Chlorine Dioxide:
One Way Out of the Chlorine Controversy
March 28,1994

Chlorine dioxide can virtually eliminate persistent and bio-accumulative toxic substances in pulp and paper mill waste water. The recent debate over chlorine has focused on the possible environmental effects of a number of chlorinated compounds. Legislation to fund a study of chlorine and chlorinated compounds is under consideration. To better understand the range of issues, the following needs to be taken into account:

• All chlorinated compounds are not alike. This simple fact has been omitted from the debate. When chlorine reacts with organic material such as lignin, the tissue that holds the wood's cellular walls together, it can result in potentially harmful chlorinated organics in mill waste water.

  Chlorine dioxide is radically different from elemental chlorine, both in its chemical structure and behavior. Chlorine dioxide virtually eliminates the formation of persistent and bio-accumulative toxic substances, and the remaining chlorinated organic material in mill waste water is non-toxic, and similar to naturally occurring chemical compounds.

• Chlorine dioxide is a proven pollution prevention technology. Laboratory studies and field tests clearly demonstrate chlorine dioxide's superior environmental performance. A panel of some of the world's foremost experts in their respective fields concluded in a report recently prepared for AET,

"The environmental risks of chlorinated compounds from bleaching with chlorine dioxide are insignificant. Chlorine dioxide solves the problem of dioxin and other persistent, bio-accumulative toxic substances in pulp and paper mill was te water."

• Chlorine dioxide is an environmentally superior bleaching agent, and produces the strongest paper for today's rising recycling requirements. Chlorine dioxide is today's best bleaching option for recyclable paper for use in high-quality magazines that require bright white, extremely thin, and very strong paper for printing presses running at race car speeds.

• The demand for pulp bleached with chlorine dioxide is rising sharply. AET market research confirms that by the end of 1994, ECF (Elemental Chlorine-Free), pulp bleached with chlorine dioxide, will have penetrated 30 percent of the North American market. In contrast TCF (Totally Chlorine-Free) pulp will account for less than 1 percent of the market.

• Chlorine dioxide is not chlorine: It is an individual substance. For any Administration study of chlorine and chlorinated substances, chlorine dioxide should be subject of a separate and formal scientific review, based on the EPA's weight-of-evidence approach.

• EPA has both the office and the analytical framework for conducting the review. The EPA's Office of Research and Development should lead the review, and it should adhere to the guidelines set forth in the EPA's Framework for Ecological Risk Assessment.