by Mr. Jack Weinberg

I thank UNEP and the Russian Federation State Committee on Environmental Protection for inviting me to this workshop on persistent organic pollutants - or "POPs" - for East European government representatives, and others. My assigned topic is to present the view of non-governmental organizations - "NGOs" - on POPs as a global problem. I will expand the assignment and also present an NGO perspective on proper and appropriate solutions to this very serious global problem.

I am here representing the international environmental organization, Greenpeace. My organization works very actively to eliminate persistent organic pollutants from the environment in many countries and has been doing so for more than a decade. The perspective I will present, however, is shared not only by Greenpeace, but also - at least in general terms - by most independent environmental and public health advocacy organizations that have addressed these issues.

I am especially excited to attend this workshop in the city of St. Petersburg on the shores of the Baltic Sea.

My home in the United States is Chicago and I have lived most of my life near the shores of our great inland water system, the Great Lakes of North America. My own interest and knowledge about POPs begins with the experience of my region.

While, of course, there are important differences - the Great Lakes is a fresh water system while the Baltic's water is salt - there are also important similarities. So much so that I have warm feelings about the Baltic as a "sister" region.

Both waterways are centers of international transport and commerce. Both have major, world class cities on their shores with combined populations in the tens of millions. Both are centers of industry and of agriculture. And both are northern waterways that have suffered serious pollution problems.

In the 1960's, pollution in the Great Lakes became a highly visible public issue. In one of the Great Lakes - Lake Erie - life systems collapsed and the newspapers declared that Lake Erie was "dead."

The source of this highly visible and politically embarrassing pollution problem was a class of pollutants that might be called "conventional" pollutants or "gross" pollutants. This category includes untreated or poorly treated sewage; phosphate-containing detergents, fertilizers and other nutrients; uncontrolled industrial discharges; oil and grease; and so on.

These pollutants caused algae blooms and fish die-offs (caused by eutrophication). Fecal matter could be found in the lakes. Beaches were closed to swimming. Surface pollutants on tributary rivers in industrial cities would sometimes catch on fire. The Great Lakes, at many locations, could be very dirty and smelly.

By the end of the 1980's, however, as a result of concerted action under cooperative leadership from the Canadian and American governments, gross pollution in the Great Lakes was significantly reduced. Problems remained, but their scope was diminished and the lakes appeared to be much improved.

New sanitary treatment works had been constructed and were operating. Phosphate detergents and other nutrient sources had been significantly abated. Direct discharges by industrial facilities to the waterways were being routinely monitored, tested and controlled.

The water of the Great Lakes system, in most locations, looked cleaner and smelled cleaner. Beaches reopened; some decimated fish populations began to recover. Political leaders took credit for what was widely seen as a success story.

The experience contains useful lessons on the abatement of conventional pollutants. This subject may be of further interest to some of you, but it is not my area of expertise nor the topic of the present workshop. I bring up the example of the Great Lakes because also it provides important lessons about persistent organic pollutants.

While conventional pollution in the Great Lakes system was largely brought under control, top predator species never recovered. In fact, even in remote and pristine corners of the Great Lakes system that had never been much affected by conventional pollutants, populations of predator species suffered injury and decline. The source of this injury was persistent pollutants: an invisible infliction that no one can see and no one can smell.

This provides an important lesson. When a large water system is fouled with gross and conventional pollutants, it may be difficult to fully appreciate or even comprehend the effects of persistent organic pollution even though these impacts are present and real.

A second lesson learned in the Great Lakes is that persistent organic pollution is a phenomenon that is very different from pollution arising from more conventional sources. Most conventional pollutants entering the Great Lakes originated from near-shore activities. (Acid rain and airborne nutrient depositions were also of some concern.) These conventional pollutants, however, could be effectively controlled, in many cases, through measures that reduce inputs to levels that the Great Lakes water system can dilute and assimilate without harm.

POPs, on the other hand, are more likely to enter the lakes through the air from distant sources. Upon entering the water system, POPs tend not to become dilute, but rather, they tend to build up through the food chain, accumulate in the tissues of biota, and can cause injury to living things at microscale concentrations.

Because of these mechanisms, the ecosystem has, in effect, no - zero - assimilative capacity for POPs. Abatement strategies and programs that may have proven good and useful for controlling conventional pollution are often totally inappropriate and of little use as solutions to persistent organic pollution. This lesson applies not only to the marine or other aquatic ecosystems, but to terrestial ecosystems as well.

