TL: ALTERNATIVES TO DIOXIN SOURCES IN THE MEDITERRANEAN SO: GREENPEACE MEDITERRANEAN, (GP) DT: SEPTEMBER, 1996 Written by Beverley Thorpe, Clean Production Action for Greenpeace Mediterranean Project September 1996 _________________________________________________________ TABLE OF CONTENTS: 1. INTRODUCTION 1.1 INADEQUACIES OF END OF PIPE CONTROLS AND BENEFITS OF A CLEAN PRODUCTION MATERIALS POLICY 1.2 UNEP CLEANER PRODUCTION DEFINITION 2. ALTERNATIVES TO MAIN DIOXIN SOURCES 2.1 POLYVINYL CHLORIDE (PVC) PHASE-OUTS AND RESTRCTIONS IN OTHER REGIONS 2.1.1 DIOXIN GENERATION FROM PVCIN FIRES 2.1.2 SOME SUBSTITTION DESCRIPTIONS 2.1.3 NATURAL MATERIALS 2.1.4 SYNTHETIC MATERIALS FOR SPECIAL CASES 3. COMBUSTION SOURCES 3.1 MUNICIPAL WASTE INCINERATION 3.1.1 3. ALTERNATIVES TO MAIN DIOXIN SOURCES 3.1 PVC 3.2 COMBUSTION SOURCES 3.2.1 Municipal waste incineration 3.2.2 Hospital waste incineration 3.2.3 Hazardous waste incineration 3.2.4 Cement kilns 3.2.5 Smelters 3.2.6 Other combustion sources 3.3 PULP AND PAPER 3.4 SOLVENTS 3.5 PESTICIDES 4. COSTS 5. TRANSITION PLANNING 6. REFERENCES 1. INTRODUCTION INADEQUACIES OF END OF PIPE CONTROLS AND THE BENEFITS OF A CLEAN PRODUCTION MATERIALS POLICY "Perfection of means and confusion of ends seems to characterize our age" - Albert Einstein An effective international dioxin/furan elimination programme will only be successful via a materials policy based on clean production. Incineration is currently recognized as the major source of dioxin emissions in the industrialized world (USEPA, 1994) Best Available Techniques to reduce these emissions is usually described as better pollution control (POPs, etc). However end of pipe pollution control equipment can never eliminate dioxin emissions to the Mediterranean region as long as dioxin point sources continue to exist. This is because end of pipe controls such as incinerators, simply catch some of the dioxin emissions from one environmental media (air emissions) and transfer them to another (incineration ash, aqueous discharge). Currently defined best available techniques such as modern carbon injection systems do not prevent the formation of dioxins (Huang et al, 1995) In effect, the total quantity of dioxins and furans generated by these incinerators is more than six times greater than the amount they release into the air. Eventually these filters and ash residues are reintroduced back into the environment (Acharya et al. 1991) The question to focus on is why are incinerable wastes being created in the first place? By focussing on front-end solutions, these back-end problems can be eliminated. A recent overview of cleaner production in the mediterranean region by ECOMED, the City of Rome and UNEP (ECOMED, 1995) emphasises that "the key difference between pollution control and cleaner production is one of timing. Pollution control was an after-the- event, 'react and treat' approach: cleaner production is a forward-looking, 'anticipate and prevent' philosophy. Prevention, as is well known, is always better than cure." Dioxin synthesis requires three things: 1. A source of chlorine (or bromine); 2. Organic matter; 3. A thermally or chemically reactive environment in which these materials can combine. The production of dioxin is inherently linked to chlorine chemistry. Studies of atmospheric emission from coal-burning power plants did not detect any PCDD/Fs (US EPA 1987, Fiedler et al. 1990). Evidence from sediment cores from the Great Lakes in Canada and the United States (Czuczwa & Hites, 1985) indicates that the increase in dioxin concentrations in the environment correlate not with coal consumption but with production of chlorinated aromatic compounds. Similarly, dioxin released from forest fires and wood burning are probably due to contamination of the wood by phenoxyherbicides (Fiedler et al, 1990) or from resuspended material from aerial deposits (Schaum, 1993) Combustion point sources of dioxin other than incinerators are commonly found in the Mediterranean region. These include smoldering landfills and house fires -- both involving the burning of polyvinyl chloride (PVC) plastics (BLAU, 1992) and car exhausts -- due to dichloroethane use as a gasoline additive. (Marklund et al. 1990) This makes containment from the ecosystem impossible. The only real solution is to avoid the use of such chlorinated precursors in household products and transport fuels -- both of which are feasible. Furthermore, organochlorine contamination is no longer a regional problem. Dioxin generation is globally carried via air currents and is now causing severe problems in the Arctic (POPS, 1995). The Barcelona Convention Parties resolution to eliminate by the year 2005 emissions of organohalogens to levels that are not harmful to man or nature (UNEP, 1995) can only be achieved with a sustainable materials policy. This would not only eliminate dioxin emissions but would conserve resources and would prove highly beneficial to the communities and economy of the Mediterranean region. UNEP CLEANER PRODUCTION DEFINITION A sustainable materials policy incorporates clean production and the UNEP definition of Cleaner Production (UNEP, 1992) is useful in emphasizing the need for non toxic raw materials: o FOR PRODUCTION PROCESSES: cleaner production includes conserving raw materials and energy, eliminating toxic raw materials, and reducing the quantity and toxicity of all emissions and wastes before they leave a process. o FOR PRODUCTS: the strategy focuses on reducing impacts along the entire life cycle of the product, from raw materials extraction to the ultimate disposal of the products. o FOR SERVICES: Cleaner Production reduces the environmental impact of the service provided over the entire life cycle, from system design and use to the entire consumption of resources required to provide the services. o Cleaner production requires applying know-how, improving technology, and changing attitudes. "Using renewable materials in products means that we could live, produce and develop in harmony with the ecosystem of which we are part, without causing erosion to that system. Additionally, using these materials in products will not violate the right of future generations to live, produce and develop." - Professor El-Mously, Director of the Centre for the Development of Small-Scale Industries and Local Technologies at Ain-Shams University, Cairo, Egypt. (UNEP SPD, 1996) With the awareness of global contamination by dioxins and other persistent compounds and the desire for clean sustainable employment [PHI, 1993] there is renewed research and implementation of biologically based materials as non-toxic solutions. The return to renewable materials and indigenous natural materials not only benefits the environment and local employment but is also supported by many architects, designers and health professionals based on aesthetic appeal and indoor air quality. [SNTRI, 1990). For instance, the American Institute of Architects (Demkin, 1995) advocates the benefits of natural materials over the use of PVC plastics in buildings. Investment in renewable materials as alternatives to petrochemical based plastics in other industrial sectors also continues to grow. For example: Some car manufacturers are designing for increased lightness and recyclability - spurred in some part by product take back legislation in Germany, the Netherlands and Sweden (Thorpe, 1996). Mercedes has prototyped automobile body parts made from agro-based materials such as flax. They found that utilising renewable materials would 1) make significant weight savings due to the low density of these materials 2) improve safety as these materials will not shatter 3) reduce manufacturing costs 4) insulate better against sound 5) improve moulding specifications. (UNEP WG SPD. 1996) Local solutions based within local bioregions ensures not only sustenance but social diversity (Shiva, 1989). Traditional building materials and design that optimise solar heating and cooling are resource efficient. New technologies that enhance the preservation of wood in a chemical free-process now prolong the use and repairability of this natural material. (TME, 1995). Other technologies that hydraulically compress natural plant fibres with no synthetic resin mixes, are now being used for building and construction. This process is particularly supported by international funders who recognize its importance as an alternative to wood use (DeSantis, 1996) Carbohydrates, or bio-materials, can also be used as feedstocks for chemical and fuel production. Biochemical substitution exists for direct, indirect and end product substitution of petrochemicals. Bio-based products have successfully replaced petrochemically-derived end products in plastics, paints, inks, polymeric resins, polymeric plasticizers, and detergents. (Ahmed, E et al, 1994) Plastics, resins and related chemicals are the largest consumer of chemicals in the processing industry and used significantly in the Mediterranean. Bio-based alternatives to thermoplastics exist by polymerizing lactic acid. This acid is produced by bacteria from sugars derived from corn, potatoes, grains and milk. Cargill Inc., the largest grain trader in the world, has built a 4.5 million kilogram plant to produce lactic acid biopolymers and by the end of 1996 they will be cost-competitive to synthetic lactic acid (Ahmed, E. 1994) Terpenes, made from citrus rinds, are a popular alternative to chlorinated solvent use. (Ahmed, E, 1994) Plant based surfactants can now successfully replace the use of perchloroethylene in drycleaning. All these raw materials can be sourced and produced within the Mediterranean region. Because sustainability encompasses a system view of production it is inherent that farming methods and pest control work within natural ecosystem dynamics. This necessarily avoids monocultures, synthetic inputs, genetically engineered organisms, and unsustainable water use. It also mandates a holistic approach to product use and reduction of resource intensity even for renewable materials.