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Five Great Reasons Why We Care:
The Pulp and Paper Industry's Virtual Elimination Strategy

Douglas C. Pryke, Executive Director
The Alliance for Environmental Technology

September, 1995

Table of Contents


The pulp and paper industry has met the challenge of pollution prevention. In an unprecedented, voluntary effort, the industry has virtually eliminated discharges of persistent, bio-accumulative, toxic substances to the Great Lakes eco-system. This paper details this effort and its successes.

Section 1, Pollution Prevention in the Pulp and Paper Industry, highlights and defines the industry's pollution prevention methodology. By employing process changes, product reformulation, and raw material substitution, the industry implemented a virtual elimination strategy that has met the objectives of key policy and regulatory initiatives in the United States and Canada.

The key to this success story was the industry's increased substitution of chlorine dioxide for chlorine in the first stage of chemical pulp bleaching. As Section 2, Proven Progress, shows, the implementation of the strategy virtually eliminated dioxin loadings to the Great Lakes from the pulp and paper industry.

Section 3, Eco-System Recovery, documents a further dimension of progress. As a result of virtual elimination, fish dioxin body burdens have rapidly declined while aquatic eco-systems continue to recover. These indicators of progress toward broader eco-system integrity demonstrate the success of the pulp and paper industry's virtual elimination strategy.

The fourth and final section, Toward the Future, places these successes in perspective and discusses prospects for continued progress. The industry's leadership has minimized industrial impacts and helped restore the Great Lakes eco-system. Elemental Chlorine-Free (ECF) technology, based on chlorine dioxide, now and for the future, may offer the best alternative for sustainability, product quality, and recyclability.

Perhaps most encouraging, other industries look to these successes as a model for pollution prevention, virtual elimination, and enlightened environmental stewardship.

Section 1


Following the identification, in the late 1980s, of trace levels of dioxin, an inadvertent by-product of the prevailing chemical pulp bleaching process, the international pulp and paper industry moved quickly and voluntarily to implement a comprehensive, multi-faceted strategy that has virtually eliminated dioxins and furans. By applying the principles of pollution prevention -- process changes, product reformulation, and raw material substitution -- the industry has achieved both the letter and the intent of a range of US and Canadian regulatory and policy initiatives, including the US Pollution Prevention Act of 1990, the Canadian Environmental Protection Act (CEPA), and the Great Lakes Water Quality Agreement (GLWQA).

Components Of A Virtual Elimination Strategy

The International Joint Commission (IJC) monitors and evaluates activities governed by the Great Lakes Water Quality Agreement. To move forward toward the goal of virtual elimination of persistent, toxic substances, the IJC appointed a Virtual Elimination Task Force (VETF), comprising representatives of government, industry, academia, and other stakeholders. IJC endorsed the VETF's 1993 report which identified five key components that together create a virtual elimination strategy [1]:

  • Criteria to determine which substances are considered persistent and toxic and therefore candidates for virtual elimination;

  • Criteria for identifying sources of candidate substances and intervention points to eliminate and prevent inputs to the environment;

  • Guidelines for adoption and development of improved treatment and control of residual and non-point releases and guidelines for adoption and development of pollution prevention technology such as changes to production processes, raw materials, and product formulation;

  • Criteria for examining mechanisms including legislation, regulations, technology, education, and consultation, to facilitate adoption of a virtual elimination strategy; and

  • Indications of progress in reduction and virtual elimination of persistent, toxic substances.

These fundamental concepts are common to four policy initiatives affecting the pulp and paper industry: The US Pollution Prevention Act, the Canadian Environmental Protection Act, the Canadian Toxic Substances Management Policy, and the Great Lakes Water Quality Agreement, each of which is discussed below. As Table 1.1 shows, the industry's successful application of these core components provided the basis for public policy.

Table 1.1

Criteria for Virtual Elimination and Industry Action

Date Virtual Elimination Strategy Industry Action Government Action
1978 GLWQA
1985-1989 Identification of Candidate Substances and Sources
  • "US 5 Mill Study"
  • "US 104 Mill Study"
  • CPPA National Mill Dioxin Characterization Survey
  • Great Lakes Water Quality Board lists 11 critical pollutants
  • US National Dioxin Survey
  • "US 5 Mill Study"
  • "US 104 Mill Study"
1987-1989 Development of Pollution Prevention Technologies
  • International pulp and paper research collaboration
  • Contaminated wood chips eliminated
  • Precursor-free defoamers introduced
  • Increased chlorine dioxide substitution
  • Fish advisories posted
1990 Facilitation of Virtual Elimination Through Public Policy
  • US Pollution Prevention Act
  • CEPA Dioxin Assessment
1990-1995 Measuring Progress
  • Dioxin virtually eliminated within four years
  • Fish advisories lifted
  • CEPA Regulations
  • IJC VETF Report
  • Proposed EPA Cluster Rule

The US Pollution Prevention Act (PPA)

The US Pollution Prevention Act of 1990 (PPA) recognized that, "... there are significant opportunities for industry to reduce or prevent pollution at the source through cost-effective changes in production, operation, and raw materials use..."[2]. The PPA also acknowledged that "... source reduction is fundamentally different and more desirable than waste management and pollution control...".

