(Lighting the way to Less Toxic Living)

Liberty Goodwin, Director

P.O. Box 40441, Providence, RI 02940

Tel. 401-351-9193, E-Mail:



Recognizing and Addressing the Environmental and Occupational Health Problems Posed by Chlorinated Organic Chemicals


(American Public Health Association Statement on Chlorine)




9304:     Recognizing and Addressing the Environmental and Occupational Health Problems Posed by Chlorinated Organic Chemicals


The American Public Health Association,


Recalling APHA’s long-standing commitment to primary prevention in the reduction of environmental pollution, expressed recently in Policy Statement 8912: Public Health Control of Hazardous Pollutants, which states that APHA:


“will actively support legislation which establishes prevention as the primary promise for controlling and managing hazardous air emissions, and expeditiously reduces emissions, for existing and new sources, of all substances which are reasonably anticipated to pose hazards to human health and the environment;” and


Understanding that often classes of compounds must be considered as a group for preventive/public health purposes, as recently expressed in APHA Policy Statement 8709: Depletion of Stratospheric Ozone Layer, which supported:


“a global policy that calls for a ban on CFC (chloroflourocarbon) aerosol propellents, and a timely phase-out of known ozone-depleting substances within 10 years;” and


Noting that chlorinated organic chemicals, including PCBs, pesticides, dibenzodi-oxins, dibenzofurans, and many other products or byproducts of chlorine based industrial processes, comprise the majority of identified persistent xenobiotic substances, whose half lives or those of their toxic byproducts are 8 weeks or more in the environment and human tissues and fluids1 and are also the primary cause of stratospheric ozone depletion;5 and


Noting that virtually all chlorinated organic compounds that have been studied exhibit at least one of a wide range of serious toxic effects such as endocrine dysfunction, developmental impairment, birth defects, reproductive dysfunction and infertility,6-10 immunosuppression, and cancer, often at extremely low doses11-13 and that many chlorinated organic compounds, such as methylene chloride and trichloroethylene, are recognized as significant workplace hazards; and


Understanding that stratospheric ozone depletion caused by a relatively wide range of halogenated compounds including chlorinated compounds is expected to cause millions of additional cases of human skin cancer, cataracts, and immune suppression, as well as having major effects on aquatic and terrestrial food chains;14 and


Understanding that in the Great Lakes, a vast well-studied ecosystem that provides an early warning sentinel for xenobiotic-induced health effects, contamination by a broad spectrum of chlorinated organic chemicals has caused a wide range of reproductive, developmental, and behavioral dysfunction effects in 14 species at the top of the food chain, including humans;15,16 and


Recognizing the subtle and widespread effects on human and wildlife health attributed to exposure to chlorinated organic chemicals and our current inability to identify, predict, or control the release of these compounds from manufacturing processes, and that the bi-national Science Advisory Board of the International Joint Commission on the Great Lakes (IJC) concluded by the weight of scientific evidence16 that exposure to all organochlorines should be presumed to pose a health problem and that policies to protect public health should be directed toward eventually achieving no exposure to chlorinated organic chemicals as a class rather than continuing to focus on a series of isolated, individual chemicals; and


Understanding, as has the IJC, that the only feasible and prudent approach to eliminating the release and discharge of chlorinated organic chemicals and consequent exposure is to avoid the use of chlorine and its compounds in manufacturing processes;16 and


Clearly realizing that implementation of such a goal should proceed initially via an investigation of the feasibility of phasing out chlorine and chlorinated organic chemicals by industry category; and


Yet recognizing that specific deadlines for phase-outs are appropriate in industrial categories where alternative processes have already been developed (e.g., for bleaching in the pulp and paper industry16 or degreasing in manufacturing as has been adopted by IBM, GE, and others);17,18 and


But recognizing as well that some uses of chlorine, in particular its use in residual disinfection of drinking water and in pharmaceuticals, have no currently available alternatives; and


Further, being aware that the phase-out of ozone-depleting chlorinated chemicals in feed stock has been a major reason for the closure of five chlorine plants during the past two years, resulting in substantial layoffs;19 and


Projecting that further restrictions on the use of chlorine, or the production of chlorinated compounds, will result in additional job loss; and


Recognizing that unemployment leads to increases in physical and mental illness, death, and crime and requires environmental protection policies that contain provisions for a transition that ensures that displaced workers do not bear unfair societal costs through the loss of income, benefits, or jobs as has been the case in the past;20 and


Understanding that the Job Training Partnership Act serves only 4% of all eligible workers and that these workers, on average, are eligible for jobs paying near or below the family poverty level,21 and that the Oil, Chemical, and Atomic Workers Union proposal for a policy based on the GI Bill of 1944 would allow workers to maintain their families’ standard of living while retraining and securing jobs in nonpolluting industries; therefore


