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Honorable
Christine Todd Whitman Dear Administrator Whitman: The Alliance for the Responsible Use of Chlorine Chemistry (ARCC) supports your call for an interagency review of U.S. policy regarding dioxin and the EPA Dioxin Reassessment. The ARCC is a coalition of US unions and companies concerned with jobs and investments in the chlorine chemistry industries (see www.chlorallies.org). We are aware of the dioxin exposure guidelines used by the Department of Agriculture and the Food and Drug Administration, and the guidelines established by scientists of the US Agency for Toxic Substances and Disease Registry in 2000. They indicate that current exposure levels do not pose unacceptable risks to the American public. These US guidelines are even more conservative than those recently established by food experts at the United Nations/World Health Organization and recently adopted by the European Commission. The global scientific consensus signals good news for the American public, and American workers and industry, and for the success of EPA's regulatory program that has resulted in a 93 percent reduction in dioxin emissions since 1987. However, we understand that findings in EPA's new Reassessment could be extrapolated to indicate that the current US exposure levels are not acceptable - that in fact they are hundreds or thousands of times too high. This is confusing to say the least, with major ramifications for public health, other risk management priorities and the economy. We believe an interagency process must be convened to address the discrepancy between US EPA and the rest of the global scientific community, including other US scientific agencies. Otherwise, basing US health policy on EPA's Dioxin Reassessment going forward may work to the detriment of US sectors including public health, chemicals, agriculture, transportation and utilities. Sincerely,
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