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This is the latest issue of Dioxin Digest. If you are on our dioxin
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* FOURTH NATIONAL CCHW GRASSROOTS CONVENTION *
* ARLINGTON, VIRGINIA - OCTOBER 3-5, 1997 *
* FOR MORE INFO, CHECK OUT OUR WEB PAGE *
* http://www.essential.org/cchw *
Vol. 1 No. 3 August 1997
Taking Action to Stop Dioxin Exposure
Where is the EPA's Dioxin Reassessment? When will the final version be
completed and the long promised public hearings on the document's policy
implications begin? The answers to these questions depend on how much
pressure we bring to bear on the USEPA. We all need to take action
immediately to get Carol Browner to complete this long chapter in the
You may remember that the chapter began with William Reilly, who as EPA
Administrator ordered the second EPA reassessment of dioxin in April
1991. Reilly was responding to a Chlorine Institute- sponsored public
relations effort promoting "new findings" that dioxin was much less toxic
than previously thought.
Within months of Reilly's order, studies by the National Institute for
Environmental Health Sciences and other scientists seriously discredited
the Chlorine Institute's initiative. The NIEHS study and other research
presented at the September 1991 International Symposium on Chlorinated
Dioxins and Related Compounds supported the findings of the EPA's original
1985 health assessment.
In 1993, Carol Browner became the Administrator of the EPA. That
September, she wrote a letter to Greenpeace's Rick Hind stating that
publication of the draft dioxin reassessment would take place within the
next few months. But it wasn't until September 1994 that the 1,700 page
draft document was actually released.
In May 1995, the EPA's Science Advisory Board (SAB) reviewed the draft
reassessment report. The entire exposure document and almost all of the
scientific chapters of the health assessment document were approved by the
SAB. The SAB suggested clarification and amplification of some sections of
the final chapter of the health document, notably the sections that
characterize the risks to people and wildlife from dioxin exposure. EPA's
William Farland told the Science Advisory Board that revisions of the
document would probably be ready by the Fall of 1995.
Now, more than two years since the Science Advisory Board meeting, the
revisions have still not been completed. The most recent promise is that
the reassessment will be completed by Labor Day, 1997. The peer review
process for the risk characterization document would then take place
during the fall and the final document would go to the Science Advisory
Board in the winter. Public hearings on the policy implications would be
scheduled for the spring of 1998.
Every month that goes by without a final version of the reassessment is an
additional gift to the dioxin polluters and an additional burden on the
American people. EPA is writing new rules for major sources of dioxin
pollution -- pulp and paper manufacturing and medical waste incineration
-- that are deaf to the alarms of the dioxin reassessment.
The Dioxin Campaign Coordinating Committee has a proposal for grassroots
action on the EPA's dioxin reassessment.
But we can't start until the EPA completes the final draft. Two extra
years is two too many. Call, write, fax or e-mail Carol Browner. Ask her
to finalize the reassessment now.
Carol Browner, Administrator
401 M Street, SW
Washington, DC 20460
Here's the plan devised by the Dioxin Campaign Coordinating Committee:
As soon as EPA releases the final text, the Stop Dioxin Exposure Campaign
will get to work writing a layperson's version of the new document. That
report will be made available in a brochure and on-line to activists
willing to carry the message to members of their community.
Then we all need to spread the word everywhere we can. Letters to the
editor, speeches to the county commission, meetings with organic farmers
and breast feeding advocates. We need to mobilize as many people as
possible to participate in the policy hearings the EPA has promised will
happen next spring. Every one of those hearings needs to have hundreds of
people demanding strong and swift protection -- dairy farmers and prostate
cancer victims, families of learning disabled children and Vietnam
Veterans, doctors and residents of contaminated communities.
How will all of these people find out about dioxin and these hearings?
Because we will tell them. We can build on all the organizing and
educating that has already been done and use the time between the
publication of the final document and the public hearings to build even
more connections with an even broader and more diverse group of
organizations. The Stop Dioxin Exposure Campaign hopes to bring together
activists in each of the EPA's regions to encourage coordinated efforts to
educate and organize in preparation for the regional hearings. If you'd
like to help in your region, let us know.
EPA Wants Your Advice on Policy Implications of the Dioxin Reassessment
With or without a final draft, the EPA is planning to open a public
comment period in September on the policy implications of the
reassessment. Everyone who reads this digest should use that comment
period to write, for the public record, what you think EPA should do about
dioxin. Greenpeace's Jack Weinberg offers the following five policy
principles to get you started.
US EPA dioxin policy should be:
1) BASED ON THE PRECAUTIONARY PRINCIPLE. Scientific uncertainty can no
longer be an excuse to avoid or continue the delay in establishing and
implementing an effective USEPA dioxin policy. Since the evidence shows
that dioxin pollution poses a potentially severe and irreversible threat
to the public's health and the environment there is now ample
justification for strong action.
