FEATURE
The Changing Landscape of the Chlorine Debate Growing health concerns and emerging market forces have reshaped the terms of the chlorine debate. TERRY F. YOSIE
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lready several decades old, the public debate about the human health and environmental effects of chlorinated organic compounds has entered a critical new phase. The number of human health and ecological effects of concern has increased, expanding the scope and complexity of the scientific debate, policy considerations, and public concerns. The marketplace is emerging as an important force as companies begin to differentiate products based on chlorine content or use. Also, advocacy groups have developed innovative strategies to communicate their concerns to the public. Resolution of this debate is not likely to come soon either from breakthroughs in scientific understanding or traditional regulatory actions. Within the scientific community there is a lack of consensus about the relative severity and importance of reported hypotheses or effects related to many of these compounds. Regulators are finding it difficult to evaluate the risks and benefits of compounds used in a broad array of industrial and consumer sectors and to then devise policy responses. As a result, the policy initiatives currently under way target different aspects of the chlorine issue. EPA is completing its reassessment of the health and environmental risks and control strategies associated with dioxins; developing air toxin and wastewater discharge limits for the pulp and paper industry; and reviewing options to control such activities as sludge burning, land application of chlorine-containing sludge, and hazardous waste and medical waste incineration. Meanwhile, Congress has passed amendments to the drinking water and pesticide statutes that would require screening for the presence of endocrine-disrupting compounds. Germany and other nations within the European Union are evaluating whether to limit or phase out uses of polyvinyl chloride and other chlorinebased products. Numerous Scandinavian firms have already implemented substitutes for chlorine in pulp 4 9 8 A • VOL. 30, NO. 11, 1996/ ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS
and paper bleaching operations, and the United Nations Economic Commission for Europe has initiated negotiations with more than 50 countries to develop an international agreement, scheduled for completion at the end of 1997. This agreement would curb the use of a dozen persistent chlorinated organics, including DDT and polychlorinated biphenyls. Scientific dilemma: outstanding questions A major dilemma persists against this backdrop of policy considerations regarding society's use of chlorinated compounds: Can current scientific information resolve chlorine-related human health and environmental issues? Relatively little data are available on literally thousands of chlorinated compounds commonly used. Between the bookends of the scientific and public debates of the past 30 years— Rachel Carson's Silent Spring and the recently published Our Stolen Future (i)—stand a number of reviews by regulatory agencies; the National Research Council, EPA's Science Advisory Board; the National Toxicology Program; the International Agency for Research on Cancer; the International Joint Commission; and other scientific bodies of the health and environmental effects of dioxins, furans, solvents, and other classes of chlorinated compounds. In addition, numerous special studies have been generated by industry groups and environmentalists, often in support of their policy objectives. Interest in the scientific community to resolve the major questions and research gaps is rapidly expanding. Major issues actively pursued include determining exposure levels from chlorinated compounds that are most relevant to assessing human health risks; identifying the mechanisms by which health and ecological effects can occur; developing screening capabilities to identify hormone disruption; and evaluating the potential for biopersistence and bioaccumulation for a broad range of chlorinated compounds. Recently, workshops have been sponsored by government, industry, universities, and professional so0013-936X/96/0930-498A$12.00/0 © 1996 American Chemical Society
cieties to define research needs. EPAs Office of Research and ^ Development, for example, H has recently proposed a stra- « | tegic research plan (2) that in- 9 eludes six high-priority top- • ics, two of which are related to 1 potential risks associated with the use of chlorinated com- } pounds, as well as a research needs assessment for endocrine disrupters (3). Given the variety of research hypotheses involved, no agreement has yet been reached on a comprehensive research agenda. This is one of the likely byproducts of the review currently under way by the National Research Council's Committee on Hormonally Active Agents in the Environment, \ which is scheduled for completion in 1997. The scientific community is at least a decade away from obtaining more definitive information on critical health and environmental issues of interest to policymakers, consumers, and other stakeholders.
