Hancock currently use the folowing chlorinated pesticides on their plantations: Clopyralid, Simazine, Terbacil and Triclopyr. Hancock Watch is calling for the removal of all chlorinated pesticides by Hancock. Click on HERE to get a full list of chlorinated pesticides in Australia.

The Chlorine Crisis

Sources and impacts of chlorine chemistry in Australia

Prepared by Matt Ruchel - June 1995 Greenpeace Australia

Page 1 “Executive Summary


Pollution control in Australia has largely been confined to setting arbitrary limits on releases of wastes into the environment. The theory underlying this policy is that environments have an unlimited capacity to assimilate or deal with certain amounts of contaminants with negligible risk. This is a flawed philosophy which ignores both the effects of bioaccumulation and combined or synergistic effects of persistent toxic inputs.

In many cases there is no ‘safe’ level of release into the environment of some toxic substances. Laws which set emission and exposure limits implicitly sanction the use and release of toxic chemicals into the environment. This ‘end of pipe’, out of mind approach to pollution means that the planet is being slowly poisoned by legal pollution. Repeated studies have shown that pollution levels of persistent and bioaccumulative substances only fall when their use in production is reduced, phased out or stopped.

We should not wait for problems of particular chemicals to materialize. Instead of allowing the discharge of chemicals until damage to the environment has been proven, the onus of proof should be on the polluter to show a substance is safe. The implication of this is that industry is not just required to restrict emissions of environmental toxins but reduce them to zero, in some cases not just for individual chemicals. This may mean that whole production processes may have to be changed, and products phased out or fundamentally altered.

This report presents arguments and evidence identifying chlorine and the chlorine industry as a class of chemicals and a mode of production which should be eliminated, phased out or substituted”.

Page 2 “Chlorine Chemistry and Toxic Soup

Chlorine is the common link in many of the world’s most notorious environmental poisons: dioxin, DDT, Agent Orange, PCBs and the ozone-destroying chlorofluorocarbons (CFCs) are all based on chlorine. These chlorine-containing substances dominate government lists of priority pollutants that threaten health and the environment. But thousands of other chlorinated poisons that cause similar harm are not regulated or even monitored.

The global threat posed by this toxic ‘chlorine soup’ now present in the ecosystem is too complex to be solved by addressing these chemicals one at a time. If we wish to preserve the life-sustaining capacity of the planet, the root of the problem - the production and use of chlorine - must be phased out.

At all points of its production and life-cycle, chlorine causes problems for the environment and human health. In almost all its major uses, chlorine pollution is apparent. This includes:

*chlorine production

*the manufacture, use and disposal of Poly-Vinyl Chloride (PVC) plastic;

*the manufacture and use of chlorinated solvents;

*dry cleaning;

*accidents and spills;

*the pulp and paper industry;

*the manufacture and use of chlorinated pesticides” . . .

p17 “ . . . Pollution control in Australia has been confined to setting arbitrary limits on releases of wastes into the space common to all organisms on earth, namely the air, land and water. The theory underlying this policy is that environments have an unlimited capacity to assimilate or deal with certain amounts of contaminants with negligible risk There is an assumption that once released, substances are diluted or transformed so thoroughly that they become mere traces which do little damage and do not re-concentrate or reform. This approach ignores both the effects of bioaccumulation and the combined or synergistic effects of persistent toxic inputs.

Assimilative capacity is a flawed philosophy; in fact many synthetic chemicals and materials resist degradation. Organochlorines such as DDT, PCBs, dioxin or heavy metals such as mercury or cadmium compounds stay in the environment for decades. Even when these substances are released within permitted levels, they collect in the atmosphere, the sediments of oceans and lakes and in underground aquifers4.

Some chemicals, particularly heavy metals and organochlorines, can build up or bioaccumulate in the bodies of wildlife and humans. In many cases the interaction of these thousands of different types of chemicals released into the environment through human activities is so complex and bewildering that it simply falls outside the pale of reckoning5.

It is impossible to actually calculate what the assimilative capacity of the environment is. There are too many chemicals released and ecosystems are too complex to predict what the real effects will be. Most chemicals are only tested on a few species of test animals for a matter of days or weeks. They are also only generally tested in isolation; ie on a substance by substance basis (though of course some effluents are tested in the mixed form they are released). Often only acute toxicity is measured (eg. Fatality or other insensitive measures). This system cannot account for the complex interactions between chemicals and species in the environment or for the subtle effects that can have a marked effect on an individual’s or species’ ability to survive or reproduce. . .

P18 1.1 The Precautionary Principle We should not have to wait for the problems of a particular chemical to materialise. The substance-by substance approach adopted in Australia for evaluation of chemicals draws out the process of regulation and allows discharges of chemicals to continue while the evaluation process is followed through. Likewise, effluents which contain mixtures of chemicals in addition to those identified as priority substances are being regulated on a basis which does not take full account of possible combined or synergistic impacts, particularly those exerted in the longer term.10 In addition, regulation is further confused by the implications of new information (and lack of knowledge) about natural processes and substances.11

For example, with around 11,000 organochlorines identified to date, 12 the substance-by substance approach to regulation could see the process drag on for a millennium. The only feasible alternative strategy for the control and regulation of bioaccumulative and persistent chemicals, particularly chlorinated substances, is based on the precautionary principle. This approach employs a different philosophy in relation to releases of pollutants. Instead of allowing the discharge of a particular chemical until damage to the environment has been proven, the onus of proof is on the polluter to show a substance is safe.

