By Peter von Stackelberg | Return to Main Page
Published March/April 1989 in Greenpeace volume 14 – number 2

IN THE DYING days of the summer of 1987, a ramshackle house in an isolated valley in Oregon's Coastal Range became the focus of international media attention. It was long in coming. Since the mid-1970's, Carol Van Strum had almost single-handedly conducted a vigorous campaign to end the use of dioxin-contaminated herbicides in her home state. The decade of struggle, chronicled in A Bitter Fog, might well have ended with the conclusion of the book. Except that Van Strum and her husband of eight years, attorney Paul Merrell, soon realized that the herbicide story was just part of something bigger. Information on dioxin, a chemical that can be as dangerous as plutonium, was scattered and incomplete, they discovered. Even worse, EPA officials were reluctant to release publicly their own studies, some of which showed a connection between dioxin and paper mills. Using freedom of information laws, Van Strum and Merrell obtained EPA's dioxin studies in 1986 and set to work piecing together a report that pulled the dioxin/paper mill connection from behind, in the author's words, "a smokescreen of government secrecy." In August 1987, the report, entitled No Margin of Safety and published by Greenpeace, burst like a bomb on the pulp and paper industry and its regulators within the Environmental Protection Agency (EPA). Evidence gleamed from thousands of pages of the EPA's own documents demonstrated that pulp mills were spewing dioxins into the air and water, creating what Van Strum and Merrell call a public health emergency. But that was only the beginning. Someone inside the American Paper Institute (API), the paper manufacturer's trade organization, saw the report and sent a collection of documents to Greenpeace. These documents substantiated Merrell and Van Strum's charges that senior EPA officials and the industries the agency was supposed to regulate were working together to limit public knowledge about the hazards of dioxin and a host of other dangerous chemicals. According to US District Judge Owen M. Panner, the documents revealed an agreement "between the EPA and the industry to suppress, modify or delay the results of the joint EPA/industry [dioxin] study or the manner in which they are publicly presented."

Since at least 1980, EPA scientists and researchers with Canada's environment and health departments have been expressing their concern about the growing dioxin contamination of the environment. They are concerned about the high toxicity of dioxin and its extreme ability to bioaccumulate. Dioxin is the term commonly used to describe a group of about 75 compounds with the same basic chemical structure. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) is the most studied member of the dioxin family. TCDD is also the deadliest substance ever produced. Its toxicity has been compared to plutonium – the EPA's procedures for handling these materials are the same. Industry representatives have argued that low levels of dioxin do no harm, but this contention has never been supported by scientific research. During congressional hearings in 1980, EPA scientists testified that TCDD was so powerful a carcinogen and tertogen that even the lowest measurable doses caused cancer and birth defects during laboratory tests. "EPA considers dioxin a carcinogen and, as all carcinogens, considers there to be a finite risk at any level," said the EPA's Alec McBride. "EPA considers any level as posing a degree of risk."

Cancer is not the only danger that dioxin poses. The effects of TCDD in all species of animals tested under laboratory conditions included weight loss, liver damage, hair loss, abnormal retention of body fluids and suppression of the immune system. Other effects of exposure to TCDD include birth defects and infertility. The dangers to the unborn in particular were emphasized by the EPA's Don Barnes. In a memo written on March 16, 1987, he said: "Pregnant women, lactating mothers, developing fetuses and nursing infants constitute a subpopulation of special concern. Human body burdens [of dioxins and furans, a closely related group of highly toxic chemicals that are often found in dioxins] are likely to lead to additional burdens to the fetus and the unborn infant, which are not mimicked in the laboratory tests. Increases in the mother's body burden as the result of [dioxin/furan] contaminated food would likely lead to additional exposure." In the late 1970's and early 1980's, public concern over dioxin contamination, centered on sites like Love Canal and Times Beach. But it soon became evident that dioxins are far more widespread in the environment than two places in New York and Missouri.

In the forests of Van Strum and Merrell's valley, and in many others up and down the coastal range, the spraying of defoliants similar to Agent Orange was commonplace during the 1970's and into the early 1980's. So were health problems that many people complained were the result of that spraying. "One woman had had fourteen miscarriages in the years she had lived in the valley. Another told of her two miscarriages and of her son born with defective lungs and liver. The young wife of a logger had been unable to complete a pregnancy in the five years they had been married," wrote Van Strum in her book.

