OVERVIEW OF TOXICS PROGRAMS

AT THE GLOBAL AND CONTINENTAL SCALES

Friday, September 24, 1999

One of a Series of Workshops Held in Conjunction

with the

International Joint Commission

1999 Great Lakes Water Quality Forum

Milwaukee, Wisconsin

Purpose: This session provides an overview of multinational programs and progress toward the control of persistent toxic substances at the North American and global levels. The speakers reflect a variety of perspectives on initiatives with important implications for the long-term success of Great Lakes programs.

OVERVIEW OF TOXICS PROGRAMS

AT THE

GLOBAL AND CONTINENTAL SCALES

LIGHTLY EDITED, VERBATIM TRANSCRIPT

[We apologize for any errors in this lightly edited, verbatim transcript.]

[Due to a recording glitch, Dr. Orris' introductory remarks and the first part of Dr. Hamilton's presentation were not recorded.]

************************************************************

*************************************************************

*************************************************************

Toxic Substances Programs at the Global Scale

John Buccini

I guess maybe I should be taller. I've been telling myself that for most of my life, but thank you for pointing it out in a new context.

If we could have the first overhead, I'd like to let you know where I'm going to take you in the next 20 minutes or so. I'm going to cover four topics with you. I always start out with the assumption that not everyone in the room really knows the background of the POPs issue, at least the global part. I'll then cover the mandate for the UNEP activity, which is the one that Peter just referred to, and I'll give you a status report that's really only about 11 days old, based on the third negotiating session. Then I'd like to take a few minutes and just try and bring what I see are the relevant aspects of the UNEP POPs process and the Great Lakes process. And I don't see one to the other, I see them as interconnected. One feeds into the other and back again.

Next slide. What is it about POPs that make them the problem that they are? Well, it's a particular blend of physical chemical characteristics. But basically, they are first and foremost organic compounds, so compounds containing carbon. They can be of either natural or anthropogenic origin, and they have this peculiar chemical property such that they resist degradation in the environment, combined with physical properties such as low-water and high-lipid solubility, such that they bio-accumulate in fatty tissues.

Again, they have another property which is referred to as semi-volatility. They have a very small but distinct volatility, just enough to get them up into the atmosphere. One of the slides that Andy Hamilton used about the so-called grasshopper effect or cold condensation effect ... they just have a particular combination of all of these properties.

But when you combine all of this low-water, high-lipid solubility, bio-accumulation, semi-volatility, they do end up in all media, so they're referred to as multimedia contaminants. The net results of all of this physical and chemical properties package is that they do tend to undergo local, regional and, at times, global distribution, and for extended periods of time. When you combine that with the fact they do have distinct toxic properties, we're looking at continuous or continued exposure of entire populations, in some cases globally, for extended periods of time which, in human terms, will span several generations. So that's why they are of concern.

This is not a new issue in many respects. I'd like to start with the Great Lakes Agreement, because I think it may in fact be the first one that really identified this. And I'm not sure of the date, but I think it goes back to '72, when they first got this Agreement going. Some people are nodding, so I do remember the date right.

Many of the other regional agreements that I pointed out here -- and I will not go into them -- time just doesn't permit it -- but it's to show you that they have been of concern in other regions of the globe. So we have the Oslo-Paris Convention, sometimes referred as OsPar Convention, which is designed to protect the northeast Atlantic Ocean. I point out that in many of these other agreements, POPs are not the only substances of concern, but they are of concern and have been included in each of them. The Helsinki Convention to protect the Baltic Sea. There is an international conference to protect the North Sea. The Barcelona Resolution, aimed at cooperation among Mediterranean countries to protect that sea. Next slide.

Over the last few years, the polar countries have been engaged in the Arctic Environmental Protection Strategy, looking at POPs and metals movement across the pole. I don't have to take more than five seconds but to mention the North American Agreement on Environmental Cooperation, and Andrew has just summarized what we have done there, but the fact that it deals with both POPs and metals -- Andy's mentioned the three POPs that have been worked on.

At the global level now, we have the UNEP GPA, global program of action for protection of the marine environment. In Washington in 1995, there was a commitment to developing national and regional programs to protect the marine environment from land-based sources of pollution. There is a specific mention of POPs in there, but there are mentions of metals and sewage and the whole range of contaminants.

As well, in 1995, countries, in agreeing to this program of action, actually committed that there was support in principle for developing a global convention on POPs. That was really the first time that we've had such a strong indication of a global commitment.

Within one of the five UN regions, and that's the UN Economic Commission for Europe -- and Canada and the United States are members of this particular organisation -- there is the Long Range Transboundary Air Pollution Convention, which has been in place for some time. It deals with a series of issues such as oxides of nitrogen and sulphur.

Effective June of 1998, the countries agreed on protocols, one on POPs and another on metals. A little bit of bragging, if I can do it for a minute, Canada was the first country to ratify these protocols; they did that on December 21st of last year. Unfortunately, they're still the only country which has so far ratified them, although I hear that there's probably about five or six countries which are now getting close to ratification, and hopefully that will happen in the next few to several months. It will take 16 countries to ratify before that protocol becomes operative.

Last but not least, the one I want to take a bit more time with you on now is the new UNEP POPs Convention, which has a target date for completion of 2001. The question mark just indicates you can never be sure.

First of all, to define the universe of POPs for the UNEP activities, these are the dirty dozen or the UNEP 12. I'll just read them out quickly: aldrin, dieldrin, endrin, DDT, heptachlor, chlordane, mirex, toxaphene, hexachlorobenzene or HCB, polychlorinated biphenyls or PCBs, and the chlorinated dioxins and furans.

I'd point out that the first eight or nine are all pesticides, but hexachlorobenzene also has seen industrial use as a feed stock and intermediate. Also, as a number of presenters as this morning's session have pointed out, hexachlorobenzene also comes in as a triple threat because it's also found as a by-product or a contaminant in industrial processes or in some industrial solvent manufacturing. Of course, the dioxins and furans are also in the by-products category, and PCBs are an industrial chemical.

So what got us started? In May of '95, the UNEP Governing Council, which is the policy body that makes the decisions for the United Nations Environment Program or UNEP, agreed that they wanted to have carried out an assessment of the chemistry, toxicology, environmental fate and transport, the socio-economics, the sources, the risks and benefits, and possible substitutes for the UNEP 12. This was a rather comprehensive assessment that was being asked for. They also looked to a newly formed group, the Intergovernmental Forum on Chemical Safety, the IFCS, to recommend any needed international actions back to the UNEP Governing Council and to the WHA -- which is not the World Hockey Association but the World Health Assembly -- which is the governing body for the World Health Organisation.

This was to be done by 1997, and the first meeting of the UNEP Governing Council was January. Given that this was May, there was less than 18 months to do all this. How it got done is a story in itself, but I won't have time for that today, so I'll jump quickly to the next slide, which has the conclusion of this activity.

The first conclusion, which was really a key one that allowed us to start moving forward, was we got agreement from stakeholders. When I say stakeholders, I'm talking about governments, intergovernmental organisations, international business and public interest groups and academic groups. All of them were involved in the decision making that led to this. The conclusion was that there was sufficient science to warrant immediate international action to protect health and the environment. If I could now move to the next one, which shows what the recommendations are that were built upon that conclusion.

The recommendations were that the immediate international action should be initiated through -- and this is a quote -- measures which will reduce and/or eliminate the emissions and discharges of the 12 and, where appropriate, eliminate production and subsequently the remaining use of those POPs that are intentionally produced. That's the policy statement that we've been asked to work towards. In the recommendations, it was always pointed out that different treatments for pesticides, industrial chemicals, and by-products was likely going to be needed and should be followed.

Also, to make provision for the number 13 and 14 POPs that may come up in the future, is that we needed a criteria and a process to identify new POPs, we should develop a global legally binding instrument, and the stakeholders that were involved in the process up to that point should continue to be involved.

Those were the recommendations. I can make this brief by saying all of the recommendations and the conclusions were accepted both by UNEP Governing Council and by the World Health Assembly.

The net result was that the second mandate, as I refer to it now, in February of '97, was that there should be developed a convention, preferably by the year 2000, and the work on this convention should start in early 1998. You'll notice, looking at this date of '97 to here there was a deferment of the start of the negotiations. This was not an indication of lack of interest. There was another convention on chemicals called the Rotterdam Convention on Prior Informed Consent on banned and severely restricted chemicals. That negotiation process was on-going and was expected to conclude by the spring or summer of 1998. What this really said is, we won't get on to negotiation of the POPs Convention until the Rotterdam Convention has been concluded. Governments were encouraged to take immediate action on the recommendations in the report. That's an important point. Governments do not have to wait until a convention is in place. They can and should be taking action right now, even while the negotiations are going on. I'll come back to that point later.

Lastly, UNEP as an organization was directed to take actions to support the countries' efforts in dealing with POPs. UNEP has been quite active in this regard, but I won't have time to go into that today, either.

So here's the road map, if you will, the road to a POPs Convention. We began in Montréal in the middle of 1998 at INC1, the Intergovernmental Negotiating Committee -- that's the acronym or abbreviation. The second meeting was in Nairobi ... (tape change) ... the site of the last INC, and this based on a grant of funds by the Danish government to make that possible. The Swedish government has offered to host the diplomatic conference, which is basically a signing ceremony, in the year 2001. On the assumption that something on the order of 50 countries are identified as being a minimum to ratify a convention, my expectation would be that it would take two to three years, so somewhere between 2003 and 2004, for this convention to come into play. This is where we are.

