The Alliance For A Clean Environment
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Deceptive and Misleading Industry Allegations
Risking Our Health and Well Being

How do corporations deliver dangerous junk science?
They use their MONEY, POWER, and CONNECTIONS to Purchase Industry Friendly Science

Read Toxic Deception, particularly the chapter called
“Science for Sale”
Published by Center for Public Integrity

Examples of Dangerous Industry Deception about Dioxin and DEHP

Industry Allegation: Dioxin levels have been declining in industrialized nations for years, while vinyl production has increased. Therefore, PVC can’t be responsible.

Response: The decline in dioxin emissions appears to be associated with decreased emissions from large-scale combustion systems. Combustion of materials containing chlorinated organics (like PVC) is the primary source of dioxin to the environment. This indicates that reducing sources such as uncontrolled incinerators can result in a decrease in dioxin generation and release.
  • The decline does not suggest that burning PVC doesn’t produce DIOXIN.
  • The majority of PVC is used in construction. The useful life of construction materials is typically 20-30 years. Many of these materials have not yet entered the waste stream for the first time.

Industry Allegation: A landmark study by the American Society of Mechanical Engineers found no relationship between chlorine content and dioxin emissions (this is often call the Rigo Report).

Response: The study of chlorine’s relationship to dioxin output in waste incineration was conducted by Gregory Rigo, who was contracted to write the report by the Vinyl Institute.

  • A leaked internal Vinyl Institute memo shows that Rigo was chosen because, “He is also user friendly (i.e. willing to set his priorities to our needs) and appears to be sympathetic to Plastics, Vinyl, PVC, and Chlorine.”
  • The Vinyl Institute’s reported conclusions don’t agree with Rigo’s own statistical analyses and most technical literature that finds a positive correlation between chlorine input and dioxin output.
  • Greenpeace reviewed the Rigo Report and found evidence to support a conclusion OPPOSITE that of the Vinyl Institute.

Industry Allegation: PVC is the only material suited to medical uses.

Response: Many alternatives to PVC are superior in quality and performance. PVC may in fact be ill suited to medical uses because of the amount of additives necessary to give it desirable characteristics. Alternatives are widely used in the U.S. and Europe.
  • Manufacturers of products from IV bags to household items are announcing plans to phase out their use of PVC. These manufacturers include: Lego, Mattel, Ikea, Nike, Tenet, Universal Health Care, and Baxter Health Care.

Industry Allegation: Vinyl plants are insignificant sources of dioxin.

Response: Show us the studies to prove that statement. We want to know who paid for them and who did them. Where is the data from the lab to prove that statement about Occidental in Pottstown? Where is your peer-reviewed science? There is very little hard data because industry won’t test for dioxin, and EPA does not require it. We will not accept data based on calculations using self-reported industry data. According to other sources:
  • PVC manufacturing is a SIGNIFICANT SOURCE of DIOXIN. High levels of dioxin have been measured in the waste products of PVC manufacturing. There is a lot of data from Europe showing this to be true.
  • The Vinyl Institute acknowledges that dioxin formation is unavoidable during PVC manufacturing.
  • Dioxin does not break down easily in the environment, and builds up in the food chain.
  • Even tiny amounts of dioxin, if discharged over a period of time, can pose significant hazards.
  • Dioxin is a potent cancer-causing agent according to EPA, National Toxicology Program, and the International Agency for Research on Cancer.
  • Dioxin can have reproductive and developmental effects in animals at very low doses.
  • Dioxin exposure damages the immune system, leading to increased susceptibility to infectious diseases.
  • Dioxin can disrupt the proper function of hormones.
  • EPA’s draft reassessment of dioxin found that the adverse effects of dioxin may occur at levels close to the amounts currently found in the general population.

To establish exact or true levels of dioxin released from any Vinyl or PVC plant, like Occidental, SITE-SPECIFIC DIOXIN TESTING would have to be done TO MEASURE ALL DIOXIN WASTE STREAMS from each facility. This must include: Air Emissions, Waste Water, Sludge Residue, and Residuals from Processing Batch.

Industry Allegation: The Chlorine Chemistry Council funded a report, which says that chlorine levels in feed are not the dominant controlling factor for rates of dioxin stack emissions for commercial scale incinerators.

Response: EPA has completely changed its position on the relationship between chlorine input and dioxin output based on this report by the Chlorine Chemistry Council, while ignoring the papers cited in their own 1994 report that did show a positive relationship between chlorine input and dioxin emissions. EPA ignored work by Pat Costner of Greenpeace that clearly showed that the data in both reports that EPA cites did not support the authors’ conclusions. All of the data needs to be used and all of the data does not support the agency’s conclusions. This suggests undue influence on EPA’s decisions by the Chlorine Chemistry Council.

Industry Allegation: A U.S. Food and Drug Administration (FDA) official is quoted saying that PVC products are safe.

Response: The FDA requires labeling of some products, which leach DEHP, although that labeling is not consistent.
  • The FDA is currently reviewing a petition to label devices containing PVC or DEHP. Devices registered prior to 1976 have been grandfathered, which means they have not been subject to the same extensive testing regimen required of new products.
  • The FDA is currently conducting a risk assessment of DEHP in medical devices.