Though "pollution prevention" is not specifically defined, the PPA makes clear that "pollution prevention" incorporates the concepts of both preventing and reducing the formation of pollution.

The PPA defines the term "source reduction" as any practice that:

  1. reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment; and
  2. reduces the hazards to public health and the environment that are associated with the release of such substances, pollutants, or contaminants.

Source reduction may include equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, and substitution of raw materials.

The Canadian Environmental Protection Act (CEPA)

A CEPA Priority Substances List Assessment judged polychlorinated dibenzodioxins and polychlorinated dibenzofurans as "toxic" [3]. Although other sources of dioxins and furans exist, as discussed later in this document, the pulp and paper industry was the only sector affected by this assessment. In 1992, regulations under CEPA were promulgated to control the formation and discharge of polychlorinated dioxins and furans from Canadian pulp and paper mills that operate bleach plants using chlorine and/or chlorine dioxide [4]. The CEPA Pulp and Paper Mill Effluent Chlorinated Dioxins and Furans Regulations prohibit the release of final effluent that contains any measurable concentration of 2,3,7,8-TCDD or 2,3,7,8-TCDF. The regulation defines "measurable concentration of 2,3,7,8-TCDD" as "a concentration of 2,3,7,8- TCDD that is greater than the level of quantification as defined in the Reference Method" which is currently 15 ppq (parts per quadrillion).

The Canadian Toxic Substances Management Policy

The philosophy of the June 1995 Canadian Toxic Substances Management Policy is similar to the CEPA Pulp and Paper Effluent Chlorinated Dioxins and Furans Regulations. The Policy has as one of its key management objectives, "... the virtual elimination from the environment of toxic substances that result predominately from human activity and that are persistent and bio-accumulative..." The Policy further states that "... pollution prevention strategies will be used to prevent the measurable release ..." of such substances. To verify no measurable releases, the Policy calls for the development of limits based on the lowest concentration of a substance that can be accurately detected and quantified using sensitive but routine analytical methods. Underscoring its intent, the Policy specifies that, "... the objective of virtual elimination of a substance does not mean chasing down that substance to the last molecule. Common sense will apply as progress toward the substance's elimination is monitored..."[5].

The Great Lakes Water Quality Agreement

The second Great Lakes Water Quality Agreement, signed in 1978 by the Governments of Canada and the United States, establishes a collective commitment to protecting the eco-systems of these common waterbodies. The Agreement calls for the virtual elimination of persistent, toxic substances and the adoption of an eco-system approach for restoration and protection of the Great Lakes. The International Joint Commission's Seventh Biennial Report on Great Lakes Water Quality, "... supported the Virtual Elimination Task Force's proposed approach to virtual elimination as a framework for a specific, immediate action plan for persistent toxic substances..."[6].

A key principle of the virtual elimination strategy is the anticipation and prevention of pollution. Like the Pollution Prevention Act, the IJC's VETF also considers pollution prevention as an attempt to avoid generation of persistent, toxic substances through process change, product reformulation, and raw material substitution. In effect, pollution prevention shifts the focus from remediation to the generation of the persistent, toxic substance itself.


As suggested above, each of these policies embraces the concept of virtual elimination, and incorporates - implicitly or explicitly - the core components recommended by the VETF on the basis of foundations developed by the industry. The five-point program is discussed below.

Identifying Candidate Substances

The IJC Water Quality Board has identified 11 Critical Pollutants that are persistent and bio-accumulate in living organisms [7]. In 1985, the bleached chemical pulp and paper industry was tentatively identified as a potential source of two of the 11 Critical Pollutants:

  • 2,3,7,8-tetrachlorodibenzo-p-dioxin, (2,3,7,8-TCDD); and
  • 2,3,7,8-tetrachlorodibenzofuran, (2,3,7,8-TCDF)

Identifying Sources

Once the pulp and paper industry was identified as a potential source of these two compounds, the US industry entered into a collaborative effort with the US EPA to confirm the findings. A landmark report, known as the "5-Mill Study," essentially confirmed a relationship between trace levels of dioxin formation and the prevailing chemical pulp bleaching process. In 1988 and 1989, the US and Canadian industries extensively analyzed pulps, sludge, and effluents from their respective chemical pulp bleaching mills. The results for the US, summarized in the National Council of the Paper Industry for Air and Stream Improvement's (NCASI) "104 Mill Study," and for Canada in the "CPPA National Mill Dioxin Characterization Survey," showed that the pulp and paper industry was a source of 2,3,7,8-TCDD and 2,3,7,8-TCDF [8,9]

Developing Pollution Prevention Technologies

A concerted effort by industry, based on a strong research foundation, identified pollution prevention technologies to meet the virtual elimination challenge.