What I am going to do now is brief you on what came out of Geneva 11 days ago. First, I'd like to mention what the three key issues are that we have identified, and are dealing with and will continue to deal with. They are the controls on the initial 12 POPs and, really, that's all I'm going to speak to you about today. But there's also the development of criteria and a procedure for adding POPs and this has been done, at least in principle. We have a working draft of a procedure and criteria, although there are a couple numbers yet which haven't been decided upon. I won't go into that.

I just want to point out this part here, what we refer to as implementation aspects. Technical assistance, technology transfer, and financial assistance for the developing world are going to be key aspects. I actually believe it will be the deal-maker to get this convention agreed to. So it's a huge issue, but again I will not be able to discuss much of that with you today.

The fine print. What I'm going to give you is a summary of draft proposals -- underscoring the word draft -- and these are for the proposals on the controls on the 12, and they will be subjected to review by governments and discussed again at INC4. So these are not final, but these are what governments have agreed to consult on over the next few months. Next slide.

First of all, we were able to come up with statements of objective or a goal statement for the intentionally produced POPs, remembering that dioxins, furans and, to a degree hexachlorobenzenes, are the by-products issues. And the goal is to eliminate production and use, and this is the first time we've been able to get agreement on that as a declarative statement which is almost unqualified. And I say almost because the lack of agreement right now is on exactly what set of words will be used to attain this, but I think that the negotiators have clearly identified elimination of production and use of intentionally produced POPs as the objective of the convention. So that was, I think, a real good step forward.

I've tried to give you some specific information, for three of them, aldrin, endrin, and toxaphene. The current proposal would be that production and use would cease at the entry into force of the convention. So there has been no qualification on those three.

On the next five, chlordane, dieldrin, heptachlor, mirex, and hexachlorobenzene as either pesticide or industrial chemical, that the objective is to eliminate production, but the production may be permitted but limited to some critical uses. And governments are now being asked to identify what these critical uses may be.

And these uses, however, are going to be subject to review at specified dates. So they're not for ever and ever, grandfathering type of thing. If the convention comes in, say in 2004, I would expect within three years or four years, at some specified point, that there would be a mandatory review to see whether these uses are still viewed as critical or whether they may be moved from this category, if you will, up into this category, which is no more production and no more use. Next slide.

Now one of the really interesting issues is DDT. As you're all aware, DDT is used in some two dozen or so countries in anti-malaria programs. Well, the goal for DDT, however, has been agreed upon tentatively as elimination of production for all except public health uses, coupled with a review of the need for remaining uses to see when production may be completely halted.

So the tone or the direction is there, and it's the same as it is for the others. We would like to see DDT production eliminated; however, recognising the life-saving use of DDT in anti-malaria programs, we agreed to have those types of uses, and there's a couple of others, I think there's two or three other communicable diseases or vector-borne diseases that DDT is used for.

The important thing here is that it sets the end point, agrees to an exemption for now, but also builds in a review mechanism such that when and if we get to a point where countries can agree that we no longer need DDT for malaria control and the other disease vector control, so that we could say fine, now let's pull the plug entirely on that. This has been a very hotly debated issue, but I think we're finally seeing emerge a policy position which all sides of the issue seem comfortable with, at least at this stage in the discussion.

The other difficult one is on the next slide, which has to do with PCBs. That's no stranger, I'm sure, to anybody in the room, but PCBs are used in electrical equipment, transformers, condensers, certain other hydraulic uses. The goal has been agreed upon: elimination of production for all new uses but, having said that, recognising that these electrical pieces of equipment, some of which are designed for 40-year lifespans, may be around for a while. So there would be a permission for current uses in equipment. However, this would be combined with some statement with regard to phase-out of use. I think the language in there right now is as soon as possible -- that's about as far as we got in Geneva -- but others are talking about specifying a deadline for this type of phase-out. I think we have more work to do at INC4 to see just how far this can be taken. But the interesting thing was that there were one or two governments that still had retained the capacity to manufacture PCBs, and they seem now comfortable with a statement that says manufacture of new PCBs should cease. So we are moving forward. Next slide.

Now we enter dilemma land, the by-products issues. As I mentioned, three substances are included here: the dioxins, furans, and hexachlorobenzene. There was no clear agreement on a statement of a goal, recognising the nature of the issues that we're addressing. However, the kinds of language or the kinds of phrases that are being used are minimisation of releases or elimination of releases, and there's quite a deal of difference between minimising and eliminating in a legally binding instrument.

In discussing this, there was, in my view, somewhat limited support for an approach which would see targeted reductions against baseline year emission levels. You know, by coming into effect, you'd have to reduce by X per cent against the year 2000 national levels for release. The reason behind this is that, you know, if you want to spend your first billion dollars -- make it U.S. dollars to make it interesting -- if you want to spend your first billion on dioxin problems, would you spend that on trying to develop inventories to see just how bad the problem really is or would you be happier seeing that money spent on actually reducing the releases regardless of whatever the baselines actually are?

That's why I put it down that there is limited support for this, although some feel that it may be politically important to have something of this nature in the agreement. But again, this is still a discussion which is still in progress. The bottom line, and the reason I put it last here, is that I think there is right now agreement on reducing releases, national releases of dioxins and furans and HCB to the environment. Next slide.

So what are the measures that are being talked about in the convention? Well, governments are being asked to promote the use of strategies and measures, first of all, to reduce releases and/or eliminate sources by feasible and practical means. They're also being asked to look into taking strategies and measures, again, to prevent the formation and release; this is pollution prevention. They're also being asked to apply best available technologies, or BATs, for new and, in some cases, existing sources of releases of these materials to the environment. And they are being asked to develop national and regional or sub-regional action plans to deal with these materials. Now, I point out that one of the other provisions in the convention calls on countries to develop national action plans to implement the POPs convention, so this would be an element, if you will, a distinct element or sub-element within such action plans. Next slide.

Continuing on the by-products, what about these action plans? In the action plans, countries would be asked to evaluate their current and projected releases, and whether this is done through analytical work or whether it's done through modelling or predictive approaches is being left open at this point. The countries are also being asked to develop and maintain source inventories and release estimates.

After they've gone through some of these steps, to evaluate the adequacy of their laws and policies and then developing strategies to prevent and reduce releases based on the obligations of the convention which I've just covered with you and the evaluations which they would do here, having looked at their laws and their policies. Next slide.

As well, in the national action plans for by-products, governments are being asked to look into education, training, and the awareness of prevention and reduction strategies, and this is everything from the very technical audiences down to the general public. They are being asked to develop implementation schedules and to do those as a formal commitment under the convention, and then they're asked to monitor the progress of their strategies and to review their success every so many years, where X has yet to be specified in the convention negotiations. Next slide.

There's another aspect to POPs, which is the waste issue, and governments would be asked to develop strategies for identification of articles, products, and wastes that may be containing POPs. This is a huge issue in the developing world. We have, through the Food and Agriculture Organization, an inventory or at least an estimate of unwanted stocks of pesticides in Africa, and the numbers are huge. If you look at the economic consequences of trying to treat or destroy these wastes, it's a very large social and economic issue, and it does raise some current concerns on the technical feasibility or the technical aspects of doing it. So this is a huge issue.

Environmentally sound waste destruction for all of the materials, when they become waste, and as I pointed out here, you get into the dilemma. If you talk incineration or other methods, you may in fact bump up against the problem or the dilemma. Do you try to destroy X tonnes of POPs-containing pesticides or waste knowing you're going to be create Y kilograms of dioxins and furans? So that's a bit of a dilemma. The other part is if you don't do anything, you know you'll be continuing to release POPs to the environment. And once that's happened, the genie is out of the bottle and you really cannot manage them.

But the other thing is your disposal methods. Are they going to be such that you're not deferring or delaying the release of the POPs into the environment? Is landfill acceptable for certain types of POPs-containing waste, even if you have a properly maintained landfill? Some people will argue but you're merely burying it and deferring it for the next century, for it to become a problem.

So these are some of the aspects of the debate that we're engaged in. Last but not least, I've already alluded to this, the technical and financial assistance for the less developed countries is a huge issue for us to address.

Now we shift a little bit to a provision that hopefully we'll see a little bit of POPs birth control, if I can put it that way. For those countries that have programs that screen new industrial chemicals and new pesticides, the convention would indicate that those governments that have those programs should screen all of the industrial chemicals and pesticides that are proposed for use for persistence, for bio-accumulation, for toxicity, and for the potential for long-range transport. Of course, there's an inference there that if you do that, you should not be agreeing to introduce on a commercial scale industrial products or pesticides that have POPs properties.

That's the convention stuff. Now I'd like to try and make a connection back to what's probably closer to your hearts, which is Great Lakes aspects. First of all, I think that a lot of what's gone on in the Great Lakes over the past 27 years, that that experience really has to be shared. It has to be shared in a number of places.

Andy Hamilton talked about what we're doing under the North American Agreement on Environmental Cooperation, and we have made, through our series of meetings, public consultation meetings, formal contacts with the Binational Toxics Strategy management structure. We now have an interconnection between the players who handle your BNTS programs and the NACEC, remembering that two out of three of the governments are still the same, Canada and the U.S. The addition is getting Mexico engaged in this and then trying to see how we can build upon what's going on between Canada and the U.S. and extend it to include Mexico, so we have a truly continental approach to dealing with persistent toxic substances.

The Arctic. A lot of the programs ... well, Canada and the U.S. again are two of the circumpolar nations engaged in the Arctic programs, and they should be able to bring this POPs agenda and, for that matter, other aspects of the agenda, such as long-range transport of metals, mercury issues. And into UNEP, which is, again, I think, fairly close to my heart, certainly lately.

