TOXICS INFORMATION PROJECT (TIP)
(Lighting the way to
Less Toxic Living)
Liberty Goodwin, Director
P.O. Box 40572,
Providence, RI 02940
Tel. 401-351-9193,
E-Mail: TIP@toxicsinfo.org
Recognizing
and Addressing the Environmental and Occupational Health Problems Posed by
Chlorinated Organic Chemicals
01/01/1993
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.
References: