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Greenpeace's Letter to EPA on a Emergency Dioxin Task Forc

May 17, 2000

Ms. Carol Browner, Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460

Dear Ms. Browner,
Because the US EPA's dioxin reassessment has already been leaked to the media, we recommend that you now post the entire report on EPA's web page. In addition, we urge you to immediately convene an Emergency Task Force on Dioxin Elimination. After three different dioxin reassessments over the last 15 years, the time has come for strong and decisive action based on the formidable body of scientific evidence the Agency has amassed.

This task force should focus on initiatives to prevent new dioxin sources and to eliminate existing sources of dioxin. Although recent end-of-the-pipe regulations of incinerators and paper mills were in part designed to make "reductions" in dioxin output, they have failed to eliminate or even significantly reduce dioxin levels in humans and the food we eat.

For general guidance, we suggest the task force pursue the 1992 recommendations of the International Joint Commission (IJC), a bi-national body of the US and Canada which had some very fundamental recommendations and scientific reports on dioxin policy for the Great Lakes Region. Given the new evidence in EPA's reassessment, these recommendations should now be applied to both US national and global dioxin policies.

The IJC's 1992 biennial report recommended the "the Parties" [U.S. and Canada]:

*** "...alter production processes and feedstock chemicals so that dioxin, furan and hexachlorobenzene no longer result as byproducts.

*** "...develop timetables to sunset the use of chlorine- containing compounds as industrial feedstocks and that the means of reducing or eliminating other uses be examined.

*** "Incineration facilities in the region [Detroit-Windsor and Port Huron-Sarnia] be phased out of use or required to eliminate the production and emission of dioxins, furans, PCBs and inorganic materials, especially mercury and hydrochloric acid."

In particular, several local and global dioxin issues should be given priority by an EPA task force, including:

*** The EPA's latest review of the safety and legality of the WTI incinerator in East Liverpool, Ohio, located 1,100 feet from an elementary school.

*** EPA decisions on whether to allow the dioxin laden PVC industry to expand in Lake Charles area of Louisiana, where dioxin levels are three times the national average in the blood of local citizens.

*** The US State Department's dioxin policy at current UN treaty negotiations on POPs should be modified to reject chemical industry pressure and support the "elimination" of dioxin instead of weak plans for unspecified "reductions."
Although the dioxin reassessment confirms that dioxins are highly toxic, persistent, bio-accumulative by-products of industrial activities and products, it is a problem that is almost entirely unnecessary and preventable. According to EPA's reassessment the levels of dioxin in ancient human tissue were 2 percent of what they are in people living in the US today. And according to EPA's lake sediment studies, dioxin only began to rise steadily in the environment around the 1930s when chlorine use in industry increased dramatically.

By pursuing proactive policies of precaution and prevention, the formation of new dioxins can be eliminated and background levels, now threatening the general US population, can be reduced as dramatically as they were increased over the last century.

Thank you for a responding at your earliest convenience.

Sincerely,

Rick Hind
Legislative Director,
Greenpeace Toxics Campaign

Cc:
President William Clinton
Vice President Albert Gore
Secretary of State Madeleine Albright