We were entertained by Healthy Building Network’s Jim Vallette’s wordy response to our factual takedown of his original post riddled with errors about PVC. So we’ll get straight to the point and highlight Vallette’s continued omissions and distortions:
Why won’t Vallette hold himself accountable to his own statements? Vallette’s 1,700+ word rebuttal conveniently sidesteps any reference to a glaring error we exposed in his original post. He initially claimed a mercury cell chlorine plant in East Berlin, New Hampshire was used by the PVC industry. But we pointed out the industry has never operated in the state. And the site he references was dedicated for use in adjacent pulp and paper production, and had nothing to do with the PVC industry at all. If Vallette is so concerned with accountability on these issues, why won’t he acknowledge that he misled his readers on this point? Why won’t he be truthful and admit he made a mistake?
No agenda? Why, then, does Vallette irresponsibly fixate on PVC while ignoring the hundreds of uses of chlorine by the two plants he spotlights? Water filtration is perhaps the most widely used application for the chlorine manufactured by the facilities noted in Vallette’s post. There are hundreds of other uses, too. Yet Vallette makes no mention of this – misleading unwitting readers to mistakenly believe the PVC industry is somehow a primary contributor of mercury pollution.
Vallette cites decades-old examples to convey a dishonest impression about our modern-day industry. Vallette desperately tries to blame the PVC industry for the events at Cato Ridge, a mercury recovery facility in South Africa that closed in 1998. But this contradicts an earlier essay Vallette penned about this very plant, where he made no mention of PVC as the cause of any pollution there. Yet his most recent response now conveys the misguided notion that the PVC industry somehow bears primary responsibility for the events there, avoiding any reference to the countless other companies around the world that utilized this facility. His evidence? Small shipments of mercury and vinyl chloride waste sent by one company, prior to 1998, for treatment at the South Africa plant. A company which closed its doors in 2002, and whose current owners no longer use mercury cell technology in their operations. So how, exactly, does this prove Vallette’s thesis that the PVC industry is responsible for present-day mercury pollution? It doesn’t. Vallette’s selective, cherry-picked examples from decades ago only mislead the public. And they intentionally ignore the tremendous strides our industry has undertaken to modernize operations and phase out the use of mercury cell technology in the U.S.
There is no vinyl chloride production at / near either of the two chlorine plants that use mercury cell technology featured by Vallette. Over the past 20 years, U.S. vinyl chloride producers reconfigured their operations to rely on chlorine either manufactured on-site or from adjacent / nearby facilities. Chlorine produced from these plants is intended to supply all the chlorine requirements for the manufacture of vinyl chloride and its precursors used in the production of PVC resins. Regional chlorine plants supply regional markets, as is the case with Axiall’s Natrium, WV and ASHTA’s Ashtabula, OH facilities featured in Vallette’s posts. There is no vinyl chloride production near either of these facilities. As such, these facilities market their chlor-alkali products to uses other than vinyl chloride production.
Mercury cell technology has been systematically phased out in the U.S. since the 1970s by more efficient and modern membrane technology. ASHTA’s Ohio plant is nearing completion of this conversion. Vallette fails to note this, or point out to readers that once the ASHTA plant is converted, there will only be one remaining mercury cell technology plant in the U.S. and Canada.
Vallette infers that chlorine shipped from Axiall’s WV plant supports vinyl chloride production in other locations – but he fails to prove it. He claims chlorine from Axiall’s WV plant is shipped by barge to company “facilities” in Lake Charles, LA. But as noted above, chlorine has hundreds of uses, and these shipments could support any number of purposes other than vinyl chloride production. He fails to draw a direct connection, and instead draws dotted lines and misguides readers to believe that chlorine is shipped with regularity from WV to Lake Charles and ends up in PVC – when that is simply not the case.
