Citation: Sharon Beder, 'The dioxin controversy: spilling over into schools', Australian Science Teachers' Journal, November 1998, pp. 28-34.

This is a final version submitted for publication. Minor editorial changes may have subsequently been made.

Sharon Beder's Other Publications


The production of industry sponsored and funded educational materials is a growing trend that stems from the US where hundreds of millions of corporate dollars are spent each year for this purpose. The aim of this material is to teach children a corporate view of scientific and environmental controversies in a way that is often too subtle for teachers to realise. In this paper educational materials produced by the chemical industry in both the US and Australia, which give an industry viewpoint on dioxin, are used as a case study.

The health and environmental effects of dioxin have been the subject of fierce debate for more than 20 years. Dioxin earned a reputation as "one of the most toxic substances know to humans" as a result of tests on animals which found that one form of dioxin, 2,3,7,8-TCDD, was "the most potent carcinogen ever tested." There are 75 other dioxin compounds, apart from 2,3,7,8-TCDD, of varying toxicity (Hay, 1989; Roberts, 1991).

Dioxins are by-products of many industrial processes including waste incineration, chemical manufacturing, chlorine bleaching of pulp and paper, and smelting. In fact any process in which chlorine and organic matter are brought together at high temperatures can create dioxin (Johnson, 1995). It is for this reason that the debate over dioxin has been central to Australian controversy over pulp and paper mill discharges as well as the emissions of municipal and medical waste incinerators. The proposal to site a high temperature incinerator in Australia also focussed on the issue of dioxin emissions and their relative safety (Beder, 1991; Beder & Shortland, 1992).

Between the 1950s, when dioxin was discovered to be a contaminant in herbicides, and 1995, when the US Environmental Protection Agency (EPA) concluded that the general population may be exposed to unacceptably high levels of dioxins, corporations have set out to confuse the public and influence government regulation of dioxin. That debate is now reaching into the classrooms with the production of 'educational' materials designed by the chlorine industry to stress the importance of chlorine to children and to downplay the risks associated with dioxins.

Targeting Education: Infiltrating School Lessons

Teachers are being overwhelmed with free and unsolicited curriculum material from public relations firms, corporations and industry associations (Ely-Lawrence, 1994). The corporate stampede to get their messages into schools through 'educational' resources whilst their customers are very young is a recent phenomenon (Vandervoot, 1991). In 1993 corporations spent $381 million in the US on school education which accounted for 15 per cent of all corporate donations (Anon., 1995). Australian companies and industry associations are beginning to follow this trend and a researcher for APM Educational Media estimates that there is potential for a multi-billion dollar market in Australia.

Lifetime Learning Systems is one of the companies which compiles educational materials on behalf of corporations and trade associations. It services more than 350 corporations in the US alone, as well as associations such as the American Nuclear Society, and claims to reach almost one hundred percent of US schools-63 million young people every year (Jacobson & Mazur, 1995; Karpatkin & Holmes, 1995). According to Lifetime Learning Systems promotional literature (Jacobson & Mazur, 1995; Shenk, 1995) :

Let Lifetime Learning Systems bring your message to the classroom, where young people are forming attitudes that will last a lifetime.

Coming from school, all these materials carry an extra measure of credibility that gives your message added weight.

Often the corporate message is so subtle that the teachers don't even notice it. If they do they may turn a blind eye so that they can use the materials, which are hard for teachers to resist, particularly those from poorly resourced schools (France, 1996). The materials, professionally produced with lots of colour and games, prepared homework assignments and even computers that automatically grade the students work, are either offered for free or very cheaply (Knaus, 1992; Lapp, 1994).

In the US, as in Australia and Canada, school education receives inadequate government funding and teachers have few teaching resources available to help them outside of what is offered by corporate and trade interests. In Canada, the Ontario Secondary School Teachers' Federation has prepared and distributed a pamphlet on the commercialisation of schools in Canada, noting that budget cuts by provincial governments in the 1990s have made the school system a major target for business interests who seek to fill the resource gap (Anon., 1996).

Some say that corporations are "taking advantage of schools short on funds by feeding them materials, filled with company logos, that are designed to encourage consumption." (Fried, 1994) It is almost as if underfunding of schools is part of a corporate strategy to enable advertisers better access (Knaus, 1992). At the very least corporate sponsorship of school resources enables the underfunding of schools by governments to continue (Anon., 1996).

