BELLONA COMMENT ON PVC
BELLONA PVC LETTER TO DANISH POLITICIANS
Because of political concerns on the use of PVC and PVC-additives and the
call for a ban on PVC use of certain politicians in Sweden and Denmark,
a Norwegian environmental group, has written a letter to political
Although we don't agree on several points, we give you here the original
translated text of the letter. Where we don't agree is the phase out of
phtalates, because these are abundant in nature, see our Chlorine
and hormonal changes pages. Also in the case of the use of lead as
a stabiliser in PVC. We don't think that is an environmental or health
problem. See our PVC and additives
pages. And even for short-living PVC, the costs of neutralising HCl in
municipal waste incinerators are much lower than the higher prices, consumers
will have to pay for the alternatives. HCl is not an environmental problem
at all, compared with the 300-600 million tonnes of HCl, annualy released
by the sea ...
THE BELLONA LETTER
Oslo, March 18, 1996.
To Danmarks Sosialdemokratiske Parti
Proposal about ban on PVC
Re. proposal no. B 92 1995-96, 1. assembly.
A lot of ingredients which are used in PVC as plasticisers or stabilisers
are documented to be toxic and/or 'hormone repeating' (synthetic oestrogens).
These materials ought to be phased out as soon as possible.
Environmental problems from other plastics are very little investigated,
because of focus on PVC. Danish Technology Institute has commisioned from
the Environmental Agency in Denmark a series of scanning litterature studies
of other plastics. These studies indicate a lot of problems linked to other
plastics generally and illustrates the need for deeper comparative studies.
We will point at the need for studiing additives used in alternative
plastics to PVC, like brominated fire retardants used in so called halogen
free cable (which could emit brominated dioxins) and uranium, which is
used as catalyst in ABS-plastic.
A general problem for all plastics is addition of heavy metals in form
of pigments. European industry still uses environmental suspect pigments
containing cadmium, chromium, copper and lead.
These heavy metals create environmental problems by disposure, both
by use as stabiliser or pigment in the plastic.
Concerning outphasing of the polymeric material PVC we agree that this
should be done for short lived products (< 1 year), because this will
have a positive effect on the reduction of HCl in the waste disposal furnaces.
A wider outphasing must be seen in relation to the chlorine/alcali balance,
otherwise there will be a risk for increased global environmental problems
linked to chlorinated solvents and pesticides. 2/3 of chlorine produces
in Sweden is used in PVC. This is a stable and environmental safe way of
treating chlorine, compared to the alternatives (CFC, chlorinated solvents&pesticides).
Chlorine has to be handled because the consumption of alcali increases
and will increase due to activities in the Al- and paperindustry. By technological
improvements as removal of toxic ingredients and establishment of recycling,
PVC can with advantage be used in longlasting products (pipes etc.). We
refer to our fact sheet, which shows in more detail our views.
Metal based alternatives
Bellona agrees in the demand for phasing out lead and tin as additives
in plastics. With our knowledge to the plastic industry we think however
that January 1, 2000 is a too long time for the industry. It will not mean
serious technical or economical problems for the industry to convert to
other stabiliser systems than lead and tin within a relative short time
limit, because environmental friendly systems already exist. Total outphasing
of these products can be carried out 90% within 12 months and 100% within
24 months after decision has been taken. The time limit can therefore be
much tighter. One has, however, to secure good routines for import control,
so imported products get the same declarations as Danish produced goods.
There are used a lot more environmental- and health suspicious heavy
metals in plastics, than what is said in the proposal. This is the case,
both for additives for PVC and other plastics. We will mention pigments
used in all thermoplastics, as:
Yellow (Barium, Titanium, Antimony, Nickel, Chromium, Zinc, Cadmium,
Green (Chromium, Cobalt, Titanium, Nickel, Zinc)
Blue (Cobalt, Chromium and others)
Brown (Chromium and others)
Red (Cadmium, Selenium, Lead, Chromium, Molybdenum and others)
In addition, heavy metals are used in plastics for other purposes. It
will be too much to cover that item in this letter. As an example we will
mention that Swedish Telia for environmental reasons wish to change their
PVC cards with ABS. ABS can contain uranium, depending on the producer.
Bellona anticipate that this was not known to Telia when substitution was
launched. This illustrates the need for as much knowledge for the alternatives
as we have for PVC today.
However, an offensive and realistic environmental policy for both Denmark
and the EU will be a general ban on all suspicious heavy metals in all
plastics, otherwise it will not have a positive environmental effect.
To Bellonas knowledge, there is only limited use of Bisphenol A in PVC.
We have just one reference for such use. On the other side this material
is used both as raw material and additive in a lot of alternative plastics
Bisphenol A is the main component in this chapter, which is the most
potent oestrogen imitator. This substance was already in 1936 discovered
as endocrinic disturbing.
Bisphenol A is as separate additive in a lot of plastics, which have
direct contact with food and humans, as in internal lacquering of Al-cans
and in fillings for dental work. Bisphenol A should primarily phased out
[in food applications], secondarily in products with human contact. In
that case it are other plastics than PVC, which primarily should be phased
out, or they have to be improved.
Concerning the phtalates DEHP, DINP, BBP and DBP, we wonder why it is
just 4 of 20 commercial used phtalates, which should be phased out. To
our knowledge from studies on different effects, it are not these 4 phtalates,
which are worst concerning environment/health.
The uncertainity about the effects are great and Bellona thinks it's
needed to initiate a better aimed research on this chemical group. This
must be independent of potential law regulations against PVC, as long as
phtalates are used for other purposes and because the level in the environment
is occasionally high.
The Environment Agency's comparison document between PET and PVC reveals
that there are also other plastic related sources for human exposure of
PET, which is used all over Europe as mineral water bottles, is based
on phtalates. Analyses taken on water and mineral water stored on PET show
high values of phtalates in the drinking water. This bottle content can
be health related suspicious and should therefore be investigated more
Already in 1993 the Environment Agency got this information.
The dimension and potential health risk for human exposure of phtalates
from beverages in PET have not been satisfactory investigated. It has been
focused on effects from phtalates in flooring and other products, which
have never been in contact with foodstuff.
Bellona agree in the aim for chlorinated paraffins. We cannot see any technical
problems in changing the chlorinated paraffins in cutting oils as rapid
as in plastics. In 1990 Bellona carried out a survey on the use in Norway
and negotiated with the main users. As a result of that, the use of these
materials is minimised in Norway.
Official buying regulations
Bellona will not recommend the Danish departments to implement buying regulations,
which are not based on a good view of the market. So far it is only the
environmental consequences on PVC, which has been investigated. Until one
has a similar view on the alternatives, one should not push further. We
know that some of the environmental problems, linked to PVC, are also the
case for the substitutes and that the alternatives have other problems
which are limited investigated. Until one get the cards on the table from
the non-PVC industry, it is wise to held back regulations.
If the autorities phase out one product in a hurry and later on get
something which is worse, it will hit back on the environmental reputation
of the authorities.
Polyethylene versus polyvinylchloride
In the proposal it is concluded that PE has a lower impact on environment
and health than PVC. The environmental impact these two plastics have,
are partly comparable and also partly different. A direct comparison therefore
is difficult, but possible. The problem is that so far there is not a single
decent environmental report about PE, but hundreds on PVC.
Bellona agrees in the criticism of the progress to achieve recycling arangements.
For all the thermoplastics we have the rule that the quality is falling
with the number of recycling. This waste, which by nature has a low degradation
ability and high mechanical stability, should be canalised to applications
where these properties can be of advantage instead as of disadvantage.
It should, independent of PVC regulations, encourage the industry to
do this. In particular it is actual to produce drainage pipes from waste
plastics. Pipe products are needed in thousands of tons yearly and plastic
waste can contribute to make cheap and long lasting pipes.
Dioxins and furans
It is said in the arguments for the decisionproposal that 'among these
dioxins and furans, which are unavoidable linked to PVC'. This must
be a clear misunderstanding. The prime source for dioxins has little to
do with PVC.
The dioxin emissions from the burning of household waste and hospital
waste, is first of all due to the technical standard of the burning ovens
and not the chlorine content. The dioxin problems Denmark has with the
waste handling equipment, can be fully solved by upgrading the burning
Otherwise we will point at the fact that in the Nordic area, the dioxins
come primarly from the metal melting industry. In Norway the main source
is coming from the production of Mg, Fe and Ni, when in Sweden it comes
from recycling of steel and Al-scrap.
Hydrochloric acid formation in waste burning
HCl formation in waste burning equipment is a considerable environmental
and costproblem, especially with the standard on the Danish waste burning
plants. This situation has to be improved. Generally is can be said that
the authorities in Sweden and Norway have shown more interest for better
waste treatment than burning. This has resulted in several material recycling
plants, which have created jobs and have given better utilisation of the
resources than burning.
For Denmark, which has short transport distances, and denser population,
it should be a good base for increased recycling. With the present situation
one has to combine increased material recycling with upgrading of the waste
furnaces. Even with increased material recycling, there will be a lot of
waste, which can and should be burned. For the Danish society it seems
strange that the economical and labour related advantages with material
recycling has not been of interest.
The decision proposal should be revised so all environmental suspicious
plastic- and rubber additives and other environmental problems linked to
plastics and rubber are eliminated in accordance with the goal of the Esbjerg-declaration.
With kind regards
Environmental foundation BELLONA
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Created: 2 juni 1996.
Last update: 27 april 2002.
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