The chlorine industry has expanded its strategy of communicating the beneficial uses of chlorine to the public. The Chlorine Chemistry Council has pub, lished a series of brochures extolling specific uses of chlorinated compounds and opened a World Wide Web site earlier this year.
Industry's risk-benefit strategy As the scientific debate evolves, two principal protagonists—the chlorine industry and the environmental advocacy groups—advance formal strategies to achieve their public policy objectives. Industry has raised the issue of the relative risks and benefits of these compounds, while many environmentalists have increasingly narrowed their focus from all chlorinated compounds to the most environmentally persistent ones. In the aggregate, various sectors of the chlorine business community, including the chemical, consumer products, pharmaceutical, pulp and paper, and water treatment industries, have developed a chlorine strategy that includes the following objectives: Avoid or delay new regulatory initiatives; alter policy decision criteria in favor of risk-benefit-cost factors; enable companies that produce or use chlorine compounds to minimize potential disruptions to their operating processes and markets from legislative and The chlorine inregulatory actions; and achieve a level playingfieldof dustry has also helped refocus the deregulatory requirements for industries. bate on real versus theoretical risks associated with Industry groups have commissioned literature re- exposure to chlorinated compounds. The weight of views to highlight the scientific uncertainties asso- scientific opinion, which reflects available techniciated with proposals to reduce the use of chlori- cal information and methods, has increasingly shifted nated compounds. One example of this strategy was away from the a priori use of conservative models the publication of a special supplement to the jour- in favor of approaches that present a variety of risknal Regulatory Toxicology and Pharmacology (4), "In- estimation techniques. Building on the growing poterpretive Review of the Potential Adverse Effects of litical support for targeting high-priority risks and inChlorinated Organic Chemicals on Human Health tegrating benefit-cost information into the decisionand the Environment." This assessment, funded by making process, chlorine business groups have the Chlorine Chemistry Council, the Chlorine Insti- advocated legislative and regulatory initiatives such tute, the EuroChlor Federation, the European Coun- as HR 9 and S 343, which would expand the use of cil of Vinyl Manufacturers, the Halogenated Sol- such criteria. Although these bills failed to pass this vents Industry Alliance, and the Vinyl Institute, year, environmental policy making continued to presents 1056 pages of scientific information that, in evolve in this direction, as seen in amendments to the words of the journal's editors, "clearly indicate the Safe Drinking Water Act. that the alarms about chlorine-containing comOrganizations such as the Chemical Manufacturpounds are unwarranted." ers Association and the Chlorine Chemistry CounVOL. 30, NO. 11, 1996 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS • 4 9 9 A
Environmental groups have sought to personalize the risks of exposure to chlorinated compounds. In its 1995 publication "Dow Brand Dioxin," Greenpeace links Dow Chemical, a major chlorine producer, with health impacts such as male and female reproductive disorders caused by the toxic compound.