2) A POLICY OF DIOXIN SOURCE ELIMINATION. The overarching goal of USEPA
dioxin policy should be to eliminate dioxin sources. This policy should
apply to dioxin sources inside the US, and as opportunities arise, it
should also apply to global sources. In some cases, measures by USEPA to
control or to manage dioxin releases may be appropriate. USEPA, however,
should always view regulations to control or manage dioxin releases as
interim measures to be implemented in the context of a longer term
commitment to dioxin source elimination.
3) TO PHASE OUT INDUSTRIAL PROCESSES THAT GENERATE DIOXIN. Certain
industrial processes always generate dioxin and must be eliminated. It
should be USEPA policy to phase out such industrial processes over time.
Priority should go to: waste incineration; pulp and paper bleaching with
chlorine-containing chemicals; and the manufacturing process for certain
chlorine-containing compounds, including the manufacture of certain
chlorinated pesticides and the oxychlorination process in the production
of ethylene dichloride and perchloroethylene.
4) TO IMPLEMENT MATERIALS SUBSTITUTION POLICIES. Dioxin is generated and
released to the environment during the ordinary life cycle of certain
chlorine-containing materials of anthropogenic (human) origin. Most new
dioxin generation, it appears, results from the life cycle of a relatively
small number of these materials. It should be USEPA policy to phase out
such materials over time as appropriate substitutes (including appropriate
non-chemical substitutes) can be made available. Priority materials
targeted for substitution should include: chlorinated plastics (such as
PVC); chlorinated solvents;
chlorinated pesticides; chlorine- containing automotive fuel additives;
chlorine-containing hydraulic fluids and others.
5) IMPLEMENTED THROUGH AN ORDERLY AND A JUST TRANSITION.
In many cases, there can be significant economic and/or social
consequences resulting from a decision to phase out industrial processes
or anthropogenic materials, and to replace them with appropriate, cleaner
alternatives. These consequences include benefits as well as costs since,
in most cases, economic activity of one type will be replaced with
economic activity of another. When phase-outs are implemented, it should
be US EPA policy to promote an Orderly Transition; that is, a transition
in which economic and social costs are minimized and all benefits are
maximized. It should also be USEPA policy to promote a Just Transition.
Workers and communities who depend on economic activities being eliminated
should share fully in the benefits associated with the new economic
activities. If this is not possible or adequate, affected workers and
communities should receive full compensation for their loss.
The Stop Dioxin Exposure Campaign will let you know as soon as this
comment period for dioxin policy begins..
PVC COMPANIES ARE MOVING IN ON LOUISIANA'S SMALL TOWNS.
The United States produces 25% of the PVC produced globally. Of the 14
vinyl facilities in this country, 13 are located in Texas and Louisiana.
PVC facility expansions are occurring in Louisiana's small rural
communities. Two communities are being hit especially hard.
Vincent Settlement in Calcasieu Parish is located about 30 miles from the
southwest border of Louisiana. Westlake Corporation, a Taiwanese-owned
vinyl production company, has proposed to build five facilities in Vincent
Settlement which will produce and process chemicals for polyvinyl chloride
(PVC). Two of these facilities, the chlor-alkali and ethylene dichloride
plants, are scheduled to be built by February 1998, and will be located
within a half mile of the Vincent Settlement Elementary School.
According to the Louisiana Department of Environmental Quality (LDEQ),
Calcasieu Parish has one of the highest toxic release levels in the state
with over 12 million pounds of toxic substances. Westlake Corporation
estimates that its proposed ethylene dichloride and chlor-alkali plants
will pollute the air with 500,000 pounds of toxic contaminants. Ethylene
dichloride is a known human carcinogen.
Romeville, in Saint James Parish, faces a similar situation. Shintech, a
Japanese-owned PVC company, plans to construct and operate an immense PVC
Shintech's proposed facility would produce 1.3 billion pounds each of
chlorine, chlor alkali, ethylene dichloride, vinylchloride monamer, and
polyvinyl chloride. These processes will generate more than 600,000
pounds of toxic airborne pollutants annually.
This community is already in the center of "Cancer Alley". The area where
Shintech wants to operate is 73% African- American and 40% of the total
population lives below the poverty level. Two low income housing
projects, an elementary school and a Head Start program are located within
one mile of the site. The parish already ranks as having the third
highest level of toxic air emissions in a state that is second in the
country for such emissions.
THE PEOPLE OF VINCENT SETTLEMENT AND ROMEVILLE, LOUISIANA NEED YOUR HELP.
