Vallette Could Use a Fact Checker … (And a Proofreader)

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.[1] 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.[2] 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.[3] 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,[4] 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.”[5] 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.[6] 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.[7] Another producer of chlorinated paraffins, Ineos, reported that 74% of its products are used in metal working fluids.[8] 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[9] 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.[10] 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.[11]

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?

Note to Medical Construction & Design Magazine’s (MCDM) Publisher Evan Mann

Dear Mr. Mann, 

My name is Dick Doyle, and I am the President & CEO of The Vinyl Institute.  I am following up on my letter to Michelle Tennis on May 2, 2016 highlighting the inaccurate and misleading characterizations about vinyl contained in an April 7, 2016 white paper promoted by Medical Construction & Design Magazine (MCDM) on behalf of its paid sponsor Nora, a rubber flooring manufacturer. 

Ms. Tennis told us that she forwarded my inquiry to you on May 2, 2016.  For convenience, I have attached a copy text of my letter to Ms. Tennis.  You may also find a copy of it posted on our website

It’s been over a week and we still haven’t heard from you.  I realize you are very busy, but we do hope you will take our inquiry seriously, as I trust we share a mutual interest to ensure your readers have the facts about the issues your publication covers and promotes.  

We certainly value this mission, as it’s the reason we’re writing you and seeking your action on this matter.  We hope you do as well, although we remain surprised to see that MCDM still has not taken action to remove this white paper from the website.

We eagerly await your response to our stated concerns in our May 2, 2016 letter.  Specifically, we’d like to know what MCDM’s procedures are in confirming the accuracy of the white papers it promotes to its readers on behalf of its advertisers.  And we reiterate our request to have this white paper immediately removed from MCDM, and that the Magazine send a proactive correction to its subscribers who received the original advertisement, to ensure readers are not misled.

We look forward to your prompt response to these important questions.

 

Thanks,Richard Doyle
President & CEO
The Vinyl Institute

See our letter to the editors HERE.

 

Addressing the Media’s Irresponsible Obsession With Junk Science

Addressing the Media’s Irresponsible Obsession With Junk Science

THE PREMISE:  Every time we read an article or turn on the TV, there seems to be a study warning consumers about something. But how reliable are they? Are they based on scientific facts -- or are they just scary gotcha headlines used to draw in readers and gin up ratings?

THE PROBLEM:  Reporters are blindly covering ideological-driven studies that lack any scientific integrity whatsoever – presenting the findings as sound, credible facts worthy of widespread public awareness.

WHY IT’S HARMFUL:  The public looks to the news media to provide factual information they can use to enhance their lives.  But when reporters give baseless studies undeserved attention, cities and communities across our nation are the ones who endure the consequences. Such publicity can cause unnecessary panic, instilling fear and worry on the minds of the consumer population.  And when the news media promote these invalid studies and give them national exposure, regulatory entities often feel pressured to take swift and decisive action – which can deny consumers the ability, the right, to make their own choices about safe products offering convenience and benefit to their everyday lives.

ARE ALL STUDIES BAD? No, and that’s important to note.  Studies that can withstand the rigor of proper scientific review and analysis, regardless of the sponsor, are worthy of attention and focus by the media. If a study upholds responsible scientific standards, we must give them careful consideration. And it’s important to confront this, if we are to distinguish studies that demand our collective focus from those that simply don’t deserve it.

GIVE ME AN EXAMPLE: Recently, Belgian researcher Soren Verstraete gave a presentation to the Endocrine Society capturing highlights from a March 2016 study asserting a correlation between ADHD and phthalates from vinyl blood bags, catheters, intubation devices and other sterile vinyl components and devices key to patient treatment and recovery.  As bizarre as this research premise appears, the study claimed a connection between these bags and the development of ADHD later in life by those who were evaluated. The problem is that it was an observational study, where no causation data was included in the review.  There were no controls on the study, and no additional testing was conducted. Also noteworthy, the ADHD diagnosis was subjective, as there was no biomarker in the study. And there was no consideration given to any number of other factors that could have contributed to the study participants’ ADHD diagnosis, such as pre-existing conditions, other drugs administered before or during their care in the hospital – or even events that occurred throughout their lives after their hospital stay. The researcher may as well have asked these individuals if they’d ever used the telephone – and drawn the same conclusions.

To give this study any respect or notable attention would be ludicrous.  Yet, the Washington Post’s Amy Ellis Nutt did just that – authoring an article that repeated, almost verbatim, a press release that was distributed to promote the researcher’s findings.   Ms. Nutt failed to question the scientific integrity of the results because it was a story too good for her not to tell.  And in doing so, she no doubt spread unnecessary fear on the part of hospital visitors everywhere that they, too, might develop ADHD if treated with vinyl medical products – which, for years, have saved countless human lives.

Then again, let’s remember The Washington Post is the same outlet that previously reported an observational analysis claiming a link between ADHD and kids with August birthdays (you read that correctly). Which raises some rather serious questions as to the organization’s standards in assessing the credibility of the studies it covers. 

WHAT NEEDS TO BE DONE? Special interests will no doubt continue to promote studies to advance their respective agendas with the news media.  That won’t change.  But it’s the media’s responsibility to scrutinize these studies and determine if they have the scientific strength to warrant exposure with readers and viewers.  The simple “scare-factor” of any given study cannot – must not ­­– be included in this calculus. To this end, reporters, such as Ms. Nutt, must ask themselves all of the following questions when evaluating a study’s integrity:

  • Is it an observational study?  If it is, the results are inconclusive.  Any study that fails to provide in-depth scientific analysis, and is based solely on observing the behavior of a group of participants, lacks proper scientific credibility, as any number of unknowns, such as those revealed in the ADHD example, can be contributing factors.
  • Is it peer-reviewed?  If not, it fails to include the proper checks and balances, and represents only the views of the authors themselves, without any independent validation.
  • Is causation proven? Researchers often confuse correlation with causation.  Just because two data points may share a relationship doesn’t mean one causes the other. (Example: People who like bananas tend to drink more coffee. Does eating bananas cause one to drink coffee? Probably not.) Studies that cannot demonstrate a clear causal connection between the claim and the conclusion cannot be taken seriously.
  • Is the study published in a reputable journal?  Research appearing in obscure outlets that fail to garner the support and respect of the broad scientific or medical community must be approached with a sensible degree of skepticism. And when those outlets have a specific ideological outlook, where the study’s conclusions support the advocacy efforts of the publisher, it’s usually because the quality of the research wasn’t strong enough to appear in a more reputable venue.   
  • Is the sample size substantial? If the number of people in a given study is an insignificant sum, how can any reliable scientific conclusions be drawn from it?
  • Is it an outlier? One study that challenges the body of scientific literature on a particular subject should not reflexively attract media attention just because it’s different, as is often the case today.  In fact, such findings should be approached with a strong sense of suspicion, and if the research lacks any of the standards described here, it doesn’t deserve our attention.
  • Are the same standards being applied to both NGO and industry studies? Industry studies are often automatically dismissed by the media – regardless of their scientific vigor – while many NGO studies lacking any legitimacy are provided widespread exposure.  To ensure the journalism ethos of fairness and objectivity is achieved, both NGO and industry funded research must be weighted equally against these standards.

It’s the media’s responsibility to ask these responsible questions when determining whether a scientific study merits public awareness.  And when reporters fail to do this, they perform a disservice to their readers.  Which is why we will continue to use this forum to expose media organizations, such as The Washington Post, when they forsake their obligations in this regard.

5.11.16 UPDATE: John Oliver recently touched on many of these exact points in a recent “Last Week Tonight” segment. He overlooks the fact that ideological-minded groups should be held to the same high standards expected of industry in assessing the credibility of sponsored scientific studies.  But he makes a strong case that the media too often shirks its responsibility to the public in failing to distinguish junk science from the real thing. 

Watch Here: https://www.youtube.com/watch?v=0Rnq1NpHdmw

 

Clean Production Action Continues Misleading Public

Clean Production Action (CPA) and its red-list allies, once again, are misleading the public about PVC.  In a recent “Buyer Beware” report, CPA and its cohorts twist the facts and assert a number of groundless claims challenging the safety of PVC – claims that just aren’t true.

We’ll be specific:

Among the myriad of mischaracterizations, the report questions the safety of PVC water pipes – but the authors omit that PVC pipe is one of the best, most efficient delivery methods used across the country for safe drinking water. And unlike metallic pipes, PVC pipes don’t corrode or leach contaminants into the water system. Recent news reports have praised PVC in this regard -- and NSF International has even certified PVC for safe drinking water delivery. Of course, these facts were predictably missing from CPA’s reflexive, agenda-driven position against PVC.

But wait, there’s more. …The report dishonestly conflates the findings of a 1970s-era PVC workplace exposure study with common, everyday, real world PVC interaction – as if to suggest that both are somehow remotely comparable.  Fittingly, it’s no shock the report omitted any reference whatsoever to the 1974 OSHA standards that reduced workplace vinyl chloride exposure by 500 times, and the enormous strides the industry has deployed since to make PVC production safe for its employees.

CPA is flat wrong on the facts about PVC.  And given the group’s strident opposition to nearly 13,000 chemicals (you read that correctly), do they honestly expect anyone to take them seriously?  

