23 April 2002
TO:The District Collector
Cuddalore District
Tamil Nadu

Dear Sir,
Sub: Setting up of Chemplast PVC plant in SIPCOT, Cuddalore
This is with respect to the setting up of a PVC plant by Chemplast in the SIPCOT Industrial Estate in Cuddalore. The plant uses VCM as the raw material to manufacture PVC resin.
Research worldwide has shown that PVC is a poison plastic that has environment and health impacts right from production, through use and disposal. Countries in the West have adopted various restrictions on the manufacture, use and disposal of PVC and are moving towards a phase-out while India seems to be encouraging its production. It is also shown that the manufacture of PVC uses a deadly raw material Vinyl Chloride Monomer (VCM). VCM is a highly flammable chemical and is capable of causing serious chemical accidents. It is cancer-causing and also capable of causing severe reproductive and developmental disorders. Workers of PVC plants and communities living around such plants are constantly exposed.
(Please refer enclosure on the hazards of VCM)
Further, the Supreme Court High-Powered Committee on Hazardous Waste has made recommendations to avoid POPs generating processes.
India has also just agreed to sign the International Convention on Persistent Organic Pollutants (POPs) to reduce generation of these toxic substances. PVC facilities are proven to release Dioxin (a POP chemical) and setting up of this plant means violating the Convention.
Considering the facts, we strongly urge you not to allow this environmentally disastrous plant to be set-up. Sincerely

Rajesh Rangarajan
Regional Coordinator

TOXICS LINKEncl: 1. Vinyl Chloride Monomer – A Profile
2. Regulations that the PVC plant violates

VINYL CHLORIDE (or) VINYL CHLORIDE MONOMER (VCM) – A Profile
Characteristics
Vinyl chloride monomer is reactive; it will polymerise in light, air or heat, unless stabilised with inhibitors. It is soluble in many organic solvents, but only slightly soluble in water. As a gas, mixed with air, vinyl chloride is a fire and explosion hazard. On standing, it can produce peroxides, which may then explode1. Vinyl Chloride is released to the environment as emissions and wastewater at polyvinyl chloride (PVC) plastics production and manufacturing facilities2.
Hazardous nature
The USEPA has listed hazardous, the wastes generated by chlorinated aliphatic industry, especially - wastewater treatment sludge from the production of Ethylene Dichloride / Vinyl Chloride Monomer3.
Toxicity
The inhalation of high levels of vinyl chloride has led to narcosis (the effects of a narcotic drug), problems in breathing, convulsions and death. At lower levels, symptoms may be headaches, and dizziness. Long-term exposure may cause impotence, blood disorders, and liver problems. The International Agency for Research on Cancer has classified vinyl chloride as a human carcinogen, based upon evidence of carcinogenicity in both humans and animals4.

CARCINOGENICITY5
Vinyl chloride is known to be a human carcinogen based on sufficient evidence of carcinogenicity in humans. Vinyl chloride has been associated with tumours of the liver, brain, lung, and hematolymphopoietic system. A large number of epidemiological studies and case reports have substantiated the causal association between vinyl chloride and angiosarcoma of the liver. Several studies also confirm that exposure to vinyl chloride causes other forms of cancer, i.e., hepatocellular carcinoma, brain tumours, lung tumours, and malignancies of the lymphatic and haematopoietic system. Exposure to poly (vinyl chloride) dust was associated with an increased incidence of lung tumours in one study; the authors suggested that trapped vinyl chloride monomer was responsible. Melanoma occurred in excess in one study but has not been mentioned in others. Slightly elevated risks for gastric and gastrointestinal cancer (other than liver cancer) were indicated in some studies, but these were not confirmed in others.
An IARC (International Agency for Research in Cancer) Working Group reported that there is sufficient evidence of carcinogenicity of vinyl chloride in experimental animals. When administered by inhalation, vinyl chloride induced pulmonary adenomas, adenocarcinomas, liver angiosarcomas, nephroblastomas, and liver angiosarcomas in rats of both sexes and mammary tumours and in female rats. When administered by inhalation, vinyl chloride induced skin tumours in male hamsters and angiosarcomas (liver, spleen, or skin), mammary carcinomas, skin carcinomas, and stomach adenomas in female hamsters. Newborn rats developed angiosarcomas when exposed to vinyl chloride by inhalation. A combination of oral administration of ethanol and inhalation of vinyl chloride resulted in more liver tumours (including angiosarcomas) than after treatment with vinyl chloride alone.

REPRODUCTIVE AND DEVELOPMENTAL TOXICITY1
Several epidemiological studies have been conducted to assess potential reproductive and developmental effects in the families of vinyl chloride workers (California Department of Health Services, 1990). Edmonds et al. (1975, 1978) conducted two case-control studies evaluating central nervous system malformations among offspring of vinyl chloride workers and families living near polyvinyl chloride facilities in Indiana and West Virginia. More cases than controls lived within three miles of the polyvinyl chloride plants (p<0.02). Mothers living in Ohio communities with PVC production facilities gave birth to an excess number of children with congenital malformations as compared to the expected number based on the state average or based on the experience in the balance of the counties in which these cities are located. In a review of epidemiological studies related to vinyl chloride exposure by Hemminki and Vineis it was concluded that there was inadequate evidence linking environmental or paternal exposures to vinyl chloride with birth defects.

