Although dioxin has no direct connection with alkaline paper or permanence or anything covered in this Newsletter, the subject keeps coming up. For the last year or two I have felt obliged to order, read and photocopy all the literature on dioxin I could find, to help me answer questions from readers not in the paper industry. Until recently, I have been very disappointed by what was available, because every single information source seemed to have turned into a propaganda machine or a player in a highly polarized public debate. I found very little that would have been accepted for publication in the professional literature of science. (As it turned out, the scientific literature is full of studies on dioxin, but the literature I was reading didn't refer to it.)
I went from one trusted source to another, and was disillusioned at every turn. Greenpeace is very effective at drawing public attention to environmental issues, but it is hopeless when it comes to facts. The American Paper Institute obviously has the business interests of the paper industry to promote, regardless of how much money they spend on special studies. I was disappointed but not very surprised by the material they sent me, which was essentially a series of communications to the public, intended to calm hysteria.
Even Barry Commoner, whom I had always regarded as an impartial source of information on environmental problem, let me down on this issue. His speech entitled "Acceptable Risks: Who Decides?" (Harpers Magazine, May 1988) is full of rhetorical tricks and shows no evidence that he has made any effort to find out what is really so. If he has discovered any reliable facts, he makes no effort in this article to communicate then honestly to his audience so that they can put then together with facts they've gotten elsewhere, and make up their own minds. The topic of his speech is the way the EPA regulates toxic substances by setting levels of acceptable risk. His position is that no level is acceptable.
Commoner oversimplifies when he defines smog ("a pollutant that originates when nitrogen dioxide is created as a result of the high temperature in modern automobile engines"), and in fact the definition is misleading and inaccurate. He impugns the motives of the scientists with the company doing the dioxin cleanup in Times Beach, without examining their evidence; draws conclusions without examining all the relevant facts; uses fallacious arguments; and uses ridicule to discredit opposing positions. Any leader and spokesman for a cause who insults the intelligence of his followers with speeches like this will soon find that attracted the kind of followers he deserves.
Dioxin does not fascinate me personally. I do care deeply about the environment, and I know something about toxicity, since I have to cover it for my other newsletter, but I also know that caring about the environment and about human lives makes it even more important to get your facts straight and look for the big picture. I have been wondering why we are constantly invited to take narrow positions on broad issues, to became one-issue activists on the environment. I have also wondered why so few observers seem to have noticed this and tried to promote a more balanced viewpoint.
On the dioxin issue, I have been wondering why I never saw any evidence, or any references to credible sources, in the literature of papermaking or environmentalism, about the toxicity of dioxin. Rhetoric, yes, and unsupported assertions, but nothing to build a dialog on.
I tried to extract some information from the Environmental Protection Agency (EPA), without success. Then, following up an a clue from an article in a paper industry journal, I called the Chlorine Institute for information. (The use of elemental chlorine in bleaching of kraft pulp has been identified as the cause of dioxin in pulp mill effluent, so chlorine manufacturers have an interest in the dioxin debate, but are not in the public eye like the pulp mills are.) They sent a packet of information, in which I found paydirt in the form of two items: a 35-page review of research and summary of the issues, and a scale of different "risk specific doses," from an EPA draft document. Briefly what they told me was that our national government has by far the strictest emission regulations in the world for 2,3,7,8-TCDD (the most toxic of the dioxin family), and that these regulations are very hard to justify on the basis of mounting evidence that dioxin is not very dangerous to people at all. As the literature review says, there is a wealth of science evaluating the toxicity of dioxins: over 17,000 reports have been published in the scientific literature. "In addition," it concludes, "more than a dozen extensive peer reviews of the weight of the scientific evidence have found little cause for concern about the human health effects of exposure to even the most potent form of dioxin, TCDD. Studies of groups most exposed to toxic levels through the workplace or through accidental release, as well as the studies evaluating herbicide exposure also are certainly reassuring." There is a 64-item bibliography.
The review was a presentation to a Chlorine Institute Plant Operations Seminar on March 7, 1990, in Houston, and is available as part of the proceedings of that seminar (not separately) from the Chlorine Institute (2001 L St., NW, Suite 506, Washington, DC 20036, 202/775-2790) for $15. The title page says: "Scientific Research on the Health Effects of Dioxins in the Environment: A Review and Summary of the Issues. George L. Carlo, Chairman, Health & Environmental Sciences Corporation.... prepared with the assistance of Health and Environment Sciences Group and Ketchum Public Relations personnel. "
Now that I have discovered a path to the professional literature on the topic, I find that there are still a few questions left. First, why is the EPA so strict an dioxin, causing the paper industry to spend billions of dollars to reduce streamflow levels to 10 parts per quintillion or lower, when so many other environmental outrages are known to be killing people every day? Is the EPA simply yielding to pressure from an uninformed public? And why are protests from individuals in the paper industry so uncoordinated and unconvincing
Why was Vernon N. Houck, director of the Center for Environmental Health and Injury Control at the Centers for Disease Control, told by the chair of a Congressional subcommittee that he should not have reviewed dioxin studies prepared by the paper industry for the state of Georgia? Has Congress started telling scientists which literature they may review and which they may not? The outcome of this case was that in March, the regional EPA administrator set a precedent by striking down the Georgia standard established an the basis of Dr. Houck's review, which had endorsed the 7.2 parts per quadrillion level suggested by the studies. (This information is from the September 1990 American Papermaker and the April 16, 1990 BNA's National Environment Watch, v.1 #1.)
Yet other questions remain. If most dioxins are generated naturally in forest fires and through other natural causes, as the paper industry literature has claimed, why does the EPA not appear to know about it? What is the evidence that dioxins really are formed this way? Who is now monitoring these emissions, if anybody, and where do the publish?
And what about the relative dangers of aflatoxins in peanut butter, pollutants in city air, UV in sunshine, and so on, compared to dioxin? Who can we trust to weigh all these things for us, so that we can direct our protests where they will do the most good? (An article by Bruce N. Ames, the man who invented the Ames test, appears to address this issue: "Ranking Possible Carcinogenic Hazards," by Bruce N. Ames, Renae Magaw, and Lois Swirsky Gold. Science 236, 17 April 1987, p. 271-280.)
Right now, I think the American public may be pressuring the government for action on dioxin partly out of well-justified resentment at the way it handled the Agent Orange and Love Canal scandals, partly out of displaced aggression toward the paper companies for unrelated environmental sins of the past and present, and partly as a consequence of the public mood that sanctions suing other people at the drop of a hat and asking for triple damages all out of proportion to the size and nature of the injury. The public may also be pressing for action simply because it has found it can get action on this issue--like the drunk who was seen walking round and round the lamppost looking for a quarter he had dropped; he knows he dropped it back down the road a ways, but he's looking for it under the lamppost because that's where the light is. But this is only my amateur opinion. Readers' opinions and facts are invited.