A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 August 1994
It is fitting that this conference, which marks a momentous turning point in the notorious history of dioxin*, should take place in St. Louis. It was not far from here that the threat of dioxin to the general public first became apparent -- when a local dealer mixed dioxin-contaminated chemical waste into used oil and sprayed it in horse arenas, killing animals and sickening children. It was here that the enormous power of dioxin to disrupt our lives was demonstrated -- when, for the first time, chemical contamination caused an entire town, Times Beach, to close down. It was the local chemical company -- Monsanto -- that first began the manufacture of polychlorbiphenyl in Anniston, Alabama -- a type of process, we now know, that inevitably produces dioxin-like substances as well. And the first unwitting discovery that such materials create dangerous industrial hazards to chemical workers was made in the early 1930s when most of the workers in the Monsanto plant became sick.
We also meet at a crucial time in the history of dioxin. I am convinced that 1994 will be seen as the year in which -- despite every effort of the chemical industry and its journalistic allies to confuse and misinform us -- the true dimensions of the ominous threat of dioxin to human health became known. The profound significance of its diverse attack on living things has now become clear:
Dioxin and dioxin-like substances represent the most perilous chemical threat to the health and biological integrity of human beings and the environment.
The history of dioxin is a sordid story -- of devastating sickness inflicted, unawares, on chemical workers; of callous disregard for the impact of toxic wastes on the public; of denial after denial by the chemical industry;
of the industrys repeated efforts to hide the facts about dioxin and, when these become known, to distort them. Our task here is to learn from this history -- not only from the data generated by the rapidly growing list of scientific studies, and the crucial facts unearthed by grassroots activists -- but also from the attempts of
the chemical industry and its allies to distort them. We need to learn what must be done, now, not merely to diminish, but to end -- the menace of dioxin and its many toxic cousins to life.
* The term dioxin is used to connote the group of 210 similar substances -- polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans. Certain types of polychlorbiphenyls (PCBs) have similar biological effects and are included among dioxin-like substances.
It took three years of work by state and U.S. health laboratories to pin down the cause of all this sickness and death. Dioxin, at a level 30-53 parts per million, was identified in a sample of the arena soil. By then it was clear that the waste oil included chemical residue from a plant in Verona, Missouri, that had been synthesizing trichlorophenol -- an intermediate of manufacturing 2,4,5-T, the herbicide Agent Orange that the U.S. had sprayed in huge amounts in the war against Vietnam.
Why should a chemical plant designed to produce trichlorophenol also produce dioxin? The explanation lies in the special nature of chemical manufacturing, which is very different from manufacturing anything else. When a car, let us say, is made, pieces of metal, glass, rubber and many other materials are assembled, but the matter of which these materials are made is not changed. The waste is just some left-over wiring, paint fumes, or perhaps a cracked windshield, produced in amounts much less than the car itself and reducible by good housekeeping.
But the purpose of chemical manufacturing is to change matter, to rearrange atoms and make new molecules. In such a chemical reaction huge numbers of molecules jostle around, their constituent atoms assemblyng and disassembling in many different arrangements. The chemist learns to favor the production of a particular molecule by controlling temperature, pressure and other conditions and, more precisely, by introducing a catalyst. But the process is never perfect; some unwanted molecules that happen to be very stable and resist being further transformed will persist -- as waste.
Dioxins are just such very stable compounds. In the production of trichlorophenol -- or for that matter in most reactions involving organic (carbon-containing) chemicals and chlorine -- dioxin is likely to be formed, and once formed, to persist as an unwanted waste. By its very nature, such waste -- much of it toxic -- is built into chemical manufacturing. Toxic waste is not simply a matter of poor housekeeping or bad management; it is an inescapable part of chlorine-based chemical production. Moreover, some of the industrys actual products, for example solvents, are themselves toxic, and many produce toxic substances -- including dioxin -- when an effort is made to dispose of them, especially by incineration.
Since the early 1970s a great deal has been learned about why dioxin should be so dangerous in such small amounts. But the fact that dioxin-like compounds -- complex, highly chlorinated organic chemicals -- are very toxic has been known, or should have been known, much earlier. Again, there is a Missouri connection, for the discovery was made in the 1930s in Monsantos Anniston, Alabama, plant. Within a year after the plant opened, most of the workers had developed chloracne and a wide range of other symptoms.