Why do I think that it would be useful? What does the Great Lakes have to do with the rest of the world? What's the connection? I think that you've got 27 years of history and you're going to know what worked and what didn't. I think it's sometimes even more valuable to know what hasn't worked, so people don't waste time and money and effort chasing ideas down blind alleys. Also, what has worked, and what I would argue, perhaps why it has worked, and that is what has characterised the Great Lakes program for the last few decades, has been, as imperfect as you individually may feel it has been carried out, but I think the fact that the engagement of stakeholders in the identification of issues and the identification of solutions and the implementation of solutions is an approach which has had only limited application in many parts of this world.

In my travels and in my work, I've talked to people from certain parts of the world, and certain governments would be absolutely abhorred at the prospect of inviting in public interest groups and other types of groups into their deliberations as they decide how to deal with an issue. I think trying to defuse that kind of angst by showing what the value of it is and how you actually extend your resources by including people outside of what many might see as the implementation gang of a certain government or industry. I think there's a lot of experience here and practice which would be of value.

Second point. What's been going on in the Great Lakes has been yielding fruit. I think what happens in the future is both at the global level, with UNEP, is going to be assisted by what continues to go on in the Great Lakes, but I also feel that you may find that if the international, that is, continental and global action, isn't taken, that you'll eventually hit a plateau, where you'll be unable to take the Great Lakes improvement further because of the foreign sources.

Certainly, in other parts of Canada, we're now putting effort into looking at what the foreign countries are that are in fact sources of deposition of POPs to Canada, and we're becoming more interested in that because we realise that once we have taken care of our own house, trying to target what are the major loading sources to Canada is going to be important if we want to continue decreasing the loadings to Canada.

Impacts of regional, global actions. A number of people have said it today, think globally, act locally. Act regionally is somewhere in between there. Trying to see how Canada, the U.S. and, I would argue, Mexico, since we now have that program going on, is a very valuable thing to do.

What we've been trying to do under the SMOC program, if I can change hats for a moment, is to see how the three countries could in fact be positioned to meet all of their future obligations under the UNEP POPs convention even before it is signed by doing NARAPs on the UNEP 12.

The last three would be dioxins, furans, and hexachlorobenzenes, and then we will have programs in place to be addressing all of the UNEP 12, at this point, four years ahead of when we see that convention coming into effect.

Next slide. For those of you who have an interest in POPs, I thought this web site here is the UNEP POPs web site. And if you're convention junkies or just want information on POPs, they have a very good web site, with lots of information on it. They also respond to questions and queries.

I want to make one last point, and that is that at the last meeting in Geneva, it was identified that over 90 countries have filed with UNEP statements of what actions they are taking on POPs. The convention will not come into place for four years and we already have a list of over 90 countries that are declaring what they're doing on POPs, and they will be doing more as the convention comes closer to coming into effect.

If anybody has a little bit of a worry about not really dealing with POPs until 2003 and 2004, my answer to that is that I think that we'll probably have in place before the negotiations are completed what is now a list of national and regional and global actions, but I think in fact that could be very easily reformulated and packaged as the global POPs action plan, even before the convention comes into place. I take great heart from that because it shows me that people are taking immediate actions, as the UNEP Governing Council has agreed they should be doing. The actions vary from country to country and region to region, depending on the nature of the problem, asking to deal with it, what their national priorities are, a whole range of features.

I, for one, feel that by the time we get this convention ratified, that we're probably going to find many of the parties are dealing with many of the issues or have dealt with many of the issues even before the ink is dry and the convention comes into place, which isn't to say there's whole a lot of work that still doesn't have to be done, but it's not like starting at ground zero, get the convention in place, and then figure out how to do it after that. So with that, I think I'll just conclude. Thank you for your time. I'd be glad to take any questions you might have.

Peter Orris

Thank you, Dr. Buccini. Are there questions? When you ask your question, please tell us who you are.

Jack Weinberg. Greenpeace

Even though I was there, it was very interesting to see your summary. Is it possible to get a copy of your slides?

I have one question. When you talk about waste and the destruction of waste, it sort of was unclear how you saw things moving on the whole issue of contaminated soils and sediments and other environmental reservoirs, which is clearly contentious, but I don't know if you include that in waste or were just not addressing that question quite yet.

John Buccini

I was not addressing that question, for a reason, the reason you're probably well aware of and would like me to bring out to others. There's two big issues here. One is, as I described it, the waste issue. Can you get your hands on it, can you put it in a barrel, can you take care of it? But I think as most of you are aware, there's a number of cases where we do have large contaminated sites, where we have soils, etc. which have been contaminated and, really, the negotiators haven't really gotten to this yet. In my capacity that I'm standing up here, which is speaking on behalf of a process, I think that it as much as I can say, because I really don't know where people are going to want to take that issue.

I do know if they try to move into addressing that issue, that the number of zeros they're going to be talking about in terms of technical assistance and financial assistance is going to go up significantly. I think that could, in fact, have an influencing factor on whether people choose to address that under the negotiations, remembering that you do not have to deal with everything in negotiating a convention. What you have to do is to get a critical mass that will allow a convention structure to come into effect and to operate.

The conference of the parties, which is the formal decision-making process of governments once they have signed onto a convention, will go on for years into the future. And if it's felt that that issue is too tricky or too difficult to deal with in the first negotiations, they may simply signal at the diplomatic conference that it is an issue that must be addressed by the conference of the parties.

If you want a convention to come into effect, you have to look at the sum total of all of the obligations in a convention. If a party is going to ratify a convention, let's say there's ten obligations, you have to indicate, certainly the Canadian policy approach is that the Department of Justice will not allow us to sign, to ratify a convention unless we have taken the legal measures to implement ten of those requirements. We have to be careful that we don't include so much in the convention that in fact, we're not going to get countries able to ratify it and get things going. It's a roundabout way of saying contaminated sites may be addressed in the negotiations, they may or may not be included within the convention, depending on what the negotiators choose to do. If it's not in when the convention as signed, it may still be identified as an issue to be dealt with in the longer term. I think those were the issues that you were trying to get me to speak to.

Mel Visser

You mentioned that some countries would be working on this before the ink was dry. Are there others that won't be working on it long after the ink is dry?

John Buccini

That is always the situation. If you look at the UN community, the numbers that I hear, the maximum is 180 parties or UN countries. 160 is probably the working ... We've started out with 93, moved up to 103, are now up to close to 115 countries participating in the negotiations. I think that's good news because it shows that more countries are finding out what's going on, are becoming part of the negotiations. There's always going to be some country ... and there's a variety of reasons for this. You take a look at some of the African nations which are in social turmoil, they're not going to be worrying about POPs. They're worrying about civil strife, tribal warfares, life and death, other issues.

The interesting thing to me is the broad range of support from countries from all five UN regions, and we haven't yet seen a north-south split. You know what I mean by that, developed-developing countries. And the negotiations themselves have been, in my view, carried out in a very respectful manner, very much listening to points of view and, the G-77 have a different point of view from the Western European countries, the developed world.

There will be countries who will not be a party to it. I don't know of a convention ... if you take a look at the Basel Convention, I think there's 90 parties to the Basel Convention out of 160 countries, and Basel's been around for close to ten years. That's the one on hazardous waste movements. On the other hand, the Montreal Protocol, I think it's pretty close to 150 parties. It depends on the convention. It depends on the capacity and interest of countries.

Unidentified

My question was about China specifically.

John Buccini

Yes, could I comment specifically on China? China has been present and very active in the negotiations. China is one of the three countries that continues to produce DDT. While I have not had it confirmed to me, we have heard that China may in fact have started up a new chlordane plant at about the time that the U.S. manufacturer voluntarily got out of the market. It may be a coincidence, it may in fact not even be true. But China is clearly negotiating actively. In my discussions with them, they seem to have an interest in this. Whether they actually will sign the convention after they go through the negotiations, I don't know. But they are there and they're active, and we've had the advantage of having continuous continuity of representation, that is the same individuals have come to all three meetings, which is usually a good sign.

************************************************************

*************************************************************

Adequacy of Toxics Management Programs at the Global Scale -- An Industry Perspective

Dr. Werner Braun

What I think is really kind of interesting is the coming together of many forces here. I had an interesting conversation with Peter Orris as we were trying to get organised for the meeting today, and I was talking about what I was going to be talking about, which is trying to find common ground, and a personal frustration of mine of how difficult often times that is. Peter made the comment to me, and I wrote it down so I'd remember it exactly, that we may need at times to start from our own individual positions before we come together. Next slide.

My job was made substantially easier by John and Andy because they have gone through in large measure the content of these various international fora, and so I'm going to be able to gloss over some of those. Some of them they didn't cover in maybe as much detail as warranted, but my focus frankly is going to be on something else. Next slide.

My focus today is going to be on what does the chemical industry support. So often times, you see us up here and in other forums arguing against things, and we're against this and we're against that. It's my sense that that is a contribution to creating polarized positions. What I'm here today to do is to try to go through a series of these various conventions that we've talked about and tell you the sorts of things that we can and do support in those various fora. I hope that is a start to an ongoing dialogue that could follow here to identify where there is common ground from the various stakeholders that are represented here. Next slide.

John has done such an excellent job in covering this that I think it would be totally redundant for me to go over that, so we can just go to the next slide.

Clearly, the ICCA position is that we support the elimination of production and use of products, of POPs products. As John indicated, there is certainly a lot of discussion about exemptions for some of those; clearly, some of those will be exempted for some period of time but, eventually, the elimination of those materials we support.

We certainly support the reduction in release of by-products, and maybe in the questions and answers, we can actually get into some of the things that we're doing proactively in that area. As John articulated in his presentation, there's a lot going on even in advance of the signing of this agreement that is going to push the peanut ahead.

