[INTERNET USERS : Document is formatted as standard ASCII-text. The tables, charts, and text will not align properly unless a standard Courier 10 cpi. font is used to view or print out the document.] Dow Brand Dioxin: Dow Makes You Poison Great Things Edited by Jack Weinberg; Contributors include: Joe Thornton, Charlie Cray and Bill Walsh. Assisted by Bonnie Rice and Katherine Schultz CONTENTS 1. Dioxin is a Corporate Product.......................... p. 3 2. Dow Dioxin: The World's Leading Brand.................. p. 6 2.1 Chlorine 2.2 Pesticides 2.3 Polyvinyl Chloride (PVC) Plastic 2.4 Solvents 3. The Dioxin Crisis...................................... p. 13 3.1 The Global Crisis 3.2 High Local Dioxin Levels 4. Dioxin Politics: Dow's Record.......................... p. 15 4.1 Agent Orange 4.2 2,4,5-T and Dioxin in The Great Lakes 4.3 Dow's New Henchman: The CCC 4.4 The Dioxin Reassessment: Undermining Science at EPA 5. Dow's Lobbying Machine................................. p. 22 6. Dow's Convenient Myth: "Most Dioxin is Natural"........ p. 24 7. What Should Dow Do?.................................... p. 27 7.1 Initial Steps 7.2 Substantive Measures ------------------------- Appendices................................................ p. 30 Sources................................................... p. 35 SUMMARY This Greenpeace report presents evidence that Dow Chemical: * Is likely the world's largest root source of dioxin; * Has major investments in facilities whose products and wastes generate dioxin; * Protects these investments by using corporate resources and power to influence scientific and public opinion; and to shape the outcome of legislative and regulatory processes; * Corrupts efforts to reach an objective scientific and public understanding of dioxin's sources and dioxin's public health impacts. Why is there so much dioxin in the environment and in the tissues of the entire human population? Where does dioxin come from? What is its potential to harm the health of present and future generations? Proper answers to these questions is a matter of more than academic concern. To view the current debate over dioxin policy as merely a clash between competing "special interests" betrays a short-sighted vision or a mind that has been numbed. Dioxin is the most toxic synthetic substance ever studied. It now contaminates the air, water, and food chain of the entire planet. Human exposure takes place mostly through consumption of ordinary foods such as fish, meat, and milk. A growing body of evidence suggests that unless society effectively curtails dioxin generation and its environmental release, the long-term health, reproductive capacity and biological integrity of the human species may be seriously harmed. Short term corporate interests must not be permitted to obstruct or thwart society's urgent need to take precautionary preventative action to eliminate dioxin sources. Average citizens already have enough dioxin in their tissues for concern. More critically, contaminated adults pass dioxin to the fetus while it is still in the womb and to the infant through mother's milk. Both the fetus and the infant are much more sensitive to dioxin than is the adult; the full health impact on the child may not be expressed until maturity. Health impacts associated with dioxin include: * Reproductive disorders. Male reproductive disorders: reduced sperm count, testicular atrophy, abnormal testis structure, reduced size of genital organs, reduced testosterone levels and changes in sexual behavior. Female reproductive disorders: decreased fertility, inability to maintain pregnancy, ovarian dysfunction, endometriosis, and hormonal changes. * Birth defects * Increased rates of cancer, including (tumors) of numerous specific sites and all cancers combined. * Impaired neurological development and related cognitive or behavioral deficits. * Immune suppression leading to increased susceptibility to infectious disease. * Diabetes. * Other effects on or injury to the liver, thymus, spleen, bone marrow, and skin. There is ample evidence for alarm about present and future injury to the public's health from dioxin in the environment. This report shows that the root source of dioxin in the environment is industrial chlorine-chemistry. It shows how Dow Chemical and other chemical manufacturers who engage in industrial chlorine chemistry promote confusion, delay and half-measures to protect their short-term interests at the expense of the public's health. This report also proposes concrete steps which Dow Chemical could take to gain credibility, increase public confidence and begin making real progress toward a plan to move away from its dependence on dioxin associated products. 1. Dioxin is a Corporate Product In this report, the term "dioxin" is used as shorthand for the family of 210 chlorinated dioxins and furans which all exhibit similar toxicity at various levels of potency. Seventeen members of this family can be considered "super toxic." Very little of the dioxin present in the environment is either natural or inevitable. Most dioxin is the by-product of a specific set of industrial processes and products: those associated with chlorine chemistry. In order to avoid recognition of this fact, Dow and its trade association the Chlorine Chemistry Council of the Chemical Manufacturers Association (CCC/CMA) attempts to confuse and mystify all serious discussions of dioxin sources and thus disorient efforts to devise an elimination strategy for these sources. According to CCC/CMA's recent "Dioxin Reassessment Briefing Packet": "Among the natural sources of dioxin are forest fires, volcanoes, and compost piles. Man-made sources of dioxin include municipal, hospital and hazardous waste incinerators, motor vehicles, residential wood burning and a variety of chemical manufacturing processes. With so many sources, it is not surprising that scientists have detected dioxins virtually everywhere they have looked." [CCC/CMA 1994] The truth is, the data on dioxin sources paint not a confusing picture but a very clear one: dioxin is formed throughout the chlorine lifecycle, in dozens of processes in which chlorine and chlorine-containing industrial chemicals are produced, used, and/or disposed of. Dioxin formation requires only three things: a source of organic matter, a source of chlorine, and a reactive environment in which these can combine. Because organic matter is ubiquitous and reactive environments (such as fires and industrial processes) are common, it is the presence of available chlorine that is the unique and preventable factor in dioxin generation. It is only because chlorine chemistry and its products have become so widespread that dioxin formation appears to be ubiquitous. The major dioxin sources are those central to chlorine chemistry. For instance, pulp and paper mills form and release dioxin when they use chlorine gas and other chlorinated chemicals to bleach wood pulp white. Dioxin is formed in chemical plants when a wide range of chlorinated organic chemicals are manufactured -- including pesticides, solvents, chemical intermediates, and feedstocks for the plastic polyvinyl chloride (PVC). Dioxin has even been identified at the root of chlorine chemistry: in the sludges and residues from the chlor-alkali process, in which chlorine gas is produced by passing a powerful electric current through salt-water. [Rappe 1991, Andersson 1993] Even for those sources not obviously related to the chlorine industry, the presence of available chlorine turns otherwise dioxin-free processes into dioxin sources. For instance: * Automobiles are sources of dioxin because chlorinated chemicals are deliberately added to fuels; vehicles burning chlorine-free fuels do not emit dioxins. [Marklund 1990] * Steel mills emit dioxin because chlorinated solvents, cutting oils and plastics are introduced into these high-temperature furnaces. [Lahl 1993] * Recycling smelters for copper, lead, and steel are major dioxin sources because the products recycled in them contain significant quantities of PVC (cable coatings, battery casings, automobile components, and so on). * Dioxin is found at sawmills because of the use pentachlorophenol as a wood preservative. Dioxin is ubiquitous, but only because chlorine chemistry itself has become ubiquitous in the last 50 years. What about the largest dioxin sources, incinerators? Incinerators are a major dioxin source because they burn huge quantities of chlorine-containing wastes. * Hospital waste incinerators burn huge quantities of PVC plastic -- which accounts for almost 10 percent of all medical waste. [Marrack 1988] * Trash incinerators generate dioxin because of the presence of disposable PVC plastic products, which accounts for about 80 percent or more of the organically-bound chlorine in the waste stream; chlorine-bleached paper and chlorine-containing household chemicals like paints, pesticides, and cleaners provide the remainder. [Danish EPA 1993] * Hazardous waste incinerators emit dioxin because they burn chlorinated solvents or -- like those that Dow operates -- burn copious wastes from the manufacture of chlorinated plastics, pesticides, and other chemicals. A host of studies indicate a clear relationship between the burning of chlorinated organic chemical products and wastes, especially PVC, and dioxin emissions from combustion facilities. [Liberti 1983, Mahle 1980, Wagner 1993, Thiesen 1991, Thiesen 1991, Danish EPA 1993, Kanters 1993, Kopponen 1992, Christmann 1989] According to one research program at the University of Florida, "These experimental, phenomenological and theoretical studies of toxic emissions from incineration all support the physically intuitive hypothesis that reduction of chlorinated plastics in the input waste stream results in reduction of aromatic chlorinated organic emissions.... We are convinced that, when all other factors are held constant, there is a direct correlation between input PVC and output PCDD/PCDF and that it is purposeful to reduce chlorinated plastics inputs to incinerators." [Wagner 1993] Dioxin in the environment at levels that potentially threaten human health is neither natural nor unavoidable; it is the necessary result of the production, distribution and disposal of the products of chlorine chemistry. Eliminating dioxin generation will require that humans stop making the chlorine-based chemicals that inevitably lead to dioxin formation. Why does Dow attempt to obscure this clear message? Because Dow is the world's largest producer of chlorine. 2. Dow Dioxin: The World's Leading Brand Determining the ultimate responsibility for dioxin emissions from any source is complex. A single product line of any one corporation may cause dioxin emissions from a wide range of facilities around the world. For example, a company that manufactures feedstocks used for the production of PVC plastic would be responsible for dioxin releases from the manufacturing process itself; from incinerators in which the waste and tars from this process are burned; and, after the plastic products are sold distributed around the world, from the disposal or recycling of these materials in trash incinerators, medical waste incinerators, and other facilities. Thus, it would be impossible to quantify with any great accuracy the dioxin associated with the products of Dow or any other corporation. Dow is the world's largest producer of chlorine and chorine-based products, however, and it is likely that Dow is also the world's largest dioxin root dioxin source. Our method for reaching this conclusion is as follows: 1) We observe that the root source of the vast majority of the dioxin in the environment is products of industrial chlorine chemistry. 2) We identify major industrial products that result in dioxin formation during a life cycle that includes their production, use, disposal and ultimate environmental fate. 3) We note that Dow appears to produce more of these products and in larger quantities than any other producer. 4) From the above, we infer it is highly likely that Dow is responsible for more anthropogenic dioxin formation than any other company. 2.1 Chlorine About 40 million tons of chlorine are produced in the world each year. Dow is by far the world's largest single producer. At facilities in the U.S., Canada, Germany and Brazil, Dow has capacity to produce over 5.3 million metric tons of chlorine per year -- 11.5 percent of the world's total. Dow's leading competitor, Occidental Chemical, comes in a distant second, with 7.1 percent. [SRI 1993] Dow's combined chlorine production capacity is greater than that of any country in the world, except the U.S. In North America, Dow is by far the largest chlorine producer. At facilities in Freeport, TX, Oyster Creek, TX, and Plaquemine, LA, Dow produces 3.7 million tons of chlorine per year -- about a third of the U.S. Total. [SRI 1992] At a single facility in Fort Saskatchewan, Alberta, Dow produces 550,000 tons of chlorine -- almost half the Canadian capacity. [SRI 1993] Some chemical companies manufacture chlorine primarily for sale to pulp mills or water treatment plants. Dow uses most of the chlorine it makes to produce organochlorine chemicals, including plastics, solvents, pesticides, and chemical intermediates. Many of these are known to result in dioxin formation during manufacture, use and disposal. 2.2 Pesticides Dow is -- and has been since World War II -- one of the largest producers of chlorinated pesticides in the U.S. Dow was a particular leader in the production of dioxin-contaminated herbicides. During and prior to the Vietnam war, Dow became the largest U.S. supplier of 2,4,5-T, the active component of Agent Orange. This pesticide may be one of the largest historical sources of dioxin in the environment. 2,4,5-T contained 2,3,7,8-TCDD (the most toxic dioxin congener) in concentrations up to 50 parts per million, although Dow insists that its 2,4,5-T contained lower levels. [Zook 1995] The wastes from manufacture contained even higher dioxin concentrations. Use of 2,4,5-T as a defoliant in South Vietnam resulted in severe and large-scale dioxin contamination; levels in South Vietnam remain among the highest in the world. [Schecter 1995] In the U.S., use of 2,4,5-T on forests and other lands resulted in dioxin contamination at dozens of sites. [EPA 1987] Workers and Vietnam veterans involved with 2,4,5-T were exposed to significant quantities of dioxin, and numerous studies have documented elevated rates of cancer and other diseases among exposed persons. [EPA 1994a] 2,4,5-T also resulted in significant contamination at dozens of U.S. facilities where 2,4,5-T was manufactured, formulated, or disposed of. [EPA 1987] In fact, at least 27 pesticides made by Dow now or in the past are known or suspected of dioxin contamination. Some, like 2,4,5-T and Erbon, were restricted in the 1980s, but Dow continues to make other dioxin-contaminated organochlorine pesticides to this day. Of particular concern is 2,4-D, a similar pesticide that was the other component of Agent Orange. EPA has known for at least 15 years that 2,4-D is contaminated with dioxin [Esposito 1980]; this knowledge was confirmed as recently as 1993, when EPA found that technical 2,4-D contains 2,3,7,8-TCDD and 1,2,3,7,8-PeCDD at concentrations of 130 and 2600 parts per trillion, respectively. [Funk 1993] Like 2,4,5-T, 2,4-D is deliberately and directly spread into the environment during its use as an herbicide on lawns, golf courses, lakes, and rights-of-way. Although no federal agency tracks the use of pesticides, U.S. EPA estimates that farmers apply 25 to 30 million pounds of the "active ingredient" 2,4-D each year. Nonagricultural uses are estimated to add another 12 to 15 million pounds. Aqua-Kleen, a commonly used aquatic herbicide manufactured by Dow and sold by Rhone-Poulenc is 28% 2,4-D. Dow continues as the nation's leading producer of numerous other chlorinated herbicides with ring structures, which are particularly susceptible to dioxin generation. These include the pesticides 2,4-DP, MCPA, Chlorpyrifos (Dursban), and Mecoprop. 2.3 Polyvinyl Chloride (PVC) Plastic Dow is the world's largest producer of feedstocks that are used to make PVC plastic. Nearly half of all the chlorine Dow produces ends up in this single production line. Recent research has suggested that PVC plastic -- throughout its entire lifecycle -- is associated with more dioxin formation than any other product. Large quantities of dioxins are produced: * During the manufacture of PVC; * When PVC-containing products are recycled; * When buildings containing PVC construction materials burn in accidental fires; and * Most important, when PVC is burned in trash and medical waste incinerators -- by far the largest known sources of dioxin. PVC is produced in a series of steps: * The first step is the production of ethylene dichloride (EDC). At its facilities in Louisiana and Texas, Dow has capacity to produce 4.45 million pounds of EDC each year -- 26 percent of the U.S. total. Dow sells much of its EDC for export to PVC producers -- especially in Latin America or the Pacific Rim. At a single facility in Fort Saskatchewan, Alberta, Dow has capacity to produce 1.8 billion pounds of EDC, [SRI 1992] 100 percent of the Canadian total. [SRI 1993] * In the next step, Dow converts its remaining EDC to vinyl chloride monomer (VCM), a highly carcinogenic gas that is the building block for polyvinyl chloride plastic. Dow's U.S. capacity for VCM is 1.5 million pounds per year, or 17 percent of the U.S. total. In Alberta, Dow's capacity is 850 million pounds per year, 100 percent of the Canadian total. * VCM is then polymerized into "raw" polyvinyl chloride resin. PVC is not useful in its pure state, so it is formulated with various combinations of additives. These formulations are then used to produce the wide range of PVC products -- including pipes, wallpaper, tiles, furniture, clothing, toys, cable coatings, and automobile components. Dow is a relatively minor player in these latter steps of PVC production. * Dow is also involved in the production of numerous other PVC-related products. For instance, Dow is the largest producer of polyvinylidene chloride films, a chemically similar product commonly known as Saran Wrap. Dow also produces numerous PVC and PVDC mixed plastics, called copolymers. Dioxin formation is endemic to the entire lifecycle of PVC plastic starting with dioxin generation when chlorine gas