cil aim to leverage these developments within the risk analysis community through supplemental research and public relations efforts to magnify the voices of scientists who advocate using less conservative risk assessment methods. For example, the U.S. chemical industry has recently set aside several million dollars for additional research related to health and environmental issues related to chlorine (5). The chlorine industry has also continued to expand its strategy of communicating the beneficial uses of chlorine to the public. Recent publications of the Chlorine Chemistry Council illustrate the beneficial use argument: "Chlorine: Vital to Public Safety," "Chlorine: Enhancing Everyday Life," and "Chlorine: Cornerstone of Modern Medicine." The broad scope of the beneficial-use argument enables business advocates to cite numerous consumer and societal benefits associated with chlorinated compounds, including their use in air bags, flame-retardant clothing, household cleaning agents, prescription and over-thecounter drugs, plastic packaging, and plumbing. Environmentalists target the marketplace On the chlorine debate, environmentalists have incorporated new elements into their traditional ad5 0 0 A • VOL. 30, NO. 11, 1996/ ENVIRONMENTAL SCIENCE & TECHNOLOGY/ NEWS
vocacy tactics. Four objectives form the core of this strategy: maintaining traditional support for regulatory agencies to expand controls on industrial processes and products; aggressively participating in the scientific debate; promoting the chlorine debate as a broad-based consumer issue that will ultimately influence purchasing decisions; and establishing closer working relationships with companies that seek a competitive advantage from the reduced use of chlorinated compounds. Although not all environmental groups subscribe to each element of this approach, organizations such as the Environmental Defense Fund, National Wildlife Federation, Natural Resources Defense Council, and the World Wildlife Fund are relying on these techniques in their advocacy. Scientists affiliated with environmental organizations have participated vigorously in the scientific debate on this issue and have published numerous studies in peer-reviewed journals (6, 7). Over time, the issues they have raised, such as the importance of noncancer health effects, have been placed on the scientific and public policy agenda. Calls for outright bans on chlorinated compounds have increasingly been abandoned by these groups, who have narrowed the focus of proposed regulatory restrictions to environmentally persistent compounds and acknowledged some of the beneficial uses of chlorine, such as in the pharmaceutical industry. Also, they have developed proposals to increasingly shift the burden of testing for po' tential health and environmental effects to industry, emphasizing preventive strategies from exposure to biopersistant and hormone-disrupting compounds, monitoring products for contamination, and expanding public reporting requirements for industry (i). Environmentalists have increasingly emphasized the personalized nature of the risk of exposure to chlorinated compounds. By educating the public about the possible links between chlorine exposures and breast cancer, reproductive dysfunction, and learning disabilities, for example, they have sought to broaden the debate beyond scientific and policy parameters into one involving consumer and personal concerns. Environmental groups are also pursuing direct discussions with industry and leveraging the marketplace. Some groups have become increasingly sophisticated in managing their relationships with individual companies and pursuing opportunities to discuss business strategies and environmental policies with senior industry leaders. This dialogue has resulted in several initiatives that have influenced chlorine markets in areas such as paper recycling, the substitution of perchloroethylene in dry cleaning processes, and technology changes in the pulp and paper industry. For example, in 1995, Greenpeace joined the International Fabricare Institute and other organizations that represent the dry cleaning industry to explore alternatives to the use of perchloroethylene (8). The Natural Resources Defense Council is heading a project to build a $465 million paper recycling plant in the Bronx that would produce chlorine-free paper (9).
No traditional regulatory fix The evolution of the chlorine debate will likely differ from approaches used to address previous health and environmental problems such as ambient air quality, acid deposition, and hazardous waste management. In these instances, technology-based and institutional controls formed the primary tools for environmental improvement. Discussions with senior EPA research and regulatory officials, however, indicate that the agency does not presendy plan to undertake major new chlorinerelated policy initiatives mat rely on traditional command-and-control regulations. Some senior EPA officials responsible for chlorine issues have concluded that such initiatives, in the face of current policy and budget uncertainties, would be ill-timed. Policy and administrative factors also impede a more aggressive EPA role in the chlorine debate. At present, the agency has no integrated strategy for managing the many