First published April 20, 1994, by
the
Environmental Conservation Organization
Why Chlorine Should NOT Be Banned
(The case for rejecting the Greenpeace proposal
to
phase out all uses of chlorine)
|
Greenpeace is leading the charge to ban chlorine. In a report by Joe Thornton, entitled The Product is Poison: The Case for a Chlorine Phase-out, Greenpeace says: "...all uses of chlorine must be phased out...." There is no documentation to justify this draconian declaration. The report emphatically concludes: "Enough is known about the persistence and toxicity of organochlorines as a class to justify an outright ban...the manufacture and use of all organochlorines must be phased out...all uses of chlorine must be phased out as well." The proposal should be rejected out of hand because:
The debate arises because a few scientists, from largely unreviewed, limited studies, contend that chlorine in its many forms cause health problems that range from breast cancer to shriveled penises. Other scientists, who study the same data, reach different conclusions. Greenpeace has proposed a sweeping public policy change that will have massive economic and public health consequences, not on the basis of scientific fact, but on the basis of their interpretation of very limited studies. In the past, public policy decisions have not waited for scientific fact. Driven by biased interpretations of limited findings, organizations such as Greenpeace, Natural Resources Defense Council, and others, have generated mass hysteria in the media and lobbied a willing Congress into premature, expensive, unnecessary policies. The current Greenpeace proposal follows the same pattern: "Enough is known," says Greenpeace "...about the toxicity of organochlorines..." to disrupt the economy and public health procedures throughout the land. "Enough" is not known. What is known does not support the Greenpeace conclusion. Although the Greenpeace report contains no evidence to support its claim that chlorine causes health threats, the report's author, Joe Thornton, is quoted in Cancer Researcher Weekly(1) as having said:
The same article quotes Dr. Susan Sieber, deputy director of the division of Cancer Etiology at the National Cancer Institute. She said that the idea that all chlorine-based chemicals should be banned "is nonsense," and that while two small studies contain intriguing findings, "they certainly are not definitive evidence that there is a link with breast cancer." More recently, studies published in the Journal of the National Cancer Institute by Kaiser-Permanente, said:
Writing in the Journal of the National Cancer Institute,(3) Dr. Stephen S. Sternberg of the Memorial Sloan-Kettering Cancer Center, discusses research on breast cancer and linkage with organochlorines. He describes the study of Mary Wolff et al, of Mount Sinai School of Medicine in New York, as "a relatively small group of women (n=58) with breast cancer." He commends the authors for reporting that "the conclusions require confirmation." He further states:
The Wolff study draws from work by Israeli Dr. Elihu Ricter that suggests incidence of breast cancer dropped by 30 percent in the decade after DDT (an organochlorine) was banned. Sternberg points out, however, that there was not a corresponding increase in breast cancer when the substance was introduced, and that in fact, "there was a 25-year continual rise in breast cancer mortality in Israel." The decrease in mortality began before the drop in pesticide exposure, and the study drew its conclusions from residues in cow milk, not from human serum levels. Sternburg concludes:
The allegation that organochlorines cause elevated incidence of breast cancer may be enough for Greenpeace, but clearly, the scientific community is not convinced. On the basis of currently available data relating to breast cancer, there is no need to ban chlorine. Another misstatment in the Greenpeace report is a carefully worded implication that organochlorines are not found in nature, but are a toxic polluntant created by industry. Dr. Gordon W. Gribble, Professor of Chemistry at Dartmouth College, says there are "...immense quantities of natural organochlorines...." In a letter published in Environment, Science, and Technology, he identifies more than a dozen known sources of natural organochlorines, including lightning-induced forest fires, volcano eruptions, and the secretions of marine organisms. He says:
His letter concludes:
The Greenpeace report states flatly:
Again, the report fails to provide specific evidence to support these sweeping, frightening, allegations. Details, however, are revealed in the popular media. Two articles published in Science News(5) provide the basis for the Greenpeace claims. In an article entitled "The Gender Benders," Janet Raloff presents the argument that minuscule quantities of organochlorines have an "estrogen mimicking" effect in wildlife and presumably, in humans. The article cites work by Louis J. Guillette, Jr., of the University of Florida, which suggests that alligators in a Florida lake have shriveled penises, which he attributes to the presence of organochlorines. Newsweek(6) embellished the story by reporting that sperm counts of men "have plunged by an average of 50 percent" since 1938, and that Guillette had told a Congressional committee "every man in this room is half the man his grandfather was." Nancy Evans, President of Breast Cancer Action, told Jane Kay, a reporter for San Francisco Examiner, "There is a movement throughout North America now, among the women's cancer groups and the environmental justice groups such as Greenpeace and the Natural Resources Defense Council, to coalesce and exert pressure...to reduce the use of these chemicals [organochlorines]."(7) The extent of coalescence was clear during the month of February, 1994. On February 1, Carol Browner released the administration's recommendations for major changes in the Clean Water Act. She said, "We've done the easy part by controlling pollution at the end of the pipeline. For the first time ever, we're tackling the hard part - the control of polluted runoff...."(8) It is an unlikely coincidence that Greenpeace issued a press release the same day with the headline "Greenpeace Applauds Clinton Call for Strategy to Phase Out Chorine in U.S." The release continues:
Two days later, J. Roger Hirl, Chairman of the Chemical Manufacturers Association, met with Browner. She told him that press reports of Clinton's plan "had been misrepresented."(10) It could be another unlikely coincidence that two weeks earlier, EPA proposed a new rule in the Federal Register that listed dozens of chlorine compounds to be added to the toxic chemicals list.(11) The magnitude of the anti-chlorine coalition became apparent on February 8 at a Washington press briefing co-sponsored by Greenpeace and Congressman Bill Richardson. The purpose of the briefing was to promote the "Chlorine Zero Discharge Act" (HR2898), introduced by Richardson. The briefing was moderated by Mark Flogel, the international coordinator of Greenpeace's anti-chlorine campaign. The briefing began with a ten-minute CNN anti-chlorine video which featured Flogel. (CNN has featured Greenpeace in 24 different documentaries in the last two years.) Theo Colborn, a zoologist who works for the World Wildlife Fund, and Jessica Landman, an attorney for the Natural Resources Defense Council, were both featured at the briefing. Congressman Richardson failed to appear. He was represented by a staffer, Ben Finzel, who tried to assure the audience that Greenpeace wasn't telling his boss what to do. With many of the players on the anti-chlorine team now identified, the expansive strategy begins to focus more clearly. The Science News articles referred to the above reports that Theo Colborn "has convened a number of symposia in the past few years for researchers who study reproductively impaired wildlife...exposed to environmental hormones." Colborn has obviously been very close to the research in the area of estrogen mimickers, or environmental hormones. She has failed to report, or even mention, those studies that reach conclusions different from the gloom-and-doom, penis-shriveling results she discusses. Unbiased science demands all the facts, not just those which support a preconceived agenda. Dr. William Hazeltine, Manager of the Butte County Mosquito Abatement District (retired), knew as early as 1971 that chlorinated hydrocarbon insecticides could produce beneficial as well as adverse effects. His work, published in Clinical Toxicology, considered both effects and suggested that DDT (an organochlorine) appears to have beneficial effects on infants, by reducing the incidence of Juvenile Jaundice.(12) Dr. Allen B. Okey's findings in 1975 indicated that DDT reduced tumor and cancer risks by increasing hepatic enzyme activity which detoxified carcinogens.(13) Dr. Stephen H. Safe of the Department of Veterinary Physiology and Pharmacology, Texas A&M University, has worked extensively in the area of environmental estrogens. Of three breast cancer studies he reviewed in ESPR - Environmental Science & Pollution Research, he says:
Safe also reviewed the Skakkebaek study which spawned the falling sperm count claims. He says:
The Skakkebaek study contained no new data, but analyzed data from other studies which used vastly different protocols. The author told a technical conference that he never said a declining trend was continuing. He said sperm counts in men have remained constant for the last 30 years. Other studies by J. MacLeod and Y. Wang also found no evidence to support the hypothesis of declining sperm count.(15) Theo Colborn and Greenpeace have to be aware of Dr. Safe's work and the other conflicting studies. They have chosen to ignore them. Safe's work demonstrates that both naturally occurring and synthetic chemicals function as estrogens and as antiestrogens. He suggests that studies which implicate organochlorines as environmental hormones "should be discussed and evaluated in terms of the balance between the occurrence of chemicals which exhibit estrogenic and antiestrogenic activity since the two classes of chemicals could be contra-active. It is possible that the overall effects of these compounds may not be highly significant...." The reasons to ban chlorine offered by Greenpeace are simply not supported by the available science. Nevertheless, Greenpeace, the World Wildlife Fund, and the Natural Resources Defense Council have chosen to ignore credible science and flaunt only the findings that advance their anti-chlorine agenda. The Guillette study of alligators has not been reviewed, nor even published.(16) Yet Congress, and the world, have been told that organochlorines leave men shortchanged. The anti-chlorine strategy intends to ban all uses of chlorine. Truth, scientific integrity, facts, consequences, and costs are but obstacles to be ignored or overcome by the anti-chlorine campaign. The proposal to ban chlorine presented by Greenpeace is only the leading edge of a massive, well-orchestrated, world-wide effort to ban one of the most important chemicals known to man. The strategy has been unfolding for several years and is now at the brink of final adoption by Congress in the form of two bills introduced by Bill Richardson. There is clearly no scientific reason to ban chlorine. There is reason to continue wide ranging studies. The anti-chlorine advocates have no interest in further studies; their goal is not scientific fact, or even consensus, but a total ban on all uses of chlorine. Public Health A ban on chlorine would have devastating public health consequences. Stig Regli, then regulation manager of the Office of Groundwater and Drinkingwater at the EPA, told a 1991 conference of the American Water Works Association that a chlorine ban "...would be outrageous. The benefits of chlorine far outweigh the risks." Keith Carns, former director of water quality in Oakland, California, told the same conference:
Ninety-eight percent of the public water supply is disinfected with chlorine. Without it, water-borne diseases such as cholera would flourish. Syndicated columnist Alston Chase reports that local authorities in Peru were advised to stop using chlorine in 1991. Since then, 8,500 deaths from cholera have been recorded in South America, and last year, the epidemic reached the United States.(18) Closer to home, the absence of chlorinated water in Gideon, Missouri caused an outbreak of Salmonella in December, 1993. Forty-four percent of the population was stricken, and four people died.(19) Few public health officials believe the proposed ban will affect chlorinated water supplies, although the Greenpeace report specifically states "...all uses of chlorine must be phased out." Dr. Fred Angulo of the Centers for Disease Control, says:
The anti-chlorine strategy has carefully avoided discussions about chlorinated water supplies. Ben Finzel in Congressman Richardson's office tells callers that the Chlorine Zero Discharge Act has nothing to do with public water supplies, the bill is aimed at the paper and pulp industry. The bill itself tells a different story. Section 2(c) creates an advisory panel (which must include members from public interest groups such as Greenpeace or the Natural Resources Defense Council) charged with producing a report within 18 months. The report must list "all types or categories of non-point sources" of organochlorines discharged into water by industrial and "permitted" facilities. Section 2(d) says:
The only way to achieve absolute zero discharge of less than detectable traces of organochlorines is to prohibit the introduction of chlorine in the first place. The "permitted facilities" referred to in Section 2(c) are those facilities required by law to secure a NPDES permit under the provisions of the National Pollution Discharge Elimination System, administered by the EPA. It is the system devised to control groundwater runoff from non-point sources. Browner's February 1 statement stressed that "...for the first time ever, we're tackling the hard part - the control of polluted runoff...." EPA's control is achieved by requiring an NPDES permit of any facility that is responsible for groundwater runoff. Every city's storm sewer system requires an NPDES permit. Municipal water systems that are disinfected with chlorine cannot allow water from fire hoses, street cleaners, or lawn sprinklers to drain into the storm sewer without violating the Chlorine Zero Discharge Act. Without discussion of public water supplies, the anti-chlorine strategy has either manipulated, or cooperated with the EPA and Bill Richardson to establish the legislative authority