In most cases the so-called educational materials give students a distorted picture of environmental issues and other problems, social choices and tradeoffs. They present a corporate view as 'fact' and report the results of corporate funded studies without saying who financed them. Classroom materials prepared by the chemical industry on chlorine in Australia and the US have sought to promote the essential nature of chlorine as n element and the benefits of chlorine as an input to industrial processes in response to new findings on the dangers of dioxin which threaten the future of chlorine-based products.

Dioxin Findings-New Dangers

The US EPA's most recent assessment study of dioxin found that:

There is adequate evidence from studies in human populations as well as in laboratory animals and from ancillary experimental data to support the inference that humans are likely to respond with a plethora of effects from exposure to dioxin and related compounds. (Montague, 1994a)

Most significant in this analysis is the heightened concern about noncancer effects in humans, including disruption of the endocrine, reproductive, and immune systems, as well as dioxin's impact on the developing fetus, which may occur in some cases at or near background levels. (Johnson, 1995)

The report referred to studies that had found "decreased sperm count in men, higher probability of endometriosis in women, weakened immune systems, and other health problems" as a result of dioxin exposure in the general population at levels already found in the food supply. The report claimed that current background levels of dioxins could be posing a risk of one additional death in every thousand or one in every ten thousand, even though as little as 30 pounds of dioxin may be released in the US each year (Johnson, 1995; Reichhardt, 1994; Stone, 1994).

The study found that most dioxin is carried through the air and taken up by plants, which are in turn eaten by fish and animals which bioaccumulate the dioxin in their fatty tissues. By the time humans eat the fish, beef, dairy products etc, the dioxin is far more concentrated than it originally had been in the environment and it accumulates in the fatty tissues of humans. Ingestion of dioxin via food is a far more significant means of exposure than breathing in polluted air. The report noted that the major source of dioxin was incinerators, and that sources such as chemical manufacturing could be significant but that there was insufficient data on them to be able to say (US EPA, 1995).

The study took almost four years (1991-94) and cost $4 million. Because of the way that dioxin was thought to mimic hormones in binding to receptors in the cells, the EPA considered a range of chemicals that act in this way including the family of dioxins, dibenzofurans (or furans) and PCBs calling them 'dioxin-like' chemicals. The study involved about 100 scientists including non-EPA scientists used to peer review each chapter as it developed. EPA management decided that:

since the question of dioxin's risk had been marked by considerable controversy for more than a decade, we should pursue a process that would achieve scientific consensus on this issue... As a first step, it would be conducted as a cooperative effort, written by both EPA scientists and external scientists and peer-reviewed by scientists outside the Agency who were experts on dioxin. We hoped this would help ensure not only that the most current, most scientifically accepted information was used, but also that all scientific views would be heard and debated. (Preuss & Farland, 1993)

Public comments were invited, three peer-review workshops were held and the drafts of each chapter, most of which were authored or co-authored by outside scientists, were reviewed and revised by a panel of scientists from other government agencies. In 1994 a draft report was released and open to public comment and in 1995 the final report was published.

Chlorine Industry Public Relations

Whilst the new risk assessment was being put together by the EPA, the scientific studies that were emerging were causing alarm in industry groups. The Chemical Manufacturers Association, established the Chlorine Chemistry Council in 1993 "to handle public relations, political lobbying, and 'scientific initiatives' on all issues for the chlorine industry". By 1994 the Council was receiving an estimated $12 million annual funding plus another $120 million of in-kind support from member companies. It hired two public relations firms to augment its own public relations staff (Gibbs & Waste, 1995; Weinberg, 1995).

The Chlorine Chemistry Council hired PR firm Mongoven, Biscoe & Duchin (MBD) which analysed the EPA reassessment report and its public relations implications. MBD warned the Chemistry Council that environmental activists would use "children and their need for protection to compel stricter regulation of toxic substances" and that "this would reduce all exposure standards to the lowest possible levels..." It also warned that the use of the 'precautionary principle' would be pushed by activists and therefore the industry should fight against the precautionary principle and "assist the public in understanding the damage it [the principle] inflicts on the role of science in modern development and production..." (Mongoven, 1994) According to Peter Montague of the Environmental Research Foundation:

Mongoven's long-term strategy is to characterize the 'phase out chlorine' position as 'a rejection of accepted scientific method,' as a violation of the chlorine industry's Constitutional right to 'have the liberty to do what they choose,' and in that sense as a threat to fundamental American values. (Montague, 1996a)

