U.S. EPA“Estimating Exposure to Dioxin-Like Compounds, Volume II: Properties, Sources, Occurrence and Background Exposures,” June 1994. EPA/600/6-88/005Cb. Also see ThorntonJoe and WeinbergJack, “Dioxin Prevention: Focusing on Chlorine Chemistry,” in New Solutions, Spring 1995, Vol. 5, No. 3, pp 27–38.
2.
CostnerPat, “PVC: A Primary Contributor to the U.S. Dioxin Burden” submitted to the U.S. EPA as supplementary comments for the Dioxin Reassessment, February, 1995. Also: ThorntonJoe: “The PVC Lifecycle: Dioxin From Cradle to Grave,”Greenpeace USA, April 1997.
3.
WesterveltR.“PPG and Vista plan VCM venture and Capacity boost,”Chemical Week, February 1, 1995, p. 9. See also 13, below.
4.
ShamelRoger, President, Consulting Resources Corp., presentation at Chemical Week conference, “The Changing Chlorine Marketplace: Business, Science & Regulation,” April 11–12, 1995, Fairmont Hotel, New Orleans. According to Consulting Resources Corporation, 37 percent of chlorine produced in 1995 went into EDC/VCM/PVC manufacture. By 2005, this figure is expected to grow to 45%
5.
Evers, “Catalytic oxychlorination processes of aliphatic hydrocarbons as new industrial sources of PCDDs and PCDFs. Paper SOU 14, “Dioxin 89,” Ninth International Symposium of Chlorinated Dioxins and Related Compounds. Toronto, Ontario, Canada, September 17–22, 1989. Also: EversErik H.G., “Levels, temporal trends and risk of dioxins and related compounds in the Dutch aquatic environment,”Organohalogen Compounds, Vol. 28, 1996, pp. 117–122. Also: “Regulation of Dioxin releases from the Runcorn operations of ICI and EVC,”British Environment Agency, March 7, 1997.
6.
“Contamination Extent Report and Preliminary Injury Evaluation for the Calcasieu Estuary,” Prepared for the National Oceanic and Atmospheric Administration by CurryMark S., Industrial Economics, Inc., September 3, 1996.
7.
U.S. EPA National Listing of Fish and Wildlife Consumption Advisories, EPA-823-F-96-006, June, 1996.
8.
“PVC and the Environment,”Norsk-Hydro. 1992, Oslo, Norway.
9.
See The Dow Chemical Company, Comments of the Dow Chemical Company Before the USEPA In Re: The Office of Toxic Substances Advanced Notices of Proposed Rulemaking Concerning Polychlorinated Biphenyls. Under cover letter from Michael E. Nevill, Dow Chemical U.S.A., to Document Control Officer, Office of Toxic Substances, U.S. Environmental Protection Agency. November 13, 1981.
10.
RosengrantL. and CraigR.Final Response to BDAT Related Comments Document, Volume I-M. Washington, D.C.: U.S. EPA Office of Solid Waste. EPA/530-SW-90-0610. May, 1990. See also, waste analysis sheet, Dow Chemical, Plaquemine, Louisiana, in # 2, above.
11.
See Costner, 1995. Under the Toxic Substances Control Act, the U.S. EPA designated VCM produces as “excluded” PCB manufacturers. With this status, as long as PCB concentrations in untreated wastes do not exceed 500 ppm, VCM manufacturers can send their PCB-containing wastes to chemical waste landfills or burn them in their own or others' boilers. PCBs are generated in the manufacture of EDC and VCM and show up in the highest concentrations in heavy ends (tars or distillation bottoms) from the oxychlorination process. In formal comments submitted to the Agency on regulations affecting EDC/VCM production, Dow Chemical admitted that “PCB's can be formed in trace quantities any time that chlorine in any reactive form is contacted with carbon or compounds of carbon at elevated temperatures and/or in the presence of a catalyst,” as occurs in EDC/VCM manufacture. See The Dow Chemical Company, Comments Before the U.S. EPA In Re: The Office of Toxic Substances, Advanced Notices of Proposed Rulemaking Concerning Polychlorinated Biphenyls. Under cover letter from Michael E. Nevill, Dow Chemical U.S.A. to Document Control Officer, Office of Toxic Substances, U.S. Environmental Protection Agency. November 13, 1981.
12.