Occupational Hazards
In the US, It has been shown that occupational exposures generally occur after production, as the finished monomer is piped to storage or transportation or during maintenance. The greatest potential for the hazard is during polymerisation of the chemical to form other materials, nearly all of which are PVC resins, and the vinyl chloride escapes into the air. This has been the major emission source and the process in which the highest occupational exposures have been reported. The National Occupational Exposure Survey (1981-1983) estimated that 18,386 workers, including 7,384 women, were potentially exposed to vinyl chloride. NIOSH estimated that 27,000 workers are exposed to vinyl chloride and that as many as 2.2 million workers are potentially exposed. According to the Toxic Release Inventory of 1995, an estimated total of 1.01 million pounds of vinyl chloride (99.9%of the total environmental releases) was discharged to the air, 227 pounds (<0.03%) to the water, and 6 pounds (<0.0006%) to the soil from manufacturing and processing facilities in the United States in 1993
Between September 1967 and December 1973, 4 cases of angiosarcoma of the liver were diagnosed among men employed in the polyvinyl chloride polymerisation section of a B.F. Goodrich plant near Louisville, Kentucky2. This section of the plant began operations in 1938. It employs about 270 persons and produces polyvinyl chloride as well as a variety of copolymers by polymerisation of vinyl chloride monomer. All 4 men had worked continuously in the section for at least 14 years prior to onset of illness; all 4 had worked directly in various phases of the polymerisation process. Subsequently, it has been declared that, the available data indicates the occurrence of angiosarcoma among workers at vinyl chloride plants seems distinctly a problem in the entire industry.

REGULATIONS THAT THE CHEMPLAST PVC PLANT VIOLATES
The following are the recent recommendations of the High Powered Committee (HPC) on Hazardous Wastes. The Committee was empowered by the Honourable Supreme Court of India in the writ petition No. 657/95 (Research Foundation for Science, Technology and Natural Resource Policy vs. Union of India and others).
The HPC Committee recommendations
“(v) It is imperative that Government declare and take steps to ensure that expansion of existing hazardous waste generating industries and new industries of this nature follow the basic parameters of Clean Production. New industries must be subjected to stringent public disclosure rules regarding emissions, processes, raw materials and hazard potential, and mitigation scenarios. Such industries must prove that the processes used are the most energy-efficient and environmentally safe technologies when submitting their proposals for seeking consent to establish. They must not be permitted to employ technologies or processes that intentionally or unintentionally generate endocrine disrupting chemicals or persistent organic pollutants. Nor should they be permitted to generate products whose final disposal would poison the environment with such chemicals or pollutants; in such cases, they must have a cradle to grave responsibility…”
[Source: “Report of the High Powered Committee on Management of Hazardous Wastes – Volume I.” p.245. 2001]

Excerpts from the Stockholm Convention
http://www.chem.unep.ch/pops/POPs_Inc/dipcon/meetingdocs/conf-2/en/conf-2e.pdf
The recently concluded Stockholm Convention on Persistent Organic Pollutants discourages the increased production and release into the environment of POP chemicals.
Preamble:
Acknowledging that precaution underlies the concerns of all the Parties and is embedded within this Convention,
Underlining the importance of manufacturers of persistent organic pollutants taking responsibility for reducing adverse effects caused by their products and for providing information to users, Governments and the public on the hazardous properties of those chemicals,
Conscious of the need to take measures to prevent adverse effects caused by persistent organic pollutants at all stages of their life cycle,
Recognizing the importance of developing and using environmentally sound alternative processes and chemicals,

Article 5
(b) Promote the application of available, feasible and practical measures that can expeditiously achieve a realistic and meaningful level of release reduction or source elimination;
(c) Promote the development and, where it deems appropriate, require the use of substitute or modified materials, products and processes to prevent the formation and release of the chemicals listed in Annex C, taking into consideration the general guidance on prevention and release reduction measures in Annex C and guidelines to be adopted by decision of the Conference of the Parties;

Annex C
Part V: General guidance on best available techniques and best environmental practices
This Part provides general guidance to Parties on preventing or reducing releases of the chemicals listed in Part I.

A. General prevention measures relating to both best available techniques and best environmental practices Priority should be given to the consideration of approaches to prevent the formation and release of the chemicals listed in Part I.
Useful measures could include: (a) The use of low-waste technology; (b) The use of less hazardous substances; (c) The promotion of the recovery and recycling of waste and of substances generated and used in a process;(d) Replacement of feed materials which are persistent organic pollutants or where there is a direct link between the materials and releases of persistent organic pollutants from the source; (e) Good housekeeping and preventive maintenance programmes; (f) Improvements in waste management with the aim of the cessation of open and other uncontrolled burning of wastes, including the burning of landfill sites. When considering proposals to construct new waste disposal facilities, consideration should be given to alternatives such as activities to minimize the generation of municipal and medical waste, including resource recovery, reuse, recycling, waste separation and promoting products that generate less waste. Under this approach, public health concerns should be carefully considered; (g) Minimization of these chemicals as contaminants in products; (h) Avoiding elemental chlorine or chemicals generating elemental chlorine for bleaching.

B. Best available techniques
(b) General release reduction measures: When considering proposals to construct new facilities or significantly modify existing facilities using processes that release chemicals listed in this Annex, priority consideration should be given to alternative processes, techniques or practices that have similar usefulness but which avoid the formation and release of such chemicals.