In 1936 two Atlanta physicians published a case history in the Archives of Dermatology and Syphilology about one of the Monsanto workers described as: O.D., a Negro aged 26 [who] began work in the distillation of chlorinated diphenyl in April 1930. They reported that the patient had a severe case of chloracne and observed that the patient, even in December 1933, ...complained of lassitude, loss of appetite and loss of libido. Some sense of the authors ability to appreciate the significance of these symptoms, later shown to be characteristic of dioxin poisoning, can be gained from their additional comment:
His complaint of lassitude was not borne out by anything more than the usual temperament of the Negro toward work...
We have heard the same sorry tale very often since then: The only human disease attributable to dioxin is chloracne. But step by distressing step, the full range of the devastating effect of dioxin on people has confirmed the reality of O.D.s symptoms, and much more.
Apart from the terrible disruption of the lives of the people of Times Beach, what does this decision tell us? Why should EPA and other government agencies try to establish such a cut-off level -- a dividing point between remedial action and doing nothing? I suppose that one reason is simply bureaucratic timidity -- a way of avoiding a decision based on personal judgment; it is safer, for the bureaucrat if not for the rest of us, to rely instead on some number, arrived at by objective science rather than by responsible human beings.
But there is much more to the notion of a safe level of exposure than protecting human health or environmental quality. For Syntex (USA) Inc. -- the company responsible for the dioxin clean-up costs in Missouri -- it is a matter of money. In 1986 Syntex staff members published a graph showing the relation between different clean-up standards and the expected costs of achieving them in the Missouri dioxin-contaminated sites. It showed, for example, that if the soil-contamination standard of one part per billion were relaxed to 10 parts per billion, Syntex would need to spend 65% less on the clean-up. The Syntex people proposed that the 1985 EPA risk assessment should be sharply reduced. This would not only save Syntex money, it would also reduce the need to clean up many Superfund sites; it would improve the environmental acceptability of incinerators; it would weaken the claims of the veterans who were exposed to Agent Orange in Vietnam, and it would affect the outcome of numerous court cases. EPA did not refute the Syntex proposal, adhering to the Reaganesque line that environmental hazards must be balanced against the cost of remedying them.
It is no wonder, then, that polluters declared open season on dioxin risk estimates. Their techniques varied. Some of the most imaginative efforts were made by companies that built incinerators -- major sources of environmental dioxin. They usually accepted the EPAs estimate of dioxins high carcinogenic potency, but tried to get around it by showing that the dioxin would be so diluted once it left the incinerator smokestack that the people exposed would fall within the one-in-a-million cancer risk standard of acceptability. The prize for the most imaginative example of dioxin detoxification by dilution goes to the author of the environmental impact statement for the proposed -- and still not built -- trash-burning incinerator at the Brooklyn Navy Yard in New York. Here is his prize-winning idea: Dioxin emitted into the air by the incinerator would fall to the ground and there become mixed into the upper 10 cm. of the soil. This would greatly dilute the dioxin, so that when it finally came in contact with the people of Brooklyn, it would result in the risk -- magically -- of just under one in a million. Unfortunately, most of Brooklyn is not covered with soil, but with asphalt and houses.
Perhaps embarrassed by such ludicrous efforts to evade the consequences of its 1985 cancer risk assessment, EPA decided to make life easier for the industrys inventive risk assessors by revising the risk assessment itself. Was dioxin really so potent a carcinogen that absorbing only 14 trillionths of an ounce per day would carry the one-in-a-million lifetime cancer risk? With the director of EPAs Office of Research and Development as Chairman, a Workgroup of EPA staff reviewed the 1985 document and re-examined its data and reasoning. They had little to say about the data and concentrated their attention on the fact that there were several different theories about how chemicals like dioxin might cause cancer. Most of the alternative theories predicted a dioxin cancer potency much lower than the 1985 risk assessment and were incompatible with the theory that guided it. If these alternative theories were right, then the assessments theory had to be wrong.
When the Workgroups draft was sent out for review in 1987, I was among those invited to respond. (Such strange things sometimes happen when a bureaucracy tries to navigate the risky passage between science and politics.) Tom Webster and I prepared a detailed point-by-point criticism of the Workgroup report. But what really counted was a much simpler point -- which I had the opportunity of making in a speech to the entire Washington EPA staff in January 1988 (another strange event): If the low-potency theories are right, then the original high-potency theory is wrong, and vice versa -- a situation that can hardly be corrected by averaging their mutually contradictory results.