U.S. EPA, Revised Standards for Hazardous Waste Combustors. Federal Register: April 19, 1996. See also JohnsonJeff, “Hazardous waste incinerator rule delayed by EPA for more than a year,”Environmental Science & Technology, Volume 31, No. 2, 1997.
13.
The production steps leading to PVC manufacture include a) the generation of chlorine in the chloralkali process using electricity to split salt, b) the combination of ethylene and chlorine into ethylene dichloride which is then c) pyrolized to form vinyl chloride monomer. VCM is then polymerized to form PVC granules, which are then combined with additives to make PVC products. The manufacture of VCM in the U.S. occurs at 14 facilities: Occidental, Convent, LA; Occidental, Ingleside, TX; Occidental, Houston (Deer Park), TX; Formosa Plastics, Baton Rouge, LA; Formosa Plastics, Point Comfort, TX; Westlake/BF Goodrich, Calvert City, KY; Dow Chemical, Plaquemine, LA; Dow Chemical, Freeport, TX; Borden, Geismar, LA; Vulcan, Geismar, LA; Georgia Gulf, Plaquemine, LA; Vista, Lake Charles, LA; PPG, Lake Charles, LA; and Geon, Houston (La Porte), TX.
14.
Executive Order on Environmental Justice, EO #012898, Section 1–103.
15.
“Race and Siting of EDC/VC Facilities,” Appendix 4 of Costner, “PVC: A Primary Contributor to the U.S. Dioxin Burden,”Greenpeace, February 1995. Unweighted mean of white and “non-white” percentage of population in zip codes with EDC/VC facilities, 1980 U.S. Census data.
16.
BowermasterJon, “A Town Called Morrisonville,”Audubon, July-August, 1993, pp. 42–51.
17.
CarrollWilliam F.Jr., “Is PVC in House Fires the Great Unknown Source of Dioxin?”, Chlorine Chemistry Council, undated abstract submitted to U.S. EPA as comments on the Draft Dioxin Reassessment (see ref. #1).
18.
MerckM., “Determination of the PCDD/F concentration in the fumes from a PVC fire.”Organohalogen Compounds23: 491–494, 1995.
19.
Versar, Inc., “Formation and Sources of Dioxin-Like Compounds: A Background Issue Paper,” prepared for Matthew Lorber, U.S. EPA National Center for Environmental Assessment, November 7, 1996.
20.
National Fire Protection Association, Quincy MA, Fire Analysis and Research Division. Note: Though PVC is made from chlorine, which is naturally flame-retardant, additives (especially plasticizers) in PVC are flammable.
21.
“PVC Usage in Construction: 1980–1995.” Figures are in Lbs. PVC per $1,000 of New Construction. From Thomas A. Waltermire, Sr. Vice President and CFO, The Geon Company, presented at Goldman, Sachs & Company, Fourth Annual Chemical Investor Forum, May 21, 1996.
22.
GoodrichBF, Notice in Accordance With TSCA Section 8(E), February 25, 1992. Industry did not submit data it had on this particular source during the EPA's data call-in for the Reassessment, and has not added it to the testing program the PVC industry designed to voluntarily characterize its own dioxin contribution, though the Executive Board Meeting Minutes of the Vinyl Institute suggest that members of the industry knew of this source since March 1992. This source may be of particular concern to workers in the plants that manufacture PVC items.
23.
U.S. EPA, “Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Medical Waste Incinerators,” 40 CFR part 60, pages 31736–31779, June 20, 1996.
24.
“Hospitals Abandoning Medical Waste Incineration Because of Strict Rules, Officials Tell Conference,”Bureau of National Affairs, Environment Reporter, November 8, 1996, 1443. Also: GillisMichael and GolarArt, “City won't rebuild incinerator. Cost too high without subsidy; foes delighted,”Chicago Sun-Times, April 5, 1996, page 6.
25.
RigoG.H.; ChandlerJ.A.; LanierS.W. (1995) The relationship between chlorine and dioxin emissions from waste combustors. In: Solid Waste Management: Thermal Treatment & Waste-to-Energy Technologies, KilgroeJ. ed. Proceedings of an international specialty conference sponsored by the Air and Waste Management Association, Washington, D.C. April 18–21, 1995, pp 433–438.
26.
CostnerPat, “The Burning Question: Chlorine & Dioxin,”Greenpeace, Washington, D.C., April, 1997. ISBN 90-73361-33-8.
27.
