“Things That Make You Go Hmmm”:

Brian McNicoll – a self-identified “freelance writer” – authored a recent piece on Townhall.com advancing many of the same falsehoods perpetuated in DIPRA’s own talking points.  

(For the record, Merriam-Webster defines “freelance” as “earning money by being hired to work on different jobs for short periods of time rather than by having a permanent job with one employer.”)

We couldn’t help but wonder how McNicoll, who by our research has never written on water infrastructure issues before, would be such an impassioned advocate for ductile iron pipe. And in doing so, cite a deeply obscure – and seriously flawed – study financed by DIPRA to help advance his case.  

Seems rather peculiar, doesn’t it?

Unless he … well …  

Let’s put that aside for a minute and focus on dismantling his assertions.

The study McNicoll uses to advance his argument? DIPRA paid for it. McNicoll repeatedly refers to a University of Michigan (UMI) study to promote his support for ductile iron pipe.  But nowhere does McNicoll point out to readers that the study was sponsored by DIPRA, which represents ductile iron pipe manufacturers. Any self-described “independent journalist” would make sure readers knew about this rather important fact … right? 

Unless he … well …   

The DIPRA-backed study McNicoll cites contains a blatant and disqualifying inaccuracy.  The UMI study incorrectly quoted Dr. Steven Folkman, who has extensively analyzed the break rates of different types of water pipes. The glaring error prompted a terse rebuke by Dr. Folkman himself, who in a letter to the study’s authors, wrote:

“[Your study] references a paper I did in 2012 on ‘Water Main Break Rates in the USA and Canada’ and claim[s] that I stated that the expected life of PVC pipe is 41-60 years. There is no such statement in that paper. …” 

Such an egregious misstatement by UMI raises serious concerns regarding the integrity of the entire study. So why didn’t McNicoll point this out to readers? After all, if he was able to find the obscure UMI study for his article, it’s reasonable to think he would have also seen our public response to it, which we posted last month. Why didn’t he include it in his story?

Unless he … well …

Other facts missing from McNicoll’s column include: 

PVC pipe has a life expectancy in excess of 100 years. Dr. Folkman’s same letter clarifies his conclusive finding that, based on his own testing at Utah State University -- and analysis by 15 other authors across the world – “a properly designed and installed PVC pipe will have an expected life in excess of 100 years.” Why wasn’t this addressed in McNicoll’s column?

Break-rate studies show PVC is resilient in freezing conditions. McNicoll cites the concerns by Flint’s mayor regarding the harsh weather conditions as a reason to use ductile iron pipes. But Dr. Folkman’s Utah State University study proves that “PVC pipes offer a high degree of resilience in freezing conditions.” Why didn’t McNicoll include this in his piece?

PVC also can save taxpayers millions of dollars. McNicoll ignores Flint’s neighbor Burton, MI, which is saving almost $2.2 million after replacing 19 miles of dilapidated iron pipe with PVC pipe. And nowhere does McNicoll address the cost and other impacts of corrosive-prone iron pipe, which is why municipalities like Burton are making the switch to durable, affordable PVC pipe.

If McNicoll is truly concerned about the state of the nation’s aging water infrastructure, why did he conceal these crucial facts in his column?

Unless he … well …

 

 

 

 

DIPRA should file this one under “E” for “Embarrassing”

The findings and credibility of a Ductile Iron Pipe Research Association (DIPRA) funded study (DIPRA is the iron pipe industry association) promoting ductile iron pipe are being called into serious question, following news that its authors grossly misrepresented an esteemed academic, attributing statements to him that were never made.

The authors of DIPRA’s University of Michigan (UMI) report claimed Dr. Steven Folkman, Director of Utah State University’s Buried Structures Laboratory -- who has extensively analyzed the break rates of different pipe materials  – stated that the life expectancy of PVC pipe was limited to between 41 and 60 years.

The only problem, of course, is that Mr. Folkman made no such statement in his 2012 report, “Water Main Brake Rates in the USA and Canada: A Comprehensive Study, April 2012.” In a letter written to the authors of the DIPRA-UMI study Mr. Folkman writes:

“[Your study] references a paper I did in 2012 on ‘Water Main Break Rates in the USA and Canada’ and claim[s] that I stated that the expected life of PVC pipe is 41-60 years. There is no such statement in that paper. …”

Dr. Folkman goes on to point out in his letter that the DIPRA-UMI report also ignores a plethora of studies showing PVC pipe’s longevity to be in excess of 100 years:

“The paper titled ‘Validation of the Long Life of PVC Pipes’ documents testing done at Utah State University and also reviews papers from 15 other authors from around the world. They all conclude that a properly design and installed PVC pipe will have an expected life in excess of 100 years.”