1.     Recognizes that chlorine-containing organic compounds are found to pose public health risks involving the workplace, consumer products, and the general environment;

2.     Recognizes that the elimination of chlorine and/or chlorinated organic compounds from certain manufacturing processes, products, and uses may be the most cost-effective and health protective way to reduce health and environmental exposures to chlorinated organic compounds;

3.     Recognizes that industry has the capacity and creativity to undertake a technological transformation of chemical manufacturing processes, products, and uses to reduce or eliminate these risks;

4.     Concludes that there should be a rebuttable presumption that chlorine-containing organic chemicals pose a significant risk, and that, therefore, before introducing new chemicals into commerce, using existing chemicals in new applications, or continuing to use these chemicals in manufacturing processes or products beyond some future date, industry should:

a.     Demonstrate that the risk is not significant for a particular compound, use, or manufacturing process; or

b.     Demonstrate that there are no substitutions, product reformulations, or changes in manufacturing processes that will result in a lower risk; or

c.     Ensure that substitutes for existing products or changes in manufacturing processes will result in a lower risk.

5.     Supports legislation that will assist workers who are displaced by resulting technological changes in the chlorine industry; and

6.     Finally, asks for measurable and progressive reduction toward the elimination of the use of chlorine-based bleaches in the pulp and paper industry and ozone-depleting chlorinated organic chemicals.




  1. Stanley J. Broad Scan Analysis of Human Adipose Tissue. Executive Summary. Springfield, VA, USEPA; 1968.
  2. Jensen A. Chemical contaminants in human milk. Residue Reviews. 1993;89:1-128.
  3. Dougherty R, Whitaker M, Smith L, Stalling D, Kaehl D. Negative chemical ionization studies of human and food chain contamination with xenobiotic chemicals. Env Health Perspectives. 1980;36:103-118.
  4. Travis C, Hattemer-Frey H. Global chemical pollution. Env Sci and Tech. 1991;23:814-819.
  5. Report from the Ozone Trends Panel. New York, NY: United Nations Environmental Program; 1988.
  6. Jacobsen JL, Jacobsen SW, Humphrey HEB. Effects of in utero exposure to polychlorinated biphenyls and related contaminants on cognitive functioning in young children. J Pediatrics. 1990;116:38-45.
  7. Daly HB. Reward reduction found more aversive by rats fed environmentally contaminated salmon. Neurotoxicology and Teratology. 1991;13:449-453.
  8. Jacobsen JL, Jacobsen SW, Padgett RJ, Brumitt GA, Billings RL. Effects of prenatal PCB exposure on cognitive processing efficiency and sustained attention. Develop Psychol. 1992;28:297-306.
  9. Thomas KB, Colborn T. Organochlorine endocrine disruptors in human tissue in chemically-induced alterations in sexual and functional development: the wildlife human connection. In: Colborn T, Clement C, eds. Advances in Modern Environmental Toxicology, Vol. 21. Princeton, NJ: Princeton Scientific Publishing Co. 1992.
  10. Daly HB. The evaluation of behavioral changes produced by consumption of environmentally contaminated fish. In: Issacson R, Jensen F, eds. The Vulnerable Brain: Nutrition and Toxins. New York, NY: Plenum Press, 1993.
  11. Colborn T, Clement C, eds. Chemically-induced alterations in sexual and functional development: the wildlife/human connection. Advances in Modern Environmental Toxicology. Vol. 21. Princeton, NJ: Princeton Scientific Publishing Co., Inc.1992.
  12. Dioxin Reassessment. Washington, DC: USEPA, 1992.
  13. Morris RD, et al. Chlorination, chlorination by-products, and cancer: a meta-analysis. AJPH. 1992;82(7):955-963.
  14. Environmental Effects of Ozone Depletion: 1991 Update. New York, NY: United Nations Environmental Program; November 1991.
  15. Allan R, Ball A, Cairns V, et al. Toxic Chemicals in the Great Lakes and Associated Effects. Toronto, Ontario: Environment Canada; March 1991.
  16. Colborn T, et al. 1991 Report to the International Joint Commission. International Joint Commission–Great Lakes Science Advisory Board. September 1991.
  17. GE set the company-wide goal of eliminating CFC-113 by 1/1/94, methyl chloroform by 1/1/96 and Trichloroethylene and perchloroethylene by 1/1/98. Press release. Santa Clara, CA. IBM; April 1990.
  18. Letter dated August 7, 1992 from Daphne Coleman, Manager-Southern Region, General Electric Company to NC-WARN.
  19. Pamphlet 10. Washington, DC: Chlorine Institute, January 1992.
  20. US Department of Labor. Press Release. August 19, 1992.
  21. US Department of Labor. JTPA Program Highlights. October 1992, 1(2):17.