This and other criticism of the Workgroups 1987 attempt to revise the 1985 risk assessment had an effect: A revised draft was issued that scrapped the first one. Now the Workgroup decided that the low-potency models were inadequate and accepted a version of the original high-potency model as the basis for its analysis. Then, without any factual evidence to support it, the Workgroup nevertheless decided that the original 1985 risk assessment ...may be an overestimate, although the scientific data do not permit an estimate of the extent of the overestimate. So, having decided that the original potency estimate was too high, and not knowing by how much (which logically could be only 1% of the original value -- a difference totally lost in the range of uncertainty of the estimate) -- the Workgroup concluded that the true value is -- once again -- 16 times lower than the 1985 estimate. That the same decision for a 16-fold reduction of dioxins cancer potency was based on two sets of mutually contradictory reasons suggested that the result was unencumbered by factual scientific analysis.
Stated a little less politely, I would credit the Workgroup with a new, highly imaginative approach to the evaluation of dioxins toxicity: fact-free detoxification. All this became clear in public hearings on the draft Workgroup report, with the result that it died a quiet death somewhere in the EPA bureaucracy. The 1985 cancer risk assessment survived.
Thus far, the attempts to downgrade the EPAs 1985 risk assessment had avoided a direct challenge to the data on which it was based -- chiefly, the results of a rat feeding test carried out by a researcher at the Dow Chemical Company. In 1986 it was confirmed that paper mills using chlorine bleach produced dioxin in their waste water at levels that would exceed a standard based on the 1985 risk assessment. This was the result of chlorine reacting with chemical constituents of wood. Seeking to avoid proposed regulations that would restrict the use of chlorine, the paper industry decided to challenge the results of the Dow rat test. They borrowed the original tissue microscope slides from Dow and assembled a panel of independent toxicologists who examined each slide and decided for themselves whether cancer was evident or not. Since they were not unanimous in their decisions, the cancer frequency was decided by majority vote. This reduced the original potency figure by half -- hardly a significant change. And once more, under this new assault -- detoxification by recount -- the 1985 risk assessment survived. Nevertheless, the paper companies asked EPA to rethink it.
This brings us to October 1990 and a place called the Banbury Center in Long Island. There, under the sponsorship of EPA and the Chlorine Institute -- an industry group -- toxicologists and biochemists were convened to consider the Biological Basis for Risk Assessment of Dioxins and Related Compounds. The purpose of the conference was to review new data about how dioxin caused cancer in order to provide a
scientific basis for a new risk assessment. The new data were studies that actually went back to the 1970s. They showed that dioxins effects were exerted through a receptor -- a particular protein in animal cells called Ah -- that tightly bound dioxin and facilitated its action, through the cells genetic system, on protein synthesis.
The EPA participants in the Banbury Conference hurried back to Washington with news that prompted the Administrator, William K. Reilly, to predict that a new reassessment would in fact reduce the dioxin risk. This set the stage for the latest chapter in dioxins sordid history: a new, Banbury-inspired, re-evaluation of the 1985 risk assessment. This has now been completed and is scheduled for release in September - we hope. But we already know what it will say, thanks to a leak of the reports conclusions a few weeks ago. The new attempt to downgrade the dioxin hazard, like all the earlier ones, has failed. But in failing, it has not simply confirmed the important but narrow result of the 1985 risk assessment that dioxin is an enormously potent carcinogen. It has also greatly expanded the range and biological impact of dioxins effects, at levels of exposure already experienced by the entire U.S. population.
If, as a skeptic like myself might conclude, the Banbury Conference was set up to urge EPA to find new scientific reasons for downgrading dioxins cancer potency, the planners made two serious tactical mistakes. First, by concentrating attention on the receptor theory, the Conference validated the growing but until then largely unconnected evidence about the non-cancer effects of dioxin, such as hormonal and developmental disruptions, at concentrations even lower than those that induce cancer. The second mistake arose out of the threshold concept itself, for it raised the question of whether the dioxin level carried in peoples bodies was already at or above the threshold. If so, added exposure would then be expected to have an effect on the incidence of cancer and other disease regardless of whether or not the threshold theory was correct.
The threshold proponents proposed that a dietary intake of one to three picograms per kilogram per day would be safe. Unfortunately, EPA studies of the body burden of dioxin showed that the U.S. average has already reached that level. Earlier, Tom Webster and I had shown that this level indicated a cancer risk of 330 per million. Apparently Americans are sufficiently exposed to some very general source of dioxin to put us all well above the acceptable cancer risk of one in a million, and within range of its numerous other harmful effects. That source, according to the forthcoming EPA report, is chiefly food.
Dr. Arnold Schecter, who has so courageously pioneered in this area, has recently completed a study of the dioxin content of U.S. food, which he has kindly allowed me to share with you. His basic conclusion is that a typical daily diet delivers between 0.3 to 3.0 picograms per kilogram of body weight (a level that represents a lifetime cancer risk of 50 - 500 per million). The new EPA risk assessment reports that if dioxin-like types of PCB are included in the assessment, the average U.S. intake is 3 - 6 picograms per kilogram per day, representing a cancer risk of 500 to 1,000 per million. As the new EPA report states -- rather delicately -- the weight of the evidence suggests concern for the impact of these chemicals on humans at or near current background levels.