The precautionary principle requires that materials should not be discharged unless it can be established that they will have no negative impact on the environment. This approach avoids the problems and limitations of our understanding of toxicology by removing the assumption of a safe level of a particular compound or compounds in the environment. Industry in this scenario is not just required to restrict emissions of environmental toxins, but to reduce them to zero, 13 in some cases not just for individual chemicals but for whole groups of chemicals. In some instances this means that the whole production process may have to be changed, and products phased out or fundamentally changed, ie elimination of chlorine chemistry. . .


p 20 2.1 Chlorine Chemistry and Toxic Soup Chlorine is the common link in many of the world’s most notorious environmental poisons: dioxin, DDT, Agent Orange, PCBs and the ozone-destroying chlorofluorocarbons (CFCs) are all based on chlorine. These chlorine containing substances dominate government lists of priority pollutants that threaten health and environment. But thousands of other chlorinated poisons that cause similar harm are not regulated or even monitored.

The global threat posed by the toxic ‘chlorine soup’ now present in the ecosystem is too complex to be solved by addressing these chemicals one at a time. If we wish to preserve the life-sustaining capacity of the planet, the root of the problem - the production and use of chlorine must be phased out.

2.2 The Chlorine Industry Chlorine Chemistry starts with ordinary salt - sodium chloride - a stable, natural substance that flows constantly through the ecosystem and our bodies. The chemical industry creates chlorine gas (Cl2) by passing huge quantities of electricity through salt water, splitting the salt molecule and fundamentally changing the character of the chlorine in it. Chlorine gas is an extremely reactive and poisonous substance that rarely occurs in nature.

Unlike ionic chlorine, chlorine (ie salt) gas bonds quickly with organic matter to form a new class of chemicals called ‘organochlorines’, Most chlorine is combined with petrochemicals to produce organochlorine products including plastics (especially PVC or Vinyl), pesticides, solvents and other chemicals.

Many more organochlorines are produced by accident. Because chlorine is so reactive, it combines quickly with organic matter to form a variety of very toxic by-products and wastes. Hundreds of these accidental organochlorines are released when chlorine is used to bleach pulp, disinfect water, manufacture other organochlorines, and whenever chlorine-containing chemicals are burned. These by-products - including the infamous dioxins and furans - are sometimes even more dangerous that the intentionally produced chemicals. Chlorine gas itself has been found to be contaminated with dioxin-like compounds and high concentrations of dioxin have also been found in sludges from spent graphite electrodes used in the production of chlorine.14

2.3 Dioxins and Furans Dioxins and furans are micro-pollutants produced as by-products from many processes in which chlorine and chlorine-derived chemicals are produced, used and disposed of. Industrial emissions of dioxins into the environment can be transported long distances on atmospheric currents, and to a lesser extent in rivers and oceanic currents. Consequently, dioxins are now globally ubiquitous. It is estimated that even if production ceases, levels in the environment will take years to decrease. This is because dioxins are persistent, taking decades or centuries to degrade, and can undergo continual recycling throughout the environment.16

2% of world use of chlorine are chlorinated pesticides (organic chemicals). 10% of world use of chlorine are the pulp and paper industry (chlorine gas).

2.4 The Chlorine Industry in Australia Australia uses around 180,000 tonnes of chlorine per year. Chlorine is produced by a number of companies, principally ICI, Nufarm-CSBP Farmers, and a number of pulp mills and smaller companies also produce chlorine in Australia. Chlorine is used principally as feedstock for pesticides manufacture, pulp mills or sale as a water treatment . . . (Manufacture of chlorinated aromatics (pesticides, dyes, speciality chemicals etc) can form dioxins and related chemicals).

P 25 2.10 Chlorinated Pesticides The production, formulation, use and disposal of chlorinated pesticides and products produces significant pollution and chlorinated waste. Pesticide manufacturing involved producing the active pesticide ingredients by chemical synthetic processes; formulating pesticides involves diluting the active ingredients with solvents or mixing them with other carriers. The manufacturing process as practiced results in discharges or pollutants to air, water and soil, as does formulating pesticides, although to a lesser extent. Discharges from both processes may be increased significantly by accidents. The processes also almost invariably entail occupational exposure to hazardous substances and releases to the environment.

Ninety percent of all synthetic organic pesticides contain chlorine or are manufactured using chlorinated intermediates.44 The production discharges, as well as the final chlorinated products, are likely to contain impurities as part of the technical grade active ingredient. Impurities will also be present in many of the additives. The impurities are likely to include dioxins and/or other organochlorines. Dioxins have been found, for example, in the herbicides 2,4D (TCX, TCDD, 2,7 dichloro-p-dioxin) and dicamba. Hexachlorobenzene has been identified in 135 pesticides. 45 (Hexachlorobenzene is an industrial by-product and constituent of pesticides).

Only a small number of chemical companies manufacture pesticides in Australia. Others import their technical ingredients and formulate the product or, alternatively, contract out the formulating . . .

Since the early 1950s the amount of pesticides used in Australia has steadily increased. Information about actual volumes is restricted, however in 1990 Australia imported over 8 million kg (nearly 18 million pounds) of pesticides from the USA alone. 46 Australian imported 146,742 kilograms of chlorine-based herbicides, insecticides and disinfectants from the USA in 1992-93. 47 There are over 30 million hectares of agricultural lands where pesticides may be used and approximately 7.5 million hectares are aerially sprayed. Over 22,000 hectares of cotton lands in NSW and Queensland are extensively sprayed by air, while in the Murray Valley, 42,500 hectares of rice are sprayed with herbicides. Large quantities of pesticides are also used in urban environments in industry and in the home.48


International Evidence and Response

Since the 1980s research into the effects of toxic chemical releases has increased, particularly in the field of organochlorine and dioxin contamination. The conclusions which can be drawn from this body of evidence are disturbing: fundamental genetic and biological functions in the environment may already be affected.

3.1 DIOXINS: The Vanishing Safety Margin

In September 1994, the US Environment Protection Agency (US EPA) released its 3 year, 9 volume Scientific Reassessment of Dioxin and Dioxin-like chemicals. The US EPA reassessment of dioxin combined with new evidence from around the globe indicates the following important points:

1. In fish, birds, mammals and humans, evidence shows that the developing foetus/embryo appears to be very sensitive to the toxic effect of dioxin. Developmental effects in humans, seen after high accidental/occupational exposure to dioxins, include: pre-natal mortality; decreased growth; organ dysfunction, (eg. Involving effects to the central nervous system such as impairment of intellectual development); functional alterations, including effects to the male reproductive system.

2. Animal and/or human studies have shown that some effects, for example cellular changes in the immune system, changes in the levels of male sex hormone testosterone, and changes in other enzymes and hormones, may be occurring in humans at, or near to, current levels (body burdens) of dioxins found in the general population of industrialized countries.

3. Biological effects from dioxins appear to depend on the concentration present in a target organ over a critical time period, rather than on dose. Animal experiments have shown that exposure to very low doses of dioxin during an extremely short critical period during gestation is sufficient to cause detrimental health effects on the foetus.

4. In industrialized countries, levels of dioxin in breast milk often result in nursing infants having dioxin intakes far in excess of the Tolerable Daily Intake (TDI) proposed by the World Health Organisation (WHO). This becomes of even greater concern when health risk assessments of dioxins do not take exposure to other chemicals into account. The effects these chemicals have on given health points may be additive to dioxin or synergistic, i.e produce a larger than additive enhanced effect.

5. Evidence from studies of occupational/accidental exposure to dioxin in humans together with animal studies indicates that dioxin causes cancer in humans. The US EPA estimated that current background exposure to the general population results in cancer risks ranging from 1 in 1000 to 1 in 10,000. 49

The US EPA reassessment confirms the dangers of dioxin as a persistent and bioaccumulative chemical and the need for vigorous action to eliminate its input into the environment. The new evidence clearly illustrates that the TDI proposed by the WHO and Australian authorities may not be valid. This clearly demonstrates the large scientific uncertainty in risk assessment methodology and the problems of basing a regulatory system on assimilative capacity. 50 The study found that levels of dioxin currently found in the bodies of the general population, in the food chain and in the environment, may already be damaging reproductive, developmental and immune systems.

In December 1990 the WHO proposed a TDI of 10 picograms/kg body weight/day. The US EPA however, which uses a different method of risk assessment for dioxin, set a value for the Virtual Safe Dose (VSD) of 0.006pg/kgbw/day, based on an additional lifetime cancer risk of one in a million or more. The current Australian TDI is therefore 1,670 times greater than this standard. The US EPA study now indicates that there may be no safe level of dioxin. It has been found that dioxin triggers the action of the hormones to turn on or off certain biochemical functions within the body, particularly in the reproductive system. By mimicking the actions of oestrogen, these chemicals can significantly disrupt sexual development in humans and wildlife. It is becoming clear that reproductive effects of chemicals or “environmental hormones” are triggered at far lower levels of exposure than those needed to induce cancers. 51 The subtlety of these changes is extremely worrying: feminization of males in both humans and animals have led to the media term ‘Gender Benders’ when referring to these chemicals.

Other chemicals may have an effect by binding onto other “receptor sites”, such as the Ah (aromatic hydrocarbon) receptor. 52 By blocking or triggering reactions at such sites, other effects may be observed in terms of growth and development. 53

The following two subsections describe the body of evidence available to support claims that humans and wildlife are being adversely affected by toxic chemical contamination.

