In late 1993 the Governing Council of the American Public Health
Association (APHA) unanimously approved Policy Statement 9304 urging
American industry to stop using the chemical chlorine. (See REHW
#363.) APHA is a professional society, founded in 1872, representing
all disciplines and specialties in public health. It is the heart of
the American public health establishment.
Chlorine is a chemical element, one of the 92 fundamental building
blocks from which everything on earth is made. Chlorine is very
reactive --it aggressively grabs onto other elements to form compounds.
That is why, in nature, chlorine never appears in a free state, but is
always combined with other elements, usually in common table salt
Around 1900, Herbert Dow, the founder of Dow Chemical, split common
salt to make commercially-valuable sodium hydroxide, releasing, as an
unwanted by-product, the highly-toxic green gas, free chlorine. Mr. Dow
(a chemistry teacher) soon began combining chlorine with other
elements, thus creating "chlorine chemistry," giving rise to solvents,
pesticides and all manner of other useful, toxic chlorinated compounds,
of which there now about 15,000 in commercial use.
In Policy Statement 9304, one of the nation's premier scientific and
medical associations is asking American industry to change a
fundamental way of doing business. APHA recognized two exceptions: the
pharmaceutical industry and disinfection of public water supplies. But
all other uses of chlorine as an industrial feedstock should be phased
out, APHA urged.
In Statement 9304, the APHA explained its opposition to the use of
chlorine as an industrial feedstock:
** "...virtually all chlorinated organic [carbon-containing] compounds
that have been studied exhibit at least one of a wide range of serious
toxic effects such as endocrine dysfunction, developmental impairment,
birth defects, reproductive dysfunction and infertility,
immunosuppression, and cancer, often at extremely low doses and... many
chlorinated organic compounds, such as methylene chloride and
trichloroethylene, are recognized as significant workplace hazards."
APHA spelled out its rationale for such a sweeping phase-out in this
** "Recognizing the subtle and widespread effects on human and wildlife
health attributed to exposure to chlorinated organic chemicals and our
current inability to identify, predict or control the release of these
compounds from manufacturing processes, and that the bi-national
[Canada and U.S.] Science Advisory Board of the International Joint
Commission on the Great Lakes (IJC) concluded by the weight of
scientific evidence that exposure to all organochlorines should be
presumed to pose a health problem and that policies to protect public
health should be directed toward eventually achieving no exposure to
chlorinated organic chemicals as a class rather than continuing to
focus on a series of isolated, individual chemicals."
Thus the APHA said, in effect: we can't study all the many possible
toxic effects of 15,000 individual chlorinated chemicals. Therefore,
based on the weight of the evidence, we should assume all chlorinated
chemicals are dangerous and we should avoid all exposures to them, to
prevent harm. Furthermore, the APHA said, because we cannot avoid
releases (and therefore exposures) whenever we make these compounds,
the only way to PREVENT exposures is to stop making chlorinated
compounds: "...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," the APHA said.
As a response to such calls for phasing out chlorine as an industrial
feedstock, the Chemical Manufacturers Association formed the Chlorine
Chemistry Council (CCC) in 1993. The CCC soon hired an aggressive
DC-based public relations firm, Mongoven, Biscoe and Duchin (MBD)
[phone: (202) 429-1800], to develop and carry out a strategic plan for
MBD makes part of its living by spying on churches, labor unions,
environmentalists, professors and students, and selling information
about them to corporate clients, such as CCC. In addition, MBD helps
corporate clients develop strategies to discredit people who are
advocating change. In its own words, MBD "assists corporations in
resolving public policy issues being driven by activist organizations
and other members of the public interest community. We help clients
anticipate and respond to movements for change in public policy which
would affect their interests adversely.... Forces for change often
include activist and public interest groups, churches, unions and/or
academia.... MBD is committed to the concept that it is critical to
know who the current and potential participants are in the public
policy process, to understand their goals and modus operandi, and to
understand their relative importance. To this end, MBD maintains
extensive files on organizations and their leadership...." (See REHW
Jack Mongoven, co-founder of MBD, has taken a keen personal interest in
the chlorine strategy, and has developed a far-reaching plan to help
the CCC discredit efforts to phase out chlorine.
Like any good plan, Jack Mongoven's blueprint contains long-term
strategic goals, and day-to-day tactical elements.
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.
On a regular basis now, Jack Mongoven sends the CCC a formal update on
what anti-chlorine activists are doing, including specific steps that
CCC should take to undercut and discredit them.