Stated more simply, the situation is this: The general spread of dioxin and dioxin-like chemicals in the U.S. environment has already exposed the entire population to levels of these extremely toxic substances that are expected to cause a number of serious health effects. These include an average risk of cancer of 100 or more per million in the entire U.S. population -- 100 times greater than the risk standard that has triggered EPA remedial action, for example at Times Beach.
* disruption of endocrine hormone systems, especially those related to sexual development; specifically by mimicking, interfering with, or amplifying the effects of estrogen especially during fetal development;
* disruption of critical stages of embryonic development, for example of the nervous system;
* damage to the developing immune system, leading to increased susceptibility to infectious diseases.
These are all intergenerational defects; they are imprinted for life on the developing fetus by the effect of dioxin on the mother and sometimes the father. In its recent Seventh Biennial Report on the environmental impact of persistent toxic substances such as dioxin on the Great Lakes, the International Joint Commission has bluntly confronted the catastrophic implication of this threat, stating:
Surely, there can be no more compelling self-interest to force us to come to grips with this problem than the spectre of damaging the integrity of our own species and its entire environment.
Why should such biologically powerful agents arise from the normal activities of the chemical industry? Why should ordinary commercial products like PCB, or a routine by-product of numerous chemical industry processes like dioxin act in the body a though they were hormones?
Dioxin and dioxin-like chemicals have become widely known as environmental hormones because they enter into the complex network of natural hormones that govern sexual development and other embryonic processes -- and disrupt them. They are man-made chemicals that, present in only miniscule amounts, can powerfully alter the natural biochemical processes that determine how animals develop, grow, and behave. However, dioxin is not in fact a hormone, a term that is properly restricted to chemical substances that are produced inside the cells of living things, and not in the reactors of the chemical industry. There is a crucial molecular difference between dioxin and hormones. Dioxin is distinctively characterized by its chlorine atoms, which, when linked to particular carbon atoms in its molecular structure, give rise to dioxins powerful toxic properties. In contrast, no natural hormone is chlorinated.
What should we call a man-made substance that is not a hormone but acts like one -- inducing powerful, often destructive changes in biochemical processes? We already have a generic name for such substances, chemicals that are designed to powerfully modify cellular chemistry, but in useful ways: pharmaceutical drugs. It makes more sense, I believe, to call dioxin an environmental drug than an environmental hormone, for it helps to explain why dioxins and dioxin-like substances are so menacing to human health and environmental quality.
Unlike ordinary pharmaceutical drugs, dioxins were not subjected to years of testing in the laboratory, and in patients, in order to make sure that they do more good than harm. Unlike ordinary drugs, they are not prescribed by a physician for the use of an individual patient in order to counter a previously diagnosed ailment. Instead, dioxin and dioxin-like substances were massively released into the environment long before their enormous biological powers were studied, let alone understood. Dioxin and its chemical cousins have been administered, wholesale, to everyone -- whether old, young, or not yet born; whether well or sick; whether they want it or not; and certainly not under the watchful care of a physician. Thus, like the pharmaceutical companies, the entire chemical
How can we bring this rogue sector of the chemical industry under control and protect ourselves from its powerful threats? The world owes the International Joint Commission (IJC), its staff and scientific consultants (and indeed, Greenpeace and the other grassroots organizations that have participated in this work) a huge debt of gratitude for their efforts to understand this issue and develop constructive ways of dealing with it. In its most recent (Seventh) Biennial Report, the IJC spells out its key conclusions:
* Persistent toxic substances are too dangerous to the biosphere and to humans to permit their release in any quantity, and
* All persistent toxic substance are dangerous to the environment, deleterious to the human condition, and can no longer be tolerated in the ecosystem, whether or not unassailable scientific proof of acute or chronic damage is universally accepted.
* The production and release of these substances into the environment must, therefore, be considered contrary to the Agreement legally, unsupportable ecologically and dangerous to health generally. Above all, they are ethically and morally unacceptable. The limits on allowable quantities of these substances entering the environment must be effectively zero, and the primary means to achieve zero should be the prevention of their production, use and release rather than their subsequent removal.
