Document kmV7gOkMbaeYrpbRj5vg9GV2O

CHM SVSTMS August 9, 1991 Mr. Roy T. Gottesman Executive Director The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 Chem Systems Inc 303 South Broadway Tarrytown NY 10591-5487 Telephone: (914) 631-2828 Telex: 221844 Facsimile: (914) 631-8851 Dear Roy: Enclosed is a copy of the analysis of global PVC environmental/health/safety challenges that I discussed with you. Thanks for your help in preparing this. If you have any comments, I would of course appreciate hearing them. / Ronald F. Cascone Senior Consultant RFCiglr Enclosure CTL007632 D:4697 F:HRB7705C.PD IV. ENVIRONMENTAL ASSESSMENT A. Summary B. Issues and Background C. The United States D. Western Europe E. Japan IV- 1 CTL007633 CHM SVST6MS :4697 F:HRB7705C.PD IV.A. SUMMARY CTL007634 CHM SVST6MS IV. Environmental Assessment Summary Resin sales for packaging is at risk from environmental, health, and safety challenges PVC will be more vulnerable than polyolefins to deselection caused by plastics recycling issues especially in automotive industries Architectural, plumbing, electrical, and other durable applications are not expected to be reduced Levels of threats are somewhat different among the United States, Western Europe and Japan; the issues are essentially related to political and social differences Each individual issue appears to be largely under control through strenuous industry efforts in both the United States, Western Europe and Japan Most responses to threats are cooperative, not competitive, through industry associations 0:4697 F:HRB7705C.PD IV- 3 CTL007635 CHM SVST6MS IV.B. ISSUES AND BACKGROUND 1697 F;HRB7705C.PO CH6M ^SSVSTT(6MS CTL007636 -4 IV. Environmental Assessment Generic issues raised about PVC Manufacture Use Waste " Recycling Issues Involve health and safety as well as environmental concerns CTL007637 0:4697 F.HRB7705C.PD IV - 5 CHM SVST6MS IV. Environmental Assessment Manufacturing issues Raw material depletion Petroleum Natural gas Fossil energy use, resulting in C02 and other pollutant release Emissions Petroleum production, refining, transportation Petrochemicals - ethylene, VCM, plasticizers Chlor-alkali - mercury, chlorinated by-products Affect of toxics in communities, global warming, ozone depletion Worker safety - exposure to petrochemicals, VCM These Issues are not unique to PVC; judgements are largely false, but difficult to change 1697 F:HRB7705C.PD CHM SVST6MS CTL007638 6 IV. Environmental Assessment In-use issues Additives Plasticizers - migration into foods and other products Stabilizers - contamination from cadmium, lead, and other heavy metals Dyes and pigments - contamination from heavy metals, and other toxic materials Residual VCM in products - migration to food, water, etc. Performance in fire Flame retardance Smoke toxicity (HCI, dioxins) Most of these Issues have motivated technical developments and standards D:4G97 F:HRB7705C.PD IV- 7 CTL007639 CHM SVST6MS IV. Environmental Assessment Waste issues: concerns/misconceptions Quantities Plastics, especially PVC packaging, perceived to take up large volumes in collection and landfills PVC seen as non-recyclable Landfill disposition Non-degradability Leaching of additives (heavy metals, etc.) Incineration HCI contribution to acid rain Dioxin - issue over uniqueness of generation versus other chlorine sources in waste incineration, fossil fuel combustion HCI attack of incinerator elements Most of these concerns are invalid or arguable, but sensitive to the public 4697 F:HRB7705C.PD CTL007640 CH6M SVST6MS -0 IV. Environmental Assessment Recycling issues Feasibility of collection, separation Uses of recycled PVC Additives required Degradation during processing is greater than with polyolefins, etc. Incompatibility of PVC in mixed resin uses Much progress made In recycling, but possible self-imposed Industry or legislated goals may exclude PVC from some packaging applications 0:4697 F:HRB7705C.PD IV- 9 CTL007641 CHM SVST6MS IV. Environmental Assessment Background on heavy metals issues Heavy metals have been a concern for decades Not acutely toxic, but bioaccumulative Linked to liver, kidney damage; some cancers Cadmium is much more toxic than lead Barium is similar to lead, but less common; tin even less Concern relatively light in Western Europe because Not acutely toxic; less newsworthy than deadlier toxins Emissions are complex and obscure, not easily understood by laymen Other concerns are more related to common activities such as eating and solid waste generation, thus of greater public interest i:4697 