I) Research and Development

Coincident with the tentative identification of the bleaching of chemical pulp as a potential source of 2,3,7,8-TCDD/F, the international pulp and paper research and development community launched an intensive effort to identify the mechanisms of formation of the substances, and technology for prevention and elimination. In an extraordinarily short time (1987-1989), cooperation among organizations such as the Pulp and Paper Research Institute of Canada (Paprican), NCASI, the Swedish Pulp and Paper Research Institute (STFI), the Institute of Paper Science and Technology (IPST), and the research departments of many of the producing companies, led to a deeper understanding of the formation mechanism, and the creation of strategies for pollution prevention and virtual elimination.

II) Raw Material Substitution

One source of dioxin was identified as originating from condensation of polychlorinated phenolic compounds during the wood preparation process prior to bleaching. The polychlorinated phenolic compounds were identified as coming from wood that had been treated with certain formulations used by the lumber industry as a wood sapstain preservative. The industry responded by terminating the purchase and use of such wood chips.

III) Product Reformulation

The formation of 2,3,7,8-TCDD/F during bleaching was also partially attributable to chlorination of unchlorinated precursor compounds dibenzo-p-dioxin (DBD) and dibenzofuran (DBF). The precursor compounds were found in chemical additive formulations -- known as defoamers -- that are used in the washing process of the pulp mill. The chemical industry responded quickly by reformulating their products to produce precursor-free defoamers. Their subsequent application in pulp washing significantly decreased 2,3,7,8-TCDD/F formation.

IV) Changes to Production Processes

Key to the industry's virtual elimination strategy was the discovery that increased substitution of chlorine dioxide for chlorine in the first stage of chemical pulp bleaching virtually eliminated the formation of both 2,3,7,8-TCDD and 2,3,7,8-TCDF. As chlorine dioxide is increasingly substituted, dioxin formation is eliminated, as shown in Figure 1.2 [10].


Chlorine Dioxide Substitution vs. Dioxin Formation
Adapted from Berry et. al. Pulp & Paper Canada 90:8 (1989)

The international pulp and paper industry rapidly adopted increased substitution of chlorine dioxide. Recently, responding to market demand and anticipated regulatory trends, approximately 25% of North American pulp and paper mills have converted to complete replacement with chlorine dioxide, a process change that has come to be known as Elemental Chlorine-Free, ECF bleaching.

Facilitating the Adoption of Virtual Elimination

By adopting these modifications, the industry undertook, "a broad movement toward manufacturing processes that eliminate the production of persistent toxic substances"[6]. This voluntary initiative required a capital investment of more than $2 billion US in North America, and effectively anticipated public policy initiatives in Canada and the US

In Canada, regulations for the bleached chemical pulp and paper industry, promulgated under the Canadian Environmental Protection Act, effective January 1, 1994 [4] prohibit:

  • the use of PCP (polychlorinated phenol) contaminated wood chips for bleached chemical production;

  • the use of contaminated defoamers; and

  • the discharge of measurable concentrations of 2,3,7,8-TCDD/F.

In the United States, the Environmental Protection Agency has a receiving stream guideline of 0.013 ppq that has been adopted by many states. The EPA is also currently developing new guidelines for the bleached chemical pulp and paper industry that will have limits for 2,3,7,8-TCDD/F [11].

Measuring Progress

The final component of a virtual elimination strategy is measurement of results to enable industry and oversight agencies to monitor progress, quantify impact, and refine strategy.

In the case of the Great Lakes, critical measurements include contaminant levels in wildlife, industrial and municipal discharges, and water quality analysis. These measurements in turn help to quantify overall eco-system integrity.

The following two sections detail this progress. Section 2 documents the pulp and paper industry's remarkable success in reducing the discharge of priority pollutants, and more importantly, the virtual elimination of formation and discharge of 2,3,7,8-TCDD/F to the Great Lakes and other watersheds. Section 3 documents two measures of the resulting eco-system recovery and integrity:

  • the declining body burdens of 2,3,7,8-TCDD/F in fish; and

  • the lifting of fish advisories in the Great Lakes eco-system and throughout North America, particularly downstream of pulp and paper mills.

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