different chlorine-related issues. EPA is principally reacting to events originated by other interests, increasing its research capabilities, and expanding screening requirements for products prior to market approval but is avoiding major controversial actions. The recent enactment of amendments to the Food Quality Protection Act and the Safe Drinking Water Act requiring screening for estrogenic substances will increase EPA's authority in this area. As a result, companies will face growing pressures to disclose more information about their use of chlorinated compounds. In the midst of a continuing cycle of scientific and policy reviews, a major new factor is emerging with the potential to reshape much of the landscape of the chlorine debate—the marketplace. Competitive and environmental pressures are pushing many users to seek substitutes for chlorinated compounds. Chlorine use is declining significantly in the pulp and paper industry and the solvents business. Increasingly, chlorinated substances used in making various commercial products such as agricultural chemicals and polyvinyl chloride are at risk because of environmental concerns and changing customer preferences. Also, chlorine use in relatively stable markets, such as water treatment, will be subject to additional scrutiny because of concerns over its efficacy in protecting against pathogens in drinking-water supplies (10). One outcome of mese competitive pressures is already evident: Solvent producers are finding chlorine substitutes such as oxygenates in order to protect and potentially expand their market share. The public health and environmental debate over chlorine use has become a major part of the competitive equation for a growing number of companies
ill). In addition, a fundamental transformation is under way in the structure of chlorine production. Average plant size has doubled in the last generation, while the number of producers and plant sites has been reduced by half. Production has become more geographically centralized, with approximately 70% of U.S. production located in the Gulf Coast region. These trends are likely to continue beyond the year 2000, resulting in fewer jobs and a less diversified in-
dustry that environmentalists and regulators will find somewhat easier to monitor (12). Public concern about the potential risks associated with chlorinated compounds is likely to grow. Environmentalists have successfully placed the issue of chlorine-induced hormone disruption permanentiy on the scientific and public policy agenda. Over time, their strategy of "personalizing" chlorine risks and directly engaging consumers in the debate will influence public policy and business practices. And although in the short-term the scientific community is unlikely to definitively resolve many of the most important questions about chlorinerelated health and ecological effects, the scope of scientists' interests and concerns will also expand as greater resources are committed to researching hormonally active compounds. The public is unlikely to wait for definitive answers, however, and neither are a number of businesses that seek to control their own destiny. Growing public concern will motivate a n u m b e r of companies to develop alternatives to chlorinated compounds and seek market opportunities for them. Regulatory policies will eventually ratify these marketplace developments to establish minimum standards. As users of chlorinated products continue to seek less controversial alternatives with equivalent price and performance value, chlorine producers may continue to prosper but in a smaller, more concentrated industry.
Acknowledgments The author would like to thank the following individuals for offering their perspectives on various aspects of the chlorine debate: William Carroll, Theo Colborn, Devra Lee Davis, Roger McClellan, Sharon Newsome, David Rail, James Reisa, and Joseph Rodricks.
References (1) Colborn, T.; Dumanoski, D.; Myers, J. P. Our Stolen Future; Dutton: New York, 1996. (2) Strategic Plan for the Office of Research and Development: 1995; U.S. Environmental Protection Agency. Office of Research and Development. U.S. Government Printing Office: Washington, DC, Nov. 1995; EPA/600/R95/162. (3) Kavlock, R. J. et al. Environ. Health Perspect. 1996, 104 (Suppl 4), 715-40. (4) Report of an expert panel. Regul. Toxicol. Pharmacol. 1994, Aug., 20, 1-1056. (5) Webber, F. L. Chemical Week 1996, Aug. 14, p. 3. (6) Colborn, X; vom Saal, E; Soto, A. Environ. Health Perspect. 1993, 101. (7) Silbergeld, E. K.; Gasiewicz, T. A. Am. J. Ind. Med. 1989, 16. (8) Black, H. Environ. Sci. Technol. 1996, 30, 284A. (9) Holusha, J. The New York Times, June 12, 1996. (10) Whitfield, R. M. Presented at Chemical Week's "The Chlorine Industry in the 21st Century" conference, New Orleans, LA, April 11-12, 1995. (11) Pourreau, D. Presented at Chemical Week's "The Chlorine Industry in the 21st Century" conference, New Orleans, LA, April 11-12, 1995. (12) Westervelt, R.; Roberts, M. Chem. Week 1995, Nov. 22, pp. 25, 26-28. TerryF.Yosie is executive vice president of the E. Bruce Harrison/Ruder Finn Co. and former director of EPA's Science Advisory Board. He currently serves on the steering committee ofSAB's Integrated Risk Project.
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