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Fallacies and Facts About Chlor-Vinyl Dioxin Emissions
Perkins+Will (P+W) and the Healthy Building Network (HBN) released a white paper in November that grossly misrepresents relevant publicly available data and leaves readers misinformed about the U.S. vinyl resin manufacturers’ environmental performance and continual improvements in reducing emissions over the last 20 years.
The white paper, Healthy Environments: What’s New (and what’s not) with PVC, is an attempt to broaden awareness of emissions yielded during chlor-vinyl manufacture using data from the U.S. Environmental Protection Agency’s (EPA) Toxic Release Inventory (TRI) annual dioxin reporting, a publically available database containing information on toxic chemical releases and other waste management activities in the United States. Unfortunately, P+W and HBN conflate the data and units of measure for emissions that the Vinyl Institute tracks and reports on for the chlor-vinyl industry. They also claim the Vinyl Institute underreports the industry’s dioxin emissions—which is factually not true.
On average during the past 5 years, over 93 percent of dioxin emissions tracked in EPA TRI data come from non-vinyl industrial sources.
The P+W and HBN white paper’s singular focus on dioxin from the chlor-vinyl industry reveals a genuine lack of understanding of industrial sources of dioxin. In fact, vinyl manufacturing accounts for less than 7 percent of the total dioxin emissions. There is no mention of or concern evidenced by P+W and HBN for the other non-vinyl industrial sources that generate 93 percent of dioxin emissions tracked in the EPA TRI database.
In fact, the EPA TRI data show that, over the previous 5-year period, the chlor-vinyl industry has accomplished a 42-percent reduction in dioxin emissions to air and water, while at the same time those emissions from all U.S. non-vinyl industries have more than doubled. Here’s what P+W and HBN get wrong—and what the data really reveals about the chlor-vinyl industry’s record.
How Perkins+Will and Healthy Building Network get it Wrong.
The P+W and HBN claim: “EPA first required the PVC industry to report any dioxin emissions over 0.1 grams per year beginning in 2000.”
FACT: P+W/HBN misrepresent EPA’s initiative by saying EPA required this reporting by the PVC industry when in fact EPA required all U.S. industries to report dioxin above a certain threshold level in its Toxic Release Inventory data collection. P+W/HBN should be forthright in representing EPA reporting requirements for all industry rather than implying it was intended for just the PVC industry.
The P+W and HBN claim: “In the past five years (2010-14), these [vinyl chloride, PVC and chlorine] factories released on average 1,212 grams of dioxin and dioxin-like compounds annually into the air and water – more than the 1,146 grams released in 2000.”
FACT: According to EPA, there are 210 different dioxin and furan congeners. EPA requires that the 17 congeners with 2,3,7,8 substituted hydrogens to be reported in its TRI database. Because the 17 different dioxin congeners have different toxic potencies, EPA and the World Health Organization both use methods to report dioxin based on corrections using Toxic Equivalent Factors (TEF). As a result, the scientific community has normally discussed dioxin in terms of its toxic equivalent (TEQ) in grams. This is similar to EPA’s methodology of reporting greenhouse gases as CO2 equivalents, which assigns different greenhouse gas (GHG) factors to specific emissions.
EPA reports in TEQ grams for a more comparable basis because of the differences between potency of the congeners from different processes into different media (air, water, solids) by the myriad of industries that create dioxin and furan byproducts in their manufacturing processes.
Appendix C in the P+W and HBN white paper is simply dioxin reported in grams; it makes no attempt to study the toxic potency assigned to the 17 congeners. Amounts reported in TEQ grams for the chlor-vinyl industry overall are approximately 500 times below what is reported as weight in grams. The white paper, however, flips from one reporting unit to another (grams in one sentence, then grams TEQ in another). This would be like talking about the speed of a car in miles per hour in one sentence, and then in feet per second in another.
The P+W and HBN claim: “While a 2013 paper authored by the Vinyl Institute states that the industry released between 6.8 and 7.9 grams TEQ of dioxin to air and water, between 2007 and 2011, an examination of US EPA Toxic Release Inventory (TRI) data submitted by facilities producing PVC and its feedstocks again reveals much higher figures.”
FACT: The Vinyl Institute accurately reported the data from EPA’s TRI database for the amounts of dioxin emitted to air and water. It is unclear why P+W and HBN believe the numbers should be higher.
The P+W and HBN claim: “In on-site releases to air and water, alone, the industry has been releasing between 12 and 19 grams TEQ of dioxin annually.”
FACT: The Vinyl Institute’s 2013 technical paper referenced by the P+W/HBN whitepaper accurately reports the amounts of dioxin emitted to air and water recorded in the EPA TRI database. The numbers quoted in the P+W/HBN white paper erroneously include amounts not emitted to air and water.
The P+W and HBN claim: “In 2013, total on- and off-site releases spiked at 91.7 grams TEQ — or more than 1,000 % higher than the Vinyl Institute claims.”
FACT: P+W and HBN are comparing total dioxin reported in the EPA TRI database to those air and water amounts tracked by the Vinyl Institute. This is an apples and oranges comparison—and incorrect. The Vinyl Institute tracks emissions to air and water since they have the potential to contribute to dioxin exposure to the general public. Dioxin that is created as solid media at chlor-vinyl facilities is sequestered in secure landfills and/or underground facilities that the general public is not exposed to.
The P+W and HBN claim: “In 2014 alone, vinyl chloride monomer and PVC manufacturers released 531,203 pounds of VCM into the air.”
FACT: For proper context, this amount reflects an 83 percent decrease in unit emissions of vinyl chloride reported in EPA’s TRI database since 1987. This marked reduction has been the result of significant recapture and reuse of unreacted vinyl chloride monomer in addition to diligent efforts to mitigate leaks. This recapture also has contributed in part to the significant reductions in dioxins tracked by the Vinyl Institute for the industry.
P+W/HBN’s focus on dioxin for the chlor-vinyl industry must be examined from the perspective that if dioxin is a continuing criteria for assessment of building materials, will they be doing a comparison that encompasses all building materials?
With so many misleading claims about the vinyl life cycle and vinyl products, in addition to false dioxin claims, in this paper, we won’t begin to address them all in one post. Look for more factually-based information to come.
Vinyl Institute sat down with Jim Vallette, director of Research at the Healthy Building Network, to discuss our concerns with this white paper. The Vinyl Institute explained its determination and reporting of dioxin emissions to air and water and the rationale as reviewed above.