These small communities are on the verge of becoming deadly dioxin
factories. Residents' health and welfare are at stake. They have decided,
"Enough is Enough".
On Memorial Day of this year an historic event took place. Black and
white, rich and poor, young and old gathered for a rally against Westlake
Corporation. The day ended by hanging a 36 foot sign on Westlake's fence
that read "We're Taking Back Our Stolen Future".
On July 14, six climbers hung a banner from a rack of pipes that carry
vinyl chloride, the carcinogenic precursor to PVC, from one vinyl
manufacturer to another. The pipes go over and under highways, by-ways,
around railroad tracks, homes and parks. The message on the banner, which
was 120 feet long, read, "No More Dioxin Factories! Stop PVC - The Poison
Plastic. Environmental Justice Now! Greenpeace." One of the climbers is a
mother of two, born and raised in Lake Charles and the daughter of a
Louisiana state senator.
In a continuation of their efforts to protect their families from dioxin,
the communities are organizing a Labor Day memorial service. Unionized
workers from the area's vinyl plants, local residents living under the
cloud of poison, community environmentalists, concerned parents and
neighbors will join together to remember the friends and family members
they loved, who have died from the illnesses related to vinyl production
For more information about the event, call Greenpeace Toxics Campaigner,
Beth Zilbert, toll free at 1-888-859-0447.
VICTORIES IN THE SOUTH BRONX & IN THE COURTS
Medical Waste Incinerator Shut Down in New York
The South Bronx Clean Air Coalition celebrated a major victory last month
when New York's Republican Governor, George E. Pataki, ordered
Browning-Ferris to shut down its medical waste incinerator in the Bronx.
This decision comes after years of community opposition to the facility.
During the first three weeks of June, the incinerator exceeded permissible
carbon-monoxide levels seven times. In one instance, levels were 26 times
the permitted allowance. The incinerator's violations trace back to before
BFI bought the incinerator in 1995.
This is the only medical waste incinerator in the state of New York. It
is unclear what will happen next. There is a chance BFI will be able to
re-open the incinerator, or they may convert it into an autoclave. In the
meantime, it may become a medical waste transfer station.
Carlos Padilla, of the South Bronx Clean Air Coalition, said, "No matter
what [BFI is] coming with, they're going to find themselves scrutinized
and fought at every turn."
US Borders Closed To PCB Imports
EPA's 1996 PCB import rule was struck down on July 7 by the U.S. Ninth
Circuit Court of Appeals in San Francisco. A three-judge panel agreed
that EPA's rule change was illegal. The Sierra Club filed suit in 1996.
Activists from Greenpeace USA, Canada and Mexico, Sierra Club and other
organizations brainstormed about their concerns with EPA's new PCB rule
at the 3rd Citizens Dioxin conference in Baton Rouge the weekend before it
became effective on March 18, 1996.
EPA's decision to open the borders and allow disposal of millions of
pounds of PCBs in the US (mostly by incinerators) resulted from the
agency's blatant cave-in to political pressures from the waste industry.
Between June 1996 and July 20, 1997 large quantities of PCBs were
imported to burn in the US from Mexico and other nations under the new
According to EPA, the PCB import rule would help the waste industry earn
an additional 50 to 100 million dollars per year, create jobs, and keep
American borders free of PCBs. Fortunately, the court agreed with the
Sierra Club that the EPA failed to disclose that the new rule violated the
Toxic Substances Control Act (TSCA). Under TSCA, Congress declared it
illegal to manufacture PCBs in the US, effective January 1, 1979. The
definition of manufacture includes "to import" which EPA tried to
circumvent, claiming this was only disposal and cleanup.
Lollapalooza & Dioxin
The day-long rock concert series Lollapalooza, currently on its seventh
tour, has taken on the theme of dioxin and toxic waste. Perry Farrell,
musician and founder of Lollapalooza, became committed to working on these
issues after reading Dying From Dioxin by Lois Marie Gibbs. This year, the
touring festival includes the "Greenhouse", a tent for grassroots
environmental organizations to set up interactive games and displays to
educate concert-goers on these issues.
Chicken & Dioxin
On July 15th, the Food and Drug Administration announced a ban on the
shipment of some chickens and eggs due to dioxin contamination.
Approximately 350 producers, primarily in Texas and Arkansas, were
affected by this order. On July 20th, the Food and Drug Administration
announced that farm raised catfish was also included in the ban. This ban
is to remain in effect until producers can demonstrate that the dioxin
level in their products is below one part per trillion (ppt).
The source of the dioxin contamination was found to be soybean-based feed
distributed by two Arkansas companies. "Ball" clay, or bentonite, which
is used as an anti-caking agent in the feed, was the source of dioxin.