In Oregon, Larry Archer and his wife Laura lived near a reservoir that was sprayed with herbicides while she was pregnant with her second child. He was present when the baby was born. Van Strum wrote, "'The baby – it was a girl,' Archer said. ‘She was perfect, from her toes to her eyebrows. I mean, her face was perfect too… But that's all there was – just this kind of bowl, with a kind of tissue over it. There wasn't any brain to tell her to breathe.'" Van Strum, Merrell and others say the evidence clearly shows a link between herbicide spraying programs, dioxins and birth defects. What concerns them is that dioxins have been detected in places where little or no spraying of herbicides has been done and from a variety of sources. Dioxins are showing up everywhere in the environment – and in the food chain.

Dioxins are always produced when chlorinated compounds are burnt. Municipal incinerators, for example, produce dioxins when they burn garbage containing chlorinated plastics like polyvinyl chloride (PVC). Dioxins are also unwanted by-products in the manufacture of chlorinated chemicals, such as Agent Orange and the wood preservative pentachlorophenol (PCP). EPA scientists suspected some sort of link between pulp mills and dioxin in 1980. Their suspicion was substantiated in 1983, when fish caught downstream from several Wisconsin River pulp mills were found to contain high (50 parts per trillion) levels of dioxin. The dioxin studies secured by Van Strum and Merrell in 1986 confirmed the cause-and-effect relationship. Samples from sites slated for "control" sampling and predicted to have only "background" dioxin levels consistently revealed high levels of dioxin contamination when downstream from or near pulp mills.

Chlorine in the pulp bleaching process acts to form toxic chlorine-based compounds, including dioxin. Kraft-type pulp mills, where chlorine gas is used in the first stage of the bleaching process, are the biggest culprits. Chlorine gas reacts with compounds in wood lignin to create dioxin precursors and many other chlorinated compounds. These toxic compounds, called organochlorines, are released into the air and water when wastes are dumped. In North America, more than 150 pulp mills are dumping organochlorines, and most likely dioxins, into nearby rivers and lakes. An average-size pulp mill discharges between 35 and 50 tons of chlorinated compounds every day.  "Dioxin, really, is only the tip of the iceberg when it comes to pulp mill effluents," says Renate Kroesa, Greenpeace's international pulp and paper campaign director. "Up to 1,000 different chlorinated compounds, only 300 of which have been identified, are formed during bleaching and discharged with the effluent. Among the compounds identified, we find many well-known carcinogens that are regulated when they come from chemical industries. But, when they are discharged by the pulp and paper industry, there are no limits."

The islands scattered in the Georgia Strait between the British Columbian mainland and Vancouver Island are close to heaven. Sparkling blue water, the deep green of fir, spruce and hemlock and rocky shores make it a beautiful area. The waters around the islands teem with life. Pods of orcas are not an uncommon sight. Crabs, oysters and shellfish abound. But the beautiful scenery is marred by foul air at Crofton, Vancouver Island, where a pulp mill vents its wastes into the air and water.

Like the canaries that once warned coal miners of deadly gases in their pits, the Crofton blue heron colony serves as a warning of new dangers. For the last few years, the eggs from the blue heron colony near Crofton have failed to hatch. Dioxins were detected in the herons' eggs during studies conducted in 1983 and 1986. The dioxins came from two sources: hexa-, hepta-, and octa-dibenzo-p-dioxins were coming from lumber industries in British Columbia that use dioxin-laden pentachlorophenol wood preservatives; TCDD was coming from the pulp mill. Since PCP use has decreased since 1987, levels of dioxins associated with it have dropped. But the pulp mill operates beyond capacity, so levels of TCDD dioxin have tripled over the last two years.

Crofton's paper mill is an example of an industry-wide problem. Dioxins not only find their way into the water. They also contaminate the bleached pulp produced by these mills. What this means is that all bleached paper products – coffee filters, disposable diapers, toilet paper, everything – are potentially contaminated by dioxins. Paper industry executives would prefer to keep this quiet. And they almost did, were it not for the ally who sent the American Paper Institute's internal papers to Greenpeace.

The API papers show a concerted effort on the part of the EPA and industry to hide the problem. The strategy began with an effort to slow the introduction of regulations aimed at eliminating dioxin contamination. In an internal memorandum to the American Paper Institute's executive on December 30, 1986, one staff member claimed that "the industry has been able to forestall major regulatory and public relations difficulties by, among other things, agreeing to cooperate in a joint study with EPA."

In addition to forestalling regulatory action, the paper industry put together a "dioxin response team", which recommended "a public affairs strategy calling for activities keyed to, and in advance of, the release of the joint EPA/industry dioxin study."

A comprehensive API plan dated March 2, 1987, treated the public health threat posed by dioxin as a public relations problem. The industry's strategy was to: 1) keep all allegations of health risks out of the public arena – or minimize them; 2) avoid confrontations with government agencies, which might trigger concerns about health risks or raise visibility of issue generally; 3) maintain customer confidence in integrity of product; and 4) achieve an appropriate regulatory climate."

