both in Europe,
and North America has shown that the primary source of dioxin is
combustion, such as municipal and
hospital waste incineration, coal buming, wood fires and metal smelting.
To date, the EPA and its
Science Advisory Board do not consider the chlorine industry a
significant source of dioxins. In the
Netherlands, a study estimated that less than one-half of one percent of
dioxin in the environment was
due to the total chemical industry.
Rather than generating positive results, eliminating chlorine
and chlorine compounds will
have serious, detrimental consequences for society.
- 98 percent of U.S. drinking water systems rely on chlorine
or chlorine-based products for disinfection.
- 85 percent of all pharmaceuticals, including those related
to treating AIDS and children's diseases either contain chlorine
or depend on chlorine chemistry as an integral part of their production.
- Chlorine chemistry is a component of about 60% of all
commercial chemistry.
In addition, here in Texas, more than 360,000 workers - most of
whom live in communities
represented by the PTA - are employed at nearly 6,500 chlorine or
chlorine-related facilities. These
workers earn nearly $9.5 billion in annual wages
During the last 20 years, dioxin levels in the environment have
fallen some 30 percent.
EPA notes that regulations currently proposed will further reduce dioxin
from incineration by 90-99 percent. Additionally, EPA is currently
conducting a dioxin reassessment - a comprehensive
evaluation of dioxin to determine whether changes are warranted to
existing dioxins policy.
Despite the assumptions in the PTA resolution, this reassessment is not
final, and in part, the
draft report has been through a peer review process that allowed the
scientific community to
assess the conclusions drawn by EPA. As a result, the reassessment is
now being rewritten and
will not be finalized for another year.
The goal of reducing dioxin levels is one all of society can and
should support. But the
proposed PTA resolution as presently instituted calls for changes that
will not achieve the desired
result and would lead to a major disruption in the overall quality of
life. In short, the changes
suggested in the PTA's proposed resolution, including its rationale,
would be a terrible policy
mistake. The Texas Institute for the Advancement of Chemical Technology
would be pleased to
provide the Texas PTA with additional information or assistance in
helping the organization
understand this important, but complex issue.
Michael Drescher
Citizens Clearinghouse for Hazardous Waste
e-mail: cchw@essential.org