3.2 Human Health Effects

3.2.1 Reproduction. In males, effects include reduced penis size, 54 reduced sperm count 55 and feminization 56. In females, effects include decreased fertility, pregnancy failure and endometriosis. 57

3.2.2 Immune System. Despite their isolation from industrial centers, Inuit communities of Arctic Canada have shown immune system suppression effects directly linked to PCB contamination known to contain high levels of organochlorines. This demonstrates the widespread transportation of toxins around the globe and their ability to concentrate up the food chain. In Sweden, subjects who consume large amounts of fish from the Baltic Sea have an accumulation of organochlorines in their bodies which may adversely affect ‘natural killer’ B-cells ( a type of white blood cell), which were found to be functionally impaired by exposure to dioxin. 58

3.2.3 Development. The levels necessary to produce developmental effects are not well known, particularly regarding the subtlety some effects can have and the length of time an effect can have and the length of time an effect can take to manifest. Tests on subjects living in a dioxin-contaminated area of Missouri, USA, have found abnormal brain measures, particularly in the frontal lobe regions of the brain. 59

3.2.4 Cancer. There are many examples of investigative work showing a link between toxic chemical exposure and subsequent cancer development. It has now also reached the courtroom with the case of Yates vs Rentokil Ltd (UK). George Yates worked for the pest control company from 1978 to 1988, using chemicals such as PCP and lindane. This was the first chlorinated pesticide/dioxin case in the world. Rentokil settled for $US270,000. 60

Rare cancer rates increased in a population exposed to dioxins after an explosion at a chemical factory in Seveso, Italy, in 1976. Cancers observed included multiple myeloma, gall bladder and related cancers, and thyroid cancer. These are all associated with hormonal activity and are particularly evident in industrialized countries. 61 DDE, a breakdown of DDT, and the PCBs have been shown to be significantly higher in women who developed breast cancer and in women who were occupationally exposed to chlorophenoxye. 62

3.2.5 Breast milk. The mobilization of organochlorines such as PCBs in human breast milk is well documented. 63 Breast milk samples from cotton growing areas of the Punjab in India showed one of the highest values for organochlorine pesticide residues, and it can be expected to have the developmental, immunological and reproductive effects described above. Inuit women were found to have PCB levels in their milk four times higher than Caucasian women, again due to their high consumption of marine mammals and fish. 64 A number of day care centers in Germany were closed when the dioxins from PCP-treated timber posed a health risk to both children and teachers.

3.3 Effects on Animals and Wildlife

Global transport of toxic chemicals by air and water ensures their distribution far from industrialized sources. 65 Even in remote areas chemicals accumulate in the blubber of marine mammals. In times of stress these fat deposits are mobilized for energy: the release of organochlorines into the blood stream affects key organs such as the liver and kidneys. 66 Organochlorines are passed on to the young via the mother’s milk. 67 Mass mortalities in marine mammal populations, which generally occur in waters adjacent to highly populated and industrialized coasts, have been linked to organochlorines. 68 Contaminants are many and varied, and include PCBs, pesticides such as DDT and its derivatives and polyaromatic hydrocarbons (PAH’s).

3.3.1 Whales and Dolphins. There has been widespread contamination of populations 69 resulting in tumours and lesions, 70 increased mortality rates, 71 breeding problems 72 and milk contamination. 73 Reproductive problems include sterility, 74 75 76 immunological deficiencies, developmental abnormalities and milk contamination.

3.3.2 Seals. Reproductive problems including sterility, 77 immunological deficiencies, 78 developmental abnormalities 79 and milk contamination. 80

3.3.3 Polar Bears. Although remote from industrialised centers, organochlorines are thought to be affecting their ability to reproduce. 81

3.3.4 Otters. The decline of European otter populations is believed to be related to contamination with PCBs and organochlorine pesticides. 82

3.3.5 Birds. In many species of birds, eggshell thinnings and related breeding problems have been observed. 83 This includes many species of seabirds, sea eagles, 84 Peregrine falcons, 85 owls, 86 waterfowl and even penguins of Antartica have been found to be significantly contaminated with chlorinated compounds. 87 In the case of birds, contamination is via the food chain through the consumption of fish or smaller animals.

3.3.6 Fish. Strong links have been made between organochlorine contamination and increases in mortality, 88 disease outbreaks, 89 breeding problems in California 90 and the Baltic Sea, 91 malformations, 92 and behavioural disturbances. 93

3.3.7 Shellfish. The common mussel, Mytilus edulis, suffers sub-lethal effects from the accumulation of lindane, an organochlorine pesticide. 94

3.3.8 Monkeys. A direct correlation was found between dioxin exposure and endometriosis in rhesus monkeys. 95

3.3.9 Mice & Rats. Male rats are highly sensitive to dioxin exposure, resulting in changes in testosterone levels early in development and leading to reduced reproductive ability in adulthood. 96 Mice exposed to dioxin showed decreased resistance to parasitic infection. 97 Effects have also been observed on other plants and animals. Of particular concern is the plankton which form the base of the marine food web. Alterations at this level could have serious ramifications throughout the entire aquatic ecosystem.

3.3.10 Plankton. Suppression of photosynthesis in phytoplankton exposed to low levels of PCBs has been reported. 98 Chronic exposure to PCBs has the ability to alter populations of the marine microlayer through the disruption of egg and larvae development. 99 The microlayer is a film of natural fats and oils on the surface of the ocean - it is a highly productive ecosystem and under extreme threat of long term damage due to the fat-loving nature of organochlorines.