(UNEP WG-SPD, 1996) Other alternatives to organochlorine based materials are substitutes made of inorganic or mineral sources. Here the primary focus is one of conserving those metals currently in circulation as part of the need to reduce resource use for eco- efficiency. (Schmidt-Bleek, 1995) To this end the reclamation and reuse of materials from demolished buildings must be a priority rather than the quarrying and mining of new materials. A major point source of dioxin is the production and use of polyvinyl chloride (PVC) plastic. For some uses natural materials and system redesign can serve as substitutes; for other uses simpler polymer plastics are proposed as other current alternatives. Those polymers - such as polypropylene (PP) and polyethylene (PE) - are useful as transition materials in some cases where the properties of plastic are preferred and where bio-plastics are not yet cost competitive. They do not generate dioxin in their life cycle - if PP uses the non- chlorine route --they do not rely on harmful additives and they can be easily recycled. However they still pose occupational health risks and ultimately rely on a non renewable resource (Ward-Harvey. 1984) Ultimately the life cycle of products must be considered. Clean production is inherently dynamic and just as pollution prevention opportunities must be continuously reviewed within a factory (Prisma, 1992] so must the environmental and social benefits of products be continuously assessed. For instance, does the life cycle of these products fit the clean production definition? Do they contribute to local economies? Is worker health protected? Are the final products durable and repairable and is the material energy efficient and able to be recirculated? Because the time factor is less than ten years to achieve significant dioxin reductions, Greenpeace recommends that the Parties to the Barcelona Convention immediately implement a plan of action based on a clean production and clean materials use policy. To this end the following report is an overview of the feasibility and success of current dioxin point source elimination activities that can be implemented at both municipal and regional level. The adoption of such alternatives will ensure both the long term sustainability of industrial investment in the Mediterranean region as well as the health of its environment and people. 2. PRODUCTS AND PROCESSES IDENTIFIED AS DIOXIN POINT SOURCES * Production of chlorine gas - Chlorine electrolysis with graphite electrodes - Chlorine electrolysis with titanium electrodes * Chemical industry use of chlorine gas * Chlorinated aromatic chemicals manufacture (chlorobenzenes, chlorophenols, PCBs others) Pesticides Dyes Speciality chemicals * Chlorinated solvents manufacture (trichloroethylene, tetrachloroethylene, carbon tetrachloride) * PVC plastic manufacture of feedstocks (ethylene dichloride, vinyl chloride Production wastes Effluent Sludge from effluent treatment Air emissions PVC plastic products * Other aliphatic organochlorines manufacture (epichlorohydrin, hexachlorobutadiene) * Some inorganic chlorides manufacture (ferric and copper chlorides, sodium hypochlorite) Uses of chlorine gas in other industries * Pulp and paper chlorine bleaching Mill effluent Mill sludge Pulp and paper products Emissions from sludge incinerators * Water and Esbjerg. 1995. Esbjerg Declaration, Para 17, June 1995. disinfection * Refined metals manufacture with chlorine (Ni, Mg) * Use of organochlorines Manufacture of chlorine-free chemicals with chlorinated intermediates (nitrophenols, parathion, others) Degreasing/extraction with organochlorine solvents in alkaline or reactive environments Oil refining with organochlorine catalysts Use of pesticides with heat (wood treatment, etc) Iron/steel sintering with organochlorine cutting oils, solvents or plastics * Burning gasoline or diesel fuel with organochlorine additives Use of chlorine-based bleaches and detergents in washing machines and dishwashers Incineration, Recycling and Fires (primary dioxin precursor in parentheses) Accidental fires in homes and offices (PVC) Fires at industrial facilities (PVC, PCBs, other chlorinated chemicals) Aluminium recycling/smelting (PVC) Steel and automobile recycling smelting (PVC) * Copper cable recycling/smelting (PVC) * Wood burning (pentachlorophenol wood preservatives, PVC) Environmental transformation Transformation of chlorophenols to dioxins in the environment Addressed by the EPA in documents related to its dioxin reassessment. (Cleverly 1993, Schaum 1993). List includes sectors in which formation of dioxin or related compounds (PCBs, chlorinated dibenzofurans, and/or hexachlorobenzene) has been confirmed in chemical analyses, as well as sectors in which dioxin formation is ~known or suspected~ according to EPA (EPA 1985, PCTN 1985) or NATO (Hutzinger 1988). _________________________________________________________ 3. ALTERNATIVES TO MAIN DIOXIN SOURCES 3.1 POLYVINYL CHLORIDE (PVC) PHASE-OUTS AND RESTRICTIONS IN OTHER REGIONS Dioxin generation and potential generation throughout the entire life cycle of PVC has been detailed in Section 1. The dangers of PVC as a dioxin source and product associated with harmful attributes has led to PVC phase-outs and restrictions in many municipalities. "It's no longer a question IF PVC should be phased out, but HOW it shall be phased out." - Anna Lindh, Swedish Minister for Environment, November 1995. This is how Swedish Environment Minister Anna Lindh welcomed the Swedish Parliament s decision in November 1995 that today s plasticized PVC, as well as rigid PVC with environmentally harmful additives, should therefore be phased out. The phase-out should begin speedily (Ecocyle, 1995). This is just the leading edge of a movement underway in countries across Europe, including (Belazzi,1996): - Austria: The Austrian city of Linz has recently achieved an 85% PVC phase-out in public buildings. Six of the nine regional governments in Austria have now placed restrictions on the use of PVC. The Supreme Court ruled in 1994 that PVC can be described as an environmental poison (Vienna, 1994) - Germany: Both the old and the new capital cities of Germany, Bonn and Berlin, have committed themselves to restrictions on the use of PVC in public buildings. (GP D. 1996) In February 1996, Bonn City Council agreed that PVC should be largely avoided in public buildings such as schools, kindergartens, senior citizen's homes and subway stations. Berlin city Council has aimed to restrict the use of PVC in construction materials since 1989. From January 1, 1997, this restriction will be extended to cables containing PVC. More than 195 local authorities and six Federal States in Germany have agreed to restrict PVC use. Spain: in 1995 the Senate asked the government for a report researching the possibilities of a PVC phase-out. In July, 1996 the municipality of the city of Cormona in Andalucia passed a resolution to phase out PVC in pubic buildings. - Switzerland: in 1992, the government banned the used of PVC mineral water bottles (CH. 1990). - The Danish government is also currently considering proposals to phase out PVC by the year 2000. - Sweden: 128 communities in Sweden have agreed to avoid PVC, including Gothenberg. In March 1996 the principal Danish supermarket chain, FDB announced a PVC phase-out. The Body Shop and furniture chain IKEA phased out PVC several years ago (BS. 1996). The organisers of the Sydney Olympics in Australia (2000) have committed to minimising the use of PVC (Oz. 1996) DIOXIN GENERATION FROM PVC IN FIRES The use of PVC in factories and houses is highly dangerous in fires because of noxious hydrochloric acid fumes (which have been proven to kill people before actual fire burns (Wallace, 1981) and because of high levels of dioxin generated in smoke and ash (UBA, 1992) For example, the quantity of dioxins released during the burning of the debris from the buildings collapsed by the 1995 earthquake in Hansin, Japan, has been estimated to equal the amount released by all of that country's municipal incinerators in one year. (Miyata, 1996) As a consequence of the release of dioxins from accidental fires, the German EPA and Ministry of Health have proposed in 1992 that "The use of plastics containing chlorine and bromine should be completely excluded, as far as is possible. UBA and BGA propose a ban on the use of plastics containing chlorine and bromine in apparatus susceptible to fire, in the manufacture of chip-board, as well as the labelling of plastics containing chlorine and if necessary a ban on the use of PVC in packaging." (UBA 1992) Just recently the inquiry by Dusseldorf Environment Department into the major fire that devastated the city's airport in April 1996 found that PVC cable casing was involved... to a substantial extent in dioxin formation (Gortz, 1996). Some Material Alternatives to PVC in Construction Applications PVC PRODUCT SUBSTITUTE MATERIALS DRAWBACKS OF PVC COMPARED TO SUBSTITUTES _________________________________________________________ Windows wood becomes brittle at low temperatures; warping and discolouration may occur under sunlight _________________________________________________________ Flooring ceramic tiles, plasticizer stoneware, marble, evaporation; terrazo, wood no moisture parquetry, linoleum permeability; rubber, cork, hemp not repairable after damage; discolouration _________________________________________________________ Walls brickwork, pebble dash; temperature wood; gypsum; plaster variations board. may cause material to come off; aesthetics; room climate _________________________________________________________ Wallpaper paper wallpaper with plasticiser protective coating on evaporation; acrylate base, ceramic tiles, paint _________________________________________________________ Facades, plaster, wood poor durability, curtain walls aesthetic appeal _________________________________________________________ Roll joints wood, metal plasticiser and hand evaporation. rails _________________________________________________________ Furniture wood, metal not repairable, plasticiser evaporation eg in artificial leather _________________________________________________________ Blinds, aluminum, wood, not as durable, shutters textiles turn brittle after 15 years; leach stabilisers eg lead _________________________________________________________ Weather/draught rubber poor durability strips for PVC turns brittle doors and insultating windows characteristic goes _________________________________________________________ Sewage pipes concrete, earthenware more marked polyethylene (PE) abrasion polypropylene (PP) _________________________________________________________ Sanitary steel, cast iron, increased installations copper, PE, PP abrasiion, lower eg pipes, stoneware stability than pipe casings steel/cast iron; limited section lengths; lower elasticity than other plastics _________________________________________________________ Electrical polyolefins heavy dioxin installations formation in case of fire _________________________________________________________ Roof sheeting plastics, bitumen expansion sheeting problems, plasticiser migration _________________________________________________________ Construction Reusable packaging disposal problems product cardboard, wood, packaging other plastics _________________________________________________________ SOME SUBSTITUTION DESCRIPTIONS PIPES AND DUCTS One of the largest uses of PVC is in rigid pipes for above ground and underground drainage, electrical cables and gas pipes. For underground sewage or water pipes vitrified clay pipes are suitable and are very durable. The expected service life of a clay pipe is commonly given as 100 years Clay pipes also have a high resistence to chemicals in waste water. Alternative materials to PVC in sewage pipes may perform better over time: the city of Nyborg in Denmark reported that the PVC main sewage pipe had become extremely brittle and required frequent replacement. In the UK, Anglian Water specify polyethylene or ductile iron pipes in their mains renovation programme. Neither do they allow developers to use PVC pipe in new sewage schemes for engineering reasons (AW, 1996) HDPE pipes are more flexible and shock resistant. For above ground drainage, ie. soil and vent pipes and guttering, materials such as zinc, cast iron, copper, galvanized steel or aluminium can be used as an alternative. Metal guttering has a longer service life although it may require some maintenance. A new urban development in Leidsche Rijn, near Utrecht in the Netherlands, which will provide over 30,000 new- built houses and 700,000 m2 of office space, is minimising the use of PVC. In particular the water and sewerage system will be PVC free. Some of the first stages of the housing project have already been built. It is possible to substitute PVC in electricity cables with polyethylene (PE) and steel. The UK gas industry now only uses medium density polyethylene MDPE) pipe because it is more flexible than PVC pipe (ECOTEC, 1995) ELECTRICAL CABLES AND WIRING PVC-free electrical cables are available from several companies and the new metro system in Bilbao uses PVC-free cabling for safety and environmental reasons. Similarly the Channel Tunnel between France and the UK uses PVC-free cabling. All the alternative cable types have better properties than PVC in the event of a fire. they generate less smoke, do not release hydrochloric acid or dioxins and have fire-resistant qualities which match or outstrip PVC. All PVC-free cables cost more at present but will drop in price as consumer and municipalities demand safer material use. Electrical cables manufacturers have already developed and marketed several halogen-free alternatives to PVC cable as a result of concern over PVC combustion emissions. When cable is designated halogen-free this means it cannot contain PVC or any other organo-chlorine based chemicals. The main alternative power cables in the high and medium voltage range use polyethylene as an insulation and sheathing material. Rubber sheathed cables are also available. For low voltage uses such as domestic wiring, the alternatives are polyethylene or rubber insulated halogen free cables. In Germany, Siemans has developed a new PVC-free power cable range, (Simaclean) for residential, public and industrial buildings which is being marketed as an environmentally- friendlier alternative to PVC. FLOORING: Alternatives to PVC flooring are easy to find, are competitively priced and perform as well as, if not better than PVC. Natural materials: Ceramic tiles and marble are highly durable and indigenous to the Mediterranean. Stone and terrazos are also traditional, durable materials. When a softer floor surface is required, wood, cork and linoleum can be used. Cork is indigenous to the Mediterranean region. It is hard- wearing, very sound absorbent and popular because it is agreeable to walk on due to reflection of warmth and its natural ounce. Cork floor coverings are available with untreated or sealed surfaces. Types which are sealed with artificial resins (polyurethane) or PVC should be avoided. Wood. Wood is a natural alternative to PVC flooring which is very durable and can be renovated by planing or sanding. Increasingly reclaimed wood floors are available. If using new wood it is important to source wood from certified forests where clear-cutting and other environmentally damaging practises are banned. Only cork and wooden flooring can be renovated and for that reason, these floorings have a longer durability which often justifies the higher costs of fitting. Linoleum once dominated the market for elastic floorings before the 1950's trend to synthetic materials. Linoleum is made of renewable materials and consists mainly of vegetable linseed oil to which a natural resin is added. The mixture is spread on hessian fabric and the surface treated with water-based acrylic 'dispersion' paint. Linoleum has very low flammability, is antistatic, light resistant, sound-absorbent, resistant to fats and oils and has a natural anti-bacterial effect. Synthetic materials for special cases could be rubber and other polymers. Rubber. Several companies in Europe produce rubber floor coverings. Particularly in situations such as airports or sports stadiums where floor coverings have to met great demands in durability, rubber floor coverings have proven effective. Rubber flooring which contains chlorine-based ingredients should be avoided. Ethylene propylene diene (EPDM) type rubber is recommended by the Danish Environmental Protection Authority as an alternative to PVC. Other polymers. Polyolefin floor coverings (PP and PE) are now offered by leading flooring manufacturers such as the German company DLW. The main application for polyolefin flooring is for industrial use but flooring for domestic use is also available. They are non-flammable, sound absorbent and resistant to wear and tear. WINDOWS The main alternative to PVC windows are wooden window frames. Wooden window frames are easy to handle, absorb sound well and keep warmth in the house. A new chemical-free preservative that transforms non-durable wood (poplar, spruce, eucalyptus) into a hardwood quality type of product has won a recent environmental technology award in the Netherlands (TME, 1995) The process involves 'scientifically cooking and baking' the wood fibers allowing mechanical properties to be maintained or even improved. The wood can also be moulded. Reclaimed wood or local timbers can be used. In general wooden windows can last for over fifty years and even after that time can be renovated whereas PVC windows have to be totally replaced after a much shorter period. Polyolefins. In Berlin, where PVC restrictions on building are in force, new polyolefin windows from a German company Helling were installed by the City Council in May 1996. In 1994, Austria's leading PVC window manufacturing company, Internorm, announced that they would stop using PVC as soon as an alternative material became available. They are doing their own intensive research into alternatives and expect to announce a new chlorine-free plastic window frame by end of 1996. PROFILES PVC is used for a huge variety of purposes such as facia boards, window sills etc. Alternative materials are wood, steel, other plastics ,PE and PP, depending on the specific purpose. The alternative materials are both technically and financially competitive with PVC. CLADDING PVC cladding used on the exterior of buildings will change appearance over time. PVC cladding is susceptible to yellowing, bleaching, and "chalking" as a result of complex chemical changes brought on by exposure to heat, UV light and moisture. PVC cladding will also become more brittle over time. Alternatives to PVC cladding include local wood species, or various composite siding products with recycled fibre content. These may require increased maintenance. Steel, concrete and stone panels can also be used. 3.2 COMBUSTION SOURCES 3.2.1. MUNICIPAL WASTE INCINERATION Municipal and biomedical waste incinerators, are considered to be the largest dioxin sources in industrial countries (USEPA,1994). Although it only accounts for approximately 0.5% of municipal waste by weight PVC provides more than 50% of available chlorine (DK EPA, 1995) - the element essential to dioxin formation. Incineration researchers at the University of Florida are convinced that, when all other factors are held constant, there is a direct correlation between input PVC and output PCDD/PCDF [dioxin] (Wagner, 1993). For this reason the Danish government aims to avoid the presence of PVC in incinerators (DK EPA, 1996) and Toronto City Council has banned the incineration of PVC waste (Toronto, 1996). REUSE/RECYCLING ALTERNATIVES "Cleaner production is as much about attitudes, approaches and management as it is about technology. This is why it is called cleaner production and not cleaner technology." -Cleaner Production in the Mediterranean Region, 1995 (ECOMED,et al. 1995) Even if all the PVC and chlorinated wastes were taken out of the waste stream, incineration would still be a poor solution due to high costs, loss of jobs in the recycling industry, lost profits from secondary resale and on-going contamination from heavy metal, hydrocarbon and other air emissions, Cost effective and eco-efficient waste management alternatives to incineration exist. Glass, metals and paper can be easily recycled and reused. Organic waste fractions can be composted at household or community level. Some plastics such as polyethylene and polypropylene can be efficiently recycled if collection and recycling systems are based within the region. ONTARIO, CANADA A ban on incinerators, legislated in 1992, stimulated both job creation