Chemical Industry Strategies
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=======================Electronic Edition========================
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. CHEMICAL INDUSTRY STRATEGIES, PART 1 .
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. Environmental Research Foundation .
. P.O. Box 5036, Annapolis, MD 21403 .
. Fax (410) 263-8944; Internet: erf@rachel.clark.net .
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CHEMICAL INDUSTRY STRATEGIES--PART 1
In late 1993 the Governing Council of the American Public Health
Association (APHA) unanimously approved Policy Statement 9304
urging American industry to stop using the chemical chlorine.[1]
(See REHW #363.) APHA is a professional society, founded in 1872,
representing all disciplines and specialties in public health.
It is the heart of the American public health establishment.
Chlorine is a chemical element, one of the 92 fundamental
building blocks from which everything on earth is made. Chlorine
is very reactive --it aggressively grabs onto other elements to
form compounds. That is why, in nature, chlorine never appears in
a free state, but is always combined with other elements, usually
in common table salt (sodium chloride).
Around 1900, Herbert Dow, the founder of Dow Chemical, split
common salt to make commercially-valuable sodium hydroxide,
releasing, as an unwanted by-product, the highly-toxic green gas,
free chlorine. Mr. Dow (a chemistry teacher) soon began
combining chlorine with other elements, thus creating "chlorine
chemistry," giving rise to solvents, pesticides and all manner of
other useful, toxic chlorinated compounds, of which there now
about 15,000 in commercial use.
In Policy Statement 9304, one of the nation's premier scientific
and medical associations is asking American industry to change a
fundamental way of doing business. APHA recognized two
exceptions: the pharmaceutical industry and disinfection of
public water supplies. But all other uses of chlorine as an
industrial feedstock should be phased out, APHA urged.
In Statement 9304, the APHA explained its opposition to the use
of chlorine as an industrial feedstock:
** "...virtually all chlorinated organic [carbon-containing]
compounds that have been studied exhibit at least one of a wide
range of serious toxic effects such as endocrine dysfunction,
developmental impairment, birth defects, reproductive
dysfunction and infertility, immunosuppression, and cancer,
often at extremely low doses and... many chlorinated organic
compounds, such as methylene chloride and trichloroethylene, are
recognized as significant workplace hazards."
APHA spelled out its rationale for such a sweeping phase-out in
this long sentence:
** "Recognizing the subtle and widespread effects on human and
wildlife health attributed to exposure to chlorinated organic
chemicals and our current inability to identify, predict or
control the release of these compounds from manufacturing
processes, and that the bi-national [Canada and U.S.] Science
Advisory Board of the International Joint Commission on the
Great Lakes (IJC) concluded by the weight of scientific evidence
that exposure to all organochlorines should be presumed to pose
a health problem and that policies to protect public health
should be directed toward eventually achieving no exposure to
chlorinated organic chemicals as a class rather than continuing
to focus on a series of isolated, individual chemicals."
Thus the APHA said, in effect: we can't study all the many
possible toxic effects of 15,000 individual chlorinated
chemicals. Therefore, based on the weight of the evidence, we
should assume all chlorinated chemicals are dangerous and we
should avoid all exposures to them, to prevent harm.
Furthermore, the APHA said, because we cannot avoid releases (and
therefore exposures) whenever we make these compounds, the only
way to PREVENT exposures is to stop making chlorinated compounds:
"...the only feasible and prudent approach to eliminating the
release and discharge of chlorinated organic chemicals and
consequent exposure is to avoid the use of chlorine and its
compounds in manufacturing processes," the APHA said.
As a response to such calls for phasing out chlorine as an
industrial feedstock, the Chemical Manufacturers Association
formed the Chlorine Chemistry Council (CCC) in 1993.[2] The CCC
soon hired an aggressive DC-based public relations firm,
Mongoven, Biscoe and Duchin (MBD) [phone: (202) 429-1800], to
develop and carry out a strategic plan for defending chlorine.
MBD makes part of its living by spying on churches, labor unions,
environmentalists, professors and students, and selling
information about them to corporate clients, such as CCC. In
addition, MBD helps corporate clients develop strategies to
discredit people who are advocating change. In its own words,
MBD "assists corporations in resolving public policy issues being
driven by activist organizations and other members of the public
interest community. We help clients anticipate and respond to
movements for change in public policy which would affect their
interests adversely.... Forces for change often include activist
and public interest groups, churches, unions and/or academia....
MBD is committed to the concept that it is critical to know who
the current and potential participants are in the public policy
process, to understand their goals and modus operandi, and to
understand their relative importance. To this end, MBD maintains
extensive files on organizations and their leadership...." (See
REHW #361.)
Jack Mongoven, co-founder of MBD, has taken a keen personal
interest in the chlorine strategy, and has developed a
far-reaching plan to help the CCC discredit efforts to phase out
chlorine.
Like any good plan, Jack Mongoven's blueprint contains long-term
strategic goals, and day-to-day tactical elements.
Mongoven's long-term strategy is to characterize the "phase out
chlorine" position as "a rejection of accepted scientific
method," as a violation of the chlorine industry's Constitutional
right to "have the liberty to do what they choose," and in that
sense as a threat to fundamental American values.[3]
On a regular basis now, Jack Mongoven sends the CCC a formal
update on what anti-chlorine activists are doing, including
specific steps that CCC should take to undercut and discredit
them.