P46 4.10 Pesticide Pollution

More than 60 per cent of water samples collected from river sites from the irrigated cotton growing Central and North West regions of NSW contained high levels of the pesticide endosulfan and measurable levels of heavy metals such as cadmium and chromium. 194 Likewise, pesticide pollution of water supplies is common in NSW. 195 In South Australia studies found DDT above WHO guidelines and residue such as chlorpyrifos, parathion and endosulfan in creek waters in relatively high concentrations. Residue work in the Murrumbidgee Irrigation Area of NSW also revealed herbicide residues in irrigation waters 196 and investigations in Western Australia revealed pesticide contamination of groundwater. 197

A 1994 study by the CSIRO of pesticide drainage from rice and maize catchment areas at Willbriggie, south of Griffith in NSW, found the pesticides chlorpyrifos, malathion, molinate and atrazine. Concentrations of these pesticides exceeded their respective water quality guideline values for ecosystem protection by several order of magnitude.

Maximum concentrations of pesticides detected in large surface drains as well as natural waterways exceeded water quality guidelines values for molinate, chlorpyrifos and atrazine. In October 1993 the concentrations of molinate in drainage water leaving the Murrumbidgee Irrigation area for stock and domestic purposes exceeded drinking water guidelines and resulted in a drainage ban being implemented by the NSW Department of Water Resources. 198

There are few or no systems in Australian for collecting information on the volume of chemicals used in the agricultural context, or for monitoring their effect on humans and the environment. There is, however, increasing evidence of the effects of persistent and bioaccumulative chemicals on the environment. 199 The Western Australian Environment Protection Authority suggests “. . . there is no doubt that some pesticide use produce, either directly or indirectly, significant undesirable impact on the environment”. 200

4.10.1 Pesticides in Breast Milk

The contamination of breast milk is of particular concern, particularly when organochlorines such as dioxin and related substances are involved, as new-borns are believed to be highly sensitive to dioxins. 201 In industrialised countries, nursing infants can ingest far more than World Health Organisation (WHO) Tolerable Daily Intake (TDI) of dioxins. Current levels of dioxins in human milk mean that the safety margin for breastfed babies calculated by European risk assessment is very low 202. Studies carried out by WHO regarding risk assessment in infants in relation to exposure through breast milk concluded that "a safety margin still exists, although rather small". 203 The risk becomes even smaller because scientific risk assessments do not take into account other synergistic or additive effects of other chemicals.

A Victorian 1985/86 breast milk survey indicated that there have been reductions in concentration levels of DDT and HCB since the previous survey in 1978. However the mean concentrations of DDT, dieldrin and PCB concentrations in the 1985/86 survey still exceeded the acceptable daily intake levels set by the United Nation's Food and Agriculture Organisation and the World Health Organisation.

Comparisons of the pesticide levels found in the Victorian study can be made with overseas studies done in Canada, the USA, Germany and Japan. The results from the Victorian study of pesticides in breast milk were generally in the 'mid range' of other developed countries. 204 Other studies have, however, suggested that levels of organochlorines in human blood, breast milk and adipose tissue are higher than in other developed countries and that this high level may be related to an increase in human exposure to organochlorines. 205

A more recent study in Victoria of contaminant intake amongst breast fed children found widespread contamination of breast milk at low levels similar with other industrialised countries, however, some infants' intakes of heptachlor epoxide, chlordane and dieldrin exceeded ADI. 206

A similar study of Western Australian women had similar results, finding in particular that levels of dieldrin consistently exceeded acceptable daily intake and that heptachlor was also found in relatively high levels in infants. The study did, however, find that reductions in the use levels of organochlorine pesticides (DDT, aldrin, dieldrin, heptachlor and chlordane) have resulted in a reduction in the concentrations of these chemicals in breast milk. 207

The high levels of some organochlorines in womens breast milk are of ongoing concern. However, the general trend of a reduction in the levels found in breast milk highlights the effectiveness of bans and phase-outs as a regulatory strategy to protect human health. The substance-by-substance approach adopted by Australian regulators will see new threats develop in the future as other chemicals are tested for. In many cases, however, only after untold damage is done. Australian authorities need to recognise that the problem is chlorinated chemicals as a group and that this problem needs to be addressed by tackling the whole group, not just individual chemicals or products.

The finding by the US EPA that dioxin contamination in industrialised countries may already be occurring at or above levels which may effect human helath clearly has implications for Australia. The expert reference panel appointed to review studies of the impact of Nufarm Ltd on the environment in 1991 recognised that there was limited data available on dioxin levels in the Australian population. The panel however suggests that they would not expect those levels to differ from those of North American and European residents. 208. There is still no systematic collection of information about the sources and levels of dioxins in Australia. The hard work has been done by the US EPA in understanding the impacts of dioxin; it is now up to the Australian governments to determine levels and sources in the environment with a view to eliminating sources of this dangerous chemical.

4.10.2 Agent Orange

A US National Academy of Science (NAS) study released in July 1993 linked Agent Orange with the lymphatic cancer Hodgkin's disease for the first time. 209 The NAS study accepted an association for both Hodgkin's disease and Porphyria Cutanea Tarda disease which causes liver dysfunction, with Agent Orange. Both the US and Australian governments already recognise the skin disease chloracne and the cancers soft tissue sarcoma and non Hodgkin's lymphoma as being associated with Agent Orange. Following the release of the NAS study, the Australian Federal Minister for Veteran Affairs commissioned an independent study to review the findings of the US study and its implications for Australian Vietnam veterans.