and the price of secondary materials. Within two years the recycling industry had benefitted from price increases of 163% for aluminum cans, 25% for PET bottles, 350% for cardboard, 210% for fine paper, 500% for HDPE, and 350% for newspapers. (MOEE, 1995) CURITIBA, Brazil "More than 500 million people will be urban dwellers in the very near future. It is important to invest in change by means of partnerships, this must be our main goal." - Jaime Lerner, former Mayor of Curitiba, Brazil A highly successful programme has been running in Curitibi, Brazil since 1989. Ten thousand families participate in the "Garbage That is Not Garbage" programme receiving two kilos of food for every four kilos of recyclable garbage collected and delivered to the mobile units. The programme was initially implemented to foster the separation of organic from inorganic garbage at source as part of the city's environmental programme. Even the admittance to the municipal open air shows requires bringing in a bag for recycling rubbish. Approximately 60 tonnes of paper are recycled every day equivalent to 1,200 trees. The goals for the future are to transform Curitiba into a centre of excellence in the areas of urban planning and transportation and demonstrate the success of good city planning in developing countries. (PP, 1994) MALLORCA A study to show the feasibility of a recycling/composting plan in the island of Mallorca was prepared by Greenpeace Spain. The annual waste production of waste is 329,000 tonnes -- the majority of which is: compostable material (37.4%) paper (22.2%) plastics (11.5%) glass (10.6%) textiles ( 7.2%) metals ( 5.1%) other ( 6.1%) An analysis of recycling potential including composting found that 72.8% of waste reclamation was possible. The financial costs of incineration (even with energy recovery) were calculated to be 6,000 pts/tonne compared to 2,325 pts/tonne if materials were recycled. Implementation could achieve a 60% beneficial use within five years and solve the country's escalating waste problem. (GP Spain, 1996) 3.2.2 HOSPITAL WASTE INCINERATION In medical waste incinerators, the dominant chlorine donor is PVC plastic, which enters these facilities as packaging and in many disposal medical products. An estimated 9.4 percent of all infectious waste is PVC, and virtually all available chlorine fed to medical waste incinerators comes from PVC. (Marrack, D.1988) Earlier this year the Indian federal government passed regulations banning the use of PVC waste in hospital incinerators. CLEANER MATERIAL USE WITHIN THE HOSPITAL: AUSTRIA Because medical waste incinerators are major point sources of dioxins some countries have brought in more stringent regulations. This has resulted in many hospitals closing their own on-site incinerator and shipping waste to a commercial incinerator with more pollution control devices. However, this is increasingly seen as an inadequate solution (Fenner, 1995) Increasingly hospitals are reducing the amount and nature of wastes by switching to reusables which can be sterilized and reducing the chlorine content of waste sent offsite. (GPA survey, 1995) Reasons for phasing out PVC: Some hospital staff surveyed said that municipal incineration plants either did not accept wastes, in which the chlorine content exceeded the determined percentage, or would do so only at a considerably increased price. Some hospitals have their own pyrolysis or incineration plants. In recent years several incineration plants had to be closed due to better emission regulations, or due to repeated complaints of neighbours. In a number of hospitals these problems gave the impetus for carrying out analyses of all waste streams. This audit highlighted the high ratio of PVC use - in some cases for the first time. As a consequence substitution of PVC products went hand in hand with programmes of waste prevention and separation for recycling. However other reasons exist to substitute PVC products within hospitals. Medical objections against the use of PVC are mainly based on the migration of the plasticiser DEHP. It is soluble in fat-containing fluids such as blood and may cause diseases of the liver, skin and cardiovascular system. (REF Animal experiments have shown a significant increase in liver tumours, when DEHP is added to the food of mice and rats. For this reason DEHP was classified as "carcinogenic in animal experiments" and for lack of adequate epidemiological studies in human beings as "possible human carcinogen" (US EPA) . Recent evidence points to its hormone disrupting potential. (Colborn, et al, 1991) Experience in Germany and Austria with implementing a PVC phase out in hospitals has pointed to the problems of increased costs of PVC alternatives (often 20-30% more expensive) and the ease of using disposables. However these costs must be weighed against the cost of ongoing incineration fees. The following requirements have to be met by medical products: *Medical products should be inert to the highest possible degree; *Products for multiple use must be sterilisable. *In case of some products the impermeability against gases, especially atmospheric oxygen, is essential.. *Medical products must be biocompatible, they are not allowed to cause chemical or physical irritations of the tissue. *Medical products should be break-proof and splinter-proof, which is especially important for use in ambulances. *Further requirements are flexion strength, favourable draining performance, noiseless and odourless reception of fluids and easy connection of the individual components. With such criteria the following have shown to be feasible substitutes for PVC use in hospitals. (GPA, 1995) NON-PVC PRODUCTS PVC Use Alternatives _________________________________________________________ Examination gloves: PE and/or PE copolymers are recommended. Latex is of higher quality and proven barrier to viruses. Overshoes: clogs with leather tops in operating rooms; multiple- use rubber shoes, shoes made of cloth or overshoes made of PE for single use e.g. visitors in intensive care rooms. Aprons: cloth alternatives used in low contamination areas PE coated in operating rooms. Mattress covers: alternative plastic and rubber use only where necessary. washable microfibre - e.g. "Kortex" or "Geritex" more comfortable to patient. Diapers, napkin already non-PVC Wound plasters and dressings textile materials recommended. Bedpans Stainless steel Syringes: PE and PP, sometimes ABS and natural rubber Glass syringes for blood extraction Infusion equipment, Non-PVC infusion equipment, eg. bottles, and/or glass for certain uses, bags with suspension PP, PE, PE/PA, EVA devices, tubings, PCCE and PSU as well as tubing clamps, stop multi use suspension cocks devices for all common infusion receptacles. Tubing EVA and EVA copolymers, PCCE or PE, In other fields of application, e.g. for respiration, silicon or rubber tubings Stop cocks ABS, PE, PC and PSU, often in combination of several plastics. Silicon adapters with connecting parts of PE and PP Gastric probes: Silicon and PP Catheters silicon and latex drainage bottles, collecting bags: glass, PE, PE/PP Scalpels: (disposable with PVC handles) Metal handles with interchangeable, sharpened blades Breathing masks: rubber, silicon, latex Special Case Blood Bags none in Austria, supplier in USA Packaging Mostly PVC free now. PP Blister packs COSTS AND BENEFITS OF ALTERNATIVE DISINFECTION In general, eighty five percent of the total medical waste stream in hospitals consists of the same mixture of discarded paper, plastic, glass, metal and food waste that is found in ordinary household waste. The remaining 15% is defined as infectious and these wastes must be sterilized before disposal. A small percentage of this waste or 0.3% of the total medical waste stream, can only be incinerated, in part for cultural or aesthetic reasons, but also because it is difficult to sterilize in any other way. Thus there are dioxin-free means of disposing of 99.7% of the medical waste stream. Non hazardous waste can be recycled within a household waste recycling plan. For disposing of infectious waste there are several alternative dioxin-free methods that are cost comparative (OTA, 1990, GP Med,1996) Three of these are: - Autoclaving An estimated 45% of infectious medical equipment from Western hospitals is already reused through autoclaving. (OTA, 1990) This is basically steam sterilisation which encourages the reuse or recycling of medical equipment. Autoclavers are commercially available in varying sizes from desk-top to industrial units. The process involves heating bags of medical waste at between 120 and 1650C for 30 to 90 minutes in chambers into which pressurised steam is introduced. The steam penetration ensures destruction of bacteria and pathogenic microorganisms. Waste is reduced by an estimated 75% of its volume and can either be landfilled directly or compacted further. The autoclaved infectious waste adds to the landfill burden, but the amount is usually less than 0.2% of the municipal solid waste stream (CBNS, 1996) According to a recent survey of hospitals that have installed autoclaves, they are easier to operate than incinerators. - Microwave Disinfection. Microwaving is economically competitive, versatile and studies in Europe have shown virtually no emissions since the internal heating system is closed. Consequently there is no need for pollution control devices. Microwave disinfection relies on treating hospital waste with moist heat and conventional microwaves at temperatures of 940C. The equipment can be installed on or off site in stationary or mobile units. The remaining residues which have been reduced by 80% in volume can be landfilled - Superheated Steam Sterilisation This technology comprises a heated shredder and sterilisation unit. In the shredder, organic liquids are vaporised and solids reduced to gas by super-heated steam at temperatures between 500 and 700C. Medical equipment is melted into a sterile mass in under an hour. Remaining residues are cooled and dropped into a collection bin or ground in a heated shredder. The process has been shown to reduce medical waste by 50 to 80% of its original volume. ECONOMIC COSTS AND BENEFITS OF ALTERNATIVES A study released this year (CBNS,1996) assessed the four