And there was a third important lesson from the Great Lakes experience. Human populations are part of the ecosystem. Persistent organic pollutants that injure fish and wildlife can also directly injure human health.

A 1991 Great Lakes Science Advisory Board Report to a joint US/Canadian intergovernmental commission (the International Joint Commission or IJC) reviewed the literature on more than a dozen Great Lakes predator species including eagles, cormorants, trout, mink, turtles and others. The report found that all these species suffered significant health effects including some combination of:

This observed health injury, according to the Report, was caused by persistent pollutants that concentrate through the food chain. The same pollutants were also found to be present in human food and to contaminate human bodily tissues.

The Science Advisory Board Report focused much of its attention on persistent organics (POPs) and especially on the chlorinated organic such as dioxins, PCBs, DDT and metabolites, dieldrin, toxaphene and others. The Report noted that often, the main health injury does not appear in the exposed adult population, but rather, in the offspring.

The International Joint Commission, reviewed the report of its science advisors and observed:

The International Joint Commission asked:

The Commission then answered its own queries:

To address this injury to the Great Lakes ecosystem and to human health, the IJC, in 1992, proposed a stepwise and consultative process to eliminate persistent pollutants at the source. The centerpiece was a process the IJC called "sunsetting" which they defined to be: "a comprehensive process to restrict, phase out and eventually ban the manufacture, generation, use, transport, storage, discharge and disposal of a persistent toxic substance."

The IJC forwarded specific recommendations to the U.S. and Canadian governments as the Parties to a bi-national agreement on Great Lakes water quality. Most of these recommendations were formally adopted as commitments by both governments. Among those accepted by both governments were commitments that:

Similar concerns were also being debated at that time under the auspices of the Oslo and Paris Conventions (OSPAR) for Preventing Marine Pollution in the North East Atlantic. In 1992, Contracting Parties to OSPAR plus Luxembourg, Switzerland and the European Union agreed in a Ministerial Declaration, that:

Contracting Parties to the Oslo and Paris Conventions are Belgium, Denmark, the European Union, Finland, France, Germany, Iceland, Ireland, the Netherlands, Norway, Portugal, Spain, Sweden, and the United Kingdom.

In 1993, the Contracting Parties to the Barcelona Convention for the Protection of the Mediterranean Sea agreed:

The Contracting Parties to the Barcelona Convention are Albania, Algeria, Bosnia, Croatia, Cyprus, Egypt, the European Union, France, Israel, Italy, Lebanon, Malta, Monaco, Morocco, Portugal, Spain, Slovenia, Syria and Tunisia.

Environmental and public health advocacy organizations were pleased that this large and influential group of governments had committed to the elimination of POPs. Segments of the chemical industry and others, however, mounted vigorous resistance. As a result, in many cases, governments failed to follow-up with proper action. This was a disappointment to the NGO community.

Five years have now passed since this first round of governmental commitments to eliminate POPs. During that time, evidence of serious injury from POPs has continued to grow and deepen. Where previously, persistent organic pollution was viewed mainly as a regionally centered concern - in the Great Lakes region, in the North Sea region, in the Mediterranean region - good evidence has emerged that POPs cause serious injury in all regions and at every latitude. The greatest injuries from POPs, however, have been documented in the Arctic, often at locations thousands of kilometers from known sources. We now know:

POPs contaminate the tissues of virtually all living creatures in all regions of the planet.

Some chemical industry representatives deny this problem because it is often difficult to demonstrate, to a high degree of certainty, the cause and effect linkage between a specific persistent organic pollutant and injury to a specific organism or person. Each individual, after all, is exposed to hundreds of synthetic organic pollutants. Nor is there any clean or "uncontaminated" control population - among humans or among wildlife.

Despite these uncertainties, however, intelligent and resourceful researchers have developed a body of literature that provides strong indication that injuries from persistent organic pollutants are real and potentially severe.

Not only have POPs been shown to disrupt ecosystems and to decimate many wildlife populations, but the scientific literature increasingly reveals - based on numerous studies - that human health can be seriously impacted. The weight of evidence is now so strong that there is no longer any valid excuse for delay - particularly in relation to those persistent organic pollutants for which evidence of injury is well established.

Strong evidence suggests that persistent organic pollutants in the environment are associated with the following impairments to human health:

Stories about injury to human health from POPs now appear in the popular press with growing frequency. Members of the public are learning that in humans as in wildlife, the greatest injury from POPs is to the offspring generation, not to the exposed adult.

In response, people in many different parts of the world have begun to ask of their governments:

These are important questions. Governments must listen! They must then take proper action.

