History of Dangerous Delays on
Dioxin Protective Policy
The U.S. Environmental Protection Agency (EPA) completed its first health assessment of dioxin in 1985. The EPA’s estimate in this report of the cancer risk to humans from dioxin exposure was by far the highest defined for any chemical by any government agency anywhere in the world. Because this report provided the scientific basis for all risk assessments used by EPA programs to regulate dioxin emissions and discharges to the environment, the regulated industries immediately protested that this risk estimate was too high.
The paper and chlorine industries in particular pressured the agency to reconsider this risk estimate. The focus of their argument was on the method used by the agency to estimate the cancer risk. These industries argued that there was a "threshold" of exposure to dioxin, below which there was no risk, and that dioxin was much less dangerous than defined by the EPA. The EPA argued that there was no threshold and that its risk estimate was supported by scientific evidence.
As part of its efforts to convince the EPA of its position, in 1990 the Chlorine Institute (later to become the Chlorine Chemistry Council) convened a scientific conference on dioxin. Shortly afterwards, in 1991, EPA Administrator William Reilly announced that the agency would undertake a reassessment of the health effects of dioxin based on findings from this conference. The industries felt confident that the agency would now find that there was a level of exposure to dioxin that does not pose any risks, forcing the agency to recalculate its cancer-risk estimate.
Instead, scientists found new evidence that there was no threshold for some of dioxin's effects and that dioxin acted like a hormone, disrupting many systems in the body. These and related findings supported the agency's original risk estimates and provided the scientific basis for the EPA's draft reassessment report, which was released in 1994. In this report, the EPA again concluded that dioxin poses a serious cancer risk and that the average American had a level of dioxin in their body that could cause adverse health effects (USEPA, 1994).
This draft prompted dioxin-generating companies to launch an aggressive campaign to stall the release of the report. This attack began with a peer review report led by industry scientists who rejected several chapters in the draft document, forcing the agency to rewrite them and delaying the process of finalizing the report (SAB, 1995). While this draft report was being rewritten, local and state agencies hesitated to take action on dioxin exposure situations, claiming that there was no clear guidance on the risks dioxin posed. This led to a six-year delay during which people continued to be exposed to dioxin while government reevaluated its risk estimates and corporations operated as usual.
In June, 2000, the EPA released a revision of the 1994 reassessment report. Much to the chemical industry’s dismay, the EPA found even stronger links between exposure to dioxin and adverse impacts on human health. One of the EPA’s key findings was that the risk of getting cancer from dioxin exposure was ten times higher than reported in 1994. The agency also acknowledged that the importance of the non cancer effects of dioxin including effects on hormones and the immune system, developmental/reproductive effects, and developmental neurotoxicity.
The EPA's Science Advisory Board (SAB) reviewed the EPA's dioxin reassessment report in the fall and winter of 2000-01. This review was to be one of the last steps in the review process before the EPA released the final document. The review process was controlled by industry and used to further stall the release of the reassessment. Members of the SAB were presumed to be neutral scientific experts whose role it was to review the report solely on its scientific merits. The SAB review process turned out to be littered with controversy. Complaints included the lack of balance on the panel, lack of public disclosure among the reviewers about conflicts of interest, and the lack of transparency throughout the process.
In June, 2001, after much watch dogging and pressure from Campaign partners, the SAB sent a letter to EPA Administrator Christine Whitman urging the reassessment be completed and released ‘expeditiously.’ Instead, the agency announced they would send the final draft to an Interagency Working Group (IWG) for one more review. The IWG consists of representatives from all the federal agencies who not only got to comment on the report, but also to develop a release strategy. It wasn’t until January of 2003 – eighteen months later - that the EPA actually sent the document to the IWG.
The process and timeline for completion are unclear, despite numerous attempts to get this information from the EPA. In 2003, during the eleventh hour of negotiations, a rider was added to the House Appropriations Bill that requires the dioxin reassessment be reviewed in it’s entirety by the National Academies (NA) if the IWG process isn’t completed within sixty days of the passing of the Appropriations Bill. The IWG did not complete its review by the required time. Thus, NA conducted a review.
The National Academies (NA) released a report on July 11, 2006 confirming what numerous scientific panels have concluded over the past 15 years: dioxin is a potent cancer-causing chemical. Chlorine-based industries have been effectively stalling the release of the EPA’s controversial dioxin reassessment for 15 years.