In a report to the CCC titled "Activists and Chlorine in August
[1994]," MBD notes that, "Anti-chlorine activists are using
children and their need for protection to compel stricter
regulation of toxic substances. This tactic is very effective
because children-based appeals touch the public's protective
nature for a vulnerable group and that makes it difficult to
refute appeals based on its needs. This tactic also is effective
in appealing to an additional segment of the public which has yet
to [be] activated in the debate, particularly parents."[4]
The MBD report includes a specific example of environmentalists
"using children." The report describes activities of the
Children's Environmental Health Network (CEHN): "The CEHN
approach, which is just taking shape, is illustrative of the
nature of the debate concerning children will take during the
next several months. [sic] The tone of the debate will focus on
the needs of children and insist that ALL safeguards be taken to
ensure their safety in development. For most substances, the
tolerances of babies and children, which includes fetal
development, are obviously much lower than in the general adult
population. Thus, 'environmental policies based on health
standards that address the special needs of children,' would
reduce all exposure standards to the lower possible levels." The
MBD report says that, although CEHN is not, itself, an
anti-chlorine group, "CEHN has adopted proposals by anti-chlorine
groups to secure a national health policy based on the needs of
children."
In sum, the MBD report says, "By characterizing children as the
biggest losers of [sic] toxic exposure, the activists have
secured an approach that will attract more mainstream support for
their anti-chemical, anti-chlorine agendas."
A 5-page cover memo signed by Jack Mongoven, dated September 7,
1994, summarizes the key points in the August report and lists
many specific steps that CCC should take to defend chlorine and
discredit the activists: "It is obvious that the battleground for
chlorine will be women's issues--reproductive health and
children--and organizations with important constituencies of
women opinion leaders should have priority," Mongoven writes.[5]
"It is especially important to begin a program directed to
pediatric groups throughout the country to counter activist
claims of chlorine-related health problems in children," Mongoven
writes.
MBD's August report listed a series of conferences for breast
cancer survivors scheduled by WEDO (Women's Environment &
Development Organization) in New York [phone: 212/759-7982]. The
report says, "Devra Lee Davis is expected to direct the Clinton
Administration's policy governing breast cancer and we expect her
to try to convert the breast cancer issue into a debate over the
use of chlorine. As a member of the administration, Davis has
unlimited access to the media while her position at the Health
and Human Services (HHS) [department] helps validate her 'junk
science.' Davis is scheduled to be a keynote speaker at each of
the upcoming WEDO breast cancer conferences."
In his cover memo, Jack Mongoven suggests that CCC deal with Dr.
Davis, the breast cancer survivors, and anti-chlorine sentiments
as follows:
** Schedule through KPR [Ketchum Public Relations, in
Washington, D.C.] editorial board meetings in Dayton prior to
Department of Health and Human Services Devra Lee Davis['s]
speech to a forum on breast cancer sponsored by Greenpeace and
WEDO to be held in Dayton....
** Enlist legitimate scientists in the Dayton area who would be
willing to ask pointed questions at the conference....
** Stimulate peer-reviewed articles for publication in the JAMA
[Journal of the American Medical Association] on the role of
chlorine chemistry in treating disease.....
** Convince through carefully crafted meetings of industry
representatives (in pharmaceuticals) with organizations devoted
to specific illnesses, e.g., arthritis, cystic fibrosis, etc.,
that the cure for their specific disease may well come through
chlorine chemistry and ask them to pass resolutions endorsing
chlorine chemistry and communicate those resolutions to medical
societies. If it is possible to identify potential prominent
allies in the organizations before the meetings that would be
preferred...."
Next week: Jack Mongoven designs strategies for the CCC to
counter and discredit what he says are the really serious
threats: the precautionary principle, and shifting the burden of
proof onto the chemical corporations.
--Peter Montague
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[1] "9304. Recognizing and Addressing the Environmental and
Occupational Health Problems Posed by Chlorinated Organic
Chemicals," AMERICAN JOURNAL OF PUBLIC HEALTH Vol. 84, No. 3
(March 1994), pgs. 514-515.
[2] The Chlorine Chemistry Council (CCC) is a "business council
of the Chemical Manufacturers Association (CMA)," founded in 1993
and located in Arlington, Virginia. CCC has no published
telephone number. CCC is part of CMA but has a separate budget,
according to Janet Flynn, a spokesperson for CCC whose phone is
(703) 741-5827.
[3] John O. Mongoven, "The Precautionary Principle," ECO-LOGIC
(March, 1995), pgs. 14-16. ECO-LOGIC is a publication the
Environmental Conservation Organization, in Hollow Rock,
Tennessee; phone: (901) 986-0099. Our thanks to Dan Barry of the
CLEAR project at the Environmental Working Group in DC [phone:
202-667-6982], and to Keith Ashdown, Cancer Prevention Coalition,
in Chicago [(312) 467-0600] and to John Stauber, editor of PR
WATCH in Madison, Wis. [(608) 233-3346] for information about ECO
and about MBD.
[4] "Activists and Chlorine in August [1994]," MBD ISSUE RESEARCH
AND ANALYSIS (Washington, D.C.: Mongoven, Biscoe, and Duchin
[phone: 202/429-1800]), 1994.
[5] Memo from Jack Mongoven to Clyde Greenert/Brad Lienhart
dated September 7, 1994, and titled, "MBD Activist Report for
August," (Washington, D.C.: Mongoven, Biscoe, and Duchin [phone:
202/429-1800]), 1994.
Descriptor terms: apha; american public health association;
chlorine; dow chemical; ijc; chemical manufacturers association;
chlorine chemistry council; mongoven, biscoe and duchin; jack
mongoven; children; children's environmental health network;
wedo; women's environment & development organization; devra lee
davis;
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