But because persistent organic pollutants travel such long distances, they pose a global problem that can not be effectively addressed by single governments or even by regions acting alone. This creates pressure for global action.

Also, because international trade has become so important and because national economies have become so interconnected, purely national efforts to effectively prevent POPs are unlikely to be fully practical or feasible. This too creates pressure for global action.

In June, 1995, the governments of Canada and the Philippines convened an International Experts Meeting on POPs in Vancouver, Canada. More than one hundred experts from over forty countries attended including significant representation from developing countries. After five days of discussion, the experts concluded that, in their judgment:

For the next 18 months, discussion and debate at the international level continued. This discussion largely was held under the auspices of an Ad Hoc Working Group on POPs created for this purpose by the Intergovernmental Forum on Chemical Safety (IFCS). In June, 1996, meeting in Manila, the Philippines, the IFCS POPs Working Group adopted a report and recommendations on POPs that was forwarded to the United Nations Environmental Programme (UNEP).

The Governing Council of UNEP, meeting in Nairobe, Kenya in February of 1997, with representatives present from one hundred governments, adopted the IFCS Report. UNEP agreed to convene - in early 1998 - an intergovernmental negotiating committee (INC) whose mandate will be to prepare a legally binding convention detailing international action to protect human health and the environment from POPs.

According to the UNEP decision, mandated global action on POPs will start with a short list of the best known, best studied and most notorious substances that contribute to global persistent organic pollution: DDT, aldrin, dieldrin, endrin, chlordane, heptachlor, hexachlorobenzene, mirex, toxaphene, polychlorinated biphenyls (PCBs), dioxins and furans.

Mandated action, however, will not end there. Criteria and a procedure will also be agreed to expand the global POPs action list beyond the UNEP short list of twelve POPs. Additional synthetic organic substances will become candidates for mandatory global action upon appropriate demonstrations of toxicity, persistence, bioaccumulation and long range transport.

Greenpeace and other independent environmental and public health advocacy organizations are optimistic that the global POPs protocol, to be negotiated under UNEP auspices, will lead to effective action to eliminate POPs and their sources.

We have been disappointed in the past, however, and understand that a good outcome is not at all a foregone conclusion. We expect there will again be significant resistance by entrenched interests similar to efforts that successfully thwarted proper action on POPs in the past. Nonetheless, we are optimistic for several reasons:

Among the twelve POPs on the UNEP short list for early action, nine are pesticides whose production and use is currently banned or severely restricted in many regions. A tenth entry on the list - polychlorinated biphenyls or PCBs - are a class of industrial chemicals that may no longer be intentionally produced anywhere in the world. And the final two entries - dioxins and furans - are chemical wastes that are not intentionally produced or intentionally released to the environment.

Because all twelve of the POPs on the UNEP short list for early action are already so widely restricted, some observers have concluded that the UNEP POPs exercise is trivial.

This is a misperception:

Those who view the UNEP POPs exercise as a trivial undertaking are wrong. The exercise can be quite a serious and meaningful undertaking. This will only be the case, however, if the Agreement mandates proper action directed toward the elimination of all significant human sources of all twelve POPs in all regions of the world!

A global POPs Agreement will be considered a failure by Greenpeace - and by most other independent environmental and public health organizations - if its program of action is not geared toward the elimination of persistent organic pollutants and their sources starting with the short list of twelve.

All twelve POPs on the short list are, in much of the world, already banned or subject to regulations and laws that severely restrict and control their use and/or environmental release. The twelve are among the best studied and the most notorious of all known toxic pollutants. If eliminating these notorious pollutants, and their significant sources, is considered too great a burden, what hope then can there be in the capacity of global society to protect itself and its environment from toxic pollutants in general. This concern is quite urgent as society learns more, each day, about the ways that toxic pollutants in the environment undermine basic life processes.

POPs must be eliminated at the source because their physical and chemical properties frustrate every effort to effective manage and control them. POPs persist in the environment a long time and can travel long distances. POPs concentrate through the food chain and disrupt life systems at unimaginably small amounts. So long as substances with these properties continue to be produced - either as intentional products or as unwanted wastes - significant quantities will enter the environment and cause damage.

Agenda 21: A Global Action Plan for the 21st Century, adopted in 1992 by the United Nations Conference on Environment and Development at Rio calls for concerted action to reduce the risks from toxic chemicals "taking into account the entire life-cycle of chemicals."