to ban all chlorine uses through the existing NPDES permitting system. The Richardson bill is offered as an amendment to the Clean Water Act. It has garnered substantial support because most of the bill attacks only the paper and pulp industries. But the bill contains the legislative authority to do exactly what Dr. Fred Angulo says would be "inconceivable." (Richardson has also introduced another bill (HR2488) which would ban the burning of chlorinated plastics.) It is another unlikely coincidence that an extensive study of the nation's water treatment facilities was completed and released by the Natural Resources Defense Council (NRDC) only a few days after the Greenpeace-Richardson press briefing. The report entitled "Victorian Water Treatment Enters the 21st Century," claims that the nation's public water treatment system is obsolete, and constitutes a serious public health threat. At the Greenpeace-Richardson press briefing, Jessica Landman, NRDC's attorney, admitted to reporters that the ultimate objective of the campaign against chlorine is the elimination of water chlorination. It is ironic that unfounded public health concerns are offered by Greenpeace as reasons to ban chlorine, while completely ignoring the proven, devastating public health consequences of the absence of chlorine in drinking water. Not a single case of cholera was reported this century in Peru, Columbia, or Ecuador, until 1991,(21) according to the Morbidity and Mortality Weekly Report, published by the Massachusetts Medical Society (which also publishes the prestigious New England Journal of Medicine). The same publication reports as of January, 1994, 941,804 cases of cholera and 8,622 deaths. The people who have been denied the use of chlorine are less likely to be concerned about the size of alligator penises, or a hypothetical one-in-a-million cancer risk alleged to be caused by chlorine than they are about burying the people who died because they were denied the use of chlorine. Economic Impact Ninety-eight percent of all U.S. drinking water systems, and 96 percent (by volume) of all disinfected wastewaters - are treated with chlorine. The cost of replacing or retrofitting municipal water systems is sobering. New investment for construction is estimated in the range of $30 billion. Additional costs of operation are estimated to be $6 billion per year.(22) For a family of four, the monthly water bill would increase about $50 per month, or $576 per year. The four known alternative technologies are: membrane filtration, ultraviolet radiation, granular activated carbon (GAC), and ozonation. Each of the alternatives is expensive; none has been tested as thoroughly as chlorine. Keith Carns told the American Water Works Roundtable: "If we switch to ozone to minimize chlorine by-products, we have to be concerned about ozone by-products and the biological impact of ozone." The fact is, no alternative is known to be as safe and effective as chlorine. The exorbitant costs associated with a chlorine ban only begin with water treatment facilities. Agricultural costs are staggering. Ninety-six percent of all crop protection products rely on chlorine. The Greenpeace proposal recommends a "rapid phase-out" of these products and says "government programs should encourage the use of natural pesticides and predators." Studies published in the Southern Journal of Agricultural Economics indicate a range of crop yield losses from 20 percent (wheat) to 70 percent (cotton,)(23) using the pre-chlorine farming techniques recommended by Greenpeace. Moreover, tens of millions of additional acres would have to be brought into production to offset the yield loss. The additional equipment, fuel, and labor required, combined with yield losses, push the estimated cost to consumers to $24 billion per year, $384 for every family. The Greenpeace suggestion that organic farming would reduce costs is not supported by any model of the farm economy. Organic farming, ironically, does not reduce the risk of exposure to carcinogenic chemicals, and could increase the risk. Dr. Bruce N. Ames, Division of Biochemistry and Molecular Biology, University of California at Berkley, says: "All plants produce toxins to protect themselves against fungi, insects, and animal predators such as man." Laboratory tests reveal these toxins to be carcinogenic at about the same rate (about half) as man-made chemical pesticides. "We estimate," says Ames, "that Americans eat about 1500mg/day of natural pesticides, over 10,000 times more than man-made pesticide residues, which the FDA estimates at a total of 0.09mg/day." Organic farming may actually increase the risk of exposure to carcinogins. New plant varieties being developed for insect resistence achieve that result by increasing the levels of natural pesticides. "A new variety of insect-resistant celery that is being widely sold is almost 10 times higher in carcinogens (2600ppb) than standard celery."