For instance, see WagnerJ.C. and GreenA. (1993). Correlation of chlorinated organic compound emissions from incineration with chlorinated organic input. Chemosphere, Vol. 26, No. 11, pp. 2039–2054. The authors concluded that: “These results, contrary to the prevailing opinion, lead to the physically reasonable conclusion that decreases in the levels of organically bound chlorine in the input leads to decreases in chlorinated organic emissions. Thus we are convinced that, when all other factors are held constant, there is a direct correlation between input PVC and output PCDD/PCDF (dioxins and furans) and that it is purposeful to reduce chlorinated plastics input to incinerators.” For a bibliography of other studies, contact Greenpeace.
28.
US EPA Workshop on Formation Mechanisms and Sources of Dioxins, November 18–20, 1996. U.S. EPA.
29.
See 23, above.
30.
ThorntonJoe, “Dioxin Prevention and Medical Waste Incinerators,”Public Health Reports (Journal of the U.S. Public Health Service), Volume3 III, Number 4, July/August 1996, page 298 ff. Also, see “First, Do No Harm: Reducing the Medical Waste Threat to Public Health and the Environment,” by the Environmental Working Group in coordination with Healthcare Without Harm: The Campaign for Environmentally Responsible Health Care, March 1997.
31.
American Public Health Association, “Prevention of Dioxin Generation from PVC Plastic Use by Health Care Facilities.”Resolution #9607, 1996.
32.
“Hospitals Abandoning Medical Waste Incineration Because of Strict Rules, Officials Tell Conference,”Bureau of National Affairs, November 8, 1996, 1443.
33.
“PVC Alternatives: IV Bags and Tubing,”Minnesota Center for Environmental Advocacy, 1996.
34.
Dwain Winters, EPA Office of Prevention, Pesticides & Toxic Substances. Dioxin Draft Policy Forum, Summary of June 1995 meeting by Suzanne Orenstein and Robin Roberts, RESOLVE, August 30, 1995.
35.
IFCS Ad Hoc Working Group on Persistent Organic Pollutants Meeting, Final Report, 21–22 June 1996, Manila, Philppines.
36.
“Taking Back Our Stolen Future: Hormone Disruption and PVC Plastic,”Greenpeace International, April 1996.
ColbornTheo and ClementCoralie, eds, Advances in Modem Environmental Toxicology, Volume XXI: Chemically-Induced Alterations in Sexual and Functional Development: The Wildlife/Human Connection, Princeton Scientific Publishing Co., Inc., 1992.
39.
ToppariJorma, Danish EPA, “Male Reproductive Health and Environmental Chemicals with Estrogenic Effects,” April 18, 1995, Copenhagen, Denmark, (draft).
40.
DeisderP., “Identification and Determination of Organic Compounds in Antarctic sediments,”Ann. Chim. Rome, 81(9–10), 595–603, 1991. See also: ATSDR, profile for DEHP (di(2-ethylhexyl)phthalate.
41.
BevansHugh E., “Synthetic Organic Compounds and Carp Endocrinology and Histology in Las Vegas Wash and Las Vegas and Callville Bays of Lake Mead, Nevada, 1992 and 1995,”US Department of Interior-U.S. Geological Survey, Carson City, NV, 1996.
42.
CastleL., “Migration of Plasticizer from poly(vinyl chloride) milk tubing,”Food Additives and Contaminants, 1990, vol. 7, No. 5, 591–596.
43.
PageDenis B. and LacroixGladys M., “The occurrence of phthlate ester and di-2-ethylhexyl adipate plasticizers in Canadian packaging and food sampled in 1985–1989: A survey,”Food Additives and Contaminants1995, Vol. 12, No. 1, 129–151.
44.
PearsonStephen D. and TrisselLawrence A.. “Leaching of diethylhexyl phthalate from polyvinyl chloride containers by selected drugs and formulation components,”Am. J. Hosp. Pharm., vol. 50, July 1993, pp 1405–1409. Also, JaegerRudolph J., Ph.D. and RubinRobert J., Ph.D. “Migration of a phthalate ester plasticizer from polyvinyl chloride blood bags into stored human blood and its localization in human tissues,”New England Journal of Medicine, November 30, 1972, 1114–1118.
45.
DirvenH.A.A.M., “Metabolites of the plasticizer di(2-ethylhexyl) phthalate in urine samples of workers in polyvinyl chloride processing industries.”International Archives of Occupational Environmental Health, 199364: 547–554.
46.