major dioxin point sources to the Great Lakes region in North America and then analysed the cost and employment implications of adopting chlorine-free alternatives. The study found the transitions could be accomplished with little or no loss in economic activity or jobs -- and even with some gains. This study has relevance to the Mediterranean since all four major dioxin point sources exist in both regions. The study found combustion of chlorinated wastes to be the major dioxin point sources as follows: - hospital incinerators responsible for 48%; and - municipal waste incinerators responsible for 22% of all dioxin generated in the region. - Iron ore sintering and cement kilns burning hazardous waste responsible for an additional 8% each - remaining 11 sources generate 14% (Note: dioxin-contaminated pulp and paper effluent emissions were dealt with separately) In sum the study found the transitions could be accomplished with little or no loss in economic activity or jobs -- and even with some gains. EMPLOYMENT: The indicated changes in pulp mills, iron sintering plants and cement kilns burning hazardous waste would reduce employment in the region by about 1,100 jobs. But jobs created in the transition from incinerating household waste to recycling it could add some 24,600 to the region`s 43 million jobs, for a net gain of more than 23,000 -- a small but positive accomplishment. COSTS: Eliminating the dioxin generated by the region`s medical waste incinerators, iron sintering plants, cement kilns burning hazardous waste, and pulp and paper mills would increase their total annual operating costs by about $370 million. But the approximately $530 million annual savings from replacing trash- burning incinerators with intensive recycling would yield a net savings of about $160 million for the region. The overall impact is therefore positive. The consequences of closing all the 52 Great Lakes garbage incinerators and creating programs of intensive recycling throughout the region capable of diverting the same tonnage of waste that is currently burned involves: - a 4% in increased collection costs. Currently 24.7% (1994) is collected but this would need to increase to 41.9%. Total: $206 million - an increased education cost to municipalities of approx $1 per capita; Total: $ 88 million - net income from processing and marketing collected recyclables eg a typical 600 tons per day municipal recycling facility can process recyclables at a cost of $46 per ton. less the tip fee for processing organic waste Total: $462 million - avoided disposal costs due to increased recycling. Weighted average tip fee is $58 per ton. Total: $675 million - Cost of incinerator debt retirement. Estimated cost of retiring the outstanding bonds on the 52 incinerators in the Great Lakes region, amortized over a 20 year period: Total: $307 million JOB BENEFITS of a Recycling Program: It is estimated 6,100 jobs would be created from additional collection and processing jobs after deducting job losses at incineration closures. Further job increases of 21,000 are predicted if the additional recycled materials are used by current and new manufacturing firms within the region. The CBNS study further examined the annual operating costs of hospital incinerators. Table 1. Total Estimated Costs of Alternative Infectious and Pathological Medical Waste Disposal Methods, for All (609) Hospitals in the Great Lakes Region DISPOSAL METHOD ANNUAL OPERATING COST (Millions of 1994 dollars) Existing incinerators (uncontrolled) 9.8 Existing incinerators with mandatory upgrading 55.5 Autoclaves plus small pathological waste incinerator 23.0 Ship to commercial facility 28.0 Autoclaving is the most profitable investment unless there are no regulations at all on incineration emissions. Further assessment was made of the costs to hospitals of converting to autoclaves including paying off the debt on the original purchase of an incinerator. In this scenario conversion costs (2.9 million dollars) are still cheaper than the annual operating cost of incineration with mandatory emission upgrading (3.4 million dollars per year). (CBNS, pg. 22) It is preferable that sterilization is done on-site at the hospital rather than shipped to a centralized sterilization plant. Examples of Spanish cities or regional communities where hospital waste is sterilized instead of incinerated: - Regional Government of Aragon has banned by law hospital waste incineration; - Palma de Mallorca. 3.2.3 HAZARDOUS WASTE INCINERATION It is estimated that 70% of all current waste and emissions from industrial processes can be PREVENTED AT SOURCE by the use of technically sound and economically profitable procedures. (Baas, et al. 1992) Clean production case studies for incinerable waste streams are available. (UNEP, 1992) No country should contemplate a hazardous waste incinerator without a national programme of cleaner production. Policy measures to achieve this have been well documented (UNEP, 1994) and cleaner production initiatives in the Mediterranean have achieved significant results within small and medium scale industries (ECOMED, 1995; EP3, 1995) Toxic USE reduction and elimination must be the focus rather than simple EMISSION reduction since toxins can be switched to off-site recycling or incorporated into the product, posing use and disposal problems later in the life cycle. It is imperative that countries in the Mediterranean undertake a cleaner production programme for all industrial sectors which naturally incorporates toxic use reduction. Once an incinerator is built, ongoing toxic waste generation is legitimized and there is little incentive to investigate process changes within industry even if cleaner production methods are more profitable. (Inform, 1988) For this reason, mandatory toxic use reduction plans should be prepared by each facility generating toxic waste. This is the basis of two of the most successful cleaner production government programmes in the United States:-- the Toxic Use Reduction Act of Massachusetts and the Pollution Prevention Act in New Jersey. BENEFITS OF TOXIC USE REDUCTION: Massachusetts, USA The Toxic Use Reduction Act was passed in 1989.(MA. 1989) The goal of the legislation is to develop toxics use reduction as its primary tool for industrial pollution control while enhancing the competitive position of Massachusetts enterprises. The first goal is to reduce toxic waste generation by 50% through toxics use reduction over a ten year period (1987-1997) Under TURA firms that use any of a list of approximately 800 chemicals in quantities that annually cross a minimum threshold must: - annually report publically on the amount of chemical used and released; - pay an annual fee - prepare a plan (updated every two years) on how to reduce or eliminate the use of those chemicals that is certified by a licensed Toxics Use Reduction Planner. In 1995, 603 firms participated. Over 87% of the participating firms implemented TUR programs. Twenty of the firms eliminated 1.29 million pounds of byproduct (wastes) and on average companies saved $35,000 per year. Between 1990 and 1993 all firms cut their toxic byproduct (waste) by 14.5% and plan to generate 23% less waste in 1998. Total volume of listed toxic chemicals in the state dropped by 6% within these three years. Of the 29 firms applying for awards in toxics use reduction, together they had eliminated the use of 2,870 tons of toxic chemicals, reduced 750 tons of hazardous wastes and saved $44 million per year. BENEFITS OF TOXIC USE REDUCTION: New Jersey, USA Similar to Massachusetts, New Jersey has a toxic use reduction goal of 50% within five years. New Jersey mandates pollution prevention planning based on full materials tracking throughout each industry covered by the state regulation. The total net benefits to facilities themselves projected as a result of savings from pollution prevention techniques amounts to $105 million dollars per year. (NJ, 1995) For every dollar spent on the entire process, including government costs, facility costs for compliance and capital costs for implementation of pollution prevention techniques, facilities project net savings of $5 to $8. The majority of facilities (74%) felt that planning was worthwhile since it allowed: cost savings, less regulation, better business decisions, more accurate reporting, shared mission between environmental and production staff. Although all facilities had reduction goals, one-quarter of those who sent in plan summaries had reduction goals of zero for all chemicals reported. The most common pollution prevention methods determined were - raw material substitution - substituting different coating materials - changing to aqueous cleaners Chlorinated solvents were among the top three chemicals targetted for toxic use elimination. 3.2.4 CEMENT KILNS: CBNS STUDY on CONVERSION COSTS Some cement kilns burn hazardous waste as fuel thereby generating dioxins in air emissions and ash. Cement products are contaminated with heavy metals and dioxins. A phase out of incinerable waste streams is possible via a toxics use reduction plan. The economic costs of converting back to fuel has been done by the CBNS study (Commoner et al, 1996) as summarized below. The study found that the added expected income from burning hazardous waste in cement kilns is likely to be less than the model estimates due to a declining market share. This would enable kilns to resume former fuel burning of coal, coke, oil or natural gas, as currently practiced by three quarters of the kilns in the region. However instead of receiving a tip fee (which in 1993 amounted to $68 million), the 9 cement kilns in the region would then pay for the normal fuel (about $9 million per year) amounting to an increase of approximately $77 million. At the same time, the transition results in a payroll saving since additional employees that handle the hazardous material are no longer needed. Furthermore the kiln could avoid the operational costs of installing control devices. 