Of course, DIPRA may position this glaring error as a simple mistake or an isolated oversight.  But it’s worth noting that the only reason it came to light is because Mr. Folkman called UMI out on it.  Which leads us to raise this question: How many other references or statements in the DIPRA-UMI study are incorrect – yet haven’t been publicly exposed? Lots more as it turns out.

The study claims that ductile iron pipe maintains its pumping efficiency for 100 years and that its thinner-walled iron pipes last a century as well, figures which are used in the study’s pipe modeling to artificially bolster iron pipe performance and reduce PVC’s, and do not reflect real life conditions. On its own web site DIPRA gives ductile iron pipes a 50 year life. The American Water Works Association has concluded that ductile iron pipe in moderately corrosive soils may only last 11-14 years.  

What’s more, a recent City of Detroit analysis shows that the pumping efficiency for ductile iron pipe continually declines with age and do not remain at factory specifications as the DIPRA-UMI report claims.

We at Vinyl Verified maintain that academics who conduct research at reputable institutions – who expect their findings to be taken seriously – must ensure that the facts they cite and the information they use to support their assertions are indeed accurate and above reproach.  DIPRA and UMI research failed, flatly, in adhering to this basic, important standard. As such, readers have every right to wonder if DIPRA’s ongoing campaign to disparage PVC -- in an effort to protect its monopoly – have unduly influenced the results of this study. 

TREACHEROUS, EXCESSIVE, NIT-PICKY, DECEITFUL, RECKLESS (TENDR)

Backpacks, lunchboxes, welcome mats, sofas, flooring, mattresses, and garden hoses – just some of the products the government would need to approve before they could be sold to consumers. This inevitably onerous process would push every item through an FDA-like gauntlet before hitting the shelves. This may seem Orwellian in nature, but it’s the reality that Project TENDR wants for America.

Project TENDR, an acronym for Targeting Environmental Neuro-Developmental Risks, says we need to “overhaul” how chemicals are reviewed, calling on regulators to “follow scientific guidance” and for businesses to eliminate products they don’t approve of. What types of products? Everything from high chairs to fragrant personal care products to fireplaces would be up for inspection.

The folks at TENDR even list “cooking fumes from stoves and grills” in the same category as tobacco smoke – since “all contain hazardous air pollutants.” The definition of what would be considered “safe” would be so absurdly restrictive that fewer and fewer products would be brought to market – including safe products that can bring added conveniences and comfort to our everyday lives.

Why did Project TENDR come together? For a noble cause: to protect children. But asking – expecting – the country to be consumers of only natural or organic materials is not only overbearing, but costly and unrealistic.  Today, people are living longer, healthier lives – thanks in large measure to many innovative materials used to make a host of safe products that have been studied extensively and available in the marketplace for decades.

A look at TENDR’s participant list may explain its radical positions. It includes agenda-driven advocates known for their extreme bias – and fundraising-motivated campaigns. Representatives from the Natural Resources Defense Council (NRDC) and Environmental Defense Fund (EDF) – staunch ideological critics of the chemical industry – are proudly listed. 

Copying the playbook of fellow alarmists Jenny McCarthy and Dr. Oz, the Project couldn’t resist the ultimate way to scare parents – raising fear over Autism: “In a large Swedish population-based study the presence of PVC flooring in the parents’ bedroom, which is a known source of phthalate exposure, was associated with autism.” One study, based in Sweden, in the presence of PVC flooring (and numerous other household items and environmental factors) showed an association? How is that proof of anything?

We’ll take it a few steps further … Where is the science here? What controls were established to demonstrate study credibility? What was the study’s sample size, and can proper scientific conclusions be drawn from it? Was the study peer reviewed by objective researchers – or published in a reputable journal? And why haven’t these results been validated by any other studies?

Groups like TENDR often avoid these questions because the answers frequently contradict their world-view.  They expect us to head for the hills based on the questionable findings of one junk science study – the very definition of irresponsibility in its truest form.

TENDR promotes a number of health scares by a host of groups that have been “fundraising fear” for years.  These include, among others, the dangers of consuming non-organic foods, promoted by the elitists at The Environmental Working Group, a group with an extensive track record of deceiving consumers through the use of junk science – dating back as far as the 1990s. And NRDC, whose efforts to raise money and spread fear over its long-standing campaign against mercury and seafood are well documented.

Consider TENDR’s funders, too. One sponsor, the Passport Foundation, is a major supporter of NRDC – to the tune of $100,000 in 2015. Passport also gives to Sustainable Markets Foundation, which in turn supports Safer Chemicals, Healthy Families (SCHF) – an alarmist group with an entrenched record of unwavering opposition against the vinyl industry.  Passport gives to another project donor, John Merck Fund, another supporter of SCHF.

