HOW TO ELIMINATE DIOXIN.
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HOW TO ELIMINATE DIOXIN
A two-year study of dioxin in the Great Lakes has concluded that
86% of dioxin sources could be eliminated without economic
sacrifice, and possibly with economic gains.[1,2] The study was
conducted by a team of researchers at Queens College in New York,
led by Dr. Barry Commoner.
Dioxin has emerged in the past 15 years as one of the two or
three most dangerous chemicals ever tested. Intensive study of
dioxin has confirmed that dioxin acts as a powerful "growth
dysregulator," an "environmental hormone" that interferes with
normal growth and development in fish, birds, reptiles,
amphibians, and mammals, including humans. (See REHW #279, #414.)
Dioxin disrupts the central nervous system, the immune system,
the hormone (endocrine) system, and the reproductive system,
preventing normal growth and development of the young and causing
a variety of cancers. Furthermore, this intensive study revealed
that Americans now carry enough dioxin in their bodies to create
a cancer hazard hundreds of times as large as the "acceptable"
cancer hazard defined by EPA [U.S. Environmental Protection
Agency]. Furthermore, existing "body burdens" of dioxin in
Americans could be expected to cause other health effects in
sensitive members of the population, such as immune system
damage. Dioxin is thus a serious public health problem. (See
REHW #390, #391.)
Dioxin is never intentionally manufactured (except for laboratory
purposes), but it occurs as an unwanted byproduct of many
industrial processes. A recent estimate of annual world-wide
dioxin production (which amounts to 3000 kilograms [kg], or 6614
pounds [lb] per year) indicates that major sources of dioxin
** municipal solid waste incinerators (1130 kg [2491 pounds], or
37.6% of world total);
** cement kilns burning hazardous waste (680 kg [1499 lb], or
23%). Only cement kilns in the U.S. burn hazardous waste, and
these incinerators produce 13 times as much dioxin, per pound of
cement manufactured, compared to cement kilns that do not burn
** steel smelters (350 kg [772 lb], or 12% of total);
** cement kilns not burning hazardous waste (320 kg (706 lb), or
** biomass combustion (350 kg [772 lb], or 12%). This is from
forest fires and from commercial and residential wood burning.
Trees do not naturally produce dioxin. But forests may be
treated with chlorinated pesticides, such as Silvex, which then
produce dioxins when burned. Alternatively, airborne dioxins may
settle onto trees and be absorbed into the leaves and wood; when
these later burn, the dioxin may be released into the atmosphere
again. The researchers who developed these global estimates
don't know which explanation is correct.
** medical waste incinerators (84 kg [185 lb], or 2.8%);
** secondary copper smelting (78 kg (172 lb), or 2.6%);
** automobiles burning leaded gasoline (11 kg [24 lb], or 0.4%);
cars burning leaded gasoline emit 9 times as much dioxin per
gallon of fuel, compared to burning unleaded gasoline.
** automobiles burning unleaded gasoline (1 kg [2.2 lb], or
These estimates are subject to large uncertainties because almost
nothing is known about dioxin sources in the former Soviet Union,
China, and India, which together hold about 43% of world
population. Furthermore, estimates of total dioxin falling onto
the Earth's surface worldwide (13,100 kg, or 28,880 lb) are about
4 times as large as total estimated worldwide emissions (3000 kg,
or 6614 lb). Thus no one is quite sure where all the world's
dioxin is coming from. One thing IS certain: dioxin is not
coming from natural sources. Study of the sediments of lakes has
shown that there was very little dioxin in the environment prior
Despite these major uncertainties, dioxin emissions into the
Great Lakes have been studied carefully by Commoner and
associates, who identified 1329 individual sources of dioxin. Of
these 1329 sources, 106 account for 86% of the dioxin entering
** 48% of the dioxin entering the Great Lakes originates in 609
hospital waste incinerators and 14 commercial medical waste
** 22% of Great lakes dioxin originates in 52 municipal solid
waste incinerators burning 11.7 million tons of trash per year.
