By: Cynthia Palmer, Senior Analyst, Petrochemicals, Moms Clean Air Force
Date: March 18, 2024
About: Docket ID No. EPA-HQ-OPPT-2018-0448
To: Michael S. Regan, EPA Administrator
Dear Administrator Regan,
Thank you for this opportunity to comment on the risk prioritization of vinyl chloride under the Toxic Substances Control Act (TSCA).
EPA’s decision to include vinyl chloride on its priority list of chemicals is an important step, one that should lead the agency to determine that vinyl chloride is a high priority substance and poses an ‘unreasonable risk’ of harm at every stage in the supply chain, from production and transport to use and ultimate disposal.
Vinyl chloride is a toxic, flammable, and explosive chemical that threatens the health of families and communities. Used to make PVC plastic, vinyl chloride is everywhere, from children’s toys to water pipes to food packaging—despite the availability of safe substitutes.
We urge EPA to ban this potent carcinogen and to jumpstart a transition to nontoxic materials, products, and processes. Even the U.S. Plastics Pact, which includes plastics packaging industry giants, has identified PVC as a “problematic and unnecessary material” and calls upon its members to take measures to eliminate PVC by 2025. Pact members include Clorox, Coca Cola, Eastman, Walmart, and many others.1
Despite the vinyl chloride industry’s decades-long campaign to suppress data and to misrepresent the science on health effects,2 there is ample evidence of vinyl chloride’s potent, multi-organ carcinogenicity. Vinyl chloride can set off a cascade of health impacts including liver cancers, brain and lung cancers, lymphoma, and leukemia.3 Vinyl chloride crosses the placental barrier during pregnancy, exposing countless children to harmful pollution before they take their first breath.4
The EPA, the U.S. Department of Health and Human services, and the International Agency for Research on Cancer (IARC) have all determined that vinyl chloride is a known human carcinogen. Fifty years ago, the U.S. government banned the use of vinyl chloride in hair sprays, cosmetics, refrigerants and drugs. Now it is time to ban vinyl chloride altogether.
Production of vinyl chloride generates vast amounts of greenhouse gases, puts workers at risk of fatal illnesses, and blankets communities with hazardous air pollution. As with so many other toxic petrochemicals, most vinyl chloride is produced in low-income communities and in communities of color. We urge EPA to visit the communities most impacted by vinyl chloride in Texas, Louisiana, Kentucky and beyond, to see and experience the conditions people are forced to live under every day and night, and to hear from local residents directly. Vinyl chloride pollution has forced people to relocate from multiple Louisiana towns including Mossville, Reveilletown, Morrisonville, and Plaquemine.
In addition to the ‘round-the-clock emissions in the vicinity of the vinyl chloride and PVC production and disposal facilities, there is the constant threat of chemical disasters, putting already overburdened neighborhoods at risk from chemical leaks and explosions. Additionally, communities across America such as East Palestine, Ohio, unwittingly host the bomb trains, bomb trucks and pipelines that transport these plastic-making chemicals.
Prior EPA risk evaluations of existing chemicals under TSCA have been marred by a systemic underestimation of risk.5 6 Given the deeply troubling human health and environmental consequences of vinyl chloride, we urge EPA to do everything in its power to conduct the most comprehensive, thorough, and rigorous risk evaluation possible.
In particular, we make the following recommendations:
1. EPA should include in its risk evaluation all exposure pathways across the entire supply chain of vinyl chloride, from the fossil fuel extraction, chemical synthesis, and production to the transportation, use, incineration, landfilling, and discharge into the natural environment.
TSCA is a full lifecycle statute that is meant to evaluate chemicals from cradle to grave. Accordingly, EPA needs to address the health and environmental impacts at every stage of the vinyl chloride supply chain and to assess all exposure pathways.
The evaluation should include the obvious junctures in the value chain including worker and
community exposures from vinyl chloride monomer and PVC production:
- the direct chlorination of ethylene to form ethylene dichloride,
- the oxychlorination of ethylene to form ethylene dichloride from hydrochloric acid and oxygen
- the purification of ethylene dichloride
- the thermal cracking of ethylene dichloride to form vinyl chloride monomer and hydrochloric acid
- the purification of the vinyl chloride monomer
- the polymerization in the reactor to make PVC plastic.
But the assessment cannot stop there. It must also include the risks from vinyl chloride use, transportation, and disposal. All of these processes endanger workers and residents alike.