Of course, when TENDR launched, most reporters blindly promoted its point-of-view without ever questioning the impact of its policies, or the motives of the organizations that support its agenda. The New York Times, surprisingly, was one of the only outlets to reach out for a quote from those with opposing views – but even its coverage was still heavily weighted in favor of TENDR’s mission.  Across the board, journalists failed to balance their stories with an objective examination of the organization’s credibility, and the consequences of its policy positions.

Which is why we will continue to publicly confront TENDR’s dishonest statements – and hold reporters who cover it accountable to their own journalism standards – to enforce a more balanced conversation about this organization moving forward.

Something smells funny over at the Environmental Working Group

If you smell something, say something. That seems to be the new motto for the agenda-driven fundraising outfit Environmental Working Group (EWG). When they’re not busy launching fear-mongering publicity stunts or promoting their baseless “EWG Verified” seal of approval, they go where their nose takes them. Smell something? Then stay away…it must be toxic! Seems like a good enough reason to call on the EPA to investigate.

As part of their “20 Toxic Chemicals the EPA should act on now” release—timed to raise money around EPA’s upcoming announcement of top priority chemicals to review under the Toxic Substances Control Act (TSCA)—EWG lists vinyl chloride.

Why? Because some products that use vinyl chloride during production smell funny.

No, really. EWG warns that vinyl chloride is “a source of the distinctive ‘new car smell.’” They say the same of shower curtains. Do new cars and new shower curtains have a distinct smell? Of course. But is vinyl chloride the cause?

The Agency for Toxic Substances and Disease Registry (ATSDR) states, “vinyl chloride has a mild, sweet odor, which may become noticeable at 3,000 parts vinyl chloride per million parts (ppm) of air.” To put that in context, 3,000 ppm is an extremely high concentration –considering that regulations prevent worker exposure over 1 ppm.

So unless you have a better sense of smell than any other human being, it’s probably not vinyl. Not much vinyl is used in shower curtains, but you can be assured that the vinyl chloride was removed during the PVC manufacturing process before the vinyl was used to make a shower curtain.”

If the researchers over at EWG used more than their noses, this would have been easy to figure out. Instead, they call on EPA to undertake a risk assessment for vinyl chloride. But vinyl chloride was one of the first chemicals listed on the initial TSCA priority list in 1976, and has been studied for over 40 years. Why does it need a new risk assessment? There is ample research, the same research used to enact strict limitations for workplace exposure by the Occupational Safety and Health Administration (OSHA) in 1974, and to set EPA limits on emissions and allowable levels of residual vinyl chloride in PVC resins. Along with decades of industry innovation, the safety of vinyl chloride has continuously improved.

EWG further warns that “The CDC has found it in about 60 percent of Americans tested.” But where does this statistic come from? No source is included in any of the release’s 28 footnotes. ATSDR, which is under the umbrella of the Centers for Disease Control and Prevention (CDC) states in their ToxGuide that there is currently no evidence “regarding distribution of vinyl chloride in humans.” So where did the mysterious CDC number come from? If such data does exist, how were these individuals tested for exposure, and what was the source of the exposure? For instance, exposure can come from smoking cigarettes or cigars— which have nothing to do with PVC plastic. ATSDR says that only a blood test administered within a few hours after exposure can yield definitive results. Were such tests used?

We realize that groups like EWG want to add their two cents to policy debates so they can make two bucks in fundraising. But the actual scientists and policymakers who will determine the next ten high priority chemicals for testing should continue to rely on the 2014 TSCA Chemical Work Plan, as the EPA has planned on doing all along.

That sure beats the smell test.

Garden Variety Dishonesty by Ecology Center

Ahhh … summer is finally here.  And with it brings the welcome return of backyard barbeques, the familiar smell of fresh cut grass -- and the Ecology Center’s failed annual attempt to scare us about our (*wait for it*) PVC garden hoses.

Garden hoses.

Not one to let any possible fundraising opportunity go unexploited, this rather strange annual ritual by the Ecology Center’s PR team dates back to at least 2011.  And judging by the complete lack of interest in this year’s effort, even the Center’s most committed followers must be scratching their heads, wondering if this sad yearly publicity stunt has finally run its course.

The Center’s unequivocal mission in issuing this report is to spread fear about the health of consuming PVC hose water. But they discreetly acknowledge at the very end that their ratings “do not provide a measure of health risk or chemical exposure associated with any individual product …”

Which is the equivalent of saying, “We want to terrify you about your PVC hose because it helps our fundraising. But we’re not making any judgments here about the health of consuming hose water.”