MBD (Mongoven, 1994) recommended a series of steps the Chlorine Chemistry Council should take including;

Of particular relevance to this article, the Chlorine Chemistry Council has developed classroom materials that seek to influence children in this debate. The stated aim of these materials is to "improve the way science and environmental issues are discussed in the classroom". The Council has produced a newsletter for teachers, curriculum materials, and a module for 9th and 10th graders on Understanding Environmental Health Risks that encourages children to "weigh risks and benefits so they can make sound decisions about environmental hazards." (Chlorine Chemistry Council, 1996a)

A package entitled Welcome to Building Block City! has been described by the a US Consumers Union study of environmental materials (CUES, 1995) as "Commercial and incomplete with several inaccuracies and strong bias for chlorine compounds... Fosters false sense of how safe chlorinated chemicals are." Similar materials are produced by individual chemical companies in Australia such as ICI Australia which produces a book on chlorine, aimed at Australian and NZ students, entitled "It's Essential."

The basic argument promoted in chlorine industry materials is that both dioxin and chlorine are perfectly natural (and by implication safe or at least non-threatening), in fact chlorine is an essential building block of the planet. Chlorine-based products made from this basic building block are not only useful and beneficial but essential to our way of life. There are risks associated with everything we do and any risks associated with chlorine-based products are minor compared to the benefits. These arguments are examined below:

Dioxin occurs naturally

The chlorine industry has attempted to attribute much of the dioxin in the environment to natural sources and to everyday familiar processes in an attempt to rid it of its image as a synthetic, man-made toxin. The idea is to present it as a natural part of modern life and to disassociate it from chlorine. The argument was first introduced by Dow in 1978 and is still used today. The Chlorine Chemistry Council says:

Among the natural sources of dioxin are forest fires, volcanoes, and compost piles. Man-made sources of dioxin include municipal, hospital and hazardous waste incinerators, motor vehicles, residential wood burning and a variety of chemical manufacturing process. With so many sources, it is not surprising that scientists have detected dioxins virtually everywhere they have looked. (Weinberg, 1995)

Similarly, educational materials produced by ICI Australia state that "It is worth noting that virtually all combustion processes produce dioxins. The main sources of dioxin production are thermal processes such as vehicle exhausts and domestic, industrial and hospital incineration... Forest fires and volcanic activity also contribute dioxins to the atmosphere." (Rome, 1995)

In contrast the EPA study concluded: "The presence of dioxin-like compounds in the environment has occurred primarily as a result of anthropogenic practices", that is human activities. It based this conclusion on the sampling of tissue of ancient humans and sediments in lakes near industrial centres in the US which showed low levels of dioxins prior to 1920 (US EPA, 1995).

Chlorine as a Building Block

Dioxin is a byproduct of the chlorine industry and dioxin is ubiquitous because chlorine products are ubiquitous. Motor vehicles emit dioxin because chlorinated chemicals are added to petrol, wood burning releases dioxin because of the use of chlorine-based wood preservatives and that incinerators are a major source of dioxin because of the chlorine-containing wastes burnt in them-PVC plastics in medical waste incinerators, chlorinated solvents and pesticides in hazardous waste incinerators, and PVC plastics, chlorine-bleached paper, chlorine-containing paints, pesticides and cleaners in municipal incinerators (Weinberg, 1995). It is this connection between dioxin and chlorine that poses the greatest threat to the chlorine industry and has led environmentalists to campaign against the manufacture of chlorine-based chemicals. For example Greenpeace says:

Dioxin in the environment at levels that potentially threaten human health is neither natural nor unavoidable; it is the necessary result of the production, distribution and disposal of the products of chlorine chemistry. Eliminating dioxin generation will require that humans stop making the chlorine-based chemicals that inevitably lead to dioxin formation. (Weinberg, 1995)

However this call for the end to the manufacture of chlorine-based chemicals has been interpreted by the industry as a call to ban chlorine. The Competitive Enterprise Institute, a think tank which has received funds from the Chemical Manufacturers Association, put out an essay subtitled "The End of Chlorine" which claimed that "there is a mounting campaign, led by environmental activists in wealthy industrialized nations, to eliminate every last man-made chlorine molecule from the face of the earth." (CEI, 1995)

The educational materials produced by the Chlorine Chemistry Institute also aim to "introduce chlorine as an important 'building block,' one of a handful of single elements that combine to form most of the matter on the earth." (Chlorine Chemistry Council, 1996a) In this way they can ridicule the idea of banning chlorine and also imply that chlorine-based products merely extend a natural process of building with chlorine. The idea of not using chlorine in industry is then supposed to seem preposterous. After all even products as harmless as common table salt incorporate chlorine.