is produced from salt water in the chlor-alkali process. Next, very large quantities of dioxin can be generated in the manufacture of EDC which is produced in two different ways: by processes called "direct chlorination" and "oxychlorination." Dow, like most manufacturers, uses a combination of the two. Most research has examined the oxychlorination process, because reaction conditions provide a perfect environment for dioxin formation. Indeed, numerous studies have found dioxin -- often in very large quantities -- in the tars, wastes, liquid effluents, and air emissions from the oxychlorination process [Evers 1989, Lower Saxony 1994, SFT 1993]. No data are available from Dow facilities, but dioxin concentrations as high as 6 parts per million TEQ have been identified in the wastes from another Gulf Coast EDC manufacturer. [Costner 1995] Dioxins and PCBs have even been identified in the PVC plastic itself. [SEPA 1994] More dioxin is produced when the copious chlorine-rich wastes from the manufacture of EDC and VCM are incinerated on-site at Dow facilities. Dow operates 115 incinerators at its plants [Lucas 1995], with 25 at its Freeport, TX, facility alone. [EPA 1995] Only very limited data are available concerning dioxin emissions from these incinerators. According to Dow, early tests identified dioxins in residues from the company's rotary kiln incinerator in concentrations ranging from 14 to 1055 ppb (total PCDDs only) and from its stationary tar burner in concentrations from 218 to 620 ppb (total PCDDs). [Bumb 1980] A more recent but very limited sampling program at Dow Canada found that the company's TOX and THROX incineration units -- which burn EDC-VCM production wastes at Dow's Fort Saskatchewan facility -- emit dioxins in concentrations ranging from 4.42 to 10.48 ng TEQ/m3. [Hicks 1995] These levels are orders of magnitude higher than the European Union's incinerator emission limit of 0.1 ng TEQ/m3. Based on Dow's figures, emissions from these incinerators alone total 1.5 to 2.1 g TEQ/year -- equivalent to U.S. EPA's maximum acceptable annual dose for 9.8 billion to 13.6 billion persons. Efforts Dow has made to reduce dioxin emissions at its PVC and other production plants has contained far more image than substance. In 1995, for instance, Dow announced through the press that it would reduce dioxin emissions from its plants by 90 percent by the year 2000, using a 1990 baseline. Dow's motive was public relations in the wake of "a good bit of stirring resulting from EPA's draft dioxin reassessment." According to Dow vice president Jerry Martin, "This is to assure the community that we are addressing areas where there is doubt and taking concerns into consideration." [Lucas 1995] Unfortunately, this plan will merely install new pollution control equipment on Dow's incinerators but result in no change in any of the products or processes that are the root cause of Dow's dioxin generation. In fact, a significant portion of Dow's "reductions" will be achieved simply by transferring wastes from its own incinerators to off-site incinerators, which Dow does not include in its emissions inventory. [Lucas 1995] Dow's claim that these measures would result in a 90 percent dioxin reduction is also questionable given that the company has yet to develop a full baseline inventory of all the dioxin emissions at its facilities. For instance, many of the incinerators, boilers and thermal oxidizers which routinely release dioxin at Dow facilities have yet to be tested for dioxin emissions. The concentration of the U.S. vinyl chloride industry in the Gulf Coast region allows Dow and other companies to easily ship PVC products and feedstocks anywhere in the world. Much of Dow's vinyl chloride is shipped to Asia. The production of massive quantities of vinyl chloride has resulted in other problems for Dow and its neighbors. Until 1973, Dow's standard method of disposal of waste at its Plaquemine, Louisiana facility was to dig a pit in the middle of the plant, dump the wastes and cover them with dirt. According to Dow, 273 million pounds of toxic liquid and sludge began sinking through the dirt toward a local aquifer. [Bowermaster 1993] In 1989 Dow had to buy up and relocate residents in the low-income African American Morrisonville community next door to the Plaquemine, Louisiana facility. Thus, a community and its historical and cultural roots was obliterated. [Bowermaster 1993] The greatest dioxin emissions associated with PVC, however, occur after PVC products are sold into commerce. Both PVC and PVDC (Saran wrap) form dioxin when burned [Christmann 1989, Yashuhara 1989]. PVC is the primary chlorine source -- and thus the major cause of dioxin emissions -- for virtually all of the largest known dioxin sources, including municipal solid waste incinerators, hospital waste incinerators, steel smelters, lead smelters, and copper smelters. As one of the world's largest PVC producers, Dow is the ultimate source of much of the dioxin released from these sources as well. In addition, the combustion of PVC in accidental fires in homes, buildings, and warehouses may be an extremely large dioxin source: samples after a fire at a German kindergarten in which PVC construction materials and appliances were abundant found dioxin concentrations as high as 45 ppb TEQ. [Fiedler 1993] Given the large number of such fires -- some 700,000 per year in the U.S. alone -- this may be a major but yet unrecognized dioxin source. Although Dow argues that there is not yet adequate evidence to conclude that U.S. production of PVC is a significant dioxin source, Dow has known that its EDC synthesis process is a major sources of dioxin-like PCBs since at least 1990. In that year, Dow found that "heavy end" wastes from EDC distillation at its Louisiana facility contained PCBs at concentrations up to 302 parts per million -- well over the legal limit. [Dow 1990] In fact, EPA had proposed to regulate dioxins and furans formation from EDC synthesis as early as 1988, but withdrew its proposal under pressure from another of Dow's trade associations, the Vinyl Institute, and numerous EDC-producing corporations. [Costner 1995] 2.4 Solvents Dow is the nation's largest producers of chlorinated solvents. These chemicals are used for cleaning and coating in a variety of industries, from automobile manufacturing to the dry cleaning of clothes. Some chlorinated solvents, like carbon tetrachloride, are also used as feedstocks in the synthesis of other chemicals. Dow produces a substantial portion of the nation's carbon tetrachloride, chloroform, methyl chloride, methylene chloride, trichloroethane, trichloroethylene and perchloroethylene. Dow's production capacity for these solvents totals 1.78 billion pounds per year -- 38 percent of the U.S. total -- making Dow by far the nation's largest manufacturer of chlorinated solvents. Like PVC, solvents result in dioxin formation at numerous points in their lifecycle. Manufacture of chlorinated solvents results in dioxin contamination: dioxins and furans have been identified in commercial samples of tetrachloroethylene, trichlorethylene and 1,2-dichloroethane in concentrations up to 50 ppt (total PCDD/Fs). [Heindl 1987] Hexachlorobenzene has been identified in carbon tetrachloride, trichloroethylene, and tetrachloroethylene. Additional dioxins are deposited in process wastes from the manufacture of chlorinated solvents. Still more dioxins are produced when these wastes are incinerated. No data are available to estimate the dioxin flux associated with burning of wastes from these processes. Once sold into commerce, chlorinated solvents result in still more dioxin formation. Dioxins are produced when these chemicals are used for cleaning and coating at elevated temperatures, particularly in the presence of other alkaline chemicals. [Heindl 1987] Dioxins are also produced when chlorinated solvents are used in the steel industry and their residues are introduced into high-temperature environments, such as smelters and sintering furnaces. Indeed, chlorinated solvents are one suspected cause of the very high dioxin emissions recently identified from European steel mills. [Lahl 1993] Finally, dioxins are known to be produced when chlorinated solvents are used in reactive environments in the chemical industry, as when they are used as feedstocks or reaction media for the synthesis of other chemicals. [Drechsler 1992, Hutzinger 1988] Still more dioxin is produced when chlorinated solvents are incinerated. Spent chlorinated solvents are one of the leading wastes burned in commercial hazardous waste incinerators and waste-burning cement kilns. In 1983, an estimated 1.1 million tons of chlorinated solvents were available for disposal by incineration, according to EPA. [Oppelt 1987] These wastes, along with wastes from the manufacture of chlorinated chemicals, are the leading chlorine source in hazardous waste incinerators and thus the major cause of dioxin emissions from these facilities. EPA estimates that these facilities release 120 to 1200 grams (TEQ) of dioxins into the air each year, with a median estimate of 409 g TEQ/year -- not including additional dioxins deposited into ash and other residues, making hazardous waste incinerators third largest of all identified dioxin sources. [EPA 1994b] Further, EPA admits that these may be underestimates due to upset conditions and other operational problems that increase dioxin emissions during routine operation. As the largest manufacture of the major dioxin precursor in these facilities, Dow can be considered the ultimate source of a substantial fraction of this dioxin. 