The life-cycle approach to chemical pollution, if it has any meaning, requires that we look not only at toxic substances as they are manifest in the environment, but also look at the human activities that cause these toxic substances to be generated and/or released to the environment. These human activities, which may include the production or use of chemicals and synthetic mateirals, are termed "anthropogenic sources."

Agenda 21 explicitly also calls for:

This Agenda 21 language, if it has meaning, points to the need for phasing out all twelve POPs on UNEP's short list together with their significant sources.

A POPs elimination strategy can succeed if properly implemented. For the public interest NGO community, no lesser effort is acceptable. Decisions to be made leading toward global action on POPs should be modeled on the decision taken several years ago by public health officials concerned with smallpox. Eradication was a real possibility and the proper goal. A lesser goal would have led to failure.

For those POPs that are intentionally manufactured and sold or distributed for use, the Agreement must mandate actions that will inevitably lead to a future time when all manufacture and all use - everywhere in the world - has come to an end.

For some POPs and in some regions, the substance of concern may be a product whose use is considered to be essential in the protection of human health or in assuring human well-being. The use of DDT in disease vector control and the use of certain POPs pesticides in food production are examples. Commitment to phase out the production and the use of products can also raise other significant and legitimate concerns of a practical or economic character.

Countries must be assured that commitments to eliminate POPs will not require them to take action harmful to the health or well-being of their people. The following outline suggests a step-wise approach that can achieve the elimination of a specific POP product where there exist significant concerns about health or well-being that must be respected.

1. Identify the range of current uses for the product in various regions of the world.

This approach may seem overly complicated and, as a practical matter, it may often be appropriate for it to be streamlined. In some cases, however, each step may be necessary.

Currently, for example, the continued production and use of DDT is justified by some uses of DDT in disease vector control that are considered to be intransigent. There exists no consensus among public health officials that existing alternatives to the use of DDT are always appropriate and effective in disease control for certain specific DDT applications in certain specific localities.

According to some experts, one must take into account specific local biting and nesting behaviors of the disease vector, as well as other local factors, in order to properly evaluate DDT alternatives and their potential effectiveness.

These apparently essential DDT applications are cited as examples to justify continued DDT production and use even though they represent what is probably only a very small proportion of total global use. In this way, certain DDT applications that are deemed to be critical become the proverbial eye of a needle through which camels are permitted to pass.

A careful, step-wise approach to DDT elimination can avoid this problem. It provides an orderly way to work through legitimate concerns while making steady and irreversible progress toward total elimination. In some cases, impatient pressure to short-circuit this orderly approach can derail the process and lead to failure.

Elimination is also a proper end goal for POPs that arise as unwanted by-products and wastes.

Among the substances on the UNEP short list, dioxins and furans arise as wastes that are never intentionally produced. While PCBs and hexachlorobenzene have historically been manufactured as products, they also are generated in significant quantity as by-products and wastes.

Other substances on the list, such as toxaphene, may also arise as waste - but this is less well established. In addition, many other waste substances that are not on the current UNEP short list, are likely to be classified as POPs in the future. One example might be octachlorostyrene.

We must therefore explore the meaning of the elimination goal as applied to POPs that arise as unwanted wastes. Dioxins are the most significant of these on the UNEP short list and will be used as our case example. Much of what follows, however, will also apply to other POP wastes.

The first task in addressing unwanted POPs wastes is to identify and characterize their significant, anthropogenic sources. This can be difficult for several reasons.

Nonetheless, the task of proper source characterization is not insurmountable.

In the characterization of sources, it is not enough to provide a catalog. It is also important to investigate and identify the likely chain of chemical synthesis by which dioxins are generated. As we are reminded by Agenda 21, we must take into account "the entire life-cycle of chemicals."

For example, forest or brush fires have been identified as a significant source of dioxins. Wild fires have been occurring since before the advent of human technology. One might therefore infer that these fires are a natural, not an anthropogenic dioxin source.

Investigation of the chain of chemical synthesis, however, will reveal that dioxin synthesis in forest fires arises mainly from the combustion of chlorinated pesticides and/or from the combustion of residues from chlorinated solvents and other chlorinated anthropogenic materials that have entered the forest by airborne deposit.

An investigation of the dioxin chain of chemical synthesis for most sources will yield similar results. Investigation will show that in most cases, when dioxins are generated and released to the environment, the source can be viewed as a combustion or reaction event in which one or more anthropogenic, chlorine-containing chemical substances is present and serves as the chlorine donor in dioxin synthesis.