In a landmark finding, the Australian study 210 not only supported the NAS study findings but expanded the list of cancers linked to Agent Orange. The Australian study added multiple myeloma, leukemia and respiratory cancers (lung, larynx and trachea) to the list of those diseases with 'sufficient evidence of an association' with Agent Orange. The authors of the Australian study reviewed studies of workers exposed to the dioxin TCDD in assessing the association of Agent Orange with respiratory cancers. This represents somewhat of a watershed in the Australian government's assessment of dioxins, as the support of a link between Agent Orange and respiratory cancer implies recognition of a link between cancer and TCDD for the first time.

The authors of the Australian study were critical of the NAS study, claiming its authors were 'very conservative in their assessment' of an association between Agent Orange and various diseases. By contrast, the Australian authors were willing to apply a 'precautionary approach' when assessing possible associations with various cancers. In supporting an association with leukemia, the Australian reviewers gave the 'benefit of the doubt' to veterans, concluding there was at least as much evidence supporting an association as there was against it. Similarly, in assessing respiratory cancers, the authors concluded the very small number of veterans suffering respiratory cancers not confounded by external factors like smoking should be given the doubt of an association.

4.10.3 Chlorine and Chronic Fatigue Syndrome

A research team at Newcastle University has discovered a possible link between chronic fatigue syndrome and the use of pesticides. In a recent study they have found that 25 sufferers of the disease have twice as much DDT and HCB (Hexachlorobenzene) in their blood as similar age group of healthy people. Of a total of 21 organochlorines which were tested for, only four (DDT, HCB, heptachlor epoxide and dieldrin) were found. DDT and HCB were easily the most prevalent, with the chronic fatigue sufferers having twice as much in their blood as healthy subjects. 211

4.11 Contamination of the Food Chain

Recent studies in Australia have found elevated concentrations of organochlorine pesticides and PCBs in foodstuffs collected from different metropolitan locations in Australia, with the notable exception of fruit. Generally, fish were the most contaminated items, followed by meat, dairy products and other agricultural commodities. During 1987 fat samples from several shipments of Australian beef to the USA and Japan were found to exceed levels for organochlorine pesticides in fat. 212 In fish, PCBs, chlordane (CHLs) and DDT were predominant, wheras in most other agricultural products, with the exception of fruit, DDT dominated. The concentrations of chlordane detected in fish were comparable with of higher than those reported in fish from the US and Japan during the mid-1980s. 213 . . .

Australian Responses and Missed Opportunities

p 56 5.2.8 National Registration Authority for Killer Chemicals

The National Registration Authority for Agricultural and Veterinary Chemicals purports to provide a national assessment and registration scheme for agricultural and veterinary chemicals. Before a chemical is permitted on the market by the NRA, the following factors must be taken into account:

*Chemicals must be safe to use and effective when used according to label instructions;

*Use of chemicals must not result in any unacceptable risk to people, animals or the environment;

*Use of chemicals must not result in any unacceptable risk to Australis's trade with other nations.

The NRA is limited by a very broad definition of commercial confidentiality, which allows industry to push assessment through without public scrutiny and recourse for review through Commonwealth Administrative law. 241 Likewise, there is no systematic information collected on the volume of chemicals used in agriculture or coordinated monitoring of their effect on humans or the environment. 242 There is virtually no information about the levels of dioxin and many other chlorinated compounds in the Australian community and environment.

Hiding behind commercial inconfidence provisions and an almost complete lack of local data about the impacts of chemicals on the environment, the National Registration Authority for Agricultural and Veterinary Chemicals acts more like a rubber stamp for the chemical industry than an authority charged with protecting the public's interest. The fact that 19 chlorinated pesticides which are banned in other countries are used in large quantities in Australia is testimony to the ineffectiveness of the NRA.



Below are listed active ingredients of pesticides classifiable as chlorinated organic pesticides. All are registered in Australia. They make up many pesticide products, either singly or in combination, The list includes only some of the brand names into which each ingredient is formulated in Australia. The final two columns highlight the regulatory status in other countries. Of the 117 chlorinated organic pesticides, 19 have been banned or targeted for phase-out internationally.

The following distinctions have been made in identifying the properties of these pesticides:

-All chemicals on the list are chlorinated organic (carbon-based) pesticides, i.e. all contain chlorine and carbon;

-A subgroup in the list are the chlorinated hydrocarbon pesticides - pesticides which contain chlorine, carbon and hydrogen. Among the chlorinated hydrocarbons are the organochlorine pesticides DDT and cyclodienes (aldrin/dieldrin and heptachlor/chlordane). The term organochlorine pesticides is popularly used to refer to those chlorinated hydrocarbon pesticides which are molecules with a high aromatic content, with a high degree of chlorine substitution and with a high insecticidal activity and persistence. Alternatively and somewhat doubtfully organochlorine pesticides have been defined as pesticides with 50 per cent chlorine content by weight or more, characterised by persistence in the environment. Chlorinated hydrocarbons listed below are asterisked (*). Organochlorines are marked with two asterisks (**).

2,2-DPA Herbicide (Graypon, Erase, Rezalon, Defender, Pro-pon).

2,4-D as amine Herbicide (Farmco, Tordon*, Tillmaster, Banvel).

2,4 dichloro-m-xylenol Insecticide (Topclip).

2,4-D as ester Herbicide (Crop King, Estericide).

2,4-D as sodium Herbicide (Rezalon, Lane KO salt).

2,4-DB Herbicide (Buticide, Legumex, Buttress, Butamine, Butoxon). Internationally banned or targeted for phase out in one country.

5 [2-chlor-4-(tri noxy]-2-nitrobenzoic acid Herbicide (Blazer)

Alkyldimethylbenzyl-ammoniumchloride Algaecide (Pace-Gard)

Alpha-cypermethrin Insectide (Dominex, Fastac).

Atrazine Herbicide (Erase, Gesaprim, Gesatop, Bantox).

Azamethiphos Insecticide (Alfacron).

Betacyfluthrin Insecticide

Bifenthrin Insecticide (Brigade, Capture, Talstar). Internationally banned or targeted for phase out in one country. Internationally Severely Restricted in one country.

Benzalkonium chloride (Algaecide) (Al-Ban, Ruply)

Chlordane** Insecticide (Chlordane). Internationally banned or targeted for phase out in eighteen countries #. Internationally Severely Restricted in nine countries.

Clethodium Herbicide

Chlorfenvinphos Insecticide (Barricade, Suprona, Birlane).

Chloridazon Herbicide (Pyramin).

Chlormequat Herbicide (Cycocel).

Chloropicrin Fumigant (Agrigas, Fungafume, Bromopic). Internationally banned or targeted for phase out in five countries. Internationally Severely Restricted in one country.

Chloroxuron Herbicide (Tenoran*).

Chloropropham Herbicide (Agchem Potato, Stop-Sprout).

Chlorpyrifos Insecticide (Dursban, Lorsban, Killmaster).

Chlorsulfuron Herbicide (Glean, Siege, Tackle, Display, Purge).

Clethodium Herbicide

Clofentezine Insecticide

Clopyralid Herbicide (Lontrel, Crop King, Thiselex).

Chlorthal-dimethyl Herbicide (Dacthal, Shamrox, Prothal). Internationally banned or targeted for phase out in one country.

Cyanazine Herbicide

Cyfluthrin Insecticide (Buffalo, Responsar, Solfac, Bulldock).

Cypermethrin Insecticide (Barricade, Cymbush, Bonus).

Dicamba Herbicide (Erase, Banvel, Kleen Lawn, Defender, Barrel, Maestro).

Dichlobenil Herbicide (Rootfoam, Casoron).

Dichlofluanid Fungicide (Euparen, Protim).

Dichlorophen Fumigant (Barmac, Kendon Kenocide).

Dichlorvos Insecticide (Vapone, DDVP, Terminator).

Diclofop-methyl Herbicide (Hoegrass, Digrass, Nugrass).

Dicloran Fungicide (Allisan).

Dicofol Insecticide (Kethane, Masta-Mite, Tetrafol). Internationally banned or targeted for phase out in two countries. Internationally Severely Restricted in one country.

Didecyl dimetyl ammonium chloride (Sapstain).

Diethyltoluamide Insecticide (Scram Easy, Bolt).



Diflubenzuron Insecticide (Fleececare).

Diflufenican Herbicide (Broadal, Jaguar, Tigrex).

Diniconazole Fungicide

Diuron Herbicide (Di-On, Diurex, Rezalon). Internationally banned or targeted for phase out in one country..

Endosulfan** Herbicide (Thiodan, Endosan, Thionex). Internationally banned or targeted for phase out in three countries. Internationally Severely Restricted in seven countries.

Esfenvalerate Insecticide

Ethephon Herbicide (Ethrel, Cerone, Bounty).

Etridiazole Fungicide (Terrazole).

Fenarimol Fungicide (Rubigan). Internationally banned or targeted for phase out in one country.

Fenoxaprop-ethyl Herbicide (Puma, Tristar).

Fenvalerate Insecticide (Sumicidin, Sumifly).

Flamprop-methyl Herbicide (Mataven).

Fluazifop-p-butyl Herbicide (Fusilade). Internationally banned or targeted for phase out in one country.

Fluvalinate Insecticide (Mavrik, Klartan).

Haloxyfop Herbicide (Verdict).

Heptachlor** Insecticide (Gold Crest Heptachlor). Internationally banned or targeted for phase out in eighteen # countries. Internationally Severely Restricted in nine countries.

Imazilil Herbicide (MCPA-500, Banvel, Tropotox, MCBP-400).

Imidacloprid Insecticide

Iprodione Fungicide (Roval).

Lambda-cyhalothrin Insecticide (Karate, Icon).

Lindane Insecticide

Linuron Herbicide (Afalon, Shamrox, Linuron). Internationally banned or targeted for phase out in one country.

MCPA Herbicide (MCPA-500, Banvel, Valiant).

MCBP Herbicide (Tropotox, MCBP-400).

Mecoprop Herbicide (Clovoxal). Internationally banned or targeted for phase out in one country.

Methazole Herbicide (Probe, Eclipse).

Metolachlor Herbicide

Mirex** Insecticide (Mirex). Internationally banned or targeted for phase out in five countries. Internationally Severely Restricted in three countries.

Myclobutanil Insecticide (Systhane).

N-alkyldimethyl-benzylammonium chloride (Combat).

o-dichlorbenzene Insecticide (KFM Blowfly Dressing). Internationally banned or targeted for phase out in one country.

Ortho-phenylphenol Insecticide (Chloromide).

Oxadiazon Herbicide (Ronstar).

Oxyfluorfen Herbicide (Goal, Rout). Internationally banned or targeted for phase out in one country.

Paclobutrazol Herbicide (Cultar, Clipper, Bonzi).

Paradichlorobenzene Insecticide (Florozettes, Fresh Klen, Virbac, Kleen-Dok).

Penconazole Fungicide (Topas).

Pentachlorophenol Wood Preservative (Protim, PCP). Internationally banned or targeted for phase out in seven countries#. Internationally Severely Restricted in sevencountries.

Permethrin Insecticide (Ambush, Coopex, Defender).

Paraquat Herbicide (Spray Seed, Spray Top, Gramaxone, Nuquat, Para-Di). Internationally banned or targeted for phase out in four countries. Internationally Severely Restricted in three countries.

Picloram Herbicide (Tordon, Grazon). Internationally banned or targeted for phase out in one country. Internationally Severely Restricted in one country.

Prochloraz Fungicide (Sportak, Octave, Protak). Internationally banned or targeted for phase out in one country.

Procymidone Fungicide (Sumisclex).

Profeneofs Insecticide

Propachlor Herbicide (Prothal, Ramrod).

Propamocarb Fungicide (Previcur).

Propanil Herbicide (Ronacil).

Propazine Herbicide

Propiconazole Fungicide (Tilt, Banner).

Propyzamide Herbicide (Kerb, Shogan).

Prothiophus Insecticide (Tokuthion).

Pyridate Herbicide

Pyrifenox Fungicide (Boxer).

Quintozene Fungicide (Terraclor, Purasoil). Internationally banned or targeted for phase out in three countries. Internationally Severely Restricted in onecountry.

Quizalofop Herbicide (Assure, Targa).

Simazine Herbicide (Gesatop, Flandor, Simat).

TCA Herbicide (Total, Fenocil, Chloronex).

Tebuconazole Fungicide (Folicur, axil).

Terbacil Herbicide

Tetradifon Insecticide (Tedion). Internationally banned or targeted for phase out in one country.

Thiobencard Herbicide (Satum EC).

Tolclofos-methyl Fungicide (Rizolex).

Triaimefon Fungicide (Bayleton).

Triadimenol Fungicide (Bayfidan, Baytan).

Tri-allate Herbicide (Avadex).

Trichlorfon Insecticide (Dipterex, Lepidex, Trichlorphon).

Triclopyr Herbicide (Blackberry & Woody Killer).

Triflumozole Fungicide

Triforine Fungicide (Saprol, Kendon, Zest Rose Spray).

Vinclozolin Fungicide (Ronilan).

End Notes

4. Rose, J. (1994). A Change of Focus. Toxics Use Reduction. An Integrated approach to pollution prevention, worker safety and public health. Australian Centre for Environmental Law, ANU. p5.

5. Guruswamy, L. (1991). The Case for Integrated Pollution Control, Law and Contemporary Problems. Vol 54, No 4. p.41. 55.

10. Johnston, P.A. & Stringer, R.L. (Sept 1994). Environmental Significance and Regulation of Organochlorines. Greenpeace Exeter Research Laboratories, University of Exeter, UK p.9. There are serious concerns about the use of microcolimetric methods being used in some EEC countries such as Germany and Denmark. For example, the AOX (Absorbable Organohalogens) does not take into account the complexity of effluents and toxicity to the environment and is cosequently not adequate for environmental protection.

11. Substances such as natural organohalogens, including organochlorines, are very confusing for substance regulation, since the precise function of many of them is unknown.

12. Johnston, P. & McCrea, I. (1992). Death in Small Doses: the effects of organochlorines on aquatic ecosystems. Greenpeace International. p.2.

13. Ibid p.17

14. Allsopp, M. (1994). Achieving Zero Dioxin: an emergency strategy for dioxin elimination. Greenpeace International, September 1994.

16. Industry and Trade Information from Greenpeace International.

44. Allsopp. Op. cit. p.36.

45. Imray, P. (1992). Physicochemical properties, environmental behaviour and bioavailability of organochlorines, in The health risk assessment and management of contaminated land: setting investigational soil criteria for chlorinated hydrocarbons, Proceedings of a Workshop on the Health Assessment and Management of Contaminated Land, Perth.

46. Short, K. (1994). Quick Poison-Slow Poison: Pesticide Risk in the Lucky Country. Southwood Press, St. Albans, NSW p.66.

47. Australian Bureau of Statistics, Monograph No 3808109025, 3808300028, 3808400030.

48. Short. Op. cit. p.70.

49. Allsopp. Op. cit.

50. Ibid.

51. Raioff, J. (1994). Gender Benders - are environmental 'Hormones' emasculating wildlife? Science News, Vol 145. pp. 24-27.