3.2.5 SMELTERS Little is known about the exact source of dioxin point sources in this process but evidence from Germany points to the various kinds of chlorinated organic substances that are used in conjunction with steel-making machinery. (Commoner, et al. 1996) These include chlorinated solvents, common in degreasing and cleaning operations; chlorinated cutting oils, used to lubricate high-speed metal-work machines; extreme-pressure lubricants, such as those used in modern rolling mills; and possibly the fluid used in the hydraulic systems that operate many steel plate machines and which may contain chlorinated additives. Chlorinated organic substances now used in steel operations could be replaced with non-chlorinated substitutes, except with one exception - the extreme-pressure lubricants. Research based on extrapolation from scarce data predicts a cost increase of 0.04% relative to the price of cold rolled steel for the Great Lakes region in North America. More research is needed for a substitute for this one use. PRIMARY AND SECONDARY SMELTING Dioxins may be formed when chlorine is used in the production of refined nickel and magnesium. All chlorine use should be phased out from metallurgical processes. PVC AS DONOR IN SECONDARY SMELTING PVC is also burnt - and dioxin produced - during the smelting of scrap containing metals such as copper (Christmann, 1989), steel (Tysklind, 1989, Aittola, 1993) and aluminum, lead, and zinc (Aittola, 1993). The PVC is present, for instance, as insulation on copper cables, or as the plastic component of scrapped telephone cases. Secondary lead smelters produce dioxin because of PVC plastic separators in lead-acid batteries. (US EPA, 1994) And secondary steel smelters produce dioxin because of PVC residues in steel scrap, primarily from automobiles (Aittola, 1993) Substituting the PVC plastic components would remove the dioxin point source. Non-halogenated cabling is available and car manufacturers such as Mercedes, Volkswagen, BMW and Opel are reducing their use of PVC in car parts. Appliance producers such as AEG and Herlitz in Austria have stopped using PVC in their products. 3.2.6 OTHER COMBUSTION SOURCES Leaded petrol is a significant source of dioxins due to the halogenated fuel scavenger used in the mix. Non-leaded petrol produces hardly any dioxins. Alternative transport fuels such as electric, solar, hydrogen fuel cell, ethanol, and aquahol are ultimately more sustainable and are slowly increasing in use. This should be a priority for a Mediterranean cleaner production plan. Sewage sludge incineration, as with all incineration, is a loss of resources. However industrial discharges to the sewer system will partition heavy metals and persistent toxins into the sludge. Safe land spreading of sewage sludge as a soil fertilizer should be the goal of wastewater treatment but this will depend on cleaner production planning in industries upstream. Ultimately, industrial waste should not mix with human waste. (Clivus, 1992) Many industries have now closed-loop their aqueous discharge: - the city of Muncie, Indiana has achieved zero discharge to sewer for one third of its industries. (Craddock, 1995) Safer forms of sewage treatment exist ranging from individual home compost toilets to facility-size reed bed filtration systems and "living machines" technology wherein a series of plant ecosystems purify influent to drinking water standards without the use of chemicals. (Todd, 1991) 3.3 PULP AND PAPER Alternative bleaching methods include: Oxygen Delignification Peroxide Ozone Enzymes and Closed loop systems In addition to the main goal of eliminating organochlorine discharges, elimination of chlorine bleaching also provides other environmental and economic benefits to pulp mills. The elimination of chlorine-based chemicals allows mills to close the loop and reuse large amounts of process water. A pulp mill with a conventional bleaching sequence will use about 4,000 gallons of water per air dried metric ton (ADMT) of pulp produced. The presence of any chlorinated compounds make that water impossible to reuse, as it will corrode equipment. The elimination of chlorinated compounds allows for an 80 percent reuse of that process water (or a use of 500 gallons of water per ADMT). (Shackford. 1992) A pulp mill producing 1,000 tons of pulp per day can reduce its water use from four million gallons per day to a half million gallons per day. Although treatment of pulp mill effluent will still be necessary to remove solids and adjust BOD, COD and pH, companies should realize significant costs savings by not having to meet increasingly stringent limits on dioxins, furans and AOX discharge. Further, sludge from settling ponds is now considered a hazardous waste because of the chlorine content. If chlorine is eliminated, the sludge would consist of woody residues and could probably sold as a mulch and become a value-added product of the mill. Many of the chlorine-free alternatives allow for the recovery of the bleaching chemicals. If all chlorine-based chemicals are eliminated and the loop is closed, pulp mills can also recover significant percentages (estimates place the recovery rate well above 50 percent) of caustic soda. Cost effectiveness of moving to TCF pulp: Example: Canada A recent report on options to chlorine use in Canada analyzed the various methods of pulp and paper production and future market potential. This is particularly important to the Canadian economy since net pulp exports represented almost 40% of Canada's merchandise trade surplus in 1993 ($11.7 billion) [ CPPA, 1994a] Recognizing that the market share of TCF pulp had grown rapidly in recent years and would possibly continue, and recognizing that the cost of TCF technology will continue to decrease, it is speculated that producers might be inclined to switch to TCF even before their current delignification and bleaching facilities wear out. "The most up-to-date study on the costs of ECF and TCF based on U.S. EPA and European data, (Vice et al. 1994) suggests that converting from traditional chlorine-based pulping to TCF involves lower capital and operating costs than converting to ECF, although this may vary according to the particular conditions in individual plants. As the relatively new TCF technology undergoes more research and application, further decreases in costs can be expected. This will be encouraged by the economic and environmental inducements in favour of closed- loop production systems, which minimize chemical inputs and waste." Similar research in the Great Lakes region examined the cost- effective of chlorine substitution (Commoner, 1996). In that region ten mills produce virgin pulp and paper and most of these mills use the kraft process in which wood chips are heated in an alkali solution that breaks down most of the lignin and releases the cellulose fibers that are used to make paper. After breakdown products are washed out of the pulp, it is treated chemically - with chlorine, for example - to bleach the pulp and break down the remaining lignin. Pulp mills have reduced the formation of chlorinated organic pollutants in three ways: limiting dioxin-contaminated inputs; reducing the amount of elemental chlorine use and/or reducing the amount of organic breakdown products that remain in the pulp when the chlorine is added. The most favoured method of achieving this in the region has been the substitution of chlorine dioxide for elemental chlorine. As a result the dioxin content of pulp and paper mill effluents have declined by 60 to 80% nationally in the US, according to the EPA. However, this has not achieved dioxin elimination and will not allow pulp mills to close-loop their effluent. The economics of producing ECF (elemental chlorine free) and TCF (totally chlorine free) pulp were investigated using four scenarios: ECF 1 - Chlorine dioxide ECF-2 - Oxygen delignification with chlorine dioxide ECF-3 - Oxygen delignification; ozone; chlorine dioxide TCF - Oxygen; ozone The main results are: - All of the alternative modifications in the existing mills increase the per-ton cost of producing pulp by amounts that are 2% to 5% of the market price of pulp ($365 - $855 per metric ton). - The technologies that are most effective in reducing the production of dioxin and other chlorinated organic pollutants, ie ECF-3 and TCF -- require the largest increases in average production costs, about 20% more than the cost of conversion to ECF-2 only. - There is no significant difference between the average increased production cost of the most advanced ECF-3 and TCF pulp. Yet, of the two, only TCF assures zero production of dioxin and pollutants since no chlorine, in any form, is used. The advantages of adopting totally chlorine free pulp production is that: - the market share for chlorine-free paper will continue to grow. Several states and cities in the USA have passed ordinances to encourage the procurement of TCF paper products, among them Oregon, Massachusetts, Seattle and Chicago. - In 1990 a Germany government scientific group called for an end to the use of all forms of chlorine in the paper industry and a year later the government advised the German paper industry to do so. Currently 30% of the printing and writing paper market in the Nordic countries and Germany use TCF kraft pulp. - By 1994, 22 European mills were producing TCF bleached kraft pulp. Europe is the US paper industry^s largest regional export market and US mills will have to adapt to growing consumer preference for chlorine free paper. - the TCF process can be entirely closed loop and effluent free because it yields byproducts that are more benign and less likely to corrode piping and equipment than those produced by chlorine dioxide. In Spain, the major pulp and paper company, ENCE, in Pontevedera produces 80% of the pulp totally chlorinefree. 