The assessment needs to include not only the exposures when things go “as planned” but also the reasonably foreseeable consequences when they do not. This evaluation must include the combustion products generated when vinyl chloride or PVC is burned. Vinyl chloride releases extremely toxic chemicals, whether it is heated in deliberate, so-called “controlled” burns (as in East Palestine, Ohio on February 6, 2023), or as PVC in municipal waste- or plastics pyrolysis incinerators, or in unplanned fires and chemical disasters. The toxic pollutants that are released include hydrogen chloride, carbon monoxide, phosgene,7 and dioxins.8 Vinyl chloride in the air can also break down into hydrochloric acid and formaldehyde.9
Be sure to include structural fires
A risk category that is sometimes overlooked involves the fire hazards faced by building occupants, (including homeowners, school children, apartment dwellers, office workers), and by emergency workers. PVC siding, flooring, wire insulation, plumbing lines, molded furniture, wall coverings, and other products transform conventional building fires into raging toxic infernos.
Reporter and publisher Jack Doyle writes about the terrifying history of plastics-fueled fires in homes and vehicles, which happen at lightning-fast speeds, harming occupants and emergency workers – both from the blaze and from the chemical exposures. He describes how early efforts to regulate the use of plastic building materials were obstructed by the plastics industry:
“During the 1960s and 1970s, airplane crashes in which victims survived the crash but died in a toxic fire began to raise questions about the plastic material inside planes. And the 1969 New York Harbor fire aboard the USS Enterprise killed many sailors after plastic-coated electric cables burned.
Following these incidents, a White House report on fire in 1972 — America Burning — noted that plastics were being sold and used without adequate attention to the special fire hazard they presented. But when the National Fire Protection Association tried in 1975 to require by code that material used in construction be no more toxic than wood, the Society of the Plastics Industry blocked the move.”10
In her 1990 book, “In the Mouth of the Dragon: Toxic Fires in the Age of Plastics,” the author, Dr. Deborah Wallace, describes numerous PVC-fueled fires11 including:
- the 16-hour blaze that engulfed 100 tons of PVC sheathing in the 1975 New York Telephone Exchange fire that injured 239 out of 700 firefighters;
- the Beverly Hills Supper Club fire of 1977, in which 165 people were killed in an electrical and PVC-fueled blaze;
- the 1978 Cambridge, Ohio Holiday Inn fire in which 10 died from smoke from burning PVC and nylon;
- the 1978 Younkers Brothers Department Store fire in which 10 people died in another PVC-electrical fire;
- the 1980 MGM Grand Hotel fire in which 85 died and 600 were injured in a fire largely fueled by plastics;
- the 1980 Stouffer’s Inn fire in which 26 people died in a blaze fueled by PVC and nylon/wool;
- the 1983 Westgate Hilton fire in which 12 died from smoke that came mainly from PVC and urethane foam; and
- the 1983 Fort Worth Ramada Inn fire in which five died from PVC and nylon fumes.
Many such fires have followed since publication of her book. Vinyl chloride also contributed to the devastating aftermath of the World Trade Center disaster. This terrorist incident killed nearly 3,000 people, but even more survivors and first responders have died due to toxic chemical exposures12 from exposure to vast amounts of asbestos as well as lead, mercury, PVC and other plastics-chemicals.13 More than 60 types of cancer and at least two dozen other conditions have been linked to Ground Zero exposures.14
While the nightmare of 9-11 directly affected only a subset of the U.S. population – and obviously vinyl chloride was only one chemical among many -- all of us are subject to the dangers of houses, schools, and office buildings made out of PVC and other plastics. As described by the National Association of Realtors,
“An average of about 3,500 people died in fires per year between 2010 and 2019, according to the U.S. Fire Administration. That number is rising.
Construction experts say that homes and buildings are at greater risk because more materials in the building of homes and furniture are more flammable than they used to be. The widespread use of synthetic materials is increasing the risk, they say.
Today, people have just three minutes to escape a home fire, according to UL, a safety certification company. About 40 years ago, homeowners had about 17 minutes to escape from a similar fire.”15
The use of combustible materials such as vinyl siding is making fires more deadly and faster spreading. We urge EPA to include fire-safety risks in its evaluation of vinyl chloride.
2. TSCA requires that risk evaluations consider the known, intended or reasonably foreseen circumstances associated with the chemicals, including conditions that result or could result in exposures to workers.16
Leaks, fires, and other incidents at vinyl chloride- and PVC facilities and during transportation are reasonably foreseeable.