** 8% originates in iron ore sintering plants. (To sinter means
to form into a solid mass using heat but without melting.)
** 8% from cement kilns burning hazardous wastes.
** 4% from secondary copper smelting.
** 3% from combustion of coal.
** 2% from wood combustion.
** 2% from cement kilns not burning hazardous wastes.
** 1% from heavy duty diesel vehicles.
** 0.8% from hazardous waste incinerators.
** 0.7% from sewage sludge incineration.
** 2.2% from other sources (secondary copper refining;
hexachlorobenzene waste incineration; combustion of leaded and
The bulk of Commoner's report is an economic analysis of the
feasibility of eliminating the sources of dioxin from medical
waste incinerators, municipal solid waste incinerators, iron ore
sintering plants, paper mills, and cement kilns burning hazardous
Commoner takes a modern "pollution prevention" approach to
dioxin: he looks for ways to change production processes to avoid
the creation of dioxin. Throughout the study, Commoner discusses
the alternative approach --pollution control --and shows that it
cannot reduce dioxin emissions to zero. Only pollution
prevention --eliminating the creation of dioxin by changing
production technologies --can achieve zero discharge of dioxins.
Interestingly, despite prominent use of the term "pollution
prevention" inside EPA (where they've even turned it into the
catchy buzzword, "P2"), Commoner shows time after time that EPA
and certain of the "big 10" environmental groups who are talking
about reducing dioxin emissions under the Clean Air Act of 1990
are all stuck in old-style "pollution control" debates. Sierra
Club, Natural Resources Defense Council (NRDC) and EPA are
spending their scarce resources jousting in court over the
meaning of "maximum available CONTROL technology" --not even
discussing real pollution prevention, which requires NOT MAKING
POLLUTION TO BEGIN WITH. (The Clinton Administration and some of
its acolytes in the Washington environmental community revealed
their contempt for real pollution prevention last month when they
helped Congress repeal the Delaney clause. Since 1958, the
Delaney clause had prohibited the addition of known carcinogens
to processed foods--the only U.S. environmental law truly based
on PREVENTION. Now the Delaney prohibition has been repealed,
replaced by a risk assessment process which allows "safe" amounts
of cancer-causing chemicals to be added to our food. In the
unprincipled world of D.C. environmental politics-and-money, this
is being touted as progress. The catch is, no one promoting the
new "risk assessment" approach actually believes that "safe"
amounts of carcinogens can be established, certainly not when
several carcinogens and other poisons are added simultaneously to
the food of tens of millions of people. So EPA and other cynical
Washington operatives are promoting public health policies
founded on risk assessments which have no basis in science, which
are not in any sense prevention-based, and which certainly cannot
"guarantee protection for children," as one environmental group
announced they would. Presumably, such cynical posturing is
the price one pays to remain an "inside player"--a sad display of
political opportunism and ethical collapse by our friends.) At
present, in Washington, P2 is just so much eye wash.
Commoner on the other hand applies the principle of pollution
prevention aggressively, and in novel ways:
** Medical wastes are incinerated, basically, to kill germs and
reduce volume. Commoner shows that medical waste incinerators
around the Great Lakes could all be shut down affordably and
replaced by autoclaving (essentially a large pressure cooker that
sterilizes) followed by landfilling. Autoclaving and landfilling
are an affordable, dioxin-free alternative to medical waste
** Commoner shows that all municipal solid waste incinerators
could be closed and retired (their outstanding bonded debt paid
off by public funds) and replaced by dioxin-free intensive
recycling programs --all at a net SAVING of $536 million each
year for Great Lakes communities. ** Commoner shows that
--despite anti-P2 regulations imposed by EPA --pulp and paper
mills could readily shift to totally-chlorine-free technologies,
thus COMPLETELY ELIMINATING THE SOURCES OF DIOXIN IN PAPER MILLS.
Real pollution PREVENTION is affordable.