(24) The Greenpeace anti-chlorine campaign has focused on the pulp and paper industries. The industry has been made to appear as irresponsible corporate polluters and individual citizens have paid little attention to the regulatory onslaught. Individual citizens, however, will pay for the conversion to non-chlorine technologies through higher prices. New investment by the industry will cost the average family $788, and each year thereafter, paper products will cost $176 more than they cost using chlorine technologies.(25) Like the unknowns associated with alternatives for water treatment, alternative technologies for paper processing have not been tested. Extensive fish kills have been reported downstream from processing plants that have switched to non-chlorine systems. The anti-chlorine pressure on paper processing may result in environmental damage far more severe than the alleged problems with chlorine. The average family of four, who will ultimately have to pay the costs of a chlorine ban, has no idea how far chlorine reaches across the economic spectrum. Nearly everything in the average family's home that contains plastic is dependent upon chlorine. Chlorinated plastics have also been targeted by Greenpeace for a "rapid phase-out." Most of the products that now use chlorinated plastics could use substitute materials. Aside from the cost of conversion, the replacement material would be more costly than plastic and the cost of use would be higher than plastics. Chlorinated plastics emerged in the competitive free market because it produced better, more efficient products than the material which would have to be used if chlorine were banned. Before large diameter PVC pipe was developed, water transmission lines were made of ductile iron (DI) pipe. Installation of DI pipe is labor intensive. Joints and fittings are extremely expensive and must be bolted together manually. From the extraction of the iron ore, through the processing, casting, delivery, and installation, DI pipe requires much more energy and labor than PVC. Virtually every other chlorinated plastic product that would be outlawed by the Greenpeace ban would be replaced by a product that costs more and performs less efficiently than plastic. Substitute products would cost the average family at least $110 per year more than the cost of chlorinated plastic products. Convenience of use and product satisfaction will suffer; these factors cannot be quantified. Other costs can be measured directly. The chlorine industry employs 1.3 million people in 48 states, and provides an annual payroll of $31.3 billion. Products that depend upon chlorine add $56.8 billion to the American economy. The cost of substitution products is estimated to be $91 billion. These known costs, translated to the average family, will take another $1400 per year out of spendable income. A chlorine ban would forever deny the world the benefits of future products this industry can provide.(26) The economic impact of a chlorine ban should not be viewed in isolation. It is another example of how government, driven by organizations such as Greenpeace and the Natural Resources Defense Council, dictates how private individuals spend their money. According to studies by Roger Meiners and Roger Miller at Clemson University, 42% of the national income goes directly to the government for taxes. The cost of regulatory compliance in 1992 was $500 billion, or 18% of national income. In other words, 60% of every dollar earned by the average family goes to the government or to expenditures required by the government.(27) Regulatory compliance now costs the average household about $5,000 per year. A chlorine ban would add another $1,400 per family. That leaves only about 38 cents of every income dollar to be spent at the discretion of the person who earns the income. The Greenpeace proposal to ban chlorine is but the current page of the history book that will record how the government took control of what once was an American free market economy. The price is too high; the proposal to ban chlorine must be rejected. Sound Public Policy Like beauty, sound public policy is in the eyes of the beholder. Our Constitution envisioned a system that would forge the most beautiful public policies on the anvil of open, honest debate. For nearly 200 years, the American system forged policies that led the world to unprecedented heights of health and prosperity. In the last quarter-century, the system has tilted. The hammers of conflicting opinion no longer strike the anvil evenly. As a result, the public policies produced on the tilted anvil tend to lean toward a bigger, more powerful government than can be contained by our Constitution. Of all the reasons for recent changes in the direction of public policy, none is as clear and as easily documented as the influence exerted by the environmental movement. Sadly, the rise to power of the environmental movement has come at the expense of scientific integrity. Public policy is now influenced more by the perception of environmental correctness than by scientific evidence. Ironically, an organochlorine, DDT, was the first victim, and the first major victory of perception over fact for the environmental movement. Within five years after its creation in 1967, the Environmental Defense Fund (EDF) led the charge to ban DDT. Despite months of hearings, testimony of hundreds of scientists, and the official findings of the EPA, which said that DDT:
