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November 12, 2002
Dear Senator Mikulski and Senator Bond: The Alliance for the Responsible Use of Chlorine Chemistry (ARCC) supports the call for an interagency review of U.S. policy regarding dioxin and the EPA Dioxin Reassessment as contained in HR 107-740. The ARCC also supports the requirement that the National Academy of Science (NAS) review EPA's health risk assessment of dioxin before it is finalized, as mandated in the original report language accompanying the Department of Veterans Affairs and Housing and Urban Development, and Independent Agencies (VA/HUD/IA) FY 2003 spending bill. 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 that the Agency for Toxic Substances and Disease Registry (ATSDR) recently published an overview concerning how different federal and international bodies assess the potential risks posed by dioxin. Whereas EPA relies solely on an overly conservative approach to quantify dioxin risks, other federal and international bodies (e.g., ATSDR, the European Commission Scientific Committee on Foods (EC), the Joint FAO/WHO Expert Committee on Food Additives (JECFA)) adhere to a "world-wide convergence" on an acceptable dioxin exposure of approximately 1 to 4 pg/kg/day. This 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. Workers in the chlorine chemistry sector, which employs over 300,000 Americans, are affected by policy positions taken by the EPA and deserve a thorough review of EPA's Dioxin Reassessment by both the NAS and the Interagency Working Group on Dioxin. We believe the interagency process that has been convened can effectively address the discrepancy between US EPA and the rest of the global scientific community, including other US scientific agencies. We also believe that NAS should be asked to review EPA's health risk assessment of dioxin. Otherwise, basing US health policy on EPA's Dioxin Reassessment going forward may work to the detriment of US industry sectors including public health, chemicals, agriculture, transportation and utilities. For the foregoing reasons, we support both the call for an interagency review, as noted in HR 107-740, and an NAS study of the dioxin reassessment. Sincerely,
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