We certainly support the focus of this convention, not only with respect to the 12 materials that are on the initial list, but also, as you can see down later, the addition in the process for adding additional new POPs as they should come along, numbers 13 and 14, as John referred to them, and probably more. We think there needs to be obligations, clearly spelled out obligations around by-products and POPs. We would even suggest that there ought to be measurable goals and targets so we can track ourselves in terms of how we're performing. We mentioned earlier that we support the process for selection of these new materials as they come along. As John indicated, I don't think we're very far apart. There are a couple of sticking points on numbers, but I think, all in all, we're getting pretty close to a process that will allow us to add new materials and also, if we use that same criteria, I might add, that would help us to make sure that we don't produce or enter into commerce materials that have those characteristics. Next slide.

Before I get into the particulars of NACEC, I would like to say that I think industry in general supports the NACEC process, not only as to sound management of chemicals, but the other programs they have going on. We think it is really an example of how the multi-stakeholder process can work, and we support the NACEC process in general. Let's turn to the next page and talk about the sound management of chemicals in particular, because that's really the focus here.

With respect to the NARAPs, industry has been involved in the development of the current NARAPs. We're looking forward to working on the development of the new NARAPs that Andy referred to in his presentation around dioxins and furans.

We also support, I think, the development of environmental monitoring and assessment because, as Mexico indicated, going about this in a compound-by-compound approach is a drain on countries that have developing economies or economies in transition. And this should allow us to focus in on materials which are really out there, which are really causing concern, so we can focus our resources in the best way that we possibly can.

Clearly, we think that the reviews on lindane and lead are appropriate, and we'll be involved in that process in supplying information and data, because obviously the industry holds a lot of that that can be used in that assessment.

Again, in this particular case, I think that the CEC has not gotten near the credit that they deserve in being pioneers in the development of criteria and process for identifying these sorts of materials. This is an excellent example of how we as a society can identify materials and really get after working on them and getting their levels in the environment down, and we support the criteria and the process developed here.

In addition to that, this is an example, certainly in the sound management of chemicals where CEC has provided processes by which the public can participate. We think again that's the only way these things can work, is if we get the public to participate in an open and transparent process, and we support the development of the public participation framework for all of the CEC processes. It certainly works here; I think it can work in the other programs as well.

One of the areas that I think from a purely industry perspective, but I think you all would share this view, the effort to harmonize regulations, to bring the high bar up to a standard level of care, to our perspective, is awfully, awfully important. From a business perspective, there is nothing more difficult than having regulations in one area that are dramatically different than they are in another.

In fact, in my previous life at the Dow Chemical Company, I had a business vice-president say to me that what he really wants is a level playing field, that he doesn't want to necessarily be advantaged or disadvantaged in one country or the other, he wants a level playing field that all of his competitors have to operate to. I think that is the direction that the CEC is going in. They want to harmonize, level the high bar at the high level, and we support that effort. Next slide.

We've heard a lot about the Binational Toxics Strategy. The only point that I didn't hear emphasized in the previous talks and, I think, bears some stressing here, the strategy sets reduction targets ... and I might say that they're stretch goals in many, many respects, but we think that's good. We think that we all need to be challenged, we need to stretch ourselves; if we don't, we're never going to improve, and certainly not at the rate that we're capable of doing. I know Mitch is a runner; if you don't stretch yourself when you run, you're relegated to running that 12-minute mile every time you run. So we need and we support stretch goals. Next slide.

With some detail, certainly with the Level 1 substances, we support the virtual elimination of PBT substances in the Great Lakes. And as I already indicated, we really like the concept of setting challenging and stretch goals that we have to work to achieve.

With respect to the Level 2 substances, the language in there has encouraged stakeholder actions to reduce environmental releases. We certainly support that and we work at that every single day. Hopefully we'll have a little time to get into this because I can share with you what the Chemical Manufacturers [Association] has done with respect to this to encourage its members to do exactly that under our policy to manage PBTs, but I'll hold that and hopefully someone will ask that question.

Again, in this particular process, the participation of stakeholders is awfully important and it's set up to do exactly that, to allow all of the stakeholders to get into the process and be part of getting these materials minimized in the Great Lakes basin and hopefully to reach all the challenge goals.

I have to say that we do like the focus on cost-effective. I think in this era of shrinking resources, it is incumbent on all of us to figure out where we can put our resources where we can have the greatest impact on the reduction of these materials in the Great Lakes and subsequently reduce risk and improve the quality of life of all of our citizens. So I think that's a very important aspect that we support in the Binational Toxics Strategy.

Clearly, the voluntary approach is important to us, we support it. Let me hasten to say that, as John Mills reminds me, it has to be part of a sound regulatory process as well. I don't mean to exclude regulatory, but certainly we support the voluntary nature of this. Next slide.

We haven't heard anything about the Cartagena Convention, but again it falls into the same sorts of things that John was talking about, about regional waters. Again here, we're looking at trying to protect the Caribbean, this particular region, from PBTs, and certainly we support that effort.

It has specific language in the convention which we find very useful. It talks about innovative approaches to control technologies and recognizing most appropriate technologies, which we certainly support in the control of PBT substances getting into the basin. Next slide.

The Barcelona Commission, John already alluded to, so I won't get into that. It certainly addresses the Mediterranean Sea. Again, the act locally comes out here. We support that. I think by our participation in what's going on in the Great Lakes, you certainly appreciate that that's true. And it's much easier to reduce these actions if they are in a localized area like the Mediterranean Sea, so we support regional, even subregional approaches to PBTs.

In the Helsinki Commission, the language in there ... and there are other parallels going on in these. I'm not trying to repeat every bit of language in each one of them, but I'm trying to highlight some of the things that are in these that we find especially supportable.

There's language in there that says, realize the ultimate goal of sustainable development in the Baltic Sea region. Clearly, we like the concept of sustainable development because it balances the need for a healthy environment, a healthy economy, and being able to maintain the social programs which are so important to quality of life. We really like that language and we support it in the HelCom.

More alphabet soup. The Oslo-Paris Commission. In there, the particular language that we support, that we like the way it's articulated, adopt programs and measures based on the best available technology and best environmental practices.

I can't remember all my alphabet soup. IPCS International Program on Chemical Safety. In this particular agreement, what we're looking at is the development of global inventory on what the ongoing research is on EDCs, endocrine-disrupting chemicals.

We also support the international assessment of the state of the science on endocrine disruption. Certainly, I mentioned earlier in one of my other interventions about our participation in the EDSTAC process, which is starting to do that here in United States, and I think that this will certainly allow us to identify where the potential science gaps are so that we can go and figure out, where we need to do research, target our money, to really be able to answer the outstanding questions that are out there.

I think earlier, Peter made a comment about the effects of low doses that might be masked or otherwise kept from being elucidated because of frank toxicity or other things going on. Clearly, that's an area that there could be some research to get at.

Harmonization of chemical hazard and risk assessment technology. Clearly, this is awfully important. We have a brand new program that we're developing right now, in fact, to look at how in North America we can take the technology which we take for granted and we use every single day, what we call standard operating technology or practices, and transfer that technology to Mexico.

I think we have an obligation, when we have technology that might help a developing country with its economy in transition, to make that technology available so that they can raise their standards of performance and do that in a way that comes ahead of any convention. And one of our pet things I couldn't leave out, supporting the reliance on sound science.

International Forum on Chemical Safety. In there, they talk about integrating, consolidating national and international efforts. Awfully, awfully important; we already talked about that. If these efforts are disjointed and we don't leverage from one to the other, we're going to be wasting a lot of time, a lot of energy and a lot of resources, so we really support that.

I can make these slides available to people. Next one. John already referred to this one, the Arctic monitoring and assessment program, I think Andy also mentioned this; this is awfully, awfully important because of the way these POPs and persistent bioaccumualtive toxics move and their characteristics. This is an area of research that we really need to elucidate. I know that the Inuit community is especially concerned about this, and clearly it's an area of research that we support because we need to figure out how to minimize that deposition in cold climates.

Let me do my Hillary Clinton speech here for a second. But she makes a good point, and I think it applies to this group. We can either look at this from a village perspective or we can look at it from our separate camp perspectives. If we choose to look at it as a village, we're going to focus on the things that we can support and that we can agree on. If we don't, we're going to be at loggerheads and we're going to be yelling across the fences at one another. So I would like to see what we can do to find ways that we can focus on the things that we agree on.

Again, this is my personal view that, if we were to focus on those things and dedicate our resources to working on those things that we agree on, we'll be a long time before we exhaust that list and we have to come back and start arguing about the things that we don't agree on. So that would be my plea to you.

And again, we progress faster when we pull together. Or another way of putting it, we can either hang together or hang separately. And partnerships certainly, I think as we have seen here in the Great Lakes, there are lots of examples of where partnerships have promoted progress and focus, so with that, I'll ... (tape change) ...

Unidentified

... just plain science?

Werner Braun

I can give you the one salient part of that that I think is probably the key thing. There's all kinds of things that are bandied about but, in my view, the thing that differentiates that is that it's peer-reviewed, that people who have more or less unbiased views of it have an opportunity to review it and say yes, this does meet the criteria for how science is done, and the results that this study purports to present are reasonable, given the methodologies that were used, not making judgements about whether this science is right or that science is right. Was the methodology that was used appropriate to support the conclusions that were reached?