In the same document the industry said it would meet with EPA administrator Lee Thomas to tell him that dioxins pose no real health hazard and that the problem is one of "public perception." One of the industry's objectives was to have the EPA "rethink" its dioxin risk assessment and issue a statement saying dioxin causes "no harm to environment or public health."

In its efforts to sway the EPA, the American Paper Institute planned to turn EPA attention away from dioxin contamination of paper products. At the same time, it was working to "improve intelligence gathering within EPA," including identification of "allies" and "adversaries" within the agency.

According to an API report distributed to its members on August 10, 1987, the industry achieved at least some of its public relations goals: "[EPA] Administrator [Lee] Thomas indicated a willingness to cooperate with the industry to ensure that the public would not be unduly alarmed about this [dioxin] issue." In its efforts to stifle public discussion of the dioxin hazards posed by its plants, the pulp and paper industry even attempted to get the EPA to violate the freedom of information laws. In a sworn statement given May 2, 1988, the EPA's McBride said the paper industry had specifically asked that the agency not release information to Van Strum, as it was required to do by law.

A letter written on March 18, 1987, by Carol Raulston, the API's vice president for government affairs, to a public relations firm employed by API, indicates that these efforts to interfere with freedom of information laws were successful. She wrote: "EPA has agreed to the following: to characterize the information (about dioxin contamination) as meaningless, used only to establish testing procedures; to respond with a letter to Ms. Van Strum today, but to ship the material on April 1; to meet with us to discuss the public affairs strategy on this and how subsequent requests for information will be handled."

When questioned about this, EPA's McBride jumped to the defense of his agency and said, "These were not agreements. When they say EPA has agreed to the following, these are EPA's decisions independent of anything we heard from the paper industry. Clearly what you have is a lobbying firm that has failed in its primary objective, which was to have us not release the data. They are trying to make it look as if they have accomplished something."

Although the pulp and paper industry was trying to stifle the release of government information, it discovered some disturbing new revelations about the dangers that dioxin contamination of paper products presented. TCDD, the most deadly of the dioxins, was found in bleached pulp at levels ranging from one part per trillion to 51 parts per trillion (ppt) in the vast majority of the samples taken. Levels of related chemicals were found to range from 1.2 ppt to 330 ppt.

Part of the industry's public relations strategy was to dismiss these levels – "trace amounts" as they have often been called – as being far below any level that presented danger to the public. In a speech to an API industry forum on March 8, 1988, Thomas C. Norris of P.H. Glatfelter Company, an API member, told his colleagues that the results of the industry's testing work into the dioxin problem had been "extremely encouraging."

"First, the dioxin detection levels are quite low," Mr. Norris said; "They range from no detection in the disposable diaper sample to 3,8 parts per trillion in paper towels to 14 parts per trillion in non-barrier food packaging." He went on to say that tests done for the industry had demonstrated only minimal movement of dioxins and related chemicals from paper products to the human body. "We are very encouraged by these results, and the bottom line is that all the testing work done to date confirms that our paper products are safe," Norris said.

Yet other tests sponsored by the API itself showed that super absorbent disposable diapers had up to 11 parts per trillion of dioxin in them, paper towels up to 7 parts per trillion, and various types of paper plates up to 10 parts per trillion.  A draft report prepared for the industry in June 1987 by the research firm of A.D. Little found that between 50 and 90 percent of the dioxins in paper products "in contact with food oils or water is available for consumption."

Even more damning words about the hazards of dioxin in paper products were then being written by EPA officials. "If the exposure estimates utilized in the risk assessment are reasonably accurate -- and I have no reason to believe they are not," wrote EPA scientist Dr. Fran Gostomski on July 10, 1987, "we are presented with a risk estimate for at least one exposure scenario -- ingestion of dioxin from coffee filters – that exceeds the lifetime risk level at which the EPA would generally be expected to take regulatory action. In addition, this risk estimate does not take into account the very probable occurrence of simultaneous exposure to multiple sources of dioxin from bleached craft paper products."

If one were to take milk or cream with that coffee, it would add even more dioxin to the diet. In the summer of 1988, at the International Dioxin Symposium, the Canadian Health Protection Branch of the federal health department presented evidence showing that dioxin in paper milk cartons had migrated into the milk. This, despite paper industry assurances, that it was impossible dioxins to migrate from cartons.