Industry Allegation: A blue-ribbon scientific panel chaired by C. Everett Koop found that “DEHP, as used in medical devices, is not harmful to humans even under chronic or higher-than-average conditions of exposure.”

Response: This report was prepared under the auspices of the American Council on Science and Health. The ACSH is an industry-funded organization, which has a long history of taking industry-slanted positions on issues related to public health.
[ For instance, ACSH has defended the toxic pesticide DDT, which has been banned in the U.S. for many years.]
  • A review of Koop’s report found serious omissions and errors of fact.
  • Authors selectively reported the literature on DEHP toxicity.
  • Koop’s analysis omits studies from readily available, peer-reviewed literature that describe toxic effects of DEHP at exposure levels relevant to humans.
  • Authors misrepresent general conclusions, which follow from a review of published studies in at least two instances.

Industry Allegation: The International Agency for Research on Cancer (IARC) found that DEHP was “not classified as a carcinogen.”
[Background: DEHP is the plasticizer added to PVC medical products to make them flexible. Large quantities of DEHP are used in medical products, which can leach into patients during treatment.]

Response: DEHP has not been given a clean bill of health. The re-designation only suggests there is not adequate evidence to conclude that there is a cancer risk from exposure to DEHP. IARC has not looked at other harmful human health effects from DEHP.
  • EPA still lists DEHP as a probable human carcinogen.
  • Reproductive and developmental toxicity of DEHP are of great concern based on animal studies. [Peer-reviewed animal studies of DEHP exposure have shown toxic effects on the developing fetus, reproductive system, liver, kidneys, heart and lungs.]

Industry Allegation: There is simply no evidence that DEHP causes reproductive effects in humans.

Response: The Vinyl Institute is very deceptive in this allegation. The standard to access hazards to humans from exposure to toxic compounds is carefully controlled animal laboratory studies. There is ample evidence in animals that DEHP poses a risk to humans, particularly to developing fetuses and children. Since it is unethical to experiment on humans, controlled studies, which provide definitive results are not possible. That is the only reason there is no evidence about reproductive effects of DEHP. Research has not been done on humans, but this does not mean DEHP does not cause these harmful health effects in humans. DEHP produces a spectrum of toxic effects in laboratory animals, including rodents and primates, in multiple organ systems including the liver, reproductive tract, kidneys, lungs and heart.
  • DEHP is also toxic to the developing fetus of rodents and primates. In addition, for some adverse effects, such as testicular toxicity, the developing organism appears to be much more sensitive than the adult.
  • It is unclear if there is any safe level of DEHP.
  • Anecdotal reports exist of deteriorating respiratory status of several premature infants being artificially ventilated with DEHP-containing PVC tubing. DEHP was measured in the inspired air, and exposures were estimated as high as 2,300 micrograms DEHP/hour.
    These infants improved when PVC tubing was replaced.
  • The only published study of liver biopsy results in dialysis patients, exposed to DEHP from the dialysis equipment, shows liver abnormalities.
  • Autopsy studies of patients who have received therapy from DEHP-containing medical devices show widespread deposition of DEHP in many different organs, including the liver and lungs.

Industry Allegation: A 1996 study, the most comprehensive to date, found no increased risk of cancer.

Response: Cancer is not the endpoint of greatest concern with DEHP. See response above.

Industry Allegation: The material has been used safely, with no evidence of harm to any patient, for more than 40 years.

Response: Lack of evidence of health damage in humans does not mean that there is evidence that DEHP is safe.
  • According to published data, some patients, including newborns and infants, are exposed to the phthalete DEHP at levels known to have adverse effects in laboratory animals, including primates.
  • Animal studies, including primates, show that testicular toxicity in the developing organism is a critical health effect and occurs at levels of exposure which are similar to those experienced by newborns or infants receiving certain kinds of infusions or other therapies from DEHP-containing PVC devices.
  • Thalidomide and DES were both used by millions of pregnant women before researchers made the link between birth defects, cervical cancer and the effects of these two drugs in utero.
  • The health effects of DEHP will not be apparent immediately after exposure. Long periods between exposure to this chemical and the appearance of toxic effects on organs or systems make it difficult to trace the effect back to EDHP exposure. Based on animal experiments, DEHP exposure is not evident until many years after exposure, making it very difficult to link an early life exposure to a later health effect.
  • Several PVC products contain solutions which can accelerate the leaching of DEHP and actually contain warnings about DEHP, clearly indicating some concern on the part of the manufacturers.

Industry Allegation: Moving away from DEHP could actually pose hazards to people.

Response: The Vinyl Institute letter is not explicit about the hazards posed to people by moving away from PVC medical devices. Where is the peer-reviewed science to back up their statement? There is evidence to the contrary.
  • Non-PVC IV bags, which contain no phthalate plasticizers, have been on the market for twelve years, providing quality care to patients without exposing them to DEHP.
  • Numerous types of non-PVC and Non-DEHP tubing and other products are available for many uses.
  • PVC is a relatively unstable and rigid plastic. It requires lots of additives to give it flexibility required.
  • Polymers used to make alternatives can actually have superior qualities and performance. Several other polymers are inherently flexible. They do not require plasticizers at all.

    Most information gathered by the Center For Health, Environment, and Justice

    Questions? Contact:

    P.O. Box 3063
    Stowe, PA 19464

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