Peter Orris

Let's move ahead to our final speaker of the afternoon, prior to a general discussion. We are indeed fortunate, being a rather parochial society, at least this side of the border, if you will, that the International Joint Commission decided that we should have some experience and information from Europe and the European experience and from someone with the training and skills and experience of Dr. Howard. Dr. Vyvyan Howard will be speaking to us from an academic and an NGO perspective on these questions. He was trained in medicine at Liverpool University. He then got a Ph.D. in developmental neurobiology from the University of Liverpool. He is trained in toxico-pathologic ... I can do this, I can even translate this into American. We're only separated by the same language; that's been said before. He's a toxico-pathologist specializing in fetal pathology, past president of the International Society of Stereology, and that one you're going to explain, though I did have it explained to me. So without further ado, Dr. Vyvyan Howard, and are these processes working from his perspective, sitting on the other side of the pond, if you will.

************************************************************

*************************************************************

Adequacy of Toxics Management Programs at the International Scale -- A European and Non-Governmental Perspective

Dr. Vyvyan Howard

Mr. Chairman, ladies and gentlemen, I'd like to thank the organizers for the invitation to come and address this conference. It's a great privilege for me. I've always read the reports of the IJC and I am a strong supporter of their stance on virtual elimination of many of the compounds that interest us all.

I want to acknowledge of help of my colleague, Dr. (Inaudible), in compiling some of this information, some of which is very hot off the press from the dioxin conference in Venice last week.

As a physician, I tend to look at things through the eyes of a patient. Really, what I want to do is to try and give you an overview of the position as I see it in Europe and on more global perspectives, with respect to some of these POPs and human health. So, can we progress?

Firstly, let's just remind ourselves that, in normal biochemistry, we can metabolize molecules very easily. They're like Lego bricks. We have enzymes for taking them into pieces and we have enzymes for sticking them back together again. Most of the tissues of the body, including things like bone, have a relatively high turnover.

So when things start to stick around and accumulate and persist, it tells us that we don't have the metabolism to actually cope with that and that, in fact, bio-accumulation is almost diagnostic of an anthropogenic man-made compound. Next slide.

Just to let you know where I come from, this is the Irish Sea. It's one of the more radioactive seas in the world. They even say you can cook the fish now by putting them in the heat until they go critical. That's due to a little plant up here called Sellafield. But I live down in this estuary here. This is Roncorn just here, which has got one of the earliest organo-chlorine industries. And this is the Mersea estuary, that's my house. Just remember this little place here called Wolmly (?) Island. Next slide.

This is a chromatogram of a dab, which is a fish caught off Wolmly Island in the Irish Sea. You can see there are a numbers of peaks here on this chromatogram for PCBs and down here for a number of organo-hlorine pesticides. In the next slide, this is a fish caught off near where I live, and many of these peaks are not identifiable or identified.

So we know -- this must be no news to many of you living around the Great Lakes -- that these compounds tend to accumulate and persist in biology. Next slide. And as we progress up the food chain, of course, they bioconcentrate.

What I want you to remember from this thing here is if you put a mammal here, firstly, during your development, the fetus is inside, and therefore is at the same sort of body burden conditions as the mother, but then after birth, you put the suckling infant one stage higher up the food chain because the mother bioconcentrates these compounds in breast milk, a further stage. Next slide.

This was from a paper by Liam at the Venice conference, Dioxin '99. It shows some of the latest contributions to total daily intakes of dioxin-like substances -- that's dioxins and furans -- and you can see the majority, as we all know, come from food, but that there are other contributions like air which are actually significant. And in Canada and Germany and the Netherlands, you see that they're fairly similar in westernized countries. Next slide.

Following on from his presentation in Venice, the general population is taking in about 2 to 3 picograms per kilogram of body weight per day currently in the western world. Close to municipal waste incinerators, they have measured this intake to be somewhat higher.

The suckling infant is about on average 100 times higher than the mother, and this can range from 50 times to over 200 times the daily intake that is recommended by WHO, which at is currently 1 to 4 picograms per kilogram of body weight per day. In Seveso, they reckon it was 10 to 100, so you can see that the fetus, that the suckling infant is in something of a (inaudible) state.

We don't know about the answer from Belgium yet, but I'm just going to go on and talk a little bit about one or two food crises that we've had in Europe recently. That's the graph on that one. This is just to show breast milk levels in picograms TEQ, that's parts per trillion, in milk fat, from a number of countries. You can see this is Pakistan here, this is Albania, but the more developed countries tend to have high levels. It's common knowledge, I guess, in this forum. Next slide.

If this is the absolute amount of the substances being taken in by a baby and by the mother who is giving breast milk to the baby on a body weight basis, this is absolute amount on a body weight basis; it's a graphical indication of why the baby is actually getting such a large slug at this time in life. This is work that was done by Gunila Lindstrom in Umia (?) University, and she measured the decrease in the mother's body burden of dioxin-like substances as she breast-fed over six months falls by about 15% per month. This is one of the best ways of actually detoxifying your own body, if you're a mother. She did it on several patients and, depending on which level they started at, then again, their body burdens fell over time. Next slide.

This is a rather busy slide. You probably can't see it much. Basically, it's just saying that depending on what sort of food you eat, the dosage you get of these POPs will vary. Fish, we know, and dairy products and meat are the main ways in which we get these compounds into our body. Next slide.

This was a recent event in Europe, a food scare that may topple the Belgian government. Well, it actually did. And this is a politically sensitive topic. Next slide.

This is the Belgian food crisis. It was caused by between 25 and 40 litres. Now for those of you who like sensible units, that's about, you know, a tankful of gas, 15 gallons. If it's probably an American car, they have quite large tanks.

This was a vault of PCB transformer oil which was tipped into a container of about 80 tonnes of recycled cooking oil from industrial kitchens. This again was mixed with 50 tonnes of recycled animal fat. That got into the animal food chain, it was fed in animal feed, and a total of between 1 and 1.05 grams of dioxins and furans, it's estimated, was introduced into the food chain. This has so far caused the equivalent of $3 billion U.S. worth of economic damage to food producers in the monitoring of this crisis. Next slide.

In poultry, 37,000 nanograms of PCBs per gram of animal fat in produce -- and this represents only 20% of the PCBs because that's all they measured -- were found. Also in poultry, 1,000 picograms, 1 nanogram TEQ of dioxins per gram of fat were found. The average total human body burden of dioxins is about 700 nanograms, and the World Health Organization TDI is currently between 1 and 4 picograms. And therefore, one gram of chicken fat from this particular source of contamination could cause a dose many thousand-fold over the tolerable daily intake.

The result of this for policy has been that new tolerances are being introduced into European food control. For milk, it's 100 nanograms of PCBs per gram of fat and 5 picograms TEQ for dioxins. For eggs, poultry, and pigs, it's 200 nanograms of PCBs and the dioxin limit is the same.

In animal feed, and I think this is a very important point, because up until now animal feed really has not been very much monitored for these sort of things, but because we get most of our dioxins through the animal side of the food chain, a limit is now being placed on the total amount, 20 picograms TEQ of dioxins per gram of fat in animal feed and 1,000 nanograms per gram of fat of PCBs. Now these levels were set for crisis management, and stricter regulations are being discussed within the EU.

Then there was the Brazilian citrus pulp problem. Citrus pulp is made into pellets which are fed to animals, and 60% of the 1.5 million tonnes produced globally come from Brazil. In 1997, in Germany, the watchful eye of the German system for monitoring these -- and I must say that in most European countries they don't monitor milk any more -- picked up the fact that there were high levels of dioxin. This was traced, in a rather interesting detective story, down to contaminated citrus pulp from Brazil. Eventually, this was found to be caused by the production of lime milk, which they use to lower the acidity of the citrus pulp before feeding it to animals, and that was lime coming from an organo-chlorine plant in Brazil. It caused enormous economic damage, but we don't know how much. 92,000 tonnes of the feed were blocked in Europe, and we're still, I think, trying to work out what to do with it, some of it.

Research in Brazil leads to the banning of the use of chlorinated compounds anywhere near the production of this product, and that includes some of the heating oils which were found to be chlorinated. Now it's led to another regulation in the EU, the maximum tolerance level of 500 picograms TEQ of dioxin per kilogram of citrus pulp.

So what we've seen here with these two crises is a change in the regulatory stance and the beginning of monitoring and the introduction of tolerance levels in food stuffs, particularly to do with the animal food chain, and I think that's a very important step forward.

Currently, let's just look at what current body burdens are. One per cent of the U.S. population have between 30 and 40 nanograms TEQ per kilogram body weight, according to Linda Birnbaum of the U.S. EPA. The average U.S. level is 10 nanograms of dioxin-like substances per kilogram body weight. Oxidative stress is found in experimental animals at 0.45 nanograms and, experimentally, rats at 100 nanograms TEQ per kilogram body weight, have been shown to have permanently changed allergic responses. Next slide.

If we relate that now, these are the current estimated daily intakes, these are the estimated body burdens, and this is a list, which I won't go into full detail for want of time, but basically, these levels are getting, for a proportion of the population anyway, to be such that we would expect changes in experimental animals and therefore possibly in the population. These effects include reduced sperm count, immuno-suppression, increased gonadal malformations, neuro-behavioural deficits, and endometriosis. Next slide.

With respect to infants, where we know that the time in the womb is one of the most critical times for the effect of the substances to actually, fetuses and infants have different sets of toxicological susceptibilities to adults. When you're fully formed, in general, you need a higher level of a toxic substance to produce an effect than you do just to interrupt a normal developmental process.

The Dutch have been doing some extremely valuable work. They've got a national breast milk monitoring program and they have been monitoring the level of dioxin-like substances in mothers' breast milk and then measuring effects in the offspring. There are no control groups, i.e. there are no unexposed groups, but they can put people into high and low level contamination groups.