 

 

Why is AWWA Against Open Competition?  

In a recent open letter, Gulfport, MS Mayor Billy Hewes called into question the American Water Works Association’s (AWWA) "opposition to competitive bidding for water and sewer piping materials” that “could save states and municipalities millions of dollars.” 

He continued: “When local governments invest in water and sewer infrastructure it’s critical that open and fair competitive bidding practices are utilized in order to get the best value for scarce taxpayer dollars.”        

Indeed … Why would anyone, especially the AWWA, support less competition? Why would a non-profit association representing utility engineers be taking a stand against fair and open procurement when it’s the job of engineers as public officials to objectively compare all available piping materials?  How can piping materials be objectively compared when they are excluded from even being considered in any projects or bids? And why would AWWA want to deny taxpayers the opportunity to get the best long term solutions for their water infrastructure — at the most competitive price?  

We’re curious:  Are AWWA’s positions favoring closed procurement policies for municipal water pipe procurement processes being driven by a particular constituency? And more importantly, is AWWA truly looking after the interests of water infrastructure rate payers and the health of Americans, particularly among those in need?

Interestingly, AWWA’s position against open procurement for piping is identical to that of the ductile iron pipe industry which wants to protect its closed iron-only municipal pipe markets. 

Maybe it's time to take a hard look at who is influencing the positions of AWWA, and ask:  Is there a better way to fix America's deteriorating water infrastructure?

Click here for a copy of Mayor Hewes’ open letter.  And click here for the AWWA’s opposition to open procurement.

Just Because HBN Says It Doesn’t Mean It’s True…

There’s a saying, one often attributed to Herbert Hoover, that we should never confuse the right to be heard with the right to be taken seriously. 

Nowhere is this cautionary view by our 31st president better applied than with the Healthy Building Network – a group that continues to distort the facts and mislead the public about PVC.

We’ll be specific:

In HBN’s latest screed, the group’s “Research” Director, Jim Vallette, claims two chlorine plants in the U.S. cause mercury pollution by continuing to use “mercury cathode cells” in the production of vinyl chloride.

There’s just one problem – he’s wrong. 

Neither of the two plants that continue to rely on mercury cathodes in the United States supply vinyl chloride or PVC producers. Production of vinyl consumes just over one-third of the chlorine produced in the U.S. and most PVC producers rely on facilities either on-site or nearby.  The two facilities quoted by Mr. Vallette supply water treatment, agricultural, and pharmaceutical applications.

It bears repeating – neither the ASHTA plant in Ashtabula, Ohio plant nor the Axiall plant in Proctor, West Virginia supply the PVC industry in any manner. Vallette incorrectly attributes mercury emissions from these two facilities to PVC in his story.

His inaccuracies don’t stop there… Vallette goes on to claim mercury pollution in the state of New Hampshire is attributable to the PVC industry, referencing this study in his “report” to validate his assertion.  

But that’s not what the facts show. The PVC industry has never maintained any operations in New Hampshire at all. And the study he cites to support his claim actually refers to a former paper mill that existed for over a century, and is now a Superfund Site with the Environmental Protection Agency (EPA). Vallette misinforms his readers that the environmental burden of past pulp and paper operations are now attributable to the vinyl industry. 

So… The Vinyl Institute’s statement he invokes in his story – the one he stridently positions as being inaccurate – is, indeed, correct:  there is no mercury cell chlorine technology used in vinyl production in the U.S.

There’s more: Vallette assails mercury cell use in PVC production in South Africa.  But the shutdown of those mercury cell chlorine facilities was completed in 1998. And before their closure, only an estimated 25% of mercury cell use went towards chemicals used in PVC production. Vallette no doubt knows that the Cato Ridge, Natal plant in South Africa was not solely working on chemicals for PVC – or at least he did when he claimed in his 1991 paper the function of the plant was “recovery of exhausted catalyst and electrical equipment…” Vallette again misinforms his readers that the environmental burden from this facility that reclaimed mercury from electrical equipment now is attributed to the PVC industry.    

Historically, the PVC industry has been a minor contributor to overall mercury emissions.  The EPA itself has identified power plants and metals processing facilities as its primary sources. But Vallette predictably omits these facts, too.

The real concern, of course, is that the Healthy Building Network (HBN), and groups like it, has been spoon-feeding the press with inaccuracies about PVC for some time. And the press has blindly accepted these assertions as fact, without applying any degree of scrutiny or skepticism that is routinely directed at industry.  And no one has held these agenda-driven groups accountable – or questioned their own financial fundraising motives when such baseless statements about PVC are made in the public discourse. 

No one, that is, until now.