Sondergutachten des Rates von Sachverstandigen fur Umweltfragen vom September 1990, Abfallwirtschaft, Stuttgart, 1991.
47.
U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry, Toxicological Profile for DEHP, April, 1993.
48.
JoblingSusan, “A Variety of Environmentally Persistent Chemicals, Including Some Pthalate Plasticizers, Are Weakly Estrogenic,”Environmental Health Perspectives, Volume 103, Number 6, June 1995, pp. 582–587.
49.
NarotskyMGWellerEAChinchilliVM, “Non-additive developmental toxicity in mixtures of trichloroethylene, di(2-ethylhexyl) phthalate, and heptachlor in a 5 × 5 × 5 design.”Fund. Appl. Toxicol., 27: 203–216, 1995.
50.
ColbornTheo, Ed., “Advances in Modern Environmental Toxicology, Volume XXI: Chemically-Induced Alterations in Sexual and Functional Development: The Wildlife/Human Connection,” consensus statement from the Wingspread Conference page 1–2, footnote 1.
51.
US EPA, Mercury Study Report to Congress, SAB Review Draft, Volume I: Executive Summary. EPA-462/R-90-001a, page 2–1.
52.
CurryMark S., “Contamination Extent Report and Preliminary Injury Evaluation for the Calcasieu Estuary,” (public review draft), prepared for Damage Assessment Center, National Oceanic and Atmospheric Adminstration, Silver Spring, MD, September 3, 1996.
53.
SchleifsteinMark, “Protest to meet La. chemicals in South Africa,”Times-Picayune, Thursday February 17, 1994, page B-3.
54.
German Federal Environmental Agency, commissioned by Greenpeace Germany, 1995. Also, “EuroChlor to Phase out Some Short-Chain Chlorinated Paraffins,”European Chemical News, June 28, 1995.
55.
“Government Concern About Hormone Effects Spurs Policy Seeking Ban on PVC Production,”Bureau of National Affairs, International Reporter, May 15, 1996, Page 401. RobertsMichael, “Denmark Considers PVC Phase-out,”Chemical Week, February 7, 1996, page 41. PorterAmy and HogueCheryl, “Government Concern About Hormone Effects Spurs Policy Seeking Ban on PVC Production,”Bureau of National Affairs, International Environment Reporter, May 15, 1996.
56.
“CPSC Finds Lead Poisoning Hazard for Young Children in Imported Vinyl Miniblinds,”CPSC News Release, June 25, 1996.
57.
See, for instance, “Environmental aspects of PVC,”Danish Technological Institute (for Danish EPA), November, 1995. Also “Wicked Battle” by BleifussJoel, In These Times, May 29, 1995, pp 12–13.
58.
“Some PVC applications are relatively secure, others are not,”(Graph) Charles River Associates, 1994.
59.
“Planning for the Sunset: A Case Study for Eliminating Dioxins By Phasing Out PVC Plastics,”Great Lakes United Clean Production Task Force, May 1995.
60.
Tellus Institute, “CSG/Tellus Packaging Study: Assessing the impacts of production and disposal of packaging and public policy measures to alter its mix”Prepared for The Council of State Governments, US EPA and New Jersey Dept. of Environmental Protection and Energy. May, 1992.
61.
“Characterization of Municipal Solid Waste in the U.S.: 1995 update. U.S. EPA Office of Solid Waste and Emergency Response”, March, 1996. EPA530-R-96-001.
62.
“PVC, chlorine makers urged to prepare for ‘sea changes’”, Elisabeth Kirschner, Chemical Week, September 22, 1993.
63.
“Flexible Polyolefin Family Targets Flexible PVC,”Modern Plastics, April 1996.
64.
HarrisonBruce E., “Going Green: How to Communicate Your Company's Environmental Commitment,”Business One Irwin, Homewood, IL, 1993, page 233–234.
65.
“UK retailers air worries over evidence against PVC,”European Chemical News, June 24–30, 1996, page 18.
66.
“IV Solution Containers: The PVC Issue,”McGaw, 1992. Irvine, CA.
67.
“Proposal for a European Parliament and Council Directive on end of life vehicles” (draft internal document), July 31, 1996.
68.
TyssklindM., “PCDD and PCDF Emissions From Scrap Metal Melting Processes at a Steel Mill,”Chemosphere, Vol. 19, Nos. 1–6, pp 705–710.
69.