Karen Lanting, in a recent Ph.D. thesis, has shown in the high dose groups a five-point loss of IQ, in the most highly exposed children compared to the lower exposed ones. As Chris de Rosa mentioned yesterday, lowered immunity has been demonstrated in a number of studies and, indeed, in the Amsterdam cohort, they've now shown that these children have a higher incidence of middle ear infections. This is maybe related to that. Hormone disruption, particularly of thyroid hormone, has been demonstrated.

In the background, although this has not been demonstrated, there is always this possibility of an increased cancer risk because IARC has now reclassified tetrachlorodibenzo-p-dioxin as a class I carcinogen. Next slide.

Are we estimating our exposure to dioxin-like substances adequately? This is another aspect of what I want to talk about. We have levels that are estimated, we have tolerable daily intakes, we have estimates of the daily intakes in populations. Are they realistic? The evidence suggests they may be not.

If we take hexachlorobenzene, this is the work of Van Bergelen which was just produced in Venice last week, hexachlorobenzene has an aro-hydrocarbon receptor activity, so it is a dioxin-like substance. Its toxic equivalence factor is 0.0001, so it's not very active. It's about a tenth of the activity of octachlorodioxin. However, the global production of HCB is equivalent to one tonne TEQ of dioxin in three years, according to her figures. And human breast milk levels in Germany are equivalent to 50 picograms TEQ per gram of fat, which is more than 50% of the total TEQ in breast milk. That means to say that we're underestimating the dioxin-like activity of breast milk in this particular case by up to 50%. In Canada, it could be as much as 10% of the total TEQ. This is just one example of a dioxin-like compound which has a very low activity, but is there in quite high dosage. And this is something which we should maybe start to include in our estimations. Next slide.

Another set of substances which have been talked about an awful lot in Europe now but I've not heard spoken about at all in this conference, are the brominated compounds. When PCBs, polychlorinated biphenyls were phased out, industry tended to start making brominated compounds. Now this is just an example of that. Next slide.

We have to ask if this is a case of déjà vu. They are persistent, they are bio-accumulative, and they have dioxin-like properties, many of them. The average concentrations of polybrominated diphenyl ethers, which are a flame retardant, has risen from 72 picograms per gram of lipid to 4,000 in the last 25 years, a 60-fold increase in this period. One congener, which is this tetra brominated compound, is predominant, and it constitutes about up to 70% of the total amount, and the concentration has doubled in the last five years in Sweden. They are semi-volatile, and chloracne has been reported from off-gassing from electrical equipment. It's been demonstrated that it binds specifically to the human thyroid receptor protein. This is a Swedish study. So, a number of studies which demonstrate neurobehavioural deficits with dioxin-like chlorinated compounds are also demonstrated with polybrominated compounds. So here's another set of compounds which are not taken into account in estimating the total TEQ in the body burden of humans which should be. There's a whole list of them which are not generally included.

It's estimated that we contain, the average person, between 300 and 500 appreciable chemical residues which would not have been around 50 years ago because nobody was making them. One problem is that toxicologists are not too bad at sorting out one chemical at a time, but when you ask them to start finding out what's going on in mixtures, they're not very good at it. It becomes extremely complex. Under these circumstances, one has to say that maybe precaution is a good idea. Many of the things we've been hearing about this afternoon actually add up to precaution. It seems that maybe people are not saying we have to wait around until there's absolute proof that some of the effects that we're looking at are happening before taking action.

So what are some of these effects? Next slide. Very briefly, some of the ones that haven't been aired too much so far in this conference -- accelerated child development is an interesting observation. The appearance of secondary sexual characteristics. In current medical textbooks, 1% of girls show signs of puberty before the age of 8, and the average age of puberty is 11 to 12. Currently, in the U.S.A., quite a big study has been done, it was published in Pediatrics by Herman Giddons, 1% of all girls have one or both signs, so that's either pubic hair or breast development, in America by the age of 3. And it showed that 27% of African Americans and 6.7% of white girls or Caucasian girls by the age of 7, and this went up to 48 and 14% respectively by the age of 8. No change in the age of menicke.

What's causing this, of course, is a very good question. Nobody really knows. Next slide. There's a certain amount of animal data which supports the fact that it might be due to environmental factors. A single dose of Arochlor PCB mixture in rats on the third day of life, they achieved sexual maturity at 28 days, whereas the control group were at 42 days. Next slide.

Recent data points to DDT and PCBs again being possible culprits. Walter Rogan, who is the acting clinical director of the U.S. National Institute of Environmental Health Sciences, gave preliminary data between '79 and '82. They measured PCBs and DDE in the blood and breast milk of really many, many women, and they have monitored the growth of 600 of these children. On average, girls with higher exposure entered puberty 11 months earlier than those in the lower dose exposure group.

So these are the sorts of things that we can say there are effects in human society. We can't actually say what's causing them, but they give cause for concern.

The testicular cancer incidence has been stressed before. In fact, Neil Scarcabek was talking in Oxford two weeks ago, 1% of Danish men will now develop testicular cancer. That's an astounding statistic. And he also said that 4% of all conceptions in Denmark now are receiving some sort of artificial medical assistance. That's one child in every class. Next slide. We know that this is predominantly affecting young men in the age 30 to 40. Next slide.

This is an important point, I think, to take home in that this was a study of the birth weight of Swedish fishermen's children, where they monitored how much fish the families ate. Those living on the east coast, where they consume more fish from the Baltic, than on the west coast, had a significantly reduced birth weight. If you look at those two distributions, they are not very different. In fact, you couldn't take one single member of that population and say whether they were normal or abnormal. The majority of them are within the normal range. But what we're seeing is a shift in a population, and that's the sort of statistics that we have to deal with. That means you need very large studies. When you take into account the mixtures that we're dealing with and the inherent variability of epidemiological data, it's very, very difficult to tie down specific effects to specific chemicals. In fact, I would say for most cases, it's impossible. Next slide.

My conclusion for this part of the talk is that human body burdens for dioxins are currently high enough in a proportion of mothers to cause measurable effects in their offspring. The major effects seem to be from a result of exposure in the womb. I do want to stress that.

I think we shouldn't discourage mothers from breastfeeding. The fact that there are actually committees sitting on this planet discussing whether women should or should not breastfeed or for how long they should breastfeed is a statement of where we're at. We should recognize that the fetus and the infant are the most susceptible members of society to this sort of pollution.

These are just a couple of slides to remind us of the global nature of this. These are PCB levels made in air around the planet, and the lower graph shows PCB levels measured in water, and they are ubiquitous, we know that, and there is long-range transport also in air.

These were measurements made in Sweden from transport from various different directions of air masses: from Europe, from England, which is pretty bad, and from the Arctic. Next slide.

So who's to blame? Well, to echo the previous speaker, we all are. It is us, it's the way we live. We can't blame industry for producing what we, the consumers, demand until the date of knowledge may be a potential risk, and thereafter I think we have to think again if there are actually corporate decisions made to try and obfuscate and block.

As far as I'm concerned, I think there's an awful lot of information and data, hard data on the table now. I don't think that by waiting an awful lot longer and doing massive other studies, of course, we want to do more research, but I feel that there is enough data on the table now for us to want to have action. Clearly, from what we've heard from the previous speakers, action is being taken.

In this point, actually, I think that the current Clinton administration activity with the tobacco industry is of some interest in that they seem to have actually concealed knowledge and obfuscated. Whereas I can imagine that we can do without the tobacco industry, I can't imagine that we can do without the chemical industry. It's part of our life and modern society.

Hopefully, in partnership, we are going to be able to move forward and tackle these problems. But the sense of urgency really depends on your viewpoint, and my feeling is we need fairly urgent action. And I think we'll stop there.

Peter Orris

Thank you, Dr. Howard. Do we have questions?

************************************************************

*************************************************************

Questions and Discussion

Mitch Sauerhoff. Toxicologist and human health risk assessor

I'd just like to point out a very interesting document that I read, put out by the National Research Council of the U.S. which focuses on potential human and environmental adverse health effects associated with hormonally active agents in the environment, and this document provides a great deal of perspective.

Dr. Howard covered a great deal of information pointing toward increases in adverse health effects, very serious ones including cancer. I was interested in your comments in testicular cancer increases that, I think you suggest, may have had an environmental origin at the same time, while many of these environmental agents, including PCBs and DDT and DDE, have shown substantial decreases in the environment over the last 30 years, increasing incidence and decreasing exposure. Thank you.

Vyvyan Howard

That's reminiscent of a graph that Stephen Safe showed yesterday, where he showed falling DDE and rising testicular cancer rates. There was a paper presented in Venice last week which showed that the lag time, the latency between the appearance of cancer with the introduction of, it's not a causal relationship, but it graphs the rise in the environment of the chemical and its fall and then the rise of cancer within the region of 30 years.

Of course, if fetal exposure is part of the picture, you would expect maybe that it would be, in the order of 30-35 years. See, I think these things have to be looked at over rather long time scales. Once again, I mean, causality is very, very difficult to prove. All one can do is to look at the animal data and human epidemiological data.

Mitch Sauerhoff

(inaudible) ... albeit at a very slow pace. I couldn't agree more with your comment with regard to latency. Did I understand you correctly, however, in stating that it was young men where the incidence seemed to be most profoundly increased?

Vyvyan Howard

That was the data that Scarcapek put forward in his original papers, yes.