3.4 SOLVENTS Solvents account for approximately 10% of all chlorine production, and are a correspondingly significant source of dioxins. Dioxins occur in the manufacture, use and disposal of chlorinated solvents. Manufacturing industries can replace chlorinated solvents with cleaner production processes that have been shown to result in large savings -- as much as several million dollars per company -- due to reduced costs for chemical procurement, control, and disposal. Often these processes also substitute new jobs for chemicals. (ICPIC database) Some alternative methods are summarized below: SECTOR ALTERNATIVE Metal Degreasing/ Aqueous,terpenes, mechanical Paint stripping scrubbing, alkaline cleaners high pressure water, carbon dioxide cleaning, biodegradable detergent,heat and power sprays; dry ice pellet sprays. Printing vegetable oils, non-chlorinated inks Electronics Aqueous, terpenes, no clean fluxes Painting waterborne electrostatic Pharmaceuticals use of ethanol/acetone or aqueous formulations for pill coatings; For extraction use of: supercritical fluid extraction; liquid carbon dioxide extraction; equipment modifications. Drycleaning: Since the discovery and development of non-chlorinated drycleaning techniques, a variety of reports have been done. The first conducted by the USEPA in 1993 showed that the chlorinated solvent, perchloroethylene, can be replaced with a water-based system that is equally effective and results in a 42 percent lower capital investment to install, a 78 percent better return on investment, a 5 percent increase in profits, and a 21 percent increase in jobs. (Jehassi. 1993) Implemented throughout the U.S., this system would create 33,170 new jobs with wages of $606 million per year. Since then other methods of non perchloroethylene techniques have become commercial such as: multi-process wet cleaning Aquaclean (Electrolux) Aquatex (IPSO/Belgian washer, British detergents, American dryer) A recent report (Univ Michigan, 1995) researched a combination of 70% machine wet cleaning and 30% multi process wet cleaning. Their conclusion: "Based on the five criteria of performance, environmental impacts, human health effects, cost, and regulations, wet cleaning appears to be less of a burden on the environment, and pose a lower risk to human health." Their economic analysis (based on info from Aqua Clean (wet cleaning machine) manufacturer, Environment Canada, and New York's Ecomat, they found that a wet cleaning facility could earn a yearly profit of just over $17,000 to $20,500, similar to a dry cleaner's profits. In November, 1995 an initiative between the four largest drycleaning trade associations in the USA signed a partnership with Greenpeace, UNITE Trade Union, Center for Neighborhood Technology and the Toxic Use Reduction Institute. The goals of the agreement are to develop, explore and promote professional wet cleaning for clothes that previously would have been drycleaned, and to help clothes care industry members who are under regulatory pressure to survive and prosper. In Spain there are already 11 wet cleaning shops. In the Mediterranean Project SUBSPRINT (Substitution of chlorinated solvents in the printing sector by vegetable oils) has been carried out in Spain, Italy and Greece. 3.5 PESTICIDES Approximately 97% of all synthetic pesticides use chlorine within their manufacturing process. Half of all hormone disruptors currently identified are synthetic pesticides (Colborn, 1991). Pesticide resistance continues to increase within insect species leading to increased use and resultant higher environmental and human health risks. In 1989 the United States National Academy of Science examined the costs and benefits of chemical-free agriculture. Alternative agricultural systems that reduce or eliminate pesticide use have been shown to increase crop yields, lower farmers' costs, increase financial returns, and create new jobs by substituting labour for chemicals. (NAS, 1989) In every case studied, the Academy found that yields on farms practicing alternative agriculture increased or stayed constant. Further, because these farms were typically more diversified, their owners reduced the risk and variability of new returns. The major economic barrier to wider implementation of these processes was found to be government programs that encouraged the use of pesticides and fertilizers. Alternatives to persistent pesticides include improved choice and rotation of crops, mechanical methods of weed and pest control, introduction and maintenance of natural predators and use of biological pesticides. 4. COSTS Increased concerns about dioxin's effects on the developing hormone system of children are now not only focussing on reproductive damage (Colborn, 1996) but behavioural and nervous system dysfunction as well (Erice, 1995). Each human generation is exposed to more hormone disrupting chemicals and the current generation is the first to have been exposed in the womb and now at child-bearing age. (Colborn, 1994 ) Enough evidence exists of dioxin's dangers to wildlife and humans, and enough cleaner material alternatives exist to act. CHLORINE INSTITUTE REPORT, 1993 In 1993, the Chlorine Institute, the North American representatives of the industry, commissioned and released a report asserting that the IJC recommendation to phase-out chlorine as a feedstock chemical, would cost the U.S. and Canadian economies $102 billion (US) per year, would impact 1.4 million jobs, and would severely disrupt local and regional economies. (CRA, 1993) The industry's calculations were based upon a methodology that assumed the chlorine phase-out would be implemented instantaneously, without thought, planning, or prioritization. The industry further assumed that the non-chlorinated alternatives would perform poorly or be unreasonably expensive. The analysis looked only at costs and burdens and failed to explore the benefits and savings associated with the transition to a dioxin-free society. (Thornton, 1993) The actual costs of phasing-out chlorine are likely to be only a small fraction of those calculated by the industry, and the benefits of the transition are expected to outweigh these costs. By prioritizing major chlorine use-sectors, the cost of the phase-out can be substantially reduced. Even according to the industry's own cost estimates, 97 percent of chlorine use in the USA and Canada could be phased-out for just $22 billion per year. Health care costs in the region cost $100 to $200 billion a year - some of which is due to exposure to persistent toxic substances. TWO RECENT COST STUDIES OF DIOXIN ELIMINATION, 1995 and 1996 Recently two studies of the feasibility and repercussion of chlorine product phase-out in Germany and the Netherlands were published. These were predicated by mounting public concern over dioxin levels in individuals within these industrialized countries recent evidence of dioxin`s hormone disrupting effects, particularly on the developing fetus, and the recent political decision taken by the Fourth Ministerial Declaration for the Protection of the North Sea. This commitment agreed to move towards the cessation of the discharges, emissions and losses of hazardous substances within 25 years with the ultimate aim of concentrations in the environment near background values for naturally occurring substances and close to zero concentrations for man-made synthetic substances (Esbjerg, 1995). European governments and industry are now faced with a timely decision to either invest in membrane cell chlorine technology or switch to non-chlorinated processes and products. CHLORINE PHASE OUT IN GERMANY: THE PROGNOS SUBSTITUTION REPORT, 1995 In Germany the national implementation of the Paris Commission's decision to phase out the amalgam process of chlorine manufacture would in effect mean that almost two-thirds of all chlorine production plants in Germany would be successively shut down within approximately fifteen years. German industries, like other national industries with older plants, can either invest in alternative forms of chlorine production or move to cleaner and safer material substitutes. A recent report prepared by the Prognos consultancy (Prognos. 1994) found that total amount of primary chlorine used in Germany could easily be reduced by 51% within the next twenty years through the gradual conversion of processes and substitution of products. Furthermore, the ecological advantages through less accident risks and reduction in emissions and energy would be supplemented by an increase in employment of five per cent in the areas studied. This conversion should be carried out at very little change in costs, these having a net increase of barely one per cent. The report also notes that a study of all recorded industrial accidents published by the German Federal Department of the Environment, concluded that: 1. Chlorine was the one single substance most frequently involved in accidents; and 2. A majority of injuries (60%) was due to the release of chlorine (UBA ZEMA report, April 1994). It is important to note the boundaries of this and the accompanying Dutch report. The Prognos report based its conclusions on the substitution potential for propylene oxide, PVC, epoxy resins and phosgene production. The study based its conclusion on two main assumptions: It only examined the direct chemical for chemical substitution potential based on the current price of substitutes and therefore almost half of PVC use was discounted because current alternative window and cable materials are more expensive. Secondly the product itself was not questioned from a systems analysis. For example the end use of polycarbonates and isocyanates and the potential for material substitution or system redesign were not factored in. A wider assessment of the end uses of these chemicals and the feasibility of natural materials or product redesign under a different economic costing method would have resulted in a larger conversion potential to non-chlorinated and cleaner material use. However this study and the accompanying Dutch Contrast Advies study, based on similar criteria (see following), is worth examining as an example of one method of substitution analysis. They both show the current feasibility and value of immediately investing in cleaner production. The four product substitutions are summarized below: (1) Propylene oxide Currently twenty-nine per cent of primary chlorine use in Germany is used to make propylene oxide via the chlorohydrin process. However fifty percent of propylene oxide worldwide is made by a chlorine-free coproduction process (MTBE and styrene processes). According to the Prognos report, these alternative processes have ecological advantages over the chlorohydrin process (in terms of emissions and potential hazards). The net costs of the MTBE process are 40-50 per cent below those of the chlorohydrin process due to the marketability of the by-product produced in the process, MTBE, which can suppress