Although EPA is aware of the connection between pulp mills and dioxins, the agency has failed to produce regulations that would eliminate dioxin contamination of air, water and paper products. Instead, in April 1988, the EPA decided to do another, bigger study of all 104 pulp and paper mills that use chlorine.

"It's totally unnecessary," says Van Strum. "It's the classic ‘further study' in place of taking any regulatory action. They know there are hazardous levels of dioxins and furans in pulp and paper products. There's simply no need for further study."

She said that after the initial study of five mills revealed dioxin contamination, the EPA drafted a number of regulatory actions. These drafts have never been translated into effective measures. "The industry flacks within EPA prevailed and put off action until further studies were done," Van Strum said.

The Environmental Defense Fund and National Wildlife Federation sued EPA for its complacency. Settling out of court, EPA agreed to complete a risk assessment of the 104 mills by April 30, 1990. But even after that is done, EPA can: 1) refer the problem to another federal agency; 2) decide that dioxin from bleached wood pulp doesn't produce an unacceptable risk; or 3) take another year (until April 30, 1991) to propose regulations.
 

While North America studies dioxin, several European governments have decided to deal with the problem head on. Throughout Europe, the need for highly bleached paper products is being re-evaluated. Sweden, for example, has stopped the sale of chlorine-bleached disposable diapers. In Austria, consumers are using unbleached brown coffee filters and milk cartons.

"Household products are one of the most important keys in the struggle against environmentally unsound consumer goods," said Brigitta Dahl, Swedish minister of the environment. "Therefore we are now concentrating our efforts against chlorine and dioxins in the most common household products. This will be a strategically important contribution. If one gets paper bleached with chlorine out of consumer products, one also gets large amounts of chlorine out of the industrial stage, and the consumers don't have to live with an environmental threat on their breakfast tables, in their bathrooms and in large parts of their lives."

Sweden is making great strides in getting dioxins and all other toxic organochlorines out of its pulp and paper mills. Today the Swedish pulp industry discharges about 3,5 kilograms of organically bound  1,5 kgs/ton by 1992 and completely stop it by the year 2000.  Swedish mills are using oxygen bleaching, among other things, to meet this goal.

The North American pulp and paper industry has used delaying tactics to avoid legal liability for medical problems that people may have suffered as a result of exposure to dioxin, Van Strum said. She says the EPA is hesitant to regulate dioxins for the same reason.

"There is no question they are trying to avoid regulating the most toxic known substance. There are two reasons for this," she said. "First, if the EPA were to say dioxins were hazardous, they [would] create a liability in cases like the Agent Orange litigation. Second, several laws the EPA administers specifically state only safe doses of pollutants can be released into the environment. Saying dioxins are hazardous at any level would seriously affect many industries and activities."

Industry recognizes dioxin-contaminated paper as a problem. Unfortunately, some solutions being offered are inadequate, because they eliminate or reduce dioxins in the final product, but continue releasing them into the environment. For example, Dow Chemical Corporation is developing ion-exchange resins that would remove organochlorines from pulp. But if this method were implemented, the dioxin-saturated resins would still have to be disposed of somewhere.

A major political fight may be required to stop the spread of deadly dioxins and other organochlorines. Regulations that include a time table for zero discharge of these toxics seem far away. EPA policy makers continue to stall; they attempted to reduce their obligation to clean up dioxin-contaminated sites by announcing last year their intent to increase -- by 16 times – the levels of exposure that will be deemed acceptable. Fortunately, EPA's Science Advisory Board agreed at their December 1988 meeting that "there is no firm scientific evidence" for the proposal.

Greenpeace is pushing for standards that will completely eliminate organochlorine discharges by 1993. This can be achieved by abandoning the use of chlorine in the bleaching process. "What is needed is a lot of local participation of people," Paul Merrell says. "That is the only way that the spread of dioxins into the environment from pulp mills will be halted quickly," he adds.

In addition to political pressure, the economic weight brought by changing consumer demand for bleached paper products may be needed to force government and industry in North America to deal with the problem. Greenpeace has asked for the immediate introduction of chlorine-free and/or unbleached paper products, as well as a higher recycling rate of paper products. The North American industry has resisted these demands. Coffee filter producers, for example, claim that they do not have enough unbleached pulp to produce unbleached filters. Yet at the same time the pulp industry is undergoing an enormous expansion program, all geared to producing more chlorine-bleached pulp. Unbleached pulp is cheaper and easier to manufacture.

For years, whiter-than-white paper products have been associated with hygiene by consumers. Now they should be seen as a threat to health and the environment. "Paper is a natural product, made of a potentially renewable resource," says Renate Kroesa. "How can we ever come to terms with living on this planet if we don't even produce paper in an environmentally sound way?"