In a report to the CCC titled "Activists and Chlorine in August
," MBD notes that, "Anti-chlorine activists are using children
and their need for protection to compel stricter regulation of toxic
substances. This tactic is very effective because children-based
appeals touch the public's protective nature for a vulnerable group and
that makes it difficult to refute appeals based on its needs. This
tactic also is effective in appealing to an additional segment of the
public which has yet to [be] activated in the debate, particularly
The MBD report includes a specific example of environmentalists "using
children." The report describes activities of the Children's
Environmental Health Network (CEHN): "The CEHN approach, which is just
taking shape, is illustrative of the nature of the debate concerning
children will take during the next several months. [sic] The tone of
the debate will focus on the needs of children and insist that ALL
safeguards be taken to ensure their safety in development. For most
substances, the tolerances of babies and children, which includes fetal
development, are obviously much lower than in the general adult
population. Thus, 'environmental policies based on health standards
that address the special needs of children,' would reduce all exposure
standards to the lower possible levels." The MBD report says that,
although CEHN is not, itself, an anti-chlorine group, "CEHN has adopted
proposals by anti-chlorine groups to secure a national health policy
based on the needs of children."
In sum, the MBD report says, "By characterizing children as the biggest
losers of [sic] toxic exposure, the activists have secured an approach
that will attract more mainstream support for their anti-chemical,
A 5-page cover memo signed by Jack Mongoven, dated September 7, 1994,
summarizes the key points in the August report and lists many specific
steps that CCC should take to defend chlorine and discredit the
activists: "It is obvious that the battleground for chlorine will be
women's issues--reproductive health and children--and organizations
with important constituencies of women opinion leaders should have
priority," Mongoven writes.
"It is especially important to begin a program directed to pediatric
groups throughout the country to counter activist claims of chlorine-
related health problems in children," Mongoven writes.
MBD's August report listed a series of conferences for breast cancer
survivors scheduled by WEDO (Women's Environment & Development
Organization) in New York [phone: 212/759-7982]. The report says,
"Devra Lee Davis is expected to direct the Clinton Administration's
policy governing breast cancer and we expect her to try to convert the
breast cancer issue into a debate over the use of chlorine. As a member
of the administration, Davis has unlimited access to the media while
her position at the Health and Human Services (HHS) [department] helps
validate her 'junk science.' Davis is scheduled to be a keynote speaker
at each of the upcoming WEDO breast cancer conferences."
In his cover memo, Jack Mongoven suggests that CCC deal with Dr. Davis,
the breast cancer survivors, and anti-chlorine sentiments as follows:
** Schedule through KPR [Ketchum Public Relations, in Washington, D.C.]
editorial board meetings in Dayton prior to Department of Health and
Human Services Devra Lee Davis['s] speech to a forum on breast cancer
sponsored by Greenpeace and WEDO to be held in Dayton....
** Enlist legitimate scientists in the Dayton area who would be willing
to ask pointed questions at the conference....
** Stimulate peer-reviewed articles for publication in the JAMA
[Journal of the American Medical Association] on the role of chlorine
chemistry in treating disease.....
** Convince through carefully crafted meetings of industry
representatives (in pharmaceuticals) with organizations devoted to
specific illnesses, e.g., arthritis, cystic fibrosis, etc., that the
cure for their specific disease may well come through chlorine
chemistry and ask them to pass resolutions endorsing chlorine chemistry
and communicate those resolutions to medical societies. If it is
possible to identify potential prominent allies in the organizations
before the meetings that would be preferred...."
Next week: Jack Mongoven designs strategies for the CCC to counter and
discredit what he says are the really serious threats: the
precautionary principle, and shifting the burden of proof onto the
 "9304. Recognizing and Addressing the Environmental and
Occupational Health Problems Posed by Chlorinated Organic Chemicals,"
AMERICAN JOURNAL OF PUBLIC HEALTH Vol. 84, No. 3 (March 1994), pgs.
 The Chlorine Chemistry Council (CCC) is a "business council of the
Chemical Manufacturers Association (CMA)," founded in 1993 and located
in Arlington, Virginia. CCC has no published telephone number. CCC is
part of CMA but has a separate budget, according to Janet Flynn, a
spokesperson for CCC whose phone is (703) 741-5827.
 John O. Mongoven, "The Precautionary Principle," ECO-LOGIC (March,
1995), pgs. 14-16. ECO-LOGIC is a publication the Environmental
Conservation Organization, in Hollow Rock, Tennessee; phone: (901) 986-
0099. Our thanks to Dan Barry of the CLEAR project at the Environmental
Working Group in DC [phone: 202-667-6982], and to Keith Ashdown, Cancer
Prevention Coalition, in Chicago [(312) 467-0600] and to John Stauber,
editor of PR WATCH in Madison, Wis. [(608) 233-3346] for information
about ECO and about MBD.
 "Activists and Chlorine in August ," MBD ISSUE RESEARCH AND
ANALYSIS (Washington, D.C.: Mongoven, Biscoe, and Duchin [phone:
 Memo from Jack Mongoven to Clyde Greenert/Brad Lienhart dated
September 7, 1994, and titled, "MBD Activist Report for
August," (Washington, D.C.: Mongoven, Biscoe, and Duchin [phone:
Descriptor terms: american public health association; chlorine; dow
chemical; ijc; chemical manufacturers association; chlorine chemistry
council; mongoven, biscoe and duchin; jack mongoven; children;
children's environmental health network; wedo; women's environment &
development organization; devra lee davis;