Daniel Green. Montréal

To continue on this point, referring to the Science Advisory Board report of the IJC, they comment on this issue of dose, specifically for endocrine disrupting chemicals, and I think it's important in this debate to cite it. They talk about these types of chemicals and these types of effects; we're having an inverted U shape, dose responses. In other words, at low dosage, there seems to be more effect than at high dosage. And this goes back to the mechanism of when, at high dose is the feedback mechanism, the brain shuts down the response. So what we might be seeing is that as dosage of these chemicals decrease in the environment, it is very possible we'll be going away from the effects that we have seen -- teratogenic, embryotoxic -- to more endocrine disrupting effects as the concentrations go lower.

And maybe this is what we're seeing in young males exposed to lower doses than us older males have been exposed to, having endocrine-disrupting effects while we had maybe cancer and neurodevelopmental effects. In other words, the effect is still there, the dose has changed, but we're still having health effects. Other types of health effects, but health effects nonetheless from these chemicals.

I suggest that you would read, this was published recently in Toxicological Industrial Health. I think it's recent, volume 15, so it must have been maybe this summer.

Vyvyan Howard

I think you make a very, very profound point. I noticed yesterday, actually, that two of the graphs that were shown by the lady from Kingston who was looking at breast biopsies, cancer, two of them actually suggested an inverted U dose response curve, it was the lower dose one which was significantly different to the higher dose.

I think the other thing that I've learned from this conference, the fish feeding study that was reported yesterday and compared to the Jacobson study, where it's acknowledged that the doses that this cohort were being subjected to were likely to be considerably lower than the ones that Jacobson's were, but the outcome was the same.

Marti St. Claire. Sierra Club

A lot of times, I'll read over these different strategies and plans and try to write some kind of comments on them. One common feature is a lot of these strategies mention starting studies or continuing studies on, say, fetal cord blood or breast milk from various native peoples, say Inuit or other people in polar regions. I'm always sort of torn when I write my comments because I don't know if there's sufficient evidence in the literature that there is a community health emergency, which is what I would expect based on the amount of fish they ingest, in these communities that's either not known or not studied. I don't know if it's in the literature or I don't know if they keep studying because it's kind of a Tuskegee Institute type of thing, where they're going to keep studying people of color and watching their populations fade away so that the rest of us will find out when we're going to die. I would like you to give me a picture of what is actually in the literature. Do we know on a scientific, sound science basis that there is an ongoing health emergency in these circumpolar populations, or do we have to keep studying them?

Vyvyan Howard

They are certainly more highly exposed than we are. I've got some charts here with breastt-milk levels that the Inuits have of dioxin-like substances. I think we're all in the same boat. That's one of the things which puzzles me. It seems to me that some people maybe think that we're rather special and different to the rest of nature. We have the same sort of receptor molecules in our cells. I personally think there's quite a lot of information on the table now that shows that there are effects at current body burdens, and I think the body burden should become the index by which we regulate things, not the tolerable daily intake. Now if we do that, we will immediately be in regulatory problems because most westernized countries and certainly the Inuits would be well over any levels that we would care to set. Maybe afterwards I can show you the charts that I've got and I can point you to some literature.

Peter Orris

I would commend to the group this video that is going to be shown here concerning the health effects on several indigenous groups. Some of us saw it in Geneva and it's very powerful. Often a public health emergency is defined by where you sit and how far away you are from the effects, and this is a very, very powerful film.

Lyndon Carty. Environmental consultant, on behalf of the chemical industry

I just wanted to make a sort of technical point about this U-shaped dose response curve. As a toxicologist, I think there's a great deal of misunderstanding, that there seems to be a suggestion that a U-shaped dose response curve, when you're talking about two different end points. I think that when you switch from cancer to endocrine disruption, there is no such thing as data showing a U-shaped dose response curve because you have two different end points that you're talking about. I think that it isn't to diminish the possibility that there are two levels of effect and that you see the interaction of two standard dose-response curves, but there has been some allegations essentially that standard toxicology cannot deal with this issue. I think it's a misunderstanding of what standard toxicological principles are all about. I just want to point that out, that the fact that there are things that appear, that people call U-shaped, dose response curves aren't necessarily what toxicologists accept them to be. There happens to be a very good review by Dr. Ed Calabrese of the Massachusetts School of Public Health on this, and if you're interesting in reading about that, you should consult that, because he's reviewed the entire literature, toxicology literature, since the mid-1800s about this, and has some comments about showing this type of thing.

Peter Orris

I was referring to and I believe what Dr. Howard refers to, the issue with respect to endocrine disrupting chemicals relates to the fact that there is a chemical and then a receptor within the host, and the effect is modulated between that chemical and the receptor. Therefore, if you have an effect at a certain level with that chemical, it may be due to the amount of receptors available, and so that you may get an effect at one level which then may plateau and you will not see it as the dose of the chemical increases, because the receptors themselves are not there to modulate the effect. That was the reference that I was making. That certainly is a well-known toxicologic mechanism; it is not a mechanism that was stressed when I was taking my toxicology courses, though. It has become a mechanism that is more important, a great deal in recent years. Several of these effects that we're looking at now at low doses, especially effects on the fetus during fetal development, may reflect just such a mechanism. That's all I was trying to import. It is an area that needs increased research, as was stressed.

Jack Weinberg. Greenpeace

Just a very brief comment on this debate about the testicular cancer to point out that it is rising, and testicular cancer is not something that we ignored in the past, because I believe it's fatal if untreated, so that the numbers are hard rather than soft. And to what extent it's PCBs, to what extent it might be the polybrominated diethylethers. There's certainly a lot more chemical soup out there, both persistent stuff and short-term doses of less persistent things. I think the hypothesis that this is a chemical exposure is certainly a very serious one and, presumably, we don't make this merely a debating point but something that we are really looking to take action on. I think that just heightens the concern.

I wanted to mainly take up this challenge and respond to the point that Werner made about cooperating where we have areas of agreement. It's a tricky question. There are places where we have areas of agreement, like, chemical industry is often very vigorous in pushing for all-stakeholder participation in processes where they are excluded. It would be very helpful if, in countries where they are included and the public interest sector is excluded, that they would help us to get the public interest sector at the table. That's an area where agreement only appears to exist when it's comfortable. So that would be something that would be very positive. Certainly in many Asian countries, the chemical industry is welcome to the table, the public interest groups are not, and so that would be an area where we apparently have agreement.

On other questions, however, it seems if we limit our activities to areas where there is agreement, it seems those areas we should get ... (tape change) ... disagreement, and so the other question is, where we have real disagreements of substance and we still need to interact with each other, do you have any thoughts about how we may be able to do it in a more constructive way?

Werner Braun

I think those are three really good questions. Let me try to address them one at a time. I completely support the public sector's participation. As recently as two years ago, the Council of Great Lakes Industries participated, and was a sponsor of a multi-stakeholder workshop that defined the principles for public participation in those types of forums. Those principles were subsequently published as the Boulder Principles, and clearly we ascribe to those. I'm more than happy to make those available to you. Use them where you can to insinuate more involvement of the public sector, because we clearly support that.

Jack Weinberg

May I ask you a specific on that? for example, in Thailand, where Eurochlor is heavily involved in the process dealing with these issues, but the public interest sector has not been able to get into the process. Your colleagues, who we often work together in some fora, and we even cooperated in the Canberra meeting of the intergovernmental forum on chemical safety to come up with joint rules. Can we call upon your colleagues where they actually have influence to raise this with their counterparts in governments to share with them the value of public sector participation in countries where they don't have that experience? Giving me the literature is not as effective as actually having the people who already have those relationships convey the impression.

Werner Braun

Let me just comment on that and I'll get back to your other two questions in a moment. I think there's an opportunity to do that. The way we are enlightened in different parts of the globe is not always the same. I will have the opportunity to meet with a number of my colleagues from Europe next week; I'd be certainly happy to take up the issue, which I sincerely believe, which is what's fair for one party is fair for another in this area, and I'll be happy to carry the message. So that's all I can say in that regard.

With respect to areas where we agree, I have a slide here. These are from a document which we published not too long ago in which it articulates our commitment, the commitments we are willing to make on the PBTs. I think as you look at those, you'll see that we probably don't have disagreement on those. Maybe we could look at those and say, okay, how could we press ahead and press ahead more rapidly on those? I clearly believe that there are areas where we could make better progress and make progress quicker. I've forgotten what your third question was, though, in the interim.

Peter Orris

I think we all want to note, especially Dr. Buccini, that the CMA and Greenpeace will be going hand to hand to some of these countries, and this might be helpful for the treaty process as well.

Unidentified

Dr. Howard, you suggested that this country has begun to speak up on tobacco at least, but we haven't spoken out as clearly on some other issues where it would be useful to. It's always helpful to us to get a view from across the pond here and across the border, because our own information certainly is seen differently when you get somewhere else. Could I wheedle a few comments from you on things, other things that you would like to hear us talk more about here?

Vyvyan Howard

One of the main differences between Europe and America is that we have far less confidence in regulators than we used to. And I think in America, we get the impression that you still have great faith in what you're told about the safety of this, that, and the other. Of course, the genetically modified food debate has illustrated that very graphically.

We've been through a number of crises, including the BSE, the bovine spongiform encephalopathy crisis, and everyone's rather sensitised to it, and it's very clear that many of the things that we were told in the BSE crisis were complete rubbish. I think that has sort of led us to question things far more.

One of the things, I'd like to maybe turn the question around and widen it, is that I've given you two examples where relatively small amounts of these compounds have got into the food chain, and they really illustrate how very, very vulnerable we are as a species. I just wonder what the regulators and those who are forming policy think about what we have to do to maybe control -- 70% of PCBs are still here, most of them are still in use. What the hell are we going to do over the next few decades if all someone has to do is to tip a few gallons of this stuff into food just to get rid of it?

I think as a society, we're going to have to pay to make sure that they get more money by turning things in than by actually trying to get rid of toxic substances. Because if most of this stuff, say, gets out into the ocean or something like that, we're really in very, very big trouble, and it could be very serious indeed. I just wonder if this is something society as a whole has got to be prepared to have policies, which will cost money, to actually cope with this. We've had two very stark examples in the recent past of how vulnerable we are.

Werner Braun

Regarding Jack's other question, how can we get together on things we don't agree on? Clearly, I think we don't agree on dioxins and by-products, but clearly I think they are an example of how we can get together and where progress has been made and more progress can be made. I recall some of the data that was presented earlier showed the decrease of dioxins in the last 25 years in various substrates in the Great Lakes, and it shows a 200-fold reduction in dioxins. I'm put in mind of the dioxin inventory estimates released by the United States Environmental Protection Agency that as early as '87, there were 12,000 grams of dioxins released, and the estimate in '95 was approximately 2.7 grams, with an estimate that it could be as low as 1.1 if we do nothing different beyond the regulations that are in place.

I think as we're being challenged in the Binational Toxics Strategy, I think we can and are going beyond regulations that are already in place to drive that number down faster. I think we can agree that we want to do that regardless of what each of our ultimate visions are on where that ultimate goal is. That's how I would answer Jack.

Mel Visser

Great to hear the progress, and I was glad to hear today that progress in the Great Lakes might be at a plateau if something isn't done with the global emissions. We hear in terms of what's coming into the Great Lakes and what's transferring on to the Arctic, what small amounts of chemicals we're really dealing with. The question I have is, is it bigger than a breadbox? The amount of chemicals, the produced pesticides and the PCBs that are manufactured outside of North America and Europe, where they're banned, what is the size, what is the magnitude of that problem? Is it like, what have we produced in DDT, over 100 million pounds per year? Are the quantities that have been produced since we have banned them, are they the same size of breadbox? Are they increasing? Are they decreasing?

John Buccini

I think that the good news would be that they are decreasing, but it depends on the compound you're talking about as well. China, India and, to a degree, Mexico still have a production capacity which they're using for DDT. The last number I heard was something like 10,000 tonnes last year of DDT were produced. That's probably much less than 20-25-30 years ago, when DDT was more widely used both for agriculture as well as public health. Now DDT is illegal for agricultural uses in virtually every country, although the fact that it is made for public health use makes it available for people to use illegally on agriculture. We know that that practice is going on, which is why we feel that you have to address the production. Halts. Eliminate the production is the only way to deal with it.

During the development of the UNECE POPs protocol, at the final meeting only did Russia admit that they not only had production capacity, they had continued to produce PCBs for their high energy distribution system, their power system. But the negotiations had gone on in one way or another for five or six years, and it wasn't until negotiators from other countries couldn't understand why Russia wanted a certain formulation in language that they had to admit that they actually needed to produce it. Russia has a system that is still, up until a year ago, being charged with new PCBs, and it's doubly bad: it's an inefficient power distribution system and it's a system that's leaky, so they had to keep topping up their transformers. It's about the worst situation you could ask for.

So in some cases, we're not talking about a dinosaur chemical. With PCBs, there are few countries in the world that have managed to get themselves virtually PCB-free, but you have Canada and the U.S. which have huge inventories still waiting, in use, and some in storage awaiting disposal. The issues that I alluded to about what is adequate environmental disposal, the incineration and dioxin dilemma. I think that Dr. Howard's slide that showed it was, if I remember correctly, $3 billion in damages done by 40 litres of PCBs, something like that ...

Vyvyan Howard

And counting.

John Buccini

Yes, and counting, the dollars are counting. Canada may have something like 10,000 kilos of PCBs still in use in its inventory -- and I think it's less than that, but just take that number -- what would be the economic cost of trying to deal with those PCBs if we don't come to a proper, environmentally sound phase-out approach that takes them out of use and limits the damage? Dr. Howard said it's going to cost money. It's going to cost Canada, the U.S., and all of the other countries money. But I think it's a question of pay now a fixed amount, or never know what the true limitations are going to be if you choose not to act on it.

There was a PCB fire in Binghampton, New York and dioxins and furans throughout the building. It cost millions of dollars to deal with that. Every time there's an accident, you're into six zeros, and yet we still get the arguments that the cost of destruction, the cost of disposal are prohibitive. We can't get there from here. I think people, society, is going to have to face up to that and say, okay, we do it now, and maybe it takes five years or ten years, but when it's done, it's done. Then we'll deal with the other aspects of the problem.

We've done it for ozone-depleting chemicals, if you cast your minds back to 1987. How can we possibly get there from here? All of our car air conditioners, all of our chillers in the supermarkets were CFC charged. The fact of the matter is we just spent billions of dollars world-wide, but we're now in a society where, certainly in the developed countries and many of the developing countries, we're CFC-free, or we have CFCs in use but they're being managed and phased out of use. You can't solve it magically. You have to face up to it and face the economics.

If I could add one other point. An earlier question dealt with the impacts, do we have a health emergency, I think was the expression in sensitive populations. One aspect of the high exposure, particularly to indigenous peoples, particularly in the north, is the health issue, but don't forget the social issue. Once you start getting people away from their traditional foods, because they start migrating from that, the experience up north has been that you get the northern people into what they call southern foods, they have epidemic outbreaks of diabetes, a disease which I believe was virtually non-existent in the northern populations. So you get into social practices and other social impacts which are separate from purely health impacts. Keep in mind both the social and the economic and the health, because all three of them have to be taken for each case that you're examining.

Daniel Green

All this is fine and well but, in reality, we are seeing decisions being made in Canada on these chemicals that are so contradictory to what you have just said, John, that it boggles the mind.

Recently, the Canadian and Québec governments have accepted that a plant, a magnesium extraction plant by Noranda, using a chlorine technology, will be generating on a yearly basis a mind-boggling amount of these chemicals. Rumors, rumors, engineering calculations based on the pilot plant, talk about between 20 to 400 grams of dioxins and furans yearly production, 1,000 kilograms of hexachlorobenzene, 10 kilograms of decachlorobiphenyls. This is production in a process using chlorine that will be on line by the year 2000. At this time next year, Magnolia, Noranda's plant in Asbestos, Québec, will be generating these chemicals, and yet all the king's horses and all the king's men don't seem to be able to stop Noranda of doing it again.

As an environmentalist and as a Canadian taxpayer and as a breather of air and drinker of water and eater of food, how can I accept that my government lets this happen and does nothing, when we hear the science, what it's telling us, and it smacks completely opposite to the precautionary principle, to anything we know. Yet the government is doing this because Asbestos, Québec, the asbestos mine is going to -- by the way, it's called Asbestos, Québec -- in Canada, we name towns after known human carcinogens. At any rate the issue is, there's a contradiction here, and I have difficulty with this as an environmentalist and of course as a person that knows what these chemicals can do. What is frustrating to me is that you hear the talk but you don't see the walk. So what I am supposed to believe?

What is happening now is that the people, and I guess in the two countries, are becoming completely, almost despondent as far as the regulators are concerned. If the regulators cannot regulate this, what in the hell can they regulate? And who exactly controls the agenda? Is it the corporations still? Is it because Noranda is going to offer 2,000 jobs? Is that's what's happening? Is this why Environment Canada and Environnement Québec are not doing anything about this?

They're talking about total capture of these chemicals. Total capture. I mean, they're going to surround the plant with a bubble? We know that a chemical plant of this magnitude we'll never capture all of it. They're talking about sending it to the Swan Hills hazardous waste incinerator, which itself has contaminated parts of Alberta because of bad PCB and other chemical management. You're talking about think globally and act locally, this is a global session, why can't Canada act locally on this issue?

Vyvyan Howard

I feel that the stance of the IJC, which is that these compounds can't be controlled by measured release, is the right stance. We've proven that. Every single person on this planet is carrying these products in their bodies or by-products. The aim of virtual elimination must be the right one, in my opinion. I think it is urgent. If 50 years ago, you'd said to people, well, we can give you all these aspects of a higher standard of living, but there's a downside, and the downside is we're going to actually give everybody a body burden of toxic substances, most people would have said no, thank you, we won't have any of it. We're at that point now, and I think it is a disaster. Obviously things are happening to try and turn that around, but the sort of thing that you're talking about is going in the wrong direction. I would agree with you entirely. We need to be looking to eliminate these substances from the planet.

Unidentified

Perhaps I might throw a challenge to the panel as well on a subject that hasn't come up today. I spend significant amounts of my time seeing workers who are injured in the workplace or made sick by the workplace, in consulting with their unions. One of the things that we know in that setting is the importance of finding methods and means for workers to stay employed, because unemployment is a serious threat to people's health. I'd like to know, within the INC process globally and within the process here in the hemisphere, what is the thinking and concern about what has been called just transition from some of this toxic production?

Peter Orris

That was out of the frying pan and into the fire, if you will.

John Buccini

I'm really glad we left the easy questions to the end. There's an international justice or social justice or however one wishes to phrase it. It extends not only to jobs, but also to entire populations. Let me address it on two or three aspects.

One is the international social justice thing. When they used DDT in Mexico, and we know that DDT released in Mexico will eventually migrate through the U.S., up into Canada and up into the north where it goes into the deep freeze, in my view, it will probably never be truly be released, it'll be there for centuries. When Mexico took the decision to phase down by 80% one or two years ago, two years ago now, and Andy and I were in the room when this decision was taken. We had this wonderful gentleman, Dr. Rodriguez Dominguez, who was the head of the sanitation programs in Mexico. He spoke to us for 15 minutes about all the r