carcinogenic benzene as an antiknock agent in motor fuels. Substitution of the non-chlorine route would lead to a doubling of jobs to 6,000. Given the economic attraction of the alternative process and the relatively advanced average age - about 20 years - of existing plants, a 100% changeover to this process is possible in the next five to ten years. (2) PVC Currently twenty-nine per cent of the production of primary chlorine in Germany is processed into PVC. It is technically possible to substitute 95% of PVC, mainly through PE and PP. However if the cost-intensive substitution programme for windows and cables are excluded, a mean net price increase of four percent results for fifty percent of current PVC use. The age of existing facilities means a neutral investment cost for this change-over. Prognos conclude that the ecologically advantageous and economically moderate substitution potential of 50% for current PVC uses can be realised step by step within the next fifteen to twenty years. This does not lead to any additional investment costs. The four per cent net rise in costs of products is furthermore offset by a four percent increase in employment. (3) Epoxy resin manufacture Epoxy resin manufacture from epichlorohydrin represents eight per cent of primary chlorine use in Germany. Chlorine-free processes for making epoxy resins are still at the research stage however fifteen per cent of epoxy resins can be substituted by chlorine-free substances such as phenolic resins. At present, epichlorohydrin, the chemical intermediary used in the intermediate product can be made with a greatly reduced use of chlorine via the Showa-Denko process. This has ecological advantages in terms of emissions, process costs, potential risks and total energy consumption but requires 100 fewer jobs and is not chlorine-free. Prognos concludes however that using this model and given the average age of existing facilities the ecological and benefits for an almost 60% reduction in chlorine use for this sector can be realised step by step within the next fifteen years. This results in a net cost increase of five per cent and a six per cent job loss. (4) Phosgene chemicals Fourteen per cent of all primary chlorine manufacture goes to process phosgene. Phosgene is used as a chemical intermediate in the production of (chlorine-free) isocyanates and (chlorine-free) polycarbonates. Phosgene-free processes for manufacturing isocyanates have to date only reached a mass-production stage for aliphatic isocyanates (a maximum six per cent of production). A commercially introduced phosgene-free process for making polycarbonates exists in Japan. The alternative process uses less energy, costs 17% less than the phosgene process with 30% less investment costs, and can be installed into existing plants within the normal investment cycle of 20 years. The Prognos report concludes that a 20% reduction in chlorine use for this sector, can be realised within 20 years. However with the five per cent net fall in costs associated with this there is a six per cent reduction in employment. In summary the addition of all four product substitutions result in an easily achievable reduction of 51% of total primary chlorine use in Germany by the year 2020. CHLORINE PHASE OUT IN THE NETHERLANDS: THE CONTRAST ADVIES SUBSTITUTION REPORT, 1996 At the request of Greenpeace Netherlands, a similar study was done by the Amsterdam consultancy firm, Contrast Advies, to assess the potential for chlorine reduction in the Netherlands (Contrast, 1996) This report was the first published in the Netherlands to estimate the financial and employment impacts of a conversion. The study concluded that Dutch chlorine consumption could be cut by approximately 60% within five years if four major plastic manufacturers (AKZO, Shell, Solvay, General Electric) switched to alternatives requiring little or no chlorine. The changeover is technically feasible, much less expensive than the industry claims and does not necessarily put jobs at risk. Similar to the Prognos report a full chlorine material use study was not done; only PVC, epoxy resin manufacture and polycarbonate production was analyzed since these were the major chlorine users accounting for more than two-thirds of Dutch chlorine consumption Only four production facilities are involved. In comparison to the German study the report looked at the feasible of conversion within five years, rather than the German twenty five year scenario. It also looked at actual production facilities rather than industrial sectors. As well as complying with the North Sea Conference decision to phase out toxic, persistent substances within one generation, the political value of this report in the Netherlands is also underscored by the fact that - many of the relevant chlorine processing plants (four out of the five) are approaching the end of their economic life and investment to either substitute or upgrade chlorine production would occur; - two chlorine factories must close by 2010 at the latest following the mandate of the Parcom decision to phase out the mercury polluting amalgam process of chlorine production. - the change over to the membrane process of chlorine production would entail the reduction in jobs by a factor of 2.5 to 3 in these plants. The report assumed the following substitutions: PVC: convert to the chlorine-free plastics polypropylene (PP) and Polyethylene (PE) in the ration 60-40%. ECH/epoxy resin: convert to the Showa Denko process which uses far less chlorine to produce ECH (this choice was made in the absence of commercially viable chlorine-free process. Shell has since announced its intention to focus its research effort on developing such a chlorine-free process); polycarbonate: convert to a chlorine free process. The overall costs of such a transition amount to 690 million guilders over a period of 25 years. This is a fraction of the total profits of the Dutch chemical industry which in 1994 alone made 3.2 billion guilders. If present levels of profit continue the required investment in the transition is estimated at 1.5%. Effects on employment are expected to be minimal: a few dozen extra jobs will be created. If it is assumed that only half of current PVC customers switch to PP or PE alternatives and that the closure of four chlorine factories lead to a sharp fall in the production of caustic soda and hence the need to import from elsewhere then a total of 798 jobs are lost. However it is expected that based on current trends in the chemical industry, 8,000 jobs would be shed in the coming 25 years even without the transition. On the other hand, the production of substitutes is estimated to create, on balance, a modest gain of 58 jobs. The report concludes with specific recommendations among which is the need for international negotiations to promote conversion of the chemical industry on a global scale, such as the introduction of a standard levy on chlorine and caustic soda produced by the chlorine route. CHLOR-ALKALI PROCESS A phase out of all chlor-alkali plants would necessitate a reversal to alternative forms of sodium hydroxide (also called caustic soda) production - a current by-product of chlorine production. Caustic soda has a variety of uses including soap manufacture, artificial fibres, dyes and paper. Prior to 1890 caustic soda was produced by treating soda ash (sodium carbonate) with lime (calcium hydroxide) and this process could easily be adopted again. It would also be important to adopt more efficient uses of caustic soda within each industrial sector such as with the closed loop system of totally chlorine free processes in the pulp and paper industry. Some studies have examined alternative supplies of caustic soda resulting from a chlorine elimination strategy (NL report, 1996) 5. TRANSITION PLANNING As detailed in the previous report substantial dioxin contamination has resulted at PVC production facilities and is even acknowledged by the industry itself as being inherent to its production processes (ICI, 1992). Because dioxin generation is inherent to the life cycle of PVC plastic from its production, use and disposal the issue is how to phase-out production facilities themselves and ensure a worker transition plan. EXAMPLE: THE OIL, CHEMICAL AND ATOMIC WORKERS UNION PROPOSAL Initiatives by the Oil, Chemical and Atomic Workers Union in the United States have proposed a Superfund for Workers (OCAW, 1992). The union believes that if the predicted job losses are to happen for environmental or other reasons such as free trade- induced migration of multinationals to lower wage countries, workers should not be the victim. This idea builds on the Superfund act in the United States where a budget is held for chemically contaminated land clean-ups. As the union states, "working people should be treated at least as good as the dirt the EPA and other agencies have earmarked for cleanup and restoration." The concept also stems from the economic security that corporations themselves have but which workers do not. In the United States most large corporations carry insurance against lost income during shut-downs or accidents. Similarly, a government subsidy exists to grant compensation to pesticide companies whose product is found to be a hazard to public health. All these reimbursements never considered the workers who were made unemployed. The program is also inspired by the United States' GI Bill of Rights which ensured four years of paid education for the home-coming soldiers after World War II Fourteen million soldiers were helped to find jobs The Superfund for Workers program advocates education with income support for workers dislocated for environmental and other reasons as an alternative to unemployment, welfare or poverty; and for workers unable to find work after retraining, a guaranteed annual wage coupled with education. Greenpeace supports such union initiatives and furthermore believes the program should be funded by a tax on the chlor-alkali process. The tax should begin at a modest level and rise over time. This way, funds can be built up to provide for the transition while creating an economic incentive for user industries to more quickly phase-out chlorine and organochlorines. 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