Clearly, this means that changes must be made in the chemical industry to alter or eliminate the processes that give rise to dioxin and dioxin-like substances. These dangerous chemicals can be formed in many of the industrys organo-chlorine reactions, or whenever the products of these reactions, such as PVC, are burned. What needs to be done about that has also been made clear in an earlier (the Sixth) IJC Report:
We know that when chlorine is used as a feedstock in a manufacturing process, one cannot necessarily predict or control which chlorinated organics will result, and in what quantity. Accordingly, the Commission concludes that the use of chlorine and its compounds should be avoided in the manufacturing process.
This proposal and the campaigns developed by Greenpeace and other environmental organizations have already launched the issue of banning chlorine into the domain of public debate. We have already heard the replies from the industry and its friends. One argument, advanced by the chemist G.W. Gribble, is that [C]hlorine is as natural to our world as carbon, oxygen and hydrogen. Of course that is true, but the point is that chlorinated organic compounds are not so natural. They are rare in living things; only about 600 such substances have been identified, compared with tens of thousands of different organic substances made by living things that are not chlorinated. Moreover, not a single chlorinated organic compound has been identified as natural in mammals. In Gribbles compilation of 611 chlorinated (and other halogenated organic) compounds produced by living things, there are numerous examples from fungi, higher plants, algae, sponges, jellyfish, worms, and other marine animals. There is exactly one entry under mammals -- a chlorinated compound found in the urine of a group of cattle. Recently I called the author of the paper cited by Gribble, Dr. K-C. Luk. He told me that he had no way of knowing whether the chlorinated compound was a natural metabolic product or was acquired by the cattle from the environment. Given the huge amount of unnatural chlorinated organic compounds that beset modern agriculture, I would bet on the environment.
In fact, these data are very illuminating. It looks as though in the early evolution of living things, a few organochlorine compounds were included in their biochemical systems. But when the first mammals -- or possibly vertebrates -- emerged, chlorine was abruptly excluded from this new form of life. As a result, chlorinated organic compounds like dioxin are incompatible with the distinctively complex hormonal systems and developmental processes that are characteristic of vertebrates, especially mammals. The chemical industry has violated this biological taboo, and we are all paying dearly for this transgression -- for, in the words of the IJC, it has created the spectre of damaging the integrity of our own species [and probably of other vertebrates as well] and its entire environment.
Instead of producing known products to satisfy existing industrial needs, it [the petrochemical industry] is, increasingly, producing new forms of matter which not only replace the materials used by existing industries, but which cause extension and modification of those industries...To an increasing degree it forces existing industries to adapt themselves to use its products.
I believe that this is where the industry is most vulnerable. As the source of persistent, dangerously toxic substances, the chemical industry must drastically change its methods of production -- and where necessary its products -- beginning with the elimination of chlorine. Of course, the industry will use its enormous wealth and political power to resist such change. But some of its equally powerful corporate customers -- paper mills, electronics manufacturers, and the food industry -- may be less rigid. Yes, they have been invaded by the chemical industrys products that they use. But with those products have come the built-in toxic accompaniments and the economic liability for their damage.
We now know, for example, that the U.S. population is exposed to dioxin not so much from the chemical industrys direct emissions, but chiefly from food that has been contaminated with dioxin entering the food chain, especially beef and dairy products. These industries, already suffering from reduced consumption to avoid fat and cholesterol, are now likely to be hit once more, this time by the dioxin problem. Sooner or later, properly encouraged by grassroots activists, they will use their corporate power to persuade the chemical industry to change its ways. Already the paper industry has begun -- very quietly -- to make plans for ending chlorine bleach processes. There are even whispers from the chemical industry itself that they have got the message; very quietly, I have heard, their chemists are looking for ways to take chlorine out of their processes.
These are some of the reasons why we are at a turning point not only in the history of dioxin, but of the chemical industry itself. What has brought us to this point, I am convinced, is the environmental movement -- at its powerful grassroots: the numerous community campaigns against trash-burning incinerators; the valiant battles against hazardous waste incinerators at East Liverpool and Jacksonville; the struggles at Times Beach and Love Canal; the campaign for justice for the veterans exposed to Agent Orange.
Let this conference, here in the place where it all began, be the start of new campaigns and new victories -- for the sake of the environment and people who live in it.
The 2nd Citizens Conference on Dioxin, held July 29-31, 1994, at St. Louis University, Missouri, was sponsored by Waste Not; the Gateway Green Alliance, St. Louis, Missouri; and NC WARN (Waste Awareness & Reduction Network), Sanford, North Carolina. A report containing the papers presented at the Conference will be published in early 1995.
Editors: Ellen & Paul Connett, 82 Judson Street, Canton, New York 13617. Tel: 315-379-9200. Fax: 315-379-0448.