Greenpeace's calls for a gradual phase out of the industrial use of chlorine have however been backed up by more respected mainstream organisations as the effects of dioxin emerged during the 1990s. In 1992 the Science Advisory Board of the International Joint Commission on the Great Lakes (IJC) concluded that organochlorines were a public health threat and that the use of chlorine as an industrial feedstock should be phased out:

We conclude that persistent toxic substances are too dangerous to the biosphere and to humans to permit their release in any quantity...We know that when chlorine is used as a feedstock in a manufacturing process, one cannot necessarily predict or control which chlorinated organics will result, and in what quantity. Accordingly, the Commission concludes that the use of chlorine and its compounds should be avoided in the manufacturing process. (Montague, 1996b)

The following year, in 1993, the Governing Council of the American Public Health Association, one of the leading scientific and medical associations in the US, unanimously endorsed a resolution urging US industries to stop using chlorine. It stated "the only feasible and prudent approach to eliminating the release and discharge of chlorinated organic chemicals and consequent exposure is to avoid the use of chlorine and its compounds in manufacturing processes" (Montague, 1996a)

The Vast Benefits of Chlorine

A main argument presented by the chlorine industry and emphasised in school materials is that chlorine-based chemicals provide vast benefits to society that we cannot do without. Chlorine industry supporters say that banning chlorine would mean that millions of people in the third world would die from want of disinfected water:

Even more daunting, a chlorine phase-out would halt the production of most plastics, pesticides and chlorine-containing drugs.... From safe drinking water, clean swimming pools, pest-free crops, to flame retardants and food packaging, quality white paper and bright socks, Saran wrap, plastic bottles, garden hoses, window frames and sturdy plumbing pipes, the end of chlorine would spell the end of modern civilization itself. (Malkin & Fumento, 1995)

The Chemistry Council's teaching materials similarly stress the benefits of chlorine. One activity, "Chlorine in our Lives" involves giving students a list of products in their that are manufactured with chlorine. Students are asked to circle which products are found at their school or in their homes. Teachers are instructed "Explain that chlorine likes to combine with other elements and compounds, and scientists have found ways for chlorine to help or build or improve things." Another involves an experiment with bleach. Teachers are instructed: "Tell students that chlorine is present in many other compounds that are a common part of our daily lives."

ICI Australia's "It's Essential" details "Investigations into chlorine for years 7 to 10 secondary school science (Rome, 1995). Teachers are told "After completing the activities, students should be able to:

It should be remembered that the range of chlorine compounds includes many harmless and indispensable compounds. Considering our lifestyles, it would be virtually impossible to eliminate all of them without suffering huge losses in the areas of public health (water and sewerage treatment, pharmaceuticals), electronics (cleaning solvents and insulation) and housing materials (plastics, paints) and paper and textile bleaching to name just a few. (Rome, 1995)

A writer in the Texas Observer noted:

The CCC [Chlorine Chemistry Council] and its allies are quick to characterise any attempt to point out the connection between dioxin, organochlorines and chlorine production as part of a sinister campaign to 'ban chlorine' immediately, so that they can conjure up the catastrophic effects and costs of an abrupt elimination of chlorine-as if it were to happen overnight, without transition or alternatives. (King, 1996)

Indeed the Council argues that chlorine is "irreplacable in our economy" and "it's hard to envision life without it." However, as well known environmental scientist Barry Commoner pointed out to a Citizen's Conference on Dioxin, chlorine-based products have permeated the modern world "not so much by creating new industries as by taking over existing forms of production... It grew through a virulent from of industrial imperialism." He suggests that there are and have been alternatives to these chemicals (Montague, 1994b).

The chair of the International Joint Commission which recommended a phasing out of the industrial use of chlorine, Gordon Durnil, a conservative Republican Bush appointee, wrote in his book The Making of a Conservative Environmentalist that the Commissioners had discussed how long a phase out would take, thinking that it might take 50 years. They were amazed when "Industry came to us and told us how stupid we were" for suggesting a phase out of chlorine because "finding a suitable alternative might take thirty years. Later they reduced that to twenty years." (Montague, 1996b)

Understanding Risks

The Council presents taking risks to children as an everyday part of life such as driving a car or flying in a plane: "Risk accompanies virtually everything we do. Even seemingly 'safe' activities, such as taking a bath or climbing stairs, sometimes result in injury or death." (Chlorine Chemistry Council, 1996b) The implied message is "why even bother about the risk of chlorine products when the benefits are so obvious?"