The clay came from a open pit clay mine in Sledge, Mississippi. It is not
known how the clay became contaminated with dioxin, although opinions
range from the possible presence of hazardous waste in the mine (clay
mines are often used as hazardous waste dumps) to the creation of dioxin
from fossil fuel combustion in clay kilns.
The FDA emphasized that the one part per trillion measurement was a "level
of concern" for a single instance of "avoidable" dioxin contamination.
This value is not a risk based standard, but was derived simply by looking
at the levels of dioxin in the chicken. Most of the non-contaminated
samples had levels in the 0.2 to 0.4 ppt range while the contaminated
chicken had levels in the 4 to 5 ppt range. The 1 ppt value was
conveniently in between. The FDA has decided to use the 1 ppt level to
evaluate all "adulterated" foods.
But the FDA has never taken action in response to the many studies that
have shown that the meat, fish and dairy products we routinely buy in the
supermarket are contaminated with more than 1 ppt of dioxin. Is the FDA
saying that 1 ppt contamination from a paper mill or incinerator is safer
than 1 ppt. Contamination from clay?
No Preventable Risk is an Acceptable Risk:
Fatal Flaws in EPA's Pulp and Paper "Cluster Rule"
On June 20th, the Environmental Protection Agency sent its new air and
water regulations for the pulp and paper industry (known as the "cluster
rule") to the Office of Management and Budget (OMB).
While neither of the options EPA considered would totally eliminate the
paper industry's reliance on chlorine, the EPA choose the GREATER of two
evils. Their recommendation calls for pulp and paper mills to switch from
elemental chlorine to chlorine dioxide in the bleaching process. The OMB
has 90 days to decide whether to adopt EPA's recommendation or submit its
own. By not requiring pulp and paper mills to adopt TCF technologies, the
EPA's final proposal discourages US mills from making chlorine free and
ultimately effluent-free paper. There is no word yet on whether the
federal government will adopt purchasing policies that favor chlorine free
Health Care Without Harm and the MACT Rule on Medical Waste Incineration
On July 25th, EPA sent a draft of its Maximum Achievable Control
Technology (MACT) Rule for medical waste incinerators to the White House
Office of Management and Budget (OMB). Under a court order resulting from
a lawsuit by the Sierra Club Legal Defense Fund and NRDC, the final rule
had to be issued by July 25th. But one week before the deadline, the
Administration received a court-approved extension until August 15, 1997.
Health Care Without Harm (HCWH) campaign members worked hard to win some
improvements in the final draft. But the June 25th version that EPA sent
to OMB still contains:
* excessive emission limits for dioxin, mercury and other pollutants;
* weak pollution prevention recommendations;
* exemptions for smaller, rural facilities for pollution control
* minimal inspection and monitoring programs.
It's a good bet that the final version of the MACT Rule for medical waste
incinerators will not adequately protect the American people from dioxin
and mercury. However, the new rules will substantially increase waste
disposal costs for hospitals. The Health Care Without Harm Covenant
presents an alternative to these increased disposal costs by minimizing or
eliminating the need for incineration through recycling, waste
segregation, alternative waste disposal methods, and the purchase of
products that can be reused and safely disposed.
"Healing the Harm," a new handbook for communities implementing local HCWH
campaigns, will be ready for distribution on September 9th.
Grants of $500 to $3000 are available for local, state or regional events
that implement the mission and goals of HCWH. The first deadline for
grant application is September 15, 1997. For more information about
Healing the Harm or to receive a grant application form, call, write or
e-mail the Health Care Without Harm Campaign c/o CCHW.
Don't forget to register for Winning Justice Step by Step, CCHW's Fourth
Grassroots Convention. Special hotel rates at the Crystal City Gateway
Marriot end on September 12. If you haven't received a registration
brochure, contact CCHW (703)237-2249.
ACTION CHECK LIST
Contact Carol Browner immediately. Urge her to finalize the dioxin
Before September 12, register for Winning Justice Step by Step,
CCHW's Grassroots Convention.
On Labor Day - act in solidarity with PVC communities in Louisiana.
Before September 15, apply for Health Care Without Harm event grant.
Order "Healing the Harm", a tool for adopting a hospital.
EPA's announcement of Pulp and Paper "Cluster Rule" and MACT Rule on
medical waste incinerators. Use their decisions to organize in your
communities for strong protections from dioxin.
Send EPA your comments on dioxin policy.
Make plans for EPA spring hearings on dioxin. If you would like to be
involved, contact the Stop Dioxin Exposure Campaign c/o CCHW.
To contact the Stop Dioxin Exposure Campaign and Health Care Without Harm:
CCHW Center for Health, Environment and Justice
P.O. Box 6806
Falls Church, VA 22040