Re: REHW #555 - an opening

[asagady@sojourn.com]

  At 07:19 PM 7/19/97 -0400, you wrote:
  >Hi, folks,
  >
  >The information in REHW #555 (FDA ban on dioxin-contaminated
  > chicken)
  > provides a unique opening for all dioxin activists. If we do
  >not act to take advantage
  > of the opening, we possibly lose a
  >once-in-this-decade opportunity.
  >
  >For those who haven't read their copy yet, REHW reports that the
  >  
  >FDA, upon
  > 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
  >chickens face
  > before being slaughtered...), and the clay mine was
  >somehow contaminated
  > 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.
  
  
  [SNIP]
  >
  
  >4. We need to cut dioxin production and exposure now. Stop
  >incineration, phase out PVC and organochlorine chemicals
  >and pesticides.
  
  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 
  questions.
  
  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/
  furan compounds.
  
  
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  Alex J. Sagady & Associates        Email:  asagady@sojourn.com
  Environmental Consulting and Database Systems
  PO Box 39  East Lansing, MI  48826-0039  
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