** Commoner shows that chlorinated solvents and oils could be
eliminated from iron sintering plants, thus ELIMINATING the
sources of dioxin from these facilities.
** Commoner shows that 75% of all cement is manufactured without
using hazardous waste as a fuel, and that therefore it would be
relatively easy for government to outlaw use of hazardous waste
as a fuel in cement kilns, to protect public health and safety.
Commoner's clear, quantitative analysis and low-key advocacy
offer real hope that dioxin could be brought under control
nation-wide. Unfortunately, Commoner starts his thinking from a
place quite different from the place where EPA and the big
environmental lobbying groups start their thinking. Commoner
boldly examines the production processes that are creating dioxin
--production processes that are traditionally considered the
exclusive domain of the so-called "private sector" --and suggests
how they could be modified to prevent pollution. (It seems odd
that this sector retains the label "private" even though its
decisions have polluted every square foot of the planet with
powerful poisons.) Until the environmental community adopts an
approach as bold as Commoner's, trendy talk of P2 will remain
nothing more than a cynical cover for business as usual.
(National Writers Union, UAW Local 1981/AFL-CIO)
 Barry Commoner and others, DIOXIN FALLOUT IN THE GREAT LAKES.
WHERE IT COMES FROM; HOW TO PREVENT IT; AT WHAT COST. (Flushing,
N.Y.: Queens College, Center for the Biology of Natural Systems,
June, 1996). Telephone (718) 670-4182.
 Barry Commoner and others, ZEROING OUT DIOXIN IN THE GREAT
LAKES: WITHIN OUR REACH (Flushing, N.Y.: Queens College, Center
for the Biology of Natural Systems, June, 1996). Telephone (718)
 Louis B. Brzuzy and Ronald A. Hites, "Global Mass Balance for
Polychlorinated Dibenzo-P-dioxins and Dibenzofurans,"
ENVIRONMENTAL SCIENCE & TECHNOLOGY Vol. 30, No. 6 (1996), pgs.
1797-1804. A recent "mass balance" study of U.S. (not global)
dioxin emissions is Valerie M. Thomas and Thomas G. Spiro, AN
ESTIMATION OF DIOXIN EMISSIONS IN THE UNITED STATES [PU/CEES
Report No. 285] (Princeton, N.J.: Princeton University, Center
for Energy and Environmental Studies, December, 1994).
 Jean M. Czuczwa and others, "Polychlorinated
dibenzo-p-dioxins and dibenzofurans in sediments from Siskiwit
Lake, Isle Royale," SCIENCE Vol. 226 (1984), pgs. 568-569. And
see Jean M. Czuczwa, and Ron A. Hites. "Airborne Dioxins and
Dibenzofurans: Sources and Fates." ENVIRONMENTAL SCIENCE AND
TECHNOLOGY Vol. 20 (1986), pg. 195 and following pages.
 Richard Wiles and Mark B. Childress, "Pesticide Bill
Guarantees Protection for Children and a Citizen's Right to
Know," press release dated July 17, 1996 from Environmental
Working Group, 1718 Connecticut Avenue, N.W., Suite 600,
Washington, DC 20009; telephone: (202) 667-6982. The
Environmental Working Group (EWG) knows as well as we do that
risk assessments cannot "guarantee protection for children."
President Clinton evidently liked EWG's disinformation so well
that he later repeated it himself; see Associated Press, "Clinton
Praises Bill Regulating Pesticides," NEW YORK TIMES, August 4,
1996, p. 17. And see John H. Cushman, Jr., "Pesticide Measure
Advances In House, Without Rancor," NEW YORK TIMES, July 18,
1996, pg. 20.
Descriptor terms: dioxin; great lakes; paper mills; chlorine;
msw; incineration; medical waste incinerators; steel industry;
steel smelters; pollution prevention; cement kilns; hazardous
waste; dioxin sources; biomass combustion; copper smelting;
automobiles; gasoline; lead; iron sintering;
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--Peter Montague, Editor