William D. Ruckelshaus, the EPA administrator who issued the ban, neither attended the hearings nor read the transcript. He said: "DDT was banned for political reasons."(29) Thus began the long parade of public policy decisions forged not by open and honest debate, but cunningly crafted by powerful environmental groups, amplified by sensation-seeking media, and implemented by an intimidated Congress or cooperative bureaucrat. Since the DDT success, the technique has been repeated many times. The technique is simple:
An important lesson must be taken from the DDT experience: What is true, factual, and supported by scientific evidence doesn't matter in public policy decisions. What matters is what people believe is true. Environmental organizations have become masters at masking fact with perception. Virtually every "scientific" study used by environmental groups to create the perception of imminent disaster has proven to be flawed, at best, or fraud, at worst. Unfortunately, the proof doesn't come until after the policy is enacted. In 1979, a television station in San Francisco told its viewers that dioxin is a "fetus-deforming agent one hundred thousand times more powerful than thalidomide...a synthetic chemical so powerful that an ounce could wipe out a million people." The New York Times added to the scare by printing an op-ed piece that said "dioxin can cause severe adverse health effects, and death, at the lowest doses imaginable."(30) The dioxin fear remains today despite extensive studies that have yet to find a single death or serious health problem. The American Medical Association's Council on Scientific Affairs concluded:
In a letter published in Science, Dr. Stephen S. Sternberg concludes:
In 1989, CBS's 60 Minutes told America: "The most potent cancer-causing agent in our food supply is a substance sprayed on apples...." The Alar story is well known. This charge was led by the Natural Resources Defense Council, who had to know, as later independent studies proved, that the doses used to achieve tumors in their studies were equal to a human eating 28,000 pounds of apples per day for 70 years. And when the dose was cut in half, to the equivalent of 14,000 pounds per day, no tumors appeared.(33) Bruce Ames describes the risk of eating an Alar-treated apple daily at 1/1000 the risk of drinking a daily beer. The same scenario was used to ban asbestos. The EPA now acknowledges that asbestos should have never been disturbed. The same scenario was used to ban PCBs and CFCs. The literature is full of evidence demonstrating that a long list of substances have been removed from the marketplace, at great expense to the economy, with little or no environmental benefit, by regulations enforced by an ever expanding government, that private citizens must pay for in taxes and in loss of freedoms. Greenpeace is leading the charge to ban chlorine, flanked by the Natural Resources Defense Council and the World Wildlife Fund. Many other environmental organizations march in the same army. The scenario is the same as the attack on DDT, Alar, CFCs, and on and on:
The three environmental organizations leading the anti-chlorine campaign operate with a combined annual budget of $222.1 million (1990). When the rest of the green army is counted, nearly $750 million, and a combined staff of more than 3,000 professionals are available to manipulate the media and intimidate Congress. The chlorine industry is the biggest prize yet targeted. Anti-chlorine advocates intend to ban chlorine, despite the absence of scientifically documented reasons to do so; despite the horrendous, very real, well-documented, health threat that will follow a chlorine ban; despite the calamitous economic impact such a ban would inflict; and despite the further erosion of the process of hammering out the best possible public policy through open and honest debate. Anti-chlorine advocates have unfolded their strategy for the last two years, and have now arrived at the door step of ultimate victory. Both Congress and the EPA appear ready to deliver the victory to Greenpeace. The perception that chlorine is bad has masked the fact that chlorine is an essential part of life. It is the average family that will, once again, have to pay the price. The proposal to ban chlorine must be rejected.
