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Re: REHW #555 - an opening
At 07:19 PM 7/19/97 -0400, you wrote:
>The information in REHW #555 (FDA ban on dioxin-contaminated
> provides a unique opening for all dioxin activists. If we do
>not act to take advantage
> of the opening, we possibly lose a
>For those who haven't read their copy yet, REHW reports that the
> finding much-higher-than-average dioxin levels in some
>chickens, has found
> that chickens fed with soybean from a
>particular grain mill had 3-4 ppt dioxin.
> The grain mill had added
>bentonite clay (finely ground kitty litter) to the feed
>to make it "flow" better (raises questions about what these
> before being slaughtered...), and the clay mine was
> with dioxin (unknown origin, perhaps
>toxic disposal, perhaps a dioxin-polluting
> industry nearby).
A more likely explanation is that dioxin contamination in bentonite clay was
produced as a result of combustion of fossil fuels in a kiln used to
process the clay without any presence of hazardous wastes whatsoever.
Sufficient chlorine can very well be present in coal and in feedstocks to lead
to formation of chlorinated dibenzo-dioxin/furan compounds.
It may constitute heresy to say this on this list, but
It takes precious little chlorine to make the small mass amounts of chlorinated
dioxin/furans that come from even the largest dioxin sources.
These compounds can be produced from the presence of simple
inorganic chlorine -- such as during the combustion of wood
contaminated with sea salt from sea water.
Depending on the type of combustion system, other factors can potentially
make large differences in the amounts of chlorinated
dioxin/furan compounds that are produced and emitted. These
include such matters as the type and efficiency of the air pollution
controls that are utilized, the temperature conditions in the flue
gas, the presence or absence of certain catalyzing metals, the
characteristics and residence time for fluegas/flyash interactions,
the opportunity for the reaction of residual chlorine in flue gases
with hydrocarbons found in process feedstocks, and other factors.
>4. We need to cut dioxin production and exposure now. Stop
>incineration, phase out PVC and organochlorine chemicals
OK...which sources of chlorinated dioxins/furans are you going
to stop first??? and which exposure and pathway scenarios are most
important to address first?? and which pesticides presently in
commercial use and which contain chlorine produce the greatest amount of
byproduct dioxin formation???
I ask these questions on this list on the theory that folks
motivated by an interest in protecting the environment
and human health from chlorinated dibenzo-dioxin/furan pollution
would figure out what the most important problems are so
these get the most attention first....the "worst first" theory of
decisionmaking and priority setting...
And, once you get going on addressing problems, if you
are interested in addressing whether you are being
effective or making any headway, you evaluate the
effectiveness of your approach in solving the problem.
Let me suggest that reliance on quantitative methods...just
how much emissions are occurring and just how much
risk to the population (and to non-human creatures) is
occuring is absolutely essential to dealing with these
There has not been much discussion of these issues
on this list.
There has been no targeting of the 25 largest dioxin
mass rate emission sources in the United States.
Which MSW incinerators, hazwaste incinerators,
cement kilns, medwaste incinerators, steel plants
and other sites are the absolute worst on a mass
emission per unit time basis???
Don't these largest of sources deserve the most attention
on a "worst-first" decisionmaking basis?? And if
so, why haven't the biggest environmental groups
out there identified these largest sources of all dioxin/furan sources
and why haven't the contributor and grant dollars been
spent to deal with the worst problems???
There has been no systematic
identification and targeting of the ten
specific population subgroups most exposed and
most at risk for exposure to chlorinated dibenzo-
dioxin/furan exposure. Do these population
groups know they are exposed?? Do they know
how to limit their exposure in the interim?? Are
the biggest environmental groups out there
regularly talking with these folks and their
organizations about the problem??
Sometimes, I think some environmental and citizen groups
are afraid to search for and hear the answers to questions like this
because the answers have the potential to challenge
their existing thought patterns, beliefs, programs, public
statements, priority setting and funding sources.
More tough questions....
If chlorine production and use are increasing (recently
reported in Chemical and Engineering News), how
successful can the anti-chlorine campaign have been
after several years of campaigning?
After all of the attention by many groups to bashing
PVC plastics, is the market share for PVC down
in traditional PVC uses?? Has
the production of PVC decreased?? Is there any
sign at all, on a quantitative basis, that the anti-PVC
campaign has made any difference at all in
the form of a significant drop in PVC use??
What drop in chlorinated dibenzo-dioxin/furan emissions
is attributable to the anti-PVC campaign?? What is
the basis for this claim??
I'd suggest that searching for and answering some of
these types of questions is essential for citizen groups
to keeping on track of the goal of significantly reducing (or
eliminating) exposure of the human population and
natural environment to chlorinated dibenzo-dioxin/
Alex J. Sagady & Associates Email: email@example.com
Environmental Consulting and Database Systems
PO Box 39 East Lansing, MI 48826-0039
(517) 332-6971 (voice); (517) 332-8987 (fax)