Plastics Today’s Clare Goldsberry captured the Center’s duplicity best:

“It seems that nothing is safe from the plastic fear mongers. … I was lucky I had time to look into this story and question its merits. I was able to ignore the hysteria and consider the facts. 
… 
“This isn’t the first such report. In researching this so-called problem, I found that every summer—usually in June or the first part of July—Healthy Stuff releases its newest report on toxic garden hoses. This is to ensure you get your summer off to a fearful start. These reports go back as far as 2012, with one appearing on July 3, 2014, then updated on June 29, 2015.
… 
“Some were found to contain bromine (used in flame retardants just in case your hose catches on fire); antimony (a mineral found in batteries, glasses and pottery. Oops! Throw out the glassware and stoneware! The ancient Egyptians used it as eyeliner); and tin (don’t carry your water in a metal bucket—it might have tin in it). 

“The advice to ‘let the hose run until the water sitting in the hose is now in the ground’ is a waste of water. Avoid the sun by storing the hose in the shade—sorry, but here in the desert southwest when it’s 115 degrees that doesn’t even work in the shade! In fact, that’s a good deterrent to drinking from the water hose in Phoenix because you’ll burn your tongue off! Talk about health problems! You’ll never taste a steak from the barbeque again! Oh, I forgot, charcoal briquettes are also toxic.”

So. … What’s the next seasonal scare we can expect from the Ecology Center brain-trust?  Look for the group’s annual back-to-school disinformation assault on vinyl backpacks and related classroom products next month. Where they’ll earn a well-deserved “A” in Deception, and an “F” for Creativity.

 

 

 

 

ACECO Bill protects interests, not taxpayers

The citizens of Columbus and all of Ohio should demand clean, safe water, at an affordable price.  A bill pending in the Ohio legislature will help establish the framework to do just that, but opponents from the iron pipe industry and their surrogates are working feverishly to undercut the interests of the good citizens of The Buckeye State.

Such action is reminiscent of what has occurred over the years in other states, including Michigan, which contributed to the ongoing catastrophe in Flint.  Ohioans deserves better!

Delivering water, safely and affordably, from one location to another, is what PVC pipe does best.  

But carrying water – for the metallic pipe industry?  That’s something the American Council of Engineering Companies of Ohio (ACECO) might know a thing-or-two about.

ACECO’s Donald Mader penned this Columbus Dispatch essay blindly advancing the positions of the metallic pipe industry. In it, he attacks a pending bill in the Ohio legislature which would open markets and offer local officials access to materials beyond metallic pipe to address the region’s deteriorating water infrastructure.

Mr. Mader dismisses the bill on the grounds that the PVC pipe industry is trying to “force their product into the public works marketplace and gain a competitive advantage over other pipe producers.”   

But as Mr. Mader no doubt knows, the metallic pipe industry today has a 100% competitive advantage over other pipe materials available to local officials in Ohio. Groups, such as Ductile Iron Pipe Research Association (DIPRA), have fought aggressively to block states from accessing PVC pipe – despite its proven durability and affordability – to protect its members’ monopoly.

Leading readers to rightly question:  If Mr. Mader truly believes in competitive balance, why does he support the metallic pipe industry’s exclusionary foothold in Ohio, and oppose other cost-efficient materials, like PVC pipe, from entering the market – that would save taxpayers money?

Local officials would not be “forced” or “obligated” to use one material over another under the proposed legislation, as Mr. Mader deceives readers to believe.  The bill would simply grant materials other than metallic pipe a seat at the table, and level the playing field for other manufacturers.

And his misguided thesis assumes city engineers are somehow incapable of knowing what materials work best in certain applications. It suggests these engineers are unable to make the right choices themselves. It offends the intellect and expertise of these highly skilled and trained professionals, who are well informed on material specifications – and should be allowed to make their own decisions. 

Mr. Mader wants to keep us in the past – where innovations in durable, lead-free PVC pipe are denied the opportunity to help states confront their dilapidating, corroding, lead and metallic pipe water systems. 

But history isn’t on his side. Innovation often has a funny way of kicking antiquated technology to the curb. And as PVC pipe continues to expand its reach and deliver safe drinking water throughout America, corrosive metallic pipe may one day find itself encountering the same fate as the rotary phone and the horse drawn carriage.

Ohio deserves the right to select the best pipe for the application, and city water engineers should be allowed to consider all piping materials as they work to develop the most effective water infrastructure for their communities.

Richard Doyle
President & CEO
The Vinyl Insitute

 

 

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?