3. The Dioxin Crisis Dioxins are troublesome not only because they are extremely toxic, but also because they are extremely persistent in the environment and because they bioaccumulate in fatty tissues of living things. Dioxins resist degradation in the environment for decades or centuries. They are very soluble in oil but not in water and so are attracted to living tissues which then can not excrete them. Dioxins move up the food chain and are magnified in concentrations, reaching levels in predator species (such as humans) that are millions of times greater than their concentrations in the ambient environment. 3.1 The Global Crisis Because of their persistence and tendency to bioaccumulate, dioxin's have become a long-term global pollutant. These compounds are now distributed absolutely everywhere on the planet; they contaminate our food supply; and the entire human population now carries a substantial burden of these chemicals in our bodies, particularly in fat and mothers' milk. Even in remote polar regions, far from any known dioxin source, native peoples carry some of the highest levels of dioxins in their tissues of anyone on earth. [deWailly 1994] This is of great concern because of dioxin's extreme toxicity. Dioxin remains the most toxic synthetic chemical known to science. It is an extremely potent carcinogen, causing an increase in cancer risk at numerous sites in truly infinitesimal quantities. But recent research indicates that it is dioxin's effect on reproduction, child development, and the immune system that are of the greatest concern. We now know that dioxin acts as a powerful "environmental hormone," disrupting the endocrine system which the body uses to delicately regulate a wide range of physiological functions. Dioxin interferes with the body's natural signaling hormones, resulting in such effects as feminization of male offspring, reduced sperm counts, altered sexual behavior, endometriosis, birth defects, reduced IQ in developing children, weight loss and "wasting" syndrome, and suppressed immune defenses against infectious disease. [Birnbaum 1994, EPA 1994a] Several lines of scientific evidence indicates that global dioxin pollution has already reached a level that threatens human health: * First, there appears to be no safe dose of dioxin -- no threshold below which effects do not occur. [Portier 1993, Tritscher 1995, EPA 1994a] Thus, even the low doses to which the general population is subject may cause subtle impacts on human health. * Second, the background exposures and body burdens to which the general population in industrialized countries is subject is already in the range at which metabolic, reproductive, developmental, and immunological effects have been documented in laboratory animals.[Webster 1995, Birnbaum 1994, EPA 1994a] * Finally, there is no doubt that the quantity of dioxins now in the environment has caused severe health damage to wildlife -- particularly species high on the food chain, such as bald eagles, marine mammals, and other species in the Great Lakes, Baltic Sea, and elsewhere. [Reinjders 1992, Fox 1992] If dioxin levels are high enough to cause these effects in wildlife, humans, who are high on the food chain but have slower generation times, are also at risk. Thus, global dioxin contamination poses a long-term, large-scale hazard to the health of humans and other species. Indeed, the effects may be occurring already: we know that sperm counts have declined substantially across the world in the last 50 years [Lancet 1995], and rates of most types of cancer and endometriosis have also increased steadily. [Rier1993, Davis 1990] Global dioxin pollution threatens the viability and quality of life of future generations. It is clearly time for action to stop all further releases of dioxin into the environment. 3.2 High Local Dioxin Levels Although the main focus of this report is dioxin as a toxic environmental pollutant of global concern, dioxin pollution represents an especially acute problem for many communities near incinerators and near chemical plants that engage in industrial chlorine-chemistry. A case in point is Midland, Michigan, Dow's headquarters community. According to a U.S. EPA memo dated July 30, 1985, the most toxic form of dioxin, 2,3,7,8-TCDD is found at concentrations one or two orders of magnitude [ten to one hundred times] greater in Midland soils than in the soils sampled from other industrial areas. Average soil concentrations around the Dow facility were approximately 150 times greater than the average calculated from the perimeter of an Armco plant. Concentrations in so called "public use areas" in Midland average 30 times those found in similar areas in Middletown, Ohio. [EPA, 1985] This memo also states: "Midland is unique as compared to other areas where dioxin has been found. For instance, a portion of Midland's population has had occupational exposure to PCDDs and PCDFs as reported by Dow Chemical. The extent of this exposure is uncertain." "... [A]n open question remains if continued exposure to PCDDs and PCDFs via soil or air for certain subpopulations of Midland residents is acceptable. Some consideration must also be given to the already suggestive health data from Midland County which indicates an abnormally high rate of soft tissue sarcomas among women and an early 1970's rise in birth defects of compatible etiology with 2,3,7,8-TCDD. [EPA, 1985]" 4. Dioxin Politics: Dow's Record Controversy about dioxin as a health threat is nothing new. Dow and other chemical companies were aware as early as 1963 that dioxin was extraordinarily toxic and occurred as a contaminant in at least some Dow products, including 2,4,5-T. Since then, ever-more convincing evidence has emerged showing that dioxin poses a real hazard to public health on a global scale. But Dow and others continue to manufacture chlorine and the related products that cause dioxin contamination; in fact, global chlorine production has increased by over 50 percent since 1970. [SRI 1993] Why has nothing been done to address the dioxin threat? The answer lies in the immense power of Dow and other chemical industry actors. Starting during the Vietnam war, when it covered up the presence of dioxin in Agent Orange, to its present role in derailing EPA's dioxin reassessment and dismantling U.S. environmental regulation, Dow has impeded efforts to restrict dioxin pollution. By corrupting governmental and scientific processes, Dow has used its immense influence to protect its profitable products from efforts to protect the public's health. In 1994, Dow Chemical had over $20 billion in revenues. [Fortune 1995] A thorough and comprehensive investigation of Dow's manipulation of the science and the politics of dioxin is beyond the scope of this report. The topic is too massive and a full picture would require greater resources and authority than Greenpeace possesses, such as the power to subpoena witnesses and punish perjury and contempt. More investigation is certainly warranted based upon the information that Greenpeace has been able to assemble in this report from the public record. Dow's first line of dioxin defense can be understood as a conspiracy to withhold or skew scientific information about dioxin in ways that inhibit the development of effective public policy to protect public's health. This short-term and narrow interpretation of Dow's corporate interest interferes with legitimate health interests of the general public and also with specific health interests of workers, veterans and communities located near Dow facilities. 