Vallette’s claim that “all” of ASHTA’s chlorine production serves Cristal’s titanium dioxide manufacturing is a lie. ASHTA’s press releases state the company “manufactures and markets chlorine and potassium-based chemicals to a broad customer base,” where its products “are used in a wide variety of end use markets including liquid fertilizers, runway deicers, food products and pharmaceuticals, agricultural chemicals, alkaline batteries, photochemistry, oil and gas production, industrial cleaners and water treatment.” There’s no mention of titanium dioxide anywhere. Cristal’s own website shows only some 20% of its titanium dioxide production is used to support a multitude of plastic uses. So, simply for the sake of argument, if a small fraction of this small percentage is used for downstream PVC production in some way, does he really expect readers will think it somehow validates his thesis that the industry is a primary contributor of mercury pollution?
Vallette’s statements regarding Dover Chemicals are entirely disingenuous. It is incorrect to assume, as Vallette does, that large portions of chlorinated paraffins are used in PVC. Chlorinated paraffins produced by Dover Chemicals and others are used in a variety of plastics, rubbers, metal working fluids, automotive lubricants, paints, sealants, and coatings. Had Vallette checked the pre-manufacturing notification Dover Chemicals filed with the U.S. EPA, he would have discovered that only 43% of the company’s production is used in all plastics, of which PVC products are one of several types consumed. Another producer of chlorinated paraffins, Ineos, reported that 74% of its products are used in metal working fluids. Even worse, Vallette’s assumption that Dover Chemicals sources its chlorine from the Natrium plant is based on information from 1984. How anyone can assume that a supplier from 30 years ago is still a supplier today is incomprehensible.
If Vallette firmly believes chlorinated paraffins are a significant ingredient for PVC products and made from chlorine based on mercury cell technology, he should prove it with current information. He should also read the entire EPA docket on chlorinated paraffins to understand that nearly every metal working processor in the U.S. that mills and drills high alloy metals – as well as rubber processors and automotive lubricant manufacturers, among other uses – depend on chlorinated paraffins to manufacture products and compounds he and the rest of the U.S. population use everyday. Yet Vallette won’t do this because of his entrenched, reflexive anti-PVC views – views that were likely forged during the six years he spent working with fellow ideological extremists at Greenpeace.
But we’re apparently not allowed to state these facts, as he deems any attempt to challenge or question him an “ad hominum [sp] attack.” (More on that in a moment.)
Vallette conceals important facts that contradict his own conclusions. Vallette claims that vinyl products pour into the U.S. produced using mercury cell technology. But he hides from readers the fact that the U.S. vinyl industry exports nearly one third of its resin production. And while big box global retailers do bring in some vinyl products made outside of the U.S., it represents a very small amount of the vinyl consumed in the U.S. And these multinational organizations that import offshore products have strict product safety compliance and sustainability policies that must be adhered to, in order to be able to market products through their organizations.
Vallette’s misuse of “ad hominem” speaks volumes. We were especially amused by Vallette’s claim we had engaged in “ad hominum [sp] attacks.” Not only does he misspell the term, he may not understand what it means. According to Merriam-Webster:
Ad hominem: adjective (ad ho·mi·nem): “1) appealing to feelings or prejudices rather than intellect 2) marked by or being an attack on an opponent’s character rather than by an answer to the contentions made.”
So, an ad hominem attack would have been true, for example, if, say, we had invoked similarities between his assault on PVC to today’s attack-oriented political campaign environment, as he, in fact, asserted in responding to us. Or if we said his statements were simply wrong, without providing any justification.
But we didn’t say or do anything of the kind. Do readers see any attacks on Mr. Vallette’s character in our response – where the substance of his claims are sidestepped or avoided? We don’t either. We let the facts speak for themselves. Our rebuttals presented our positions. And let’s not lose sight that Vallette is the one who initially spread misinformation about our industry, obligating us to respond and correct the record.
Leading readers to ponder: Would Vallette reflexively declare anyone who dares to challenge him in the open discourse guilty of launching an “ad hominum [sp]” attack, even when the facts prove him wrong?
 EPA docket EPA-HQ-OPPT-2015-0789
 EPA docket EPA-HQ-OPPT-2015-0789
 EPA docket EPA-HQ-OPPT-2015-0789