REFERENCES
1. Thornton, Cancer Researcher Weekly, October 25, 1993, p.13. 2. "Breast cancer studies offer comfort, warnings," The Sacramento Bee, April 20, 1994. 3. Sternberg, Journal of the National Cancer Institute, Vol 86, No. 1, January 5, 1994. 4. Gordon W. Gribble, "ES&T Letters," Environment, Science, and Technology, Vol 27, No. 13, 1993, p.2620. 5. Raloff, Science News, "The Gender Benders," January 8, 22, 1994. 6. Bagley, Newsweek, "The Estrogen Complex," March 21, 1994. 7. Jane Kay, "Cancer from DDT?" Chico Enterprise-Record, March 8, 1994, p.1B. 8. EPA Environmental News, "Administration Recommends Major Changes In Clean Water Act," February 1, 1994, (R-26). 9. Greenpeace press release, "Greenpeace Applauds Clinton call for Strategy to Phase out Chlorine in U.S." Washington, February 1, 1994, gp.press:112.0. 10. CMA News Release, "EPA administrator assures industry agency has no plan for ban on chlorine chemistry," Washington, February 8, 1994. 11. Proposed rule: Addition of certain chemicals; toxic chemical release reporting; community right-to-know /RIN2070-AC47 (FEDREGISTER 59 FR 1788 01/12/94) 40 CFR Part 372. 12. William Hazeltine, Ph.D., "DDT and Juvenile Jaundice," Clinical Toxicology, 4(1), pp. 55-61, March 1971. 13. Okey, Allan B., & Silinskas, K. Charles, Journal of the National Cancer Institute, Vol 55, No. 3, September, 1975. 14. Stephen H. Safe, ESPR - Environmental Science & Pollution Research, 1 (1) 1994, pp.29-33, copyright Ecomed Publishers, D-86899, Landsberg, Germany. 15. MacLeod, J., and Wang, Y., "Male Fertility Potential in Terms of Semen Quality: A Review of the Past, a Study of the Present," Fertil Steril 31:103-113, 1979. 16. Telephone interview with Louis J. Guillette, April 7, 1994. 17. "Will Chlorination Exist In 2000?" Journal of the American Water Works Association, Vol. 84, pp.18-20, March, 1992. 18. Alston Chase, "Planned chlorine ban could cost lives," Bozeman Daily Chronicle, February 23, 1994. 19. "Waterborne Salmonella Outbreak in Southeastern Missouri," Missouri Department of Health, P.O. Box 570, Jefferson City, MO 65102. 20. Telephone interview with Dr. Fred Angulo, April 7, 1994 (404) 639-2206. 21. "Cholera - Peru, 1991," Morbidity and Mortality Weekly Report, Massachusetts Medical Society, p.226, April 5, 1991. 22. "Assessment of the Economic Benefits of Chlor-Alkali Chemicals to the United States and Canadian Economies," Charles River Associates, 1993, p.6. 23. "Economic Impacts of Chemical Use Reduction on the South," C. Taylor et al, Southern Journal of Agricultural Economics, July 1991, p.15. 24. Bruce N. Ames, "Natural carcinogens and dioxin," The Science of the Total Environment, 104 (1991) 159-166, Elsevier Science Publishers B.V., Amsterdam. 25. Op Cit., Charles Rivers Associates, p.6. 26. Op Cit., Rivers & Associates, p.20. 27. Roger Meiners and Roger Miller, Gridlock in Government, Free Congress Foundation, Washington, DC, 1992, p.32. 28. Ron Arnold and Allen Gottlieb, Trashing the Economy, Free Enterprise Press, Bellevue, WA., 1993, p.290. 29. Ibid, p.291. 30. Michael Fumento, Science Under Siege, William Morrow and Company, New York, 1993, p.97. 31. Ibid, p.108. 32. Stephen S. Sternberg, "Is Dioxin a Human Carcinogen?" Science Vol. 263, March 18, 1994, p. 1545. 33. Dixy Lee Ray, Trashing the Planet, Regnery Gateway, Washington DC, 1990, p.78. |
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