4.1 Agent Orange The first chapter of Dow's dioxin history began with the manufacture of 2,4,5-T in 1950 at its Midland facility. As revealed in federal court documents and summarized in a 1983 New York Times story, Dow knew of the presence of dioxin in the Agent Orange it produced for at least seven years before it reported the problem to the government. [Blumenthal 1983] As early as the mid 1950s, European manufacturers discovered the presence of a highly toxic contaminant in 2,4,5-T and identified it as dioxin; one company notified Dow in writing of the problem in 1957. Dow did nothing, until 1964, when an outbreak of chloracne -- a hallmark symptom of dioxin exposure -- occurred among workers in its Midland production line, and a research laboratory detected dioxin in the final 2,4,5-T product. Subsequently, Dow invited several other 2,4,5-T manufacturers (including Monsanto and Hooker Chemical -- now Occidental) to Midland to discuss the scientific and political implications of the finding of "highly toxic impurities" in their Agent Orange production line; the representatives explicitly discussed the need to adopt a strategy to avoid Government regulation based on this new hazard. According to a 1965 internal memo written by Dow's toxicology director, Dr. V.K. Rowe: "As you well know, we had a serious situation in our operating plants because of contamination with 2,4,5-trichlorophenol with impurities, the most active of which is 2,3,7,8-tetrachlorodibenzo-p-dioxin." "The material is exceptionally toxic; it has tremendous potential for producing chloracne and systemic injury." "One of the things we want to avoid is the occurrence of any acne in consumers. I am particularly concerned here with consumers who are using the material on a daily repeated basis, such as custom operators may use it." "If this should occur, the whole 2,4,5-T industry will be hard hit and I would expect restrictive legislation, either barring the material or putting very rigid controls upon it. This is the main reason why we are so concerned that we clean up our own house from within, rather than having someone from without do it for us...." "I trust that you will be very judicious in your use of this information. It could be very embarrassing if it were misinterpreted or misused." Not until 6 years later -- in 1970 -- did Dow did report the discovery of dioxin in 2,4,5-T to the government. Throughout this period, Dow continued to make and sell contaminated Agent Orange to the U.S. armed forces for use in Vietnam. Dow became the largest of all U.S. Agent Orange contractors, selling nearly one-third of the total 12.8 million gallons supplied to the Government. This Agent Orange continued to be used in South Vietnam; millions of veterans and South Vietnamese citizens were exposed to the pesticides and its contaminants. After the Vietnam War ended, thousands of veterans exposed to Agent Orange struggled to receive compensation for their injuries. Dow and numerous government officials continued to cover up their own knowledge of dioxin's toxicity and deny that dioxin caused any illnesses besides chloracne. In public relations work Dow suggested that many of the veterans' problems were merely psychological. 4.2 2,4,5-T and Dioxin in The Great Lakes Even after the Pentagon ceased using Agent Orange in 1970 due to reports of toxic effects on Vietnamese civilians, domestic use of 2,4,5-T continued for 9 years. In 1973, EPA attempted to cancel the registration for 2,4,5-T, but the agency yielded to industry's demand for further study. In 1977, a citizens' suit in Oregon and an EPA study correlating human miscarriages with the spraying of 2,4,5-T and other contaminated herbicides in Oregon led EPA to issue an emergency suspension of 2,4,5-T registration. Dow challenged EPA's decision and the validity of the EPA study, and the issue was tied up in legal and legislative battling for the next six years. Only in 1983, when scientific documents were leaked which clearly established the role of dioxin in the Oregon miscarriage studies, was Dow forced to retreat. EPA began an investigation into the matter, and Dow voluntarily withdrew the registration of 2,4,5-T. [Merrell 1987] Dow and a local partner in New Zealand continued to produce 2,4,5-T until 1987. In 1988, newspapers revealed that vast quantities of 2,4-D and 2,4,5-T had been dumped in South Africa, one of the last countries to allow 2,4,5-T to be used. [Africa News 1988] During this same period, concern begin to grow about dioxin contamination of the Great Lakes food chain. Environment Canada had found dioxins in fish and in bird eggs, with the highest concentrations in Saginaw Bay gull colonies, near Dow's Midland facility. EPA's Great Lakes Region V office prepared a report on the problem, which discussed the hazards of dioxin in light of the evidence on Agent Orange and the Oregon miscarriage study. The report named Dow as a major dioxin source and recommended that the consumption of fish from the Tittabawassee River and Saginaw Bay, both near Dow Chemical, should be prohibited. [Merrell 1987] Before Region V's report could be released, however, EPA officials in Washington edited the report, deleting all references to Dow, the Oregon miscarriage study, and to Agent Orange. The new sanitized report, which was released to the public in 1981, also deleted all recommendations concerning human health and consumption of Great Lakes fish. Not until 1983 did a congressional investigation reveal that EPA officials, at Dow's behest, had changed the contents of the report, and several EPA top officials were forced to resign their posts. 4.3 Dow's New Henchman: The CCC During the late 1980s, most controversy around dioxin focused on the pulp and paper industry. But in the early 1990s, Dow was again confronted with a wave of anti-chlorine public opinion. From 1991 to 1993, such organizations as Greenpeace, Great Lakes United, the International Joint Commission on the Great Lakes, the American Public Health Association, the Michigan Medical Association, the Barcelona Convention on the Mediterranean Sea, the Paris Commission on the Northeast Atlantic, and many others called for broad restrictions on chlorine and/or organochlorines. The Chemical Manufacturers' Association -- of which Dow is the second largest member -- launched a new trade group, the Chlorine Chemistry Council, to handle public relations, political lobbying, and "scientific initiatives" on all issues for the chlorine industry. From its origin, the CCC was a Dow-led effort. The Council's first managing director was Brad Lienhardt, a career-long Dow employee. According to Chemical and Engineering News, the CCC's estimated 1994 budget was $12 million. In-kind contributions to the CCC-led effort from member companies was estimated at ten times that amount. This put the estimated 1994 resources of the CCC at over $130 million. [Hirl 1994] The CCC made its muscle apparent. It published a thousand-page "scientific" report, prepared by consultants which reviewed the toxicology of a wide range of organochlorines and concluded that chlorinated organic chemicals can not be regulated as a class, and that as currently used, they are safe for health and the environment. Some consultants who helped prepare and review this report were respected academics who subsequently became vocal critics of environmental groups and agencies seeking to phase-out or restrict chlorinated chemicals. The CCC contracted with public relations firms and hired its own public relations staff. In 1994, it got an opportunity to flex political muscle when the Clinton White House proposed that EPA conduct a study of the environmental and health impacts of chlorinated organic chemicals. The CCC immediately expressed "outrage". It generated, by its own estimate, a million letters to Congress. CEO and other senior officials were instructed to contact a long list of representatives, cabinet members, and executive branch appointees. The CCC sought to generate hysteria by mischaracterizing the proposed study as "EPA's Recommendation to Ban Chlorine." [Lienhardt 1994] Dow wrote to all its customers and requested that they and their employees write to the President and Congress and oppose any study of chlorine. [Sosville 1994] Dow told the press and its employees that EPA planned to "ban" chlorine and that Dow's Michigan division, "which employs about 3500 people, doesn't have replacement products in mind should chlorine be banned." [Henze 1994] Dow CEO Frank Popoff mischaracterized the proposed study as "EPA is trying to ban an element on the periodic table." [Popoff 1994] CMA officials met with cabinet members and secured a "moderating statement." Ultimately, Congress and EPA failed to act on the proposed study. 4.4 The Dioxin Reassessment: Undermining Science at EPA In 1994, EPA scientists released the long-awaited draft of their Dioxin Reassessment. This document was prepared over the course of three years by scientists at EPA, the National Institute of Environmental Health Sciences, and other agencies, was reviewed by numerous expert panels during the drafting processes, and was aired in pre-draft form at public hearings in several cities. The document concluded that dioxin was an extraordinarily potent environmental hormone, caused a wide variety of toxic effects, and that background exposures may already be in the range at which health effects can occur. The authors of EPA's report also published the majority of their findings in peer-reviewed scientific journals and books. Dow and the CCC moved immediately to undermine EPA's alarming findings. CCC organized a public relations push, and EPA public hearings in Washington on the reassessment were dominated by the CCC's hired scientific consultants. The main thrust of the Dow/CCC offensive, however, centered on the EPA Science Advisory Board, which was slated to review the draft reassessment. The SAB held one meeting to receive public comment: testimony consisted of a fifteen minute presentation by a single environmental group and thirteen presentations by industry and its consultants, for a total of 3 hours and 40 minutes. The CCC and its consultants made several separate presentations at which EPA's conclusions were attacked in the most strident tone. More significantly, the chemical industry's influence extended to members of the SAB panel, the group given the task of drafting the SAB's review of the Dioxin Reassessment's chapters covering health risks associated with dioxin in the environment. Two individuals stand out: William Greenlee, a Scientist then at Purdue University, and John Graham of the Harvard Center for Risk Analysis. Observers close to the review process have identified Greenlee and Graham as the two members of the SAB health panel who most actively and consistently challenged the validity of the dioxin health risk conclusions contained in the EPA Report. Greenlee and Graham were the panel members who pressed most vigorously and effectively for an outright rejection of the risk characterization section of the report. Were Greenlee and Graham truly objective reviewers? During an SAB meeting in May, 1995, panel members were asked to disclose research grants in dioxin-related fields. The transcript shows that Greenlee stated: "I'm Bill Greenlee from Purdue University. In addition to funding from NIH, I have received research grants from the American Forest Paper Association and General Electric, and I've also received gifts for research from Chemical Manufacturers Association and Dow Chemical." [ECR 1995] The descriptive term "gifts for research" is highly unusual. Why does Greenlee distinguish these from his "research grants." Records from the Purdue University School of Pharmacy and Pharmacal Sciences describe grants from Dow and CMA to Greenlee as having been awarded for a "dioxin research program" for the period July 1, 1994 through June 30, 1995. [Purdue, 1995] These grants amounted to $45,000 from Dow and $75,000 from CMA. Greenlee's "dioxin research program" also reportedly received $65,000 from the American Forest & Paper Association (AFPA) during the same period. [Purdue, 1995] In addition, Greenlee received a 1993-94 grant from the AFPA for $973,800 to study "Development of a Biological Basis for Dioxin Risk in Humans. [Purdue 1994] In a private conversation with editors of the newsletter "Waste Not," Greenlee confirmed he had administered grants to study dioxin for several million additional dollars from the AFPA prior to his tenure at Purdue. AFPA is the industry organization serving as the primary representative of pulp and paper manufacturers opposing regulations and legislation to curtail dioxin emissions from mills that bleach with chlorine-based chemicals. CMA (together with its subsidiary, the Chlorine-Chemistry Council) is the industry organization serving as the primary representative of the chlorine-chemistry industry on dioxin-related matters. Dow Chemical is probably the world's largest root source of dioxin. Greenlee's history of service to these organizations helps explain a strangely candid comment in the transcript of the SAB panel's May meeting. Commenting on "very personal questions about our own biasas," Greenlee said "Those of us for whom dioxin supports our family, sometimes we keep looking for problems that aren't necessarily there because it puts food on the table." [ECR] John Graham serves as director of the Harvard Center for Risk Analysis. In the month prior to the SAB meeting, Graham's Center organized a high-profile conference on drinking water and health risks, "financed by a grant from the Chlorine Chemistry Council and the Chemical Manufacturers' Association." [CCC 1995] Graham's Center has also received unrestricted grants of funds from Dow Chemical in the years 1990, 1991, 1992 & 1993. In addition, his Center has received unrestricted grants of funds from several other companies with a strong interest in the outcome of EPA's Dioxin Reassessment including: CIBA-GEIGY, DuPont, GE, Georgia-Pacific, Hoechst-Celanese, ICI, Kodak, Monsanto and Olin. Individuals like Greenlee and Graham, whose careers are enhanced by their ability to raise large sums from dioxin-interested corporations should not have agreed to participate on the health panel. They should have recused themselves to avoid the perception of a conflict of interest. Instead, both vigorously participated in the work of the panel intervening at every occasion to challenge and downplay EPA's characterization of health risks associated with dioxin. At the time of this writing, the SAB panel's report is not yet complete (though a final draft will likely be complete by time this report is released). The likely final product will be a consensus document that makes no one happy. On the one hand, scientific evidence presented by EPA linking minute levels of dioxin in the environment to potential public health injury is so strong it is unlikely efforts by panel members such as Greenlee and Graham to utterly discredit EPA conclusions will prevail. On the other hand, by the nature of consensus, strong disagreements on the panel will likely be reflected in language that muddies the EPA's conclusions and helps lay the basis for further delays in taking action. As such, Dow and its chemical industry allies will have achieved another victory. Delay and confusion have always been primary industry goals. This is the third EPA dioxin reassessment in 10 years, and the existence of an on-going reassessment has been used as an excuse for making no decisions in the interim. Each new study has been undertaken at the urging of the chemical and paper industries. The chemical industry made its "delay by studying" strategy clear at a CCC strategy session held in 1994. The newspaper "In These Times" obtained the notes of a guest at the meeting: "The speakers acknowledged that industry is vulnerable to being regulated because "dioxin can go in any direction" as a public relations issue. People don't have a bad idea of chlorine, but they do about dioxin. We were cautioned to "downplay the connection." "We were also warned that chlorine customers are very concerned about chlorinated hydrocarbons that contaminate the environment and act as estrogen mimickers that disrupt the body's glandular system. We were advised to respond to questions with long-term scientific predictions -- 10 years in the future -- that cannot be verified. They said "USA Today" in particular cannot resist such predictions. And they advised, "If you ever come across research that is negative, just talk about the need to do more research and study the issue. [Bleifuss 1995] 5. Dow's Lobbying Machine In 1995, with the election of a conservative Congress, CCC and the CMA had the opportunity to go on the offensive. Dow and the CMA have both played a key role in lobbying Congress to dismantle 20 years of environmental regulations, including proposals to gut enforcement of the Clean Water Act, Clean Air Act, Superfund, the Resource Conservation and Recovery Act, and the Community-Right-to-Know Act, which requires companies to inform the public of the types and quantities of toxic chemicals they discharge into local communities. Dow also played a lead role in a Congressional provision to undermine workplace safety protections under the Occupational Safety and Health Act. [Maraniss 1995] Dow opposes OSHA because occupational safety concerns have led many industries to reduce or eliminate use of several Dow products including chlorinated solvents and certain pesticides. Dow and the CMA have had some of their greatest legislative victories on dioxin, in particular. The FY 1996 EPA Appropriations Bill, recently passed by the House but not yet law, would cut EPA's overall budget by 33 percent and could cripple new dioxin-related regulations on pulp mills and incinerators. The bill could also prevent EPA from considering certain types of scientific information on dioxin exposure and hazards, and it could remove the agency's authority to finalize its dioxin reassessment. Dow's lobbying activity takes place against an important background. In the last decade, Dow gave politicians running for national office more than $1 million in PAC and "soft" money, according to Federal Election Commission records. In the 1992 election alone, Dow and other top chlorine producers gave more than $1.4 million to Congressional campaigns. [Paulsen 1993] Another analysis of FEC records found that Dow's 10 political action committees gave a total of $1.1 million to political candidates from January 1989 to November 1994. [PIRG 1995] Much of Dow's anti-regulatory campaigns happen under the cover and anonymity of trade associations and other D.C.-based lobby firms. Meanwhile, Dow attempts to maintain a "green image" before the public. Besides its membership in the CCC and the Chemical Manufacturers Association, Dow also participates in numerous other industry front groups, such as the Vinyl Institute, the National Association of Manufacturers, the U.S. Chamber of Commerce. Each of these is armed with lawyers and lobbyists who daily stroll the corridors of Congress, the EPA and the White House, influencing public policy in ways unimaginable, and inaccessible, to ordinary citizens. Each of these has a public relations budget, and staff to write op eds, testify before Congress or the EPA, appear on news shows as "experts," speak to civic groups. These in turn support a relatively new industry of "grass roots" lobbying firms, who specialize in spreading a carefully scripted industry line to millions of business owners and workers, and manufacturing groundswells of carefully orchestrated "citizen" support (letters, phone calls, e-mail, telegrams) for the priorities dictated by Fortune 500 corporations. This network provided the model and infrastructure for Dow's massive retaliation against efforts to investigate the link between dioxin and chlorine." Dow also uses direct corporate influence peddling. For example, this year Dow has provided one of its regional lobbyists, Dale Humbert, free of charge to the staff of the U.S. House of Representatives Commerce Committee.[Midland Daily News, 8/17/95] The committee has jurisdiction over energy, public health, and environmental matters critical to Dow's chlorine business. Humbert will work for the committee for nine months on a fellowship from the Society of Environmental Toxicology. This committee is in the front lines of Congress' attack on the EPA and the basic framework of the nation's environmental protection laws. 6. Dow's Convenient Myth: "Most Dioxin is Natural" Of all Dow efforts to confuse scientific and public understanding of dioxin and its sources, the most ingenious has been Dow's promulgation of the "Trace Chemistries of Fire" theory. In the late 1970's, attention turned to dioxin pollution because of the spraying of chlorinated herbicides and the effects of dioxin on Vietnam veterans exposed to it as a contaminant in the herbicide Agent Orange. Producers of chlorinated herbicides faced the possibility of restrictions on their products and massive class-action claims for health effects among exposed veterans. In 1980, at the height of this activity, Dow Chemical, which had been the largest producer of Agent Orange, published a novel theory in the prominent scientific magazine Science. Dioxin, Dow said, is a natural chemical, occurring in any and all combustion processes, including forest fires, volcanoes, and household stoves. [Bumb 1980] Dow's conclusion: dioxin is not a pollutant uniquely associated with the modern chemical industry but has in fact been with us "since the advent of fire." [Crummett 1979] In support of this "Trace Chemistries of Fire" theory, Dow's scientists cited data that dioxins are ubiquitous in soils, sediments and the residues from many types of incinerators, including those at its own chemical plants. Perhaps, Dow suggested, dioxin is formed from the presence of salt -- which is everywhere -- in any type of fire. Dow's implication was that "natural sources" were and always had been more important dioxin sources than the chemical industry. To this day, Dow and its allies repeat the claim of "natural dioxin." Responding to concern raised by EPA's 1995 dioxin reassessment, for instance, the Chlorine Chemistry Council emphasized the importance of volcanoes and forest fires as dioxin sources. A lengthy technical report prepared for the CCC by the American Society of Mechanical Engineers, purported to find that dioxin is formed in any and all combustion devices irrespective of the presence of chlorinated chemical products. [Rigo 1995] A study by Dow in Europe argued that there was no relationship between dioxin emissions from a German trash incinerator and the feed of chlorinated wastes to the facility. [Mark 1994] CCC submitted both documents to EPA as continuing proof of the "trace chemistries of fire" theory. Dow's own data, in fact, contradict its theory. The data in Dow's original paper indicate that Dow facilities are far more important dioxin sources than is nature. Although dioxin was found in trace amounts in soil samples from urban areas, soil samples from Dow's facility in Midland, Michigan, contained dioxin in concentrations thousands of times higher. And while trace amounts of dioxin were found in residues from combustion in automobiles, home fireplaces, and cigarettes, the dioxin levels found in particulate matter from Dow's own incinerators were orders of magnitude higher. Somehow, these facts were not acknowledged in the text of Dow's article. Dow and its allies continue to argue in support of this theory --and to sow confusion -- even though the theory has been definitively proven false. EPA's Dioxin Reassessment -- the most thorough inventory of dioxin sources ever assembled -- makes clear that if any dioxin is produced naturally, the quantities are negligible: EPA shows that more than 99 percent of all dioxin comes from industrial sources. [EPA 1994b] At the Dioxin 1995 Symposium, this general conclusion, if not the exact numbers, was confirmed in a study that concluded: 1) The amount of dioxin in a soil sample can be used to reliably estimate atmospheric dioxin deposition; 2) The amount of dioxin in soil core samples decreases as we go back in time (down in depth); 3) There was very little dioxin in the environment before 1935. [Brzuzy and Hites] If Dow's theory were valid and most dioxin in the environment occurs naturally from ordinary combustion, why was there so little dioxin in the environment 60 years ago? Forest fires and volcanoes have been with us for millennia. Coal burning has been with us a lot longer than 60 years. Work by other scientists has also disproved Dow's claim. Several independent studies have examined the dioxin levels found in the preserved tissues of ancient humans to see if, indeed, dioxin has always been a significant pollutant. These studies have found that dioxin levels in the tissues of ancient humans are no more than one to two percent of the amount found in modern humans. [Schechter 1991, Ligon 1989] According to EPA, "The theory that much of today's body burden could be due to natural sources such as forest fires has been largely discounted by testing of ancient tissues which show levels much lower than those found today." [EPA 1994b] In addition, studies of sediments in the Great Lakes [Czuczwa 1986] show that dioxin was virtually non-existent until the 20th Century; levels began to climb towards their current concentrations only after World War II. This pattern corresponds to the development and expansion of the chlorine chemical industry but bears no relationship to the increasing use of combustion to burn coal. In fact, some of the highest levels of dioxin were from Saginaw Bay, downwind and downstream from Dow Midland. According to the authors, "There is an abrupt increase in PCDD and PCDF concentrations around 1940.... Starting at thi s time, the production of chlorinated organic compounds such as chlorobenzenes and chlorophenols increased substantially. These compounds are used in a variety of products, including building supplies, herbicides and packaging. Much of these materials eventually become incorporated in solid wastes. The trend for the production of chloro organic compounds is very similar to the sedimentary PCDD and PCDF profiles. The agreement between these two trends is convincing despite the uncertainties introduced by sediment mixing and the errors inherent in the dating and quantitation techniques." "The concentrations of PCDD and PCDF are highest in those sediments collected closest to urban areas [those in Saginaw Bay] and lowest in the open lake cores. This indicates that PCDD and PCDF found in these samples are anthropogenic in origin.... The input of dioxins and furans to the sedimentary environment is probably due to the combustion of chlorinated organic products in various wastes. These wastes may be municipal wastes from Saginaw, Bay City or other urban areas. It is clear that the high levels of dioxins and furans found in presently accumulating sediments are not due to the advent of fire." [Czuczwa 1984] 7. What Should Dow Do? Dow has been aware of the association between dioxin and its products for thirty years or more. The corporation, however, has never acknowledged the full import of this problem nor developed a consistent plan to move away from its dependence on dioxin associated products. Instead, Dow has approached public and scientific debates about dioxin with a vigor and methodology that recalls the tobacco industry's participation in debates over public health implications of cigarette smoking. Dow consistently works to confuse and obscure public and scientific understanding of dioxin sources, and seeks to downplay or discredit evidence documenting dioxin's alarming health impacts. Dow works to dismantle occupational safety and health laws that provide workers some protection from Dow produced pesticides and solvents. The corporation works to dismantle clean water and clean air laws that provide some protection from the health and environmental impacts of its products. And finally, Dow vigorously opposes any government proposal to study or even look at problems associated with chlorine-chemistry, or to consider substitutes or alternatives. These policies and practices raise tension and place Dow Chemical on a collision course with environmental and public health advocates. It is still not too late, however, for Dow Chemical to step back and begin to diminish that tension. 7.1 Initial Steps Some initial steps could be helpful. Dow has made past claims about dioxin science that have been widely publicized. At a later date, many of these claims have been discredited by subsequent research and analysis. One example is Dow's "trace chemistries of fire" theory, and the claim that most dioxin in the environment is of natural origin. Dow could gain credibility by correcting the public record and acknowledging that these theories it once promoted are now discredited. Dow Chemical could gain credibility by accepting and publicly acknowledging the overwhelming evidence that most dioxin in the environment originates from the products of industrial activity, and particularly, from products associated with industrial chlorine-chemistry. Additionally, Dow could gain credibility by accepting and publicly acknowledging the potential for human health injury from dioxin exposures at or near levels presently in the environment and food supply. At a minimum, Dow could make a public statement expressing sufficient concern about potential public health impacts of dioxin using language that would counter those industry voices who continue to deny any substantial health threats associated with dioxin. In doing so, Dow could help to narrow the the areas of controversy. Finally, Dow could publicly indicate what standard of proof it would accept to justify a prudent, precautionary public policy to eliminate dioxin sources. How much proof is necessary on potential health impacts from dioxin in the environment? How much proof is necessary on the role of industrial chlorine chemistry in the chain of dioxin synthesis? Does the standard of proof Dow would require before taking preventative action regress to infinity? Or can Dow specify what type of evidence would be sufficient to change its stance and policy? On the political front, Dow Chemical can also take confidence building actions. Dow could publicly oppose U.S. Congressional efforts to weaken or dismantle dioxin-related regulations and federal laws such as the Clean Water Act, the Solid Waste Disposal Act, the Clean Air Act, Superfund and OSHA. Dow could reconsider its strong condemnation of a 1994 Clinton Administration proposal for the EPA to "study" health effects of chlorinated organic chemicals and to explore a strategy for "substituting, reducing, or prohibiting the use of chlorine and chlorinated compounds." Dow could instead endorse and welcome such a study. Dow could endorse proposals for "development of a global, legally binding, instrument for the reduction and/or elimination of emissions and discharges of certain Persistent Organic Pollutants (POPs)" that will be considered at an intergovernmental meeting sponsored by the United Nations Environmental Program on "Protection of the Marine Environment from Land-based Activities," to be held in Washington DC, October 1995. In particular, Dow should endorse proposals to make dioxin a subject to such an instrument. If Dow takes the steps described above, there would still remain important substantive issues to be addressed. Still, confidence-building measures like the above, could pave the way toward meaningful dialogue and interchange. 7.2 Substantive Measures Moving beyond confidence building, Dow Chemical has three product lines that make the largest contribution to dioxin in the environment: 1) Ethylene dichloride and Vinyl Chloride Monomer: the basic feedstock in the manufacture of chlorine-containing plastics. Most dioxin in the environment is created during the manufacture, incineration or combustion of these products. 2) Chlorinated solvents. These substances pose serious health problems in the workplace and in adjacent communities. They are associated with dioxin in their manufacture, incineration and ultimate environmental fate. 3) Chlorine-dependent pesticides. These pose serious health problems to workers and consumers; they also disrupt ecological balance. Many are associated with dioxin in their production and also may be dioxin-contaminated. Because society now depends on these substances for many applications, an immediate halt to their production and use might create unacceptable economic and social disruption. Still, Dow Chemical has developed or is working on viable alternatives and substitutes for most of these applications. Real progress could be made if Dow announced or began discussions to establish timetables for the phaseout of these products that are as rapid as practical, and that are planned to avoid economic or social dislocations to consumers, workers and communities. Even after timetables for the phaseout of these three major Dow product lines have been announced, issues of environmental toxicity and dioxin formation associated with other Dow products and processes would still need to be addressed. However, in the context of real progress on the issues detailed above, there would be good reason for optimism in finding agreement in those other areas as well. APPENDICES Appendix 1 Chlorine-containing Products Made by Dow USA, 1992 Product Annual Production % of Total Capacity (million lbs/yr U.S. Capacity ----------------------------------------------------------------- * Chlorine 8,140 31 -- PVC-related chemicals * Ethylene dichloride 4,450 26 Vinyl chloride 1,500 17 Vinylidene chloride PVC vinyl films PVDC films PVC/VDC copolymers Vinyl/benzyl chloride copolymers -- Solvents * Carbon tetrachloride 180 31 Chloroform 240 50 Ethyl chloride 10 3 Methyl chloride 300 51 Methylene chloride 300 46 1,1,1-Trichloroethane 500 51 1,1,2-Trichloroethane * Trichloroethylene 120 38 * Tetrachloroethylene (PERC) 140 19 1,3-Dichloropropene Propylene dichloride Chlorine-containing Products Made by Dow USA, 1992 (continued) Annual Production % of Total Product Capacity (million lbs/yr U.S. Capacity ----------------------------------------------------------------- -- Chemicals for other plastics * Epichlorohydrin 420 67 Phosgene 400 19 * Allyl chloride Chlorostyrenes Chlorosilanes Chlorinated polyethylene Bis (2-chloro-1-methylethyl) ether 100 -- Pesticides and their feedstocks Chlorpyrifos 100 * 2,4-D and esters and salts * 2,4-DP and esters and salts * MCPA and esters and salts * Mecoprop and esters and salts Triclopyr 100 Chloroacetic acid 30 38 Chloroacetyl chloride 100 4-chloro-2-cylclopentylphenol 100 * 2-chloro-4-phenylphenol 100 2-chloropropionic acid 100 2,2-dichloro-1,1-difluoroethyl methyl ether 100 * 2,4-Dichlorophenol 100 2,3-Dichloropropionic acid 100 2,2-Dichloropropionic acid 100 Ethyl chloroacetate * o-Benzyl-p-chlorophenol Sodium chloroacetate 1-3-chloroallyl-3,5,7-triaza-1-azoniaadamantane 100 Blanks in Appendix 1 indicate no data available. All products made at one or more of the following Dow facilities: Freeport, TX; Laporte, TX; Midland, MI; Oyster Creek, TX; Pittsburgh, PA; Plaquemine, LA. Source: Stanford Research Institute. Director of U.S. Chemical Producers. Palo Alto: SRI International, 1992. * Dioxin contamination known or suspected, in product. Appendix 2 Current or Past Dow Pesticides With Known or Suspected Dioxin Contamination Dioxin Contamination Known Still produced? ----------------------------------------------------------------- 2-Chloro-4-phenylphenol Yes Chloranil No Chlorophenols, "various" Yes 2,4-D and salts Yes 2,4-DP and salts Yes 2,4-dichlorophenol Yes Erbon No Hexachlorphene No Pentachlorophenol and salts No Ronnel No 2,4,5-T and salts No 2,4,5-Trichlorophenol No 2,3,4,6-Tetrachlorophenol No 2,3,4,6-Tetrachlorophenol No Dioxin Contamination Possible Still produced? ----------------------------------------------------------------- Allyl chloride Yes o-Benzyl-p-chlorophenol Yes Crufomate No DDT No p-Dichlorobenzene No 2,4-dichlorophenol Yes 3,4-dichloroaniline No Dinitrobutylphenol No MCPA Yes Mecoprop esters and salts Yes Picloram No 2,3,4-Trichloropropane No Sources: Esposito 1980, PTTN 1985, HSDB 1995. Includes pesticides known or suspected of contamination with PCDDs, PCDFs, and HCB. Appendix 3 Dioxin Sources in Which PVC is the Major Chlorine Donor Ranking among Dioxin emissions all known sources to air in U.S. g TEQ/yr ----------------------------------------------------------------- #1 Medical waste incinerators 5100 #2 Municipal solid waste incinerators 3000 #6 *Copper smelters 230 #11 Lead smelters 1.6 Steel smelters ? Accidental fires ? EDC manufacture ? Source: U.S. EPA 1994b. Emissions estimates based on EPA's median estimate for each source. Does not include dioxin deposited in ash or other residues. * NOTE: According to Dr. Paul Connet, Chemistry Department, St. Lawrence University, this figure should be closer to 8,000 to 9,000 grams TEQ/yr for plants operating in 1993. He bases this on emmissions measured from ten incinerators that were not included in the 1994 EPA Dioxin Reassessment numbers, but which were reported in a memorandum from the EPA dated July 27, 1995. ================================================================= Appendix 4 Industrial Chemicals Made by Dow Known to Result in Dioxin Generation in Manufacture Chlorine Ethylene dichloride (feedstock for PVC) Carbon tetrachloride Tetrachloroethylene Trichloroethylene Epichlorohydrin Allyl chloride Sources: Heindl 1987, Rossberg 1986, Rappe 1991, Evers 1989. SOURCES Africa News, September 5, 1988. Andersson, P., et al. Analys av Polyklorerade Dibensofuraner och Polyklorerade Dibensodioxiner i Processprover fran Hydro Plast AB. University of Umea, Sweden, 1993. Birnbaum, L. The mechanism of dioxin toxicity: relationship to risk assessment. Environmental Health Perspectives 102 (Suppl. 9): 157-167, 1994. Bleifuss J. Dioxin as a therapeutic agent and other PR tales. 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