F:HRB7705C.PD CH6M SVST6MS CTL007642 - 10 IV. Environmental Assessment Background on heavy metals issues (continued) Types of exposure: Inhalation during processing - solved by precompounding and low-dust material Leaching from incinerator flash - avoided by special landfills and pre-extraction Incinerator flue gas emissions - controlled with precipitator and scrubbers Leaching into groundwater from landfills - solved by collecting and treatment of leachate Leaching lead from PVC pipe to water - limits met by manufacturers - less than from soldered copper pipe (lead stabilizers are not used in the U.S. for pipe applications, but are used in Western Europe and Japan) Applications of heavy metals will nonetheless be banned - technical solutions are required D:4697 F:HRB7705C.PD IV- 11 CTL007643 CH6M SVST6MS IV. Environmental Assessment Background on plasticizers issues Plasticizers are used in all flexible PVC Dioctyl phthalate (DOP) - 50 percent of all in Western Europe, dioctyl adipate (DOA) - 40 percent Regulations focus on these two Based on National Cancer Research Institute (USA) findings in 1980, the International Agency for Research into Cancer (I ARC) classified DOP "probable human carcinogen"; DOA was only "suspect" They are not considered acute toxins in any case These plasticizers have been studied further by the European Pharmacopoeia, Germany, UK, Switzerland, and the United States - today DOP is absolved as a carcinogen Much misinformation has recently surfaced in the UK over hazards of plasticizers used in cling film Concerns are for: Ingestion of migrated plasticizer from packaging of fatty foods Evaporation of plasticizer from floor tiles, wall coverings, and auto interiors Migration of plasticizer to blood or medicines from medical devices Political bans on plasticizers unlikely, but exposure minimization initiatives are likely 4697 F:HRB7705C.PD CTL007644 CH6M SVST6MS -12 IV. Environmental Assessment Background on issues over VCM ingestion VCM has been a concern for 20 years Recognized carcinogen with no toxicological threshold Typical ambient exposures not acutely toxic Much media attention has been given to worker exposure Ingestion concerns are: a. Ingestion of residual VCM which has migrated to food from packaging b. Ingestion of residual VCM which has migrated into drinking water from PVC pipe c. Groundwater contamination by leaching from discards in municipal landfills a and b are regulated in United States and Europe; limits are 10 times lower in United States; it is not expected that the European Community will reconcile with United States because different detection methods are used Groundwater contamination issue has been raised in United States, but not in Europe and Japan; no regulations yet 0:4697 F:HRB7705C.PD Groundwater contamination concern will spread to Europe, but no regulations are expected in either region IV- 13 CTL007645 CHM SVST6MS IV. Environmental Assessment Background on hazardous combustion emissions issues Accidental fires or waste incinerations can generate hydrochloric acid (HCI) and "dioxins" (sometimes characterized as 2,3,7,8-trichlorobenzodioxin - TCDD) Incineration HCI and dioxins "Dioxins" are actually a group comprising about 200 compounds in categories of: Polychlorodibenzo-para-dioxins Polychlorinated dibenzofurans HCI can potentially contribute to "acid rain" - most acute in Northeastern United States, Scandinavia, and Germany; sulfur dioxide and nitrogen oxides are regulated European Community regulations now cover HCI from waste incinerations; PVC accounts for less than half of the emission; no direct regulation expected Dioxin release incidents in Seveso, Italy and "Agent Orange" controversy in the United States have captured press attention - very sensitive issue WHO considers TCDD occupational-exposure hazardous; risks in ambient exposures are being widely debated 1:4697 F:HRB7705C.PD CTL007646 - 14 CH6M SVST6MS IV. Environmental Assessment Background on hazardous combustion emissions issues (continued) There are two types of dioxin exposure concerns: Inhalation of airborne dioxins Ingestion in food (fish and milk) Dioxins in incinerator flue gas and flash could be from: Combustion of PVC, other chlorinated hydrocarbons and inorganic chlorides (such as salt with food) Dioxins are present in waste feeds that pass through incineration Production from precursors such as PCBs, pentachlorophenols, and chlorinated aromatics Two solutions have been proposed: Reduce chlorine in feed, including from PVC Run incinerators so that dioxins are not formed or are destroyed Dioxins will be controlled in Europe by a combination of better incineration designs and some attempts to reduce chlorine In feed by reducing disposable PVC products D:4697 F:HRB7705C.PD IV- 15 CTL007647 CH6M SVST6MS IV. Environmental Assessment Background on hazardous combustion emissions issues (continued) Smoke Toxicity Environmental and safety have been concerns since the 1970s with U.S. building codes adopting combustion-toxicity provisions The principle is that PVC should be no more toxic when burned than wood Two methods have been used to determine this: University of Pittsburgh Test - shows PVC more toxic U.S. Bureau of Standards Test - shows PVC less toxic (also differ on ranking fabrics, paints, and other plastics) Most authorities see statistical error at fault and accept PVC as a standard material (exceptions NYC subway system due to lobbying by metal conduit interests) Some German municipalities also banned PVC wire and cable (and some floor tiles) during the late 1980s, but some have rescinded CTL007648 :4697 F:HRB7705C.PD - 16 CH6M SVST6MS IV. Environmental Assessment Background on issues over limited waste disposal capacity Complex local issues of national proportions involving land use, litter, sustainable development, and trade-offs of landfill with incineration and source reduction efforts Affects PVC on: Content laws - requiring new products to contain certain levels of recycled materials Mandatory use of biodegradable materials or components Ability to separate PVC wastes from other plastics Ability to reuse PVC recycled resin D:4697 F:HRB7705C.PD IV- 17 CTL007 649 CH6M SVST6MS IV.C. THE UNITED STATES 1697 F:HRB7705C.PD CTL007650 CH6M SVST6MS - 18 IV. Environmental Assessment The United States - overview Political structure and environmental initiatives are key Some differences exist state to state Lobbying by competing trade associations and labor unions have created strong challenges Plumbers, electrical, other construction American Institute of Architects Aluminum, steel, glass and paper interests PET (and some polyolefins) marketers There have been few specific bans, but much delay and conflict Most responses have been coopera ;ve and non-competitive through: Vinyl Institute (sponsoring Vinyl Package Lifecycle Assessment by Chem Systems) Society of Plastics Industry Chlorine Institute Some individual companies are leacers in technical support and education OxyChem, BFGoodrich, Geon ia Gulf, Vista, Klockner-Pentaplast, etc. Packaging and VCM/PVC manufacturing are most challenged today, but durable ' may be more at risk in future D:4687 F:HRB7705C.PD IV - 19 CTL007651 CHM SVST6MS IV. Environmental Assessment The United States - Primary industry responses to issues Education Technical research and lobbying Health and safety effects of vinyl chloride monomer FDA activity related to use of PVC packaging and other regulated materials: Liquor and other bottles Meat wrap and other food-related films Water pipe Film coatings, gaskets, medical applications, etc. Fire performance and combustion toxicity of PVC i Alleged problems caused by heavy metal permeation and leaching through and from PVC pipe PVC solid waste management Recycling Alleged problems of landfill leachate contamination Lead has been taken by the Vinyl Institute with strong support by BFGoodrich and OxyChem; others are cooperative 1:4697 F:HRB7705C.PD CTL007652 20 CHM SVST6MS IV. Environmental Assessment The United States - environmental, health, and safety effects of VCM: responses and results Plant and equipment modifications installed VCM monitoring and alarms Stripping columns Incinerators for vents and other normal discharges EPA estimated $766 million (1977 dollars) spent between 1977-1986 on such modifications EPA later estimated total air pollution control for VCM/PVC plants was $1.2 billion between 19811990 Costs increased an average of 1.35 cents per pound (1972 to 1987) solely for environmental compliance This led to increase in the average reactor size, and a drop in the number of producers of VCM from 23 in 1976 to 12 in 1987 EPA's VCM Emission Standard requires reports for relief valve discharges, manual venting and reactor dumping within 10 days - this has led to 17 settlements of fines for $4.3 million total since 1982 CHM SVST6MS DM697 F:HRB7705C.PD IV- 21 IV. Environmental Assessment The United States - FDA regulation of PVC in packaging: responses and results FDA has been struggling with the EPA and environmentalists since mid-1986 on creating regulations for PVC films, rigid containers, food processing plant water pipe, and other PVC components in food contact FDA rule on PVC in food use started in 1975 In 1986 FDA proposed: 5 ppb RVCM limit for plasticized films and coatings 10 ppb RVCM limit for rigid and semirigid food containers 50 ppb RVCM limit for water pipes in food processing plants 50 ppb RVCM for vinyl/vinylidene chloride copolymer films and coatings Recognized prior status of PVC resins in films, coatings, water pipe, flexible tubing, gaskets, bottle and jar liners and rigid sheet Issues have been raised by the EPA and environmentalists to delay approvals due to potential environmental impacts HCI from incineration of PVC Recycling compliance Potential solid waste impacts Delay has allowed PET to penetrate nearly all liquor bottle markets to exclude PVC; otherwise, there will be little effect on markets after approval CH6M_SVSTMS 0:4697 F:HRB7705C.PD IV- 22 CTL007654 IV. Environmental Assessment The United States - Fine performance and combustion toxicity: U.S. responses and results PVC comprises 40 percent of all plastics used in U.S. construction Metal pipe and other interests have lobbied against PVC since the mid-1970s During the late 1970s, Vinyl Institute funded research at Southwest Research Institute (San Antonio) - shows that HCI generated from fire is absorbed rapidly by other materials, and rarely exceeds 300 ppm 0:4697 F:HRB7705C.PD No major impact on market seen or expected IV-23 CTL007655 CHM SVST6MS IV. Environmental Assessment The United States - concerns over permeation or leaching from PVC pipe: responses and results Plumbers' unions and others attack PVC pipe for possible solvent permeation from contaminated ground to water supplies, and leaching of solvents to water from pipe cements Unions fear loss of work with easier-to-install PVC systems and competition from do-it-yourselfers Vinyl Institute sponsored research by Battelle Columbus Labs - shows equivalent permeation for cement and iron pipe Vinyl Institute hired CH2M Hill consultants for risk assessment on California - sponsored leaching tests - concluded PVC pipe : safe Permeation of PVC is a "ve; long" process - as shown by studies in Holland and University of California o Concerns have stopped the use of PVC for water distribution in many cities (Chicago, New York City) and California o Concerns over lead solder and worker safety inhaling soldering vapors (Federal ban in 1989) will help PVC pipe sales :4697 F:HRB7705C.PD CH6M SVST6MS CTL007656 24 IV. Environmental Assessment The United States - Management of PVC in solid waste responses and results A disproportionate effort is focused on PVC Legislative bans have been proposed in New York, Minnesota, and elsewhere The Center for Plastics Packaging Recycling at Rutgers University (New Jersey) is financially supported by Vinyl Institute for PVC recycling research The Vinyl Institute/NYSERDA (Albany, NY) - ran tests on dioxin generation with and without PVC present - shows PVC to be a minor or negligible factor in incinerator dioxin generation; dioxins can be controlled with incinerator scrubbing, etc. PVC bans are not expected to have significant market impacts D:4697 F:HRB7705C.PD IV - 25 CTL007 657 CH6M SVST6MS IV. Environmental Assessment The United States - education emphasis: the "PVC Story" as told by the Vinyl Institute Chlorine may be dangerous, but in PVC it is intrinsically bound (a safe "resting place") Combustion does not release free chlorine, but hydrogen chloride (stomach acid) VCM and PVC plastics are already subject to drastic emissions and safety controls PVC products are essentially monomer free Cadmium, lead, and other heavy metals in stabilizers are gradually being substituted - use is restricted to durables (window frames, electrical insulation, etc.) Plasticizers are low volatility liquids - only minute migration occurs when in contact with oily or alcoholic products PVC is approved by toxicologists, and used with pharmaceuticals and medical devices U.S. EPA is reconsidering TCDD (dioxin) risk issues, questioning the use of animal tests to gauge human health risks PVC recycling is feasible, economic, and desirable A similar conclusion was drawn by a private study by Beilona, a Norwegian radical environmental group, leaked to press CH6M SVST6MS 0:4697 F:HRB7705C.PD V - 26 CTL007658 IV. Environmental Assessment The United States - educational literature emphasis of U.S. companies Plastics/PVC play relatively minor role in solid waste; most landfill do not biodegrade materials PVC components (liners, pipe, etc.) are useful and preferred in "building" proper landfills Controls are needed on incinerators, in which case emissions from PVC are not a problem There are benefits in using plastics/PVC - otherwise solid waste volume would increase if plastics are disallowed Recyclability of plastics/PVC Commingled resin durables and PVC durables (pipe) are proven uses Much experience already exists w'.th industrial/commercial/consumer recycling PVC can now be automatically (electronically) identified during the sorting process PVC is based primarily on salt and natural gas, not petroleum, in the United States (more petroleum for ethylene is used in Europe) PVC in food packaging has lowest contribution to taste and odor among all the plastics uVinyl-it's recyclable, dear, proven, versatile, taste free and economical" DM697 F;HRB7705C.PD IV-27 CTL007659 CH6M SVST6MS IV. Environmental Assessment The United States - salient U.S. company involvements in technical responses to challenges BFGoodrich OxyChem Georgia Gulf Vista Fire R&D for low-smoke additives R&D for low-smoke additives Food Contact / / / Recycling V V 1:4697 F:HRB7705C.PD V - 28 CTL007660 CH6M SVST6MS IV.D WESTERN EUROPE D:4697 F:HRB7705C.PD IV-29 CTL007661 CHM SVST6MS IV. Environmental Assessment Western Europe - overview Western Europe is highly individual, by country, as to views on PVC There are many socioeconomic, political, as well as technical differences as compared to the United States "Green politics," rather than commercial/industrial lobbying, has more effect International competition versus an EC "restraint-of-trade" issue is a growing factor Some deselection and packaging bans are in place Greater garbage incineration is typical Ethylene is made primarily from naphtha/gas oil, not NGLs Alternate source of soda ash (as caustic substitute for some uses) is from the Solvay process (more polluting) not trona Leaded gasoline is still used in Europe Responses to challenges has been primarily by producers Norsk Hydro Atochem EVC Hoechst Solvay :4697 RHRB7705C.PD - 30 CTL007662 CHM SVST6MS IV. Environmental Assessment Western Europe overview (continued) Some cooperative responses are starting AGPR Group in Germany European Council of Vinyl Manufacturers - patterned on U.S. - Vinyl Institute Association of Plastics Manufacturers in Europe (APME) - formed Plastics Waste Management Institute for Europe (PWMI), and is sponsoring an ecobalance for Europe 0:4697 F;HRB7705C.PD IV-31 CTL007663 CH6M SVST6MS IV. Environmental Assessment Western Europe - primary PVC environmental, health, and safety issues Ingestion/inhalation of heavy metals Ingestion/inhalation of plasticizers Ingestion/inhalation of free VCM Emissions of hazardous products formed in combustion of PVC - HCI and dioxins Limited public waste disposal capacity Unfavorable ecobalances (total energy and emissions in manufacture, use, and disposal) versus competing materials 1:4697 F:HRB7705C.PD CT^007664 32 CHM SVST6MS IV. Environmental Assessment Western Europe - forecast of direct regulations of PVC use, 1990-2000 Restriction Ban on "short-life" (disposable) applications Voluntary phase-out of PVC in grocery stores (80 percent) . Ban on PVC in beverage bottles Country Denmark Netherlands Switzerland Implementation Period 1991-1993 1991-1993 1991 Reason Dioxin emissions from incinerators Dioxin emissions from incinerators Dioxin emissions from incinerators 0:4697 F:HR077O5C.PD IV- 33 CTL007 665 CHM SYSTEMS IV. Environmental Assessment Western Europe - forecast of indirect regulations concerning PVC, 19902000 Restriction Ban cadmium in PVC Ban lead to maximum technical feasibility Maximum 15 percent plasticizer in fattyfood packaging Jurisdiction All Western Europe All Western Europe Implementation Period 1991-1993 1995-on Reason Toxicity Long-term toxicity All Western Europe 1997-2000 Suspected health risks 1:4697 F:HRB7705C.PD CTL007666 CHM SVST6MS 34 IV. Environmental Assessment Western Europe - highlights of the Norwegian Bellona Study A boycott of PVC would: Lower the price of chlorine, further encouraging manufacture of chlorinated solvents and propellants Lead to problems the disposal of excess chlorine coproduct from caustic manufacture Increase consumption of more environmentally harmful steel, cement, aluminum, and paper, or their composites Increase the emissions of "greenhouse gases" and toxins to manufacture the substitutes Lower the quality of drinking water supplies and beverages Increase the energy required for the transportation of raw materials, finished goods, and packaging D:4697 F:HRB7705C.PD The study concludes that PVC Is a desirable choice IV- 35 cTL007667 CHM SVST6MS IV. Environmental Assessment Western Europe - heavy metals regulatory profile Regulations focus on cadmium - banned in Sweden since 1987, with some exemptions; in Denmark since 1987 (except in profiles and panels) Draft bans on all cadmium uses in EC commission, Netherlands and Austria Lead being investigated, a ban is likely by 1997, with exemptions for wire and cable, and window profiles Barium being investigated in Sweden and Austria CTL007668 1:4697 F:HRB7705C.PD - 36 CH6M SVST6MS IV. Environmental Assessment Western Europe - plasticizer regulatory profile Present legal limits: Country Product Limits Application Belgium Germany Italy Netherlands Switzerland DOP DOP, DOA DOP DOP DOP, DOA Migration - 40 mg/kg 22% content 5% content Migration - 6 mg/kg Ban Food packaging Meat wrap Fatty-food packaging Food packaging Toys for children under 3 years old EC studying directive for food-contact plastics U.S, FDA following studies by independent EC advisor - Scientific Committee for Food - report expected in two to three years 0:4697 F:HRB7705C.PD EC directive on limits, but no bans are expected IV-37 CTL007669 CHM SVST6MS IV. Environmental Assessment Western Europe - free VCM (RVCM) regulatory profile Present legal limits on RVCM: Polymer <10 ppm Belgium Germany UK Packaging <1 ppm Belgium Germany EC Austria France Italy Netherlands Migration <0.01 ppm Belgium Germany EC France (<0.05 ppm) Italy Netherlands UK Sweden Migration - actually "no detection" required - limits 0.01 ppm; method in United States allows 0.001 ppm detection, which sets the limit there No harmonization of U.S. and European standards expected In the next decade 5:4697 F:HRB7705C.PD - 38 CTL007670 CHM SVST6MS IV. Environmental Assessment Western Europe - hazardous combustion regulatory profile HCI in acid rain Two EC directives - limit HCI in new incinerators (of >3 tonnes/hr) to 50 mg/SCM Not a direct control; PVC will not be banned on this issue Dioxin emissions regulations activities are essentially in countries that incinerate >30 percent of municipal waste: Denmark - 50 percent reduction of PVC in short-life uses over 1991-1993 Germany - PVC bans proposed because of dioxin; rejected Netherlands - Green Party proposed ban; rejected; a major grocery chain is phasing out PVC Sweden - Moratorium on new incinerators; lifted; O.lng/SCM TCDD limits on new/old units instead; continued push to eliminate short-life PVC uses Switzerland - Ban on PVC bottles November 1, 1991 Austria - ban on short-term PVC uses withdrawn to allow coordination with EC 0:4697 F:HRB7705C.PD IV - 39 CTL007671 CHM SVST6MS IV. Environmental Assessment Western Europe - solid waste regulatory profile Denmark - Voluntary Agreement (by year 2000) 85 percent reduction of PVC in incinerated packaging 77 percent PVC recycled for durables (pipe, profile, flooring, etc.) Switzerland - November 1991 ban on PVC beverage containers "PVC Bottle Recycling CH" formed (Atochem, EVC, Solvay, and French Mineraliers) in response EC - DG XI Packaging Waste Directive - December 4, 1991 (first draft) Objectives: to stop growth in per capita packaging waste Waste management targets: 60 percent recycling 30 percent energy conversion (incineration) 10 percent landfill The Marks & Spenser Department Store (UK) recently selected PVC over PET and OPS as an "environmentally friendly" packaging standard CHM SVST6MS :4697 F:HRB7705C.PD 40 CTL007672 0:4697 F:HRB7705C.PD IV. E JAPAN IV-41 CTL007673 CHM SYST6MS IV. Environmental Assessment Japan - overview There has been no radical environmentalist group nor anti-PVC industry lobbying in Japan who are sufficiently strong to influence politicians to initiate regulation on the PVC based on scientifically ambiguous information So far PVC producers have responded to the issues effectively and succeeded in avoiding unreasonable regulations, based on cooperative work through various associations Impact on PVC demand will come not from regulatory ban but from voluntary deselection in markets related to management of plastics solid wastes However, since the issues are emotional and global, the impact will be inevitable if strong movement against PVC should capture the U.S. and/or Western European consumers 1:4697 F:HRB7705C.PD CTL007674 CHM SVST6MS 42 IV. Environmental Assessment Japan - primary PVC environmental, health and safety issues The issues of environmental, health and safety for PVC began overseas and then were introduced into Japan, which include: Ingestion/inhalation of heavy metals Ingestion/inhalation of plasticizers Ingestion/inhalation of free VCM Emission of hazardous products formed in combustion of PVC - HCI and dioxins Municipal and industrial plastic wastes recycling 0:4697 F:HRB7705C.PD . IV-43 CTL007675 CHGM SVST6MS IV. Environmental Assessment Japan - heavy metal issues Notification No. 20 by the Ministry of Public Welfare - maximum 100 ppm of lead and cadmium in PVC packaging Japan Hygienic PVC Association set proactive self-control (PL standard), e.gM no use of lead and cadmium for food wrapping film i One package stabilizer system in granule from is a trend to avoid lead inhalation Lead stabilizer is used in pipe but with anti-leaching aids No major impact on market is seen or expected 1:4097 F:HRB7705C.PD CTL007676 CH6M SVST6MS - 44 IV. Environmental Assessment Japan - plasticizers issues The issue of "DOP being probable human carcinogen" promoted DNP/DINP to replace DOP but caused little negative impact on PVC usage Currently no regulatory argument on plasticizer 0:4697 F:HRB7705C.PD IV - 45 CTL007 677 CHM SVST6MS IV. Environmental Assessment Japan - VCM exposure and residual VCM The issues of VCM worker exposure has been solved based on introduction of closed system Most PVC food bottles were replaced by other plastics bottles when the residual VCM issue was raised 10-15 years ago Currently, the level of residual VCM which can be achieved is less than 1 ppm for pipe. No significant impact on the PVC market is expected even after new EPA standards take effect in 1993 1:4697 F:HRB7705C.PD CTL007678 CHM SVST6MS -46 IV. Environmental Assessment Japan - hazardous combustion emissions issues All incinerators are equiped with exhaust gas treatments and no HCI emissions from incinerators are expected Dioxins emissions from incinerators are being controlled according to the operating procedures directed by the Ministry of Public Welfare Scientifically there is no need to regulate PVC due to hazardous emissions. However, since it is related to municipal solid waste management, misinformation could cause source reduction and/or deselection of PVC from packaging The issue of HCI generated from fire will not have significant impact on PVC demand even if it is regulated, since PVC house siding is not permitted for use by the Fire Defense Board 0:4697 F:HRB7705C.PD IV- 47 CTL007 679 CHM SVST6MS IV. Environmental Assessment Japan - management of PVC in municipal solid wastes PVC is only 1 percent of total municipal solid wastes. However, to most housewives, the name "vinyl" means all plastics - which accounts for 10 percent of the total municipal solid waste Although over 70 percent of municipal solid waste is incinerated, recycling will be practiced in the future In the case of plastics recycling to reclaimed pellets and .liquid fuel, PVC must be separated from the feed due to its chlorine content PVC ban for packaging use in various Western European countries may have some influence on Japanese consumers toward reduction of PVC packaging As a whole, PVC is vulnerable to being targeted as a "bad actor" in municipal solid wastes and reduction or deselection of PVC could be a voluntary activity in packaging markets, although no bans are expected D:4697 F:HRB7705C.PD CTL007680 CH6M SVST6MS IV. Environmental Assessment Japan - management of pvc in industrial solid wastes About 40 percent of agricultural film is being recycled to floor tiles and sandals Automotive industry is now seriously planning recycling of plastics. In such a program, PVC will become less preferable and at risk of .eing replaced by polyolefins, which can be recycled more easily Recycling issues will not have an imp- A on PVC demand in other industrial applications 0:4697 F:HRB7705C.PD IV- 49 CTL007681 CH6M SYSTEMS IV. Environmental Assessment Japan - producers response to threats PVC producers have been very cooperative and effective in responding to threats through the Japanese PVC Association (established in 1953), Japan Hygienic PVC Association (1967) and Plastic Waste Management Institute (1967) Japan PVC Association is responsible for public education to respond to environmental challenge through press releases and educational literature Japan Hygienic PVC Association has been successfully managing health and safety challenge based on proactive self-control (PL standard) Plastic Waste Management Institute comprising various plastics industries is responsible for plastic recycling and technology development :4697 F:HRB7705C.PD CTL007682 CH6M SVST6MS -50