“Plans for PVC-free Car Will Boost PUR Uses”, Modern Plastics, November 1993, page 13.
70.
Toronto City Council, meeting minutes, April 29, 1996.
71.
SelleckDave, Building Commissioner, memo to President & Board of Trustees, Lake-in-the-Hills, March 25, 1996.
72.
German Environment Ministers. “Impacts on the Environment From the Manufacture, Use and Disposal and Substitution of PVC.”German Joint Federal-State Committee on Environmental Chemicals for the German Environmental Ministers, September 1992.
73.
German Federal Office of the Environment (1992). Environment Damage by PVC: An Overview. Berlin: Umweltbundesamt, 1992.
74.
See “Building the Future: A guide to building without PVC,”Greenpeace UK, 1996. Available from Greenpeace UK, ph: 0171 865 8100.
75.
Ecotec Research and Consulting Ltd. in association with IVAM Environmental Research and ZENIT GmbH, “New Clean and Low Waste Products, Processes and Services, and Ways to Promote the Diffusion of Such Practices to Industry,” Report on Case Studies for DGIII and DGV, Commission of the European Communities, November 1995.
76.
See WallaceDeborah, In the Mouth of the Dragon: Toxic Fires in the Age of Plastics, 1990, Avery Publishing Group, Garden City, NJ. Also, Ken Cameron, General Secretary, Fire Brigades Union, open letter, September 30, 1996.
77.
City of Chicago Plumbing Code Book, Section 13-168-710.
78.
MillerBernie, “How much risk to electronics from wire and cable smoke,”Plastics World, January 1996, pp 38–43.
79.
SchecterA.KesslerH.“Dioxin and Dibenzofuran Formation Following a Fire at a Plastic Storage Warehouse in Binghamton, New York in 1995,”Organohalogen Compounds, Vol. 27 (1996), pp. 187–191. See also TheisenJ., “Determination of PCDFs and PCDDs in Fire Accidents and Laboratory Combustion Tests Involving PVC-Containing Materials,”Chemosphere, Vol. 19, Nos. 1–6, pp 423–428, 1989.
“Literature review of the potential hazards to human health of using PVC and CPVC pipe for potable water distribution,”Southern Research Institute, Birmingham, AL (undated). Also, SadikiAbdel-Ilah, “Pilot Study on the Contamination of Drinking Water by Organotin Compounds from PVC Materials,”Chemosphere, Vol. 32, no. 12, pp. 2389–2398, 1996.
82.
WeinbauerK.P., “Analysis of Supply Lines Construction Costs,” report commissioned by the City Authorities, Graz, Austria, June 1992.
83.
DemkinJoseph A., “Environmental Resource Guide,”American Institute of Architects, Washington DC, 1996.
84.
Military Handbook General Guidelines for Electronic Equipment. MIL-HDBK-454, April 28, 1995. Department of Defense.
85.
See, for example, Environmental Building News, “Should We Phase Out PVC,” January/February 1994.
86.
CameronKen, General Secretary, Fire Brigades Union, United Kingdom, letter September 30, 1996.
87.
Statement from the Work Session on “Chemically-Induced Alterations in Sexual Development: The Wildlife/Human Connection.”In Advances in Modern Environmental Toxicology, Volume XXI, Princeton Scientific Publishing Co., Inc.1992. Also, Statement from the Work Session on Environmental Endocrine-Disrupting Chemicals: Neural, Endocrine, and Behavioral Effects, Erice, Italy, November 1995.
88.
SaundersStephen, “Cabling: What You Don't Know Can Kill You,” in Data Communications, July 1996, pp 58–66.
89.
International Joint Commission, Sixth Biennial Report on Great Lakes Water Quality, 1992.
90.
PopoffFrank, Chairman and Chief Executive Officer, Dow Chemical Company, letter to President William J. Clinton, February 8, 1994.
91.
ColbornTheoDumanoskiDianne, and MyersJohn Peterson, Our Stolen Future: Are We Threatening our Fertility, Intelligence and Survival? A Scientific Detective Story. Dutton, New York, NY, 1996.
92.
TukkerA., TNO Centre for Technology and Policy Studies and Centre of Environmental Science Leiden, “A PVC substance flow analysis for Sweden.”Apeldoorn, Netherlands, November, 1996.
93.
“CSIRO tests for indoor pollution,”The Australian, May 8, 1996.
94.
Swedish Natural Testing and Research Institute (1990) Report 1990: 25.