Chemical leaks, explosions, and fires are absolutely foreseeable, as are train derailments, vehicular crashes, and other transportation incidents. What we don’t know is the where and the when, but we know they will happen. There have been at least 35 hazardous chemical incidents in 2024 alone.17
Since 2010, there have been at least 40 chemical incidents worldwide involving the production of vinyl chloride monomer and PVC plastics. These chemical fires and explosions killed at least 71 people and injured 637 people. Countless other people and animals have suffered debilitating cancers and other long-term effects from these incidents.18
In addition to leaks, fires, and explosions at facilities, there have been incidents during transportation of vinyl chloride and its constituent chemicals. On average, three trains derail in the U.S. each day. As many as half may be carrying hazardous substances. The National League of Cities reports that over 65% of all derailments occurred within the boundaries of cities.19
As reported by Toxic Free Future and Material Research, at any given moment up to 36 million pounds of toxic vinyl chloride are shipped via rail by America’s largest producer, OxyVinyls, putting millions of Americans at risk. Every year, an estimated 1.5 billion pounds of this highly combustible and carcinogenic chemical is transported on bomb trains from from OxyVinyls chemical plants in Texas to OxyVinyls and Orbia PVC plastics factories in NJ, IL, and Niagara Falls, Ontario.20
Terrorist incidents are reasonably foreseeable.
Terrorist incidents targeting vinyl chloride installations and other toxic industrial chemicals are increasingly foreseeable as well, for a multitude of reasons. For years, vinyl chloride has been singled out by national security scholars as a terrorism hazard, employed to “primarily injure the upper respiratory tract and the lungs.”21 It is also listed as a pulmonary terrorism agent in the CDC Biological and Chemical Terrorism Strategic Plan.22 What happened in East Palestine, Ohio, gave us a glimpse of what vinyl chloride can do, whether intentional or not.23
The terrorist risk is not just from vinyl chloride but from the chlorine that makes up 56 to 67 percent of PVC, by weight.24 This is highly relevant because 99 percent of vinyl chloride is made into PVC plastic.
Some may argue that chlorine and vinyl chloride monomer are separate chemicals, and of course that is correct. But vinyl chloride is like the enabler in a very toxic relationship, and to ignore the role of vinyl chloride monomer in combination with chlorine is to bury our heads in the sand. Vinyl chloride is the reason for using massive quantities of chlorine, phthalates, heavy metals, and other extremely toxic chemicals, transporting them by truck and rail, subjecting all of us to the threat of terrorist annihilation. About 20 percent of the chlorine produced is used to make PVC plastic.25
With regard to the chlorine, as described by Dr. Benjamin Brodsky at the James Martin Center for Nonproliferation Studies,
“These concerns rest on a solid factual basis: many chemicals produced for industrial purposes are inherently dangerous due to their possession of one or more of the following properties: reactivity, flammability, explosiveness, toxicity, or carcinogenicity. In particular, the toxic industrial gases anhydrous ammonia, hydrogen fluoride, and elemental chlorine (often referred to as toxic inhalation hazards, or TIH) are of utmost concern from both safety and security standpoints.
Any of these chemicals when released in the course of an accident or a deliberate attack can form a toxic gaseous plume that when carried by wind is capable of inflicting potentially catastrophic loss of life on the population in its path. The worst industrial accident in history is illustrative: 40 metric tons of methyl isocyanate was released from a Union Carbide pesticide plant in Bhopal, India, on December 3, 1984. The resulting plume killed at least 3,000 people downwind and injured more than 100,000. A sufficiently large release of elemental chlorine may be capable of exacting a comparable toll, particularly if it were to be discharged in a highly populated civilian area.”26
3. EPA must consider environmental endpoints including harms to waterways, wildlife, ecosystems, and the climate.
As the researchers explain in the Journal of Environmental Science and Ecotechnology, burning vinyl chloride produces hydrochloric acid and phosgene, the notorious World War I chemical weapon.
“Acute exposure to these chemicals causes immediate adverse effects on local ecosystems, including the deaths of wild and farmed animals and pets…
Significantly, in addition to volatilizing into the atmosphere, VCM [vinyl chloride monomer] can dissolve in natural waters or be adsorbed onto soil particles and remains stable in the absence of oxygen and sunlight; thus, its residues can lead to long-term detrimental impacts on wildlife, including cancer and neurological disorders.
