The greatest source of exposure to dioxin does not stem from proximity to a chemical plant or incinerator, but from consumption of contaminated food. Less than 10 percent of dioxin particles settle to Earth within 30 miles of its source, i.e., an incinerator. At least half of the dioxin falling on the fields, lakes, and dairies of the Great Lakes states comes from incinerators located up to 1,500 miles away.

          Such environmental regulations as are in place fail to deal with any of the realities disclosed by Commoner's team. For one thing, nearly all of our exposure to dioxin comes from food, not from breathing contaminated air or drinking dioxin-laced water. Dioxin is a fat-soluble chemical, meaning it bioaccumulates up the food chain. For example, fish from Lake Michigan show levels of dioxin more than 100,000 times higher than the surrounding water, plants, and sediment. Two-thirds of the average American's exposure to dioxin comes from milk, cheese, and beef, a result of cows eating contaminated food crops.

          "The risk to the people of Chicago is not so much from inhaling dioxins emitted by the city's trash-burning incinerators," Commoner said. "But rather from ingesting milk and cheese produced from farms in Wisconsin and Minnesota."

          Tracing sources of contamination from their area of research around the Great Lakes, Commoner and his colleagues were able to identify 1,360 culprits, as far afield as Utah, Florida, and Texas. The biggest culprits are the least regulated: medical waste incinerators. There are 623 of them in the Great Lakes region, in the form of hospitals, nursing homes, funeral homes, medical labs, blood banks, veterinary clinics, and crematoria. One reason they are such a high source of dioxin is modern medicine's increased use of chlorinated plastics.

          In most hospitals, waste is divided into black bag and red bag categories. Black bag waste consists of discarded paper, plastic, glass, metal, and food waste--not so different from what you might find in household trash. This accounts for about 85 percent of the medical waste stream. Then there is red bag waste, which includes anatomical waste, gauze pads, catheters and infectious or pathological materials. The per-patient yield of red and black bag waste is about thirteen pounds a day. Pleading poverty, the medical and funeral lobby have persuaded the EPA to hold off from any burdensome supervision of the way they incinerate this avalanche of dioxin-suffused matter.

          The second leading source of dioxin in the Great Lakes region comes from 57 municipal waste incinerators, burning 12 million tons of trash a year. Every load of trash dumped into those solid waste incinerators contains plastics, solvents, and chlorine-based products that when burned create dioxin. In fact, recent research shows that incinerators actually synthesize dioxin, producing from the smokestacks nearly 500 times the amount of dioxin chemicals as were present in the source material. Most of the dioxin now coursing through the bodies of Americans was actually created by the incinerators.

          Of the eight Great Lakes states, Minnesota ranks behind only Michigan in the number of hospitals with an on-site incinerator. There are 113 such incinerators in Minnesota burning more than four thousand tons of infectