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Goals and Tactics
A National Strategy for Dioxin Elimination
by Joe Thornton, Greenpeace
The emerging science makes clear that current dioxin contamination poses a serious threat to public health and the environment, with future generations at the greatest risk if dioxin pollution continues. Because these compounds are so persistent in the environment and the human body, dioxins that have already accumulated will not disappear quickly.
The EPA should initiate a comprehensive national dioxin elimination program, with the goal of reducing human exposure and preventing the formation and discharge of dioxin into the environment from all sources. The program should be based on these principles:
- Zero means zero. Dioxin releases must be eliminated, not simply reduced. Because dioxin is so persistent, the ecosystem has no capacity to safely "assimilate" dioxin inputs. Even dilute discharges build up in the environment over time, eventually reaching unacceptable concentrations. Thus, zero is the only acceptable discharge of dioxin, and the current crisis demonstrates the failure of the "acceptable discharge" approach to persistent toxic substances. Given the current health threat, it would be wholly inappropriate for EPA to permit the continued release of any additional dioxin into the environment.
- Pollution prevention, not control. Once dioxin is produced, it is too late to prevent its discharge into the environment; pollution control devices, filters, treatment systems, and disposal methods such as burning and burying simply shift captured chemicals from one environmental medium to another or delay their release until a later date. Dioxin discharges can be eliminated only through primary prevention: industrial processes and feedstocks that result in dioxin formation must be changed so that no dioxin is formed. Because dioxin occurs throughout the field of chlorine chemistry, this goal appears to require the planned phase-out of chlorine and chlorinated organic feedstocks from industrial processes.
- Address all dioxin sources. EPA must address all known and suspected sources of dioxin in order to bring future releases of dioxin to zero. All identified dioxin sources must be subject to action, and EPA should initiate research to identify all unknown or suspected sources.
- Set priorities. Because dioxin is associated with the many uses of chlorine in our industrial economy, eliminating dioxin will require substantial technical and economic conversion. The largest dioxin-producing sectors for which the alternatives are available and feasible now should be subject to immediate action. Sectors that require longer implementation phases should be placed on timelines for dioxin elimination.
Step 1: General Policy Changes
1. National policy. EPA should establish a national Zero Dioxin program with the goal of eliminating the formation and release of dioxin within 10 years, through the elimination of those products, feedstocks, & processes that lead to dioxin formation.
2. Moratorium on new dioxin permits. EPA should grant no new permits for facilities to release dioxin into any environmental medium.
3. Sunset existing dioxin permits. EPA should modify all existing dioxin release permits to include timetables for the reduction and eventual elimination of all dioxin releases.
4. Comprehensive approach to all sources. For the many dioxin sources that are not currently permitted or regulated, EPA should begin a process to identify and prioritize all dioxin sources and require their elimination within 10 years. All facilities that manufacture, use, or dispose of chlorine or chlorinated organic chemicals should be required to test for dioxin formation in their products, processes and wastes. Any identifiable release of dioxin and related compounds should be reported under federal Right-to-Know programs.
Step 2: Immediate Priorities: Phase-out Major Dioxin Sources
EPA should take immediate action in the largest dioxin-producing sectors. In these sectors, regulatory action can have the most significant impact on total dioxin pollution. 1. Incineration. Incinerators that burn chlorinated wastes are the largest known producers of dioxin. EPA should take the following actions:
- Place an immediate moratorium on permits for new combustion facilities that burn chlorinated wastes and on permits for expanded capacity at existing units.
- Modify immediately all permits for combustion devices to include sunset provisions to reduce and finally eliminate the input of chlorinated wastes and products. This policy should include incinerators, boilers, kilns and furnaces that burn hazardous wastes; incinerators for trash, hospital waste, sewage sludge, tires, and soils; and metal smelters. Minimize the burning of chloride-containing wastes (i.e., food and yard wastes) through trash separation programs.
- In turn, focus waste reduction programs on eliminating the generation of chlorinated incinerable wastes, particularly solvents, PVC, and wastes from the production and use of chlorinated substances in the chemical industry.
- Immediately ban the addition of chlorinated compounds to fuels, including gasoline, diesel & others.
2. Pulp and Paper. The use of chlorine, chlorine dioxide, and other chlorine-based bleaches in the paper industry is the largest source of dioxin discharges directly to waterways and one of the largest dioxin-producing sectors overall. In other parts of the world, totally chlorine-free pulp bleaching is rapidly becoming the industry standard. EPA should establish rapid timelines for the phase-out of all chlorine-based bleaches in the pulp & paper industry.
3. PVC plastic. Throughout its life cycle, PVC results in more dioxin formation than any other single product. EPA should immediately establish a PVC phase-out program, with progressive reductions toward zero in the production and use of PVC. Particularly rapid phase-outs should be applied to short-life uses of PVC (packaging, toys, etc.), PVC in areas susceptible to fire (construction, appliances, and automobiles), and PVC in products that are recycled in combustion-based processes (i.e., cables and cars). EPA should also modify all discharge permits for chemical plants that produce PVC feedstocks to include sunset provisions on dioxin discharges to all environmental media.
Step 3: Secondary Actions: Phase-out Other Chlorine Uses
While immediate action occurs in the priority sectors discussed above, the following dioxin-producing sectors should be placed on timetables for phase-out.
1. Chlorinated solvents. In production, incineration, and some uses, chlorinated solvents cause dioxin formation. EPA should establish a rapid timetables for phasing-out the production and use of these chemicals.
2. Chlorine-related pesticides. Dioxins are formed in the production, some uses, and disposal of chlorine-containing pesticides and in the production of non-chlorinated pesticides made with chlorinated intermediates. EPA should establish a phase-out timetable for all chlorine-related pesticides.
3. Other chlorinated organic chemicals. Dioxins are formed in the production, some uses, and disposal of other chlorinated organic chemicals, such as intermediates, catalysts, and specialty chemicals. EPA should establish timelines for phasing-out the production and use of all other chlorinated organic chemicals. Any uses that serve a compelling social need (i.e., pharmaceuticals) for which alternatives may not yet be available should receive temporary exemptions.
4. Metallurgy and inorganic chemicals involving chlorine. Dioxins are formed when chlorine and chlorinated compounds are used in metallurgical processes and in the production of some inorganic chlorinated chemicals. EPA should establish phase-out timetables for the use of chlorine in high-temperature metallurgy, and for the manufacture of inorganic chlorinated chemicals associated with dioxin formation.
5. Wastewater treatment. Dioxins and related compounds are formed in the chlorination of drinking water and sewage and in the incineration of sludge from wastewater treatment plants. EPA should establish timelines for the implementation of chlorine-free water treatment methods while insuring that adequate disinfection continues. In most cases, chlorine-free methods for water disinfection can be implemented more quickly than the use of chlorine as a residual can be eliminated.
6. Remediation. A substantial quantity of dioxin and PCB-contaminated materials are now present in landfills, sediments, and extant industrial wastes. EPA should intensify the development and application of non-combustion methods for degradation of these materials.
Political and Economic Implications
Because dioxin can be formed at some point in the life cycle of all or virtually all chlorine-related processes, the only feasible method for preventing dioxin releases is to target the critical step—the production of chlorine and related compounds. Controlling dioxin formation at later steps in the chlorine "use-tree" would require specific regulations on scores of processes and thousands of chemicals. Because dioxin is an inevitable by-product of the field of industrial chlorine chemistry, addressing dioxin pollution requires a comprehensive approach to the class of chlorine-based products and processes.
For all major dioxin sources, chlorine-free alternatives are available and feasible now. There are few or no technical barriers to the elimination of dioxin releases associated with paper bleaching, PVC, solvents, sewage and drinking water disinfection, pesticides and many chemical manufacturing processes. In many cases, these alternatives result in direct economic benefits as investments in process changes are paid off with reduced costs for chemical procurement, pollution control and disposal, liability, increased resource efficiency, and more reliance on skilled labor then chemicals.
But phasing out all dioxin sources will require substantial conversion. In some industries—particularly the manufacture of chlorine-based chemicals—the transformation may be difficult. Workers and communities should not bear the economic burden of changes to protect public health and the environment. The Zero Dioxin Strategy should be guided by a transition planning process involving labor, communities, and all other stakeholders. Revenue from a tax on chlorine and related chemicals should be distributed to ensure that investment in alternative products and processes takes place in the same locations where chlorine-based processes were formerly used; it should also be used to protect, compensate, and provide future opportunities for workers and communities that are affected by conversion.
This article is reprinted with permission of the author from the July, 1994 Greenpeace publication, Achieving Zero Dioxin: An Emergency Strategy for Dioxin Elimination. A full copy of the report can be obtained by writing Greenpeace Chlorine-Free Campaign, 1436 U Street NW, Washington DC 20009.