Acid rain induced by hydrochloric acid and associated acidification, compounded by other unknown and highly complex byproducts, harms plants, fish, amphibians, and other organisms, further deteriorating biodiversity and ecological biodiversity functions such as habitat destruction in the affected areas. The situation may be exacerbated, considering that the leaked chemicals and burning byproducts travel long distances in the air or rivers, impacting habitats outside the official evacuated zone.”27
Vinyl chloride- and PVC production also releases large amounts of climate-heating gases. The lack of public data on these emissions means we are not able to calculate the precise amounts from all facilities. We know that Orbia and OxyVinyls’ VCM operations in Texas, Illinois, and New Jersey reported releasing 61,774 pounds of vinyl chloride into the air, and that EPA calculates they released 3,339,604 metric tons of greenhouse gases in 2022.28
In addition, we know that greenhouse gases are emitted from the decomposition of PVC and other plastic polymers. A study of climate pollution from several types of microplastics found that the PVC microplastic material showed the highest emission of methane and carbon dioxide.29
4. TSCA requires that EPA include all conditions of use and sources of exposure, and identify and protect all Potentially Exposed or Susceptible Subpopulations who could be harmed by vinyl chloride.
GENERAL POPULATION
We urge EPA to look carefully at general population exposures from residual vinyl chloride monomer in drinking water pipes.30 Even if vinyl chloride levels are below the outdated 2 ppb MCL, that level is not health-based. Since vinyl chloride is a no-threshold carcinogen, any level of vinyl chloride in drinking water carries risk and must be included in the evaluation.
WORKERS AND LOCAL RESIDENTS
Nineteen vinyl chloride and PVC resin factories operate in the U.S. Workers and local residents in the vicinity of these facilities, including children, are forced to breathe ‘round-the-clock air emissions of vinyl chloride. Vinyl chloride and PVC plants reported releasing 414,803 pounds of vinyl chloride into the air in the U.S. in 2021. The six largest vinyl chloride polluting facilities are three Westlake Chemical plants in Kentucky and Louisiana, a Formosa plant in Texas, and two Orbia plants in New Jersey and Illinois.31
BABIES AND CHILDREN
EPA needs to protect susceptible sub-groups such as infants and children, whether exposed to vinyl chloride at the fenceline, in proximity to a vinyl chloride disaster site, or in a neonatal intensive care unit. In EPA’s own words,
“Several studies in experimental animal models have demonstrated that early life exposure to vinyl chloride can increase susceptibility to cancer later in life. Based on these data, the U.S. ATSDR has characterized fetuses, infants, and young children as a “highly susceptible population” for vinyl chloride exposure.
Children are at risk for exposure to vinyl chloride from ambient air contaminated with vinyl chloride by emissions released from polyvinyl chloride (PVC) plastics production and manufacturing facilities, as well as some incinerators. Contamination of groundwater and drinking water with vinyl chloride-contaminated run-off from such manufacturing facilities is also a concern for exposure of children….
The greatest difference between concentrations of vinyl chloride or vinyl chloride metabolites in maternal blood and in offspring blood was estimated to occur in late pregnancy and the neonatal period.”32
Evidence suggests that PVC microplastics have become commonplace in the human placenta. A 2023 study evaluated microplastics in 17 placentas using laser direct infrared (LD-IR) spectroscopy. The researchers detected microplastics in all placenta samples. PVC was the most common plastic polymer found in the placentas, of the 11 polymer types identified. Specifically, 43.27 percent of the microplastics in the placentas were PVC plastic.33
Moms Clean Air Force is urging EPA to prioritize early life susceptibility and the impacts of vinyl chloride on fetuses, infants, and children.
EMERGENCY RESPONDERS
Among the most heavily exposed groups are firefighters and other emergency workers, such as those who handled the derailment and the detonation, and who worked to clean the waterways, in the 2023 Norfolk Southern disaster.34 Their courage and selflessness are commendable. They should not have to pay for it with their lives.
TRADES-PEOPLE EXPOSED TO PVC PRODUCTS
EPA must consider also the risks from the full range of occupational exposures, including to plumbers and construction workers who cut PVC pipe and other building materials made with PVC and who may be exposed to residual vinyl chloride monomer in the PVC dust.35 36The American Journal of Industrial Medicine singles out the danger of PVC microplastics for their association with a range of cancers from work-related exposures.37
PYROLYSIS INCINERATORS, MUNICIPAL WASTE COMBUSTORS, CEMENT KILNS
PVC plastic that is burned in pyrolysis and other combustion facilities generates high emissions of dioxins and other toxic chemicals, a danger to workers and to surrounding communities. In addition to harming health, the PVC corrodes equipment and reduces product quality. Although some waste management operators would prefer to remove the PVC rather than burn it, this is a near-impossible task. Despite decades of research, there exist no cost-effective technologies with which to separate out PVC plastic waste. Even if the plastics industry one-day were to succeed in identifying a feasible separation method, they would be left with the vast quantities of PVC plastic. There are no safe and effective ways to dispose of PVC plastic, which is made up of extremely potent carcinogens.
LANDFILL WORKERS AND NEIGHBORS
EPA must also consider ongoing exposure to vinyl chloride from landfills, as well as from the
~700 Superfund sites around the country that contain vinyl chloride. Vinyl chloride from these facilities has poisoned drinking water and has resulted in vapor intrusion – the migration of the vinyl chloride into nearby buildings. Vinyl chloride is highly mobile in soils, and can leach intogroundwater from spills, landfills, and industrial sources. It has been detected in groundwater sources and can volatilize into the air surrounding these locations.
5. TSCA requires that EPA use the best available science. This needs to include calculation of aggregate exposure (multiple routes and pathways) and cumulative risks (combined risks from multiple agents). It is not sufficient to look only at sentinel (maximum single chemical) exposures.
EPA’s risk evaluation must consider exposures to other carcinogens and also to non-carcinogens within communities or populations that may experience elevated levels of exposure to vinyl chloride. The exposures may come from mobile or stationary sources -- all reasonably foreseeable possibilities need to be considered. People are simultaneously exposed to multiple sources of vinyl chloride and to other toxic chemicals, and the “best available science” requires that EPA assess ALL these sources in combination.
Even though TSCA excludes several categories from regulation (including food, drugs, cosmetics, tobacco, and pesticides) because they fall under the jurisdiction of other statutes, nonetheless those exposures are part of the aggregate risk that EPA must consider in its evaluation.
For example, even though FDA regulates medical device products, EPA’s TSCA risk assessments will need to consider the elevated exposures to newborns in neonatal intensive care units and other health care settings. That is part of the aggregate risk faced by infants. Vinyl chloride-based PVC products are extremely common in the form of fluid bags, disposable gloves, feeding tubes, respiratory support tubes, intravenous lines, nasal cannulas, catheters, incubators, and other devices, in addition to the PVC flooring and furnishings. The U.S. healthcare sector procures extraordinary (and increasing) amounts of unnecessary single-use plastics,38 from throwaway plastic surgical tools to disposable blood pressure cuffs, and many of these items are made from PVC.39Even though TSCA excludes these items from regulation, EPA must nonetheless include the exposures in assessing the totality of infant exposures -- they are part of the aggregate risk.
Using the best available science also means including all health endpoints and using proper reference values. To capture real-world risk, EPA needs to use scientifically sound reference values for both cancer and noncancer endpoints. The current IRIS value for cancer is flawed and under-protective, as is based exclusively on the risk of liver cancer.40
The evidence is unequivocal that vinyl chloride is associated with brain cancer, lung cancers, lymphoma, and leukemia – in addition to liver cancer. Studies have also have identified a link between vinyl chloride and breast cancer.41 It is critical that EPA’s risk evaluation take into account all cancer risk and all non-cancer risk.
6. EPA needs to conduct air monitoring and not just rely on industry models
We urge EPA to use actual fenceline monitoring to assess the exposure levels in fenceline communities, rather than relying exclusively on industry-reported data. The recent situation in Calvert City Kentucky, where EPA’s air monitoring recently found dangerous levels of vinyl chloride and other chemicals, demonstrates that fenceline monitoring is essential to identifying risk.42 43
7. It is critical that EPA increase transparency in the TSCA risk evaluation process.
Companies should not be permitted to shield from public view their data on dangerous chemicals. Vinyl chloride manufacturers are hiding critical data on chemical constituents, health and environmental effects, and production volumes. Thus, we do not even know the amounts of vinyl chloride produced. EPA’s Chemical Data Reporting tool reports that companies reported producing between 10 and 20 billion pounds of vinyl chloride in 2019.44 In other words, we have 10 billion pounds of uncertainty. That is the best information the public can get. Occidental Chemical and other Westlake Chemical facilities have withheld their production volumes as “Confidential Business Information.” We demand that EPA and the plastics industry stop suppressing this critically important data.
On behalf of our more than 1.5 million members, Moms Clean Air Force is calling on EPA to designate vinyl chloride a High Priority Substance, and ultimately to put an end to the production and use of this dangerous chemical. TSCA gives EPA the authority to eliminate risk at the source, and specifically to ban vinyl chloride. Thousands of Moms Clean Air Force members have petitioned for this EPA action, because our families and our communities deserve protection from this widely-used carcinogen. We will continue to advocate for a ban on vinyl chloride and a world where all children are safe from vinyl chloride, PVC plastic, and other industrial pollutants.
Respectfully submitted,
Cynthia Palmer
Senior Analyst, Petrochemicals
Moms Clean Air Force
Sources
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