Taking the "life-cycle of chemicals" into account, the anthropogenic chlorine-donor substance can be properly viewed as a dioxin source. This concept can be very useful in devising effective strategies to eliminate dioxins at the source. Examples of anthropogenic materials that can be considered significant chlorine-donor sources in dioxin synthesis:

A relatively small number of chlorine-containing anthropogenic materials serve as the predominant chlorine-donor source in global dioxin generation. Dioxins always arise in the ordinary life-cycle during which these materials are produced and used, then treated as waste for disposal, or alternatively, released untreated to the environment.

Once dioxin sources have been identified and characterized, early action may include measures that reduce and control releases from identified sources. In some places, dioxin control measures have achieved some substantial reductions in the release of dioxins to the environment from certain source categories. This can be a starting point. However:

Successful dioxin abatement strategies must employ source elimination as a method. Industrial and waste disposal processes that generate dioxin should be changed or replaced with dioxin-free processes. Chlorine-free pulp bleaching should replace chlorine-based bleaching technologies. Waste incineration should be avoided. If utilized, chlorine-containing feedstocks should be removed.

A dioxin elimination strategy must also include measures that promote appropriate, economical, alternative materials and technologies to replace vinyl plastic, chlorinated solvents, chlorine-containing industrial bleaching agents and a few other chlorine-containing anthropogenic materials whose life cycle generates most of the dioxin in the world.

Presently, the pressure of environmental concern has begun to reduce use of these materials in some parts of Western Europe. On a global scale, however, production and use continues to grow. This growth, sadly, is now most rapid in developing countries whose waste management infrastructure and capacity is quite unprepared for the waste streams that necessarily accompany these dirty materials. Unchecked, this expansion will create a new cycle of large-scale, hidden costs to the economy, to the ecology and to the public's health.

A global POPs Agreement must encourage the transition to cleaner production on a global scale. Countries undergoing economic development should be given the opportunity to by-pass dirty technologies and dirty materials. Failure will guarantee that newly developing economies will see unacceptable expansion in the generation and release of dioxins and other POPs that arise as unwanted industrial wastes or by-products. What a tragedy this would be, especially because cleaner products and processes represent a better and more sustainable economic alternative.

There is fear and concern in some quarters that a legally binding global Agreement that mandates the elimination of POPs and POPs sources may lead to disruptions in physical or economic health and well-being. This concern is especially acute when the spotlight shines on DDT elimination or on policies that promote the substitution of cleaner, alternative materials as part of a global dioxin abatement strategy.

This concern should not be taken lightly. A POPs elimination Agreement that is inappropriately structured or implemented could cause unacceptable levels of disruption. This in turn would, of course, derail further implementation and lead to failure. But legitimate concerns of this type should not become transformed into an excuse to abandon the POPs elimination perspective.

Rather, where the potential for disruption represents a serious concern, Agreement implementation should proceed by means of a step-wise and orderly transition plan. Interests that have a stake in the outcome should have the opportunity to participate in planning with the understanding that all parties are working together toward achieving elimination as the final outcome. The purpose of the planning exercise is to find ways that will achieve POPs elimination by means that:

Each of UNEP's twelve short-listed POPs - as well as other substance that may be identified for future action under a POPs agreement - has unique properties and characteristics. In planning practical action targeting any substance, its individual properties and characteristics must be taken into account including regionally specific uses, sources, and so on - sometimes in considerable detail.

The UNEP decision calls attention to three broad categories of substances that may require somewhat different approaches: pesticides, industrial chemicals, and unintentionally produced by-products and contaminants. The decision makes it clear, however, (para 3) that these different approaches will be undertaken "in the framework of overarching objectives" and that the overarching objectives will be established by the intergovernmental negotiating committee.

In the negotiation of a global POPs Agreement, reaching decision on the "overarching objectives" should be the first task facing the intergovernmental negotiating committee, and it may be its single greatest challenge.

Good and clear objectives serve as a compass and a guide. Many detailed decisions and complications will certainly arise during Agreement negotiation and Agreement implementation. In the absence of good, clearly specified overall Agreement objectives, disorientation or confusion will almost certainly result. In order to get a global POPs Agreement that achieves the desired outcome, the first step is to establish clear and agreed upon Agreement objectives.

As a "thought starter" for discussion, we suggest the following as possible POPs Agreement objectives:

I again thank UNEP and the Russian Federation State Committee on Environmental Protection for inviting me to this workshop. Than you for giving me an opportunity to share these thoughts and proposals with such an influential and distinguished group of participants.