Although published after the US EPA study on dioxin, ICI's school materials describe the dangers of dioxin: "Of the 210 related compounds, 17 are considered toxic and one, TCDD (tetrachloro dibenzo para dioxin) is highly toxic to rodent species. The toxicity of dioxins, however, is currently under review" and "Only one dioxin at this stage has been shown to affect humans by causing headaches, nausea, sleeplessness and a skin complaint, although research is continuing." (Rome, 1995) In fact TCDD has found to be toxic to all animals it has been tested on and the US EPA found sufficient evidence to conclude "that humans are likely to respond with a plethora of effects from exposure to dioxin and related compounds" such as birth defects and lowered immunity (Montague, 1994a).

The Managing Director of the Chlorine Chemistry Council, C. T. Howlett, told a UN working party:

Rather than being guided by what we know-the scientific facts about chlorine and chlorinated compounds and the many benefits they have brought to society-the debate is revolving around what we don't know and the fears that spring from a lack of understanding and rush to judgement. (Howlett, 1995)

He called for the debate to move from "Greenpeace's slanderous characterization of 'Absolute Death' to the scientific reality of 'Absolute Necessity'..." and that common sense would show that chlorine chemistry's benefits more than outweighed its "hypothetical risks." He even suggested that dioxin "may ironically help provide a cure for breast cancer" by providing, at certain exposure levels, "a form of chemoprotection." (Howlett, 1995)

Parent Teachers Associations

Another example of how the Chlorine Chemistry Council has been operating at the school level is the battle over anti-dioxin resolutions at a Texas Parent Teacher Association (PTA) convention in 1995. A number of local PTAs had passed such resolutions without too much fuss prior to the state convention. Then less than two weeks before the convention a number of industry groups including the Chlorine Chemistry Council, the Texas Chemical Council, the Texas Association of Business and Chambers of Commerce and various others became involved in a pre-convention battle to thwart the resolutions (King, 1996). One of the resolutions stated that the PTA "supports legislation and actions that decrease, phase-out and eliminate the creation, release and exposure of dioxins...[and] the use of alternative processes, technologies, and products that avoid exposure to Dioxin, especially those that are chlorine-free." (Lester, 1995)

A front group of six PTA members who posed as 'concerned parents' sent a letter with a package of information "from leading citizen and business organizations, academic scientists and public officials" to PTA members and convention delegates. In the letter they labelled the resolutions as "one-sided... inaccurate and misleading." They described the resolution calling for the elimination of dioxin as a ban on chlorine and chlorine-derived products. The second resolution, which opposed the use of hazardous waste as fuel in a local cement kiln run by TXI, was characterised as a threat to legitimate business. Three of these 'ordinary parents' were members of the Chemical Council, one of them an employee of Du Pont; a fourth parent was TXI's director of communications; and a fifth was a "government affairs consultant" for mining companies and married to the director of the front group Texas Citizens for a Sound Economy (King, 1996).

Parents also received a letter from the President of the Texas Institute for the Advancement of Chemical Technology which claimed that "the use of waste-derived fuel by cement kilns has been proven safe by state and federal studies" and that "no scientific evidence exists connecting the process with any negative effects". The letter also cited the beneficial uses of chlorine and the jobs the chlorine industry provided (Lester, 1995).

Before the convention, five professional chemical industry representatives met with the proposer of the motion for three days, persuading her to change the wording of the anti-dioxin resolution. In the end she accepted their reworded resolution which avoided all mention of chlorine and called for further research and "voluntary reductions" of dioxin. That resolution was passed but the second resolution on the cement kiln was postponed indefinitely in a procedural motion before discussion could take place (King, 1996).


Whilst the final outcome of the dioxin battle remains to be seen, it is clear from this account that corporations have engaged in a concerted and lengthy public relations campaign to portray dioxin as relatively safe. They have used educational materials as part of their public relations efforts to do this.

Clearly the infiltration of school curricula through offering corporate based curriculum material and lesson plans in their place can conflict with educational objectives and also with the attainment of an undistorted understanding of environmental problems. Unfortunately children are usually not able to discriminate between genuine education and the manipulative messages of corporations. Many assume that what they are taught in the classroom must be the truth (Knaus, 1992)


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