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EPA's Draft
Dioxin Reassessment Needs A Full Review Health, economic implications of draft findings
potentially staggering In September 2000, the Environmental Protection Agency (EPA) released the latest draft of its reassessment of the potential health effects of dioxin exposure. Over eight years in the making and now exceeding 3,000 pages, the draft has stirred new controversy in the scientific and policy-making communities. EPA's draft asserts that the acceptable level of dioxin exposure is several thousand times below levels set in1998-99 by the World Health Organization and the U.S. Government. EPA's draft says that environmental background / dietary exposure to dioxin could be responsible for 60,000 cancer deaths in the U.S. and 1.2 million cancer deaths globally every year. Because humans ingest dioxin by eating meat, poultry and fish, this would appear to mean that EPA thinks the U.S. and global food supplies are unsafe. However, many leading dioxin research scientists are skeptical or dismissive of this claim, saying that it greatly exaggerates any actual risk. EPA reports that Americans are exposed to far less dioxin today than they were in past decades because of better regulation and improved technology. Exposure is projected to continue to decline, and has reached a 60-year low. American children born today will have virtually no lifetime exposure to the most toxic dioxin, called 2,3,7,8 TCDD. Controversial EPA Review Process Draws Fire Despite the radical revision in risk estimates, EPA has given only a few chapters of the draft to its Science Advisory Board (SAB) for review and appears to be pushing for a quick favorable decision on the validity of its new estimates. A past SAB member who reviewed and criticized EPA's 1995 draft told the New York Times that the new draft is "an embarrassment." A number of his colleagues have affirmed this view. Given the dramatic public health and economic implications, coupled with the controversy surrounding EPA's conclusions and risk estimates, ARCC unions and companies join members of Congress in calling for a full SAB review of the entire draft reassessment. Obviously, there are compelling public interest justifications for a full and open review of the draft by the SAB. It is vitally important to be certain that the EPA document is correct. Otherwise, the nation could waste tens of billions of dollars and transfer tens of thousands of high-paying jobs offshore forever in the process. Given the potential for a food scare, ARCC also supports the decision by the U.S. Department of Agriculture and the Food and Drug Administration to have the National Academies of Science undertake a full-blown review of EPA's conclusions and the body of science on dioxin. The General Accounting Office will also review the issue. History of Controversy The EPA's dioxin reassessment has been wrapped in controversy for years. The first draft of the reassessment was released by EPA in 1995. At that time, after a full and open process of public review, the EPA's SAB rejected the draft because it overstated the risk of dioxin exposure, reached conclusions not supported by its data, and failed to identify major uncertainties about its conclusions. The SAB required EPA to address these concerns quickly so that the SAB would not have to review the entire draft again. Now six years have passed, and EPA wants the SAB to review only the conclusions of its new draft - despite the inclusion of information from 300 new studies since the 1995 draft and a radically revised risk estimate. This prompted the chairman of the House Committee on Science and other congressional representatives to write to the EPA Administrator urging EPA to have the SAB review the full document. It now remains to be seen what the new Administration will do to encourage EPA to support a full review. Some industry observers think that the EPA draft is a mixture of fact and political agenda, designed to damage the chlorine sector of the chemical industry without regard to the declining risk of dioxin exposure. While regulation and technology are slashing emissions from today's chlorine chemistry industries to achieve virtual elimination, ARCC believes that clean-up of sites contaminated by dioxin in the past should be undertaken through continued responsible applications of regulation and law. The Problem of Dioxins Dioxins as a class are persistent, toxic and bio-accumulative. Dioxins are unwanted manmade and naturally-occurring byproducts of combustion processes involving carbon, chlorine, hydrogen and oxygen. Dioxin emissions are carried by wind and water to all parts of the world, even areas where there is no industry. Dioxins can persist for as long as 20 years. The potential for harm from dioxin became known in the 1970s and 1980s. Since then, government and industry have invested billions of dollars in a successful effort to identify and reduce emissions of dioxin. Exposures are now at the lowest level in 60 years. Dioxin emissions from industry and natural sources make their way onto the ground and are consumed by animals. Once consumed, dioxin accumulates in the animal's fatty tissue. The consumption of meat, poultry and dairy products contributes 95 percent of a person's exposure to dioxin. Governments and international health agencies have studied dioxin in order to determine acceptable levels of exposure that do not constitute a risk to human health. Studies of chemical workers and military personnel directly exposed to extremely high levels of dioxin over long periods in the 1960s and 1970s demonstrated increased association with cancer and mortality. However, these exposures were many thousands of times greater than current environmental background levels, and high-level workplace and occupational exposures no longer occur. The Consensus on Dioxin The World Health Organization (WHO) and the U.S. Government set an acceptable daily intake for dioxin at about 1 picogram/kilogram of bodyweight per day (pg/kgbw/d) as recently as 1998-99. WHO actually uses a range of 1 - 4 pg/kgbw/d. EPA's new number is .0002 pg/kgbw/d, thousands of times below the generally recognized acceptable level. Economic Implications for American Workers and Companies Chlorine chemistry related industries directly employ over 300,000 Americans in manufacturing jobs and provides another 180,000 service sector jobs according to a 1993 study by the economic firm of Charles River Associates. As reported by ARCC News, these workers produce a host of beneficial chlorine based chemicals and finished products that support production in most major economic sectors. The industry pays higher than average wages and has one of the best worker safety records of any manufacturing sector. Workers in this sector are affected by policy positions taken by the EPA and deserve a thorough review of the EPA's draft dioxin reassessment. The entire U.S. chlorine manufacturing industry itself only emits less than 12 grams of dioxin a year into the environment while producing 14 million tons of chlorine. Regardless of the outcome of the SAB's review of the reassessment, the report signals that the companies and workers of the chlorine industry to build new partnerships with downstream users. Such partnerships could work to devise better ways of recycling some products that contain chlorine or help direct these products to modern incineration facilities or other safe disposal methods at the end of product life. EPA's draft recognizes the success of regulations and technology improvements in addressing dioxin emissions from industrial sources and does not call for any further regulatory action on industry. However, companies and workers in the chemical industry are very concerned that alarmists will use the report to attack them without acknowledging the tremendous progress made by industry to reduce its emissions. If the U.S. implemented policy based on the draft risk estimates, other countries would be forced to ban imports of U.S. beef, pork, poultry and dairy products as well as processed foods containing them because U.S. food would not meet U.S. government health standards. Such bans would be upheld by the World Trade Organization. The cost to U.S. farmers of lost beef, pork and poultry sales alone on the export market would be over $40 billion annually. Of course, there is no way to estimate the cost or the impact of a U.S. government agency officially signaling that the food supply is unsafe. Dioxin emissions have been slashed by 75 percent over the last 20 years and new regulations already in place will further reduce emissions from the largest remaining manmade sources by another 95 percent. For example, nationwide, incinerators used to emit over 11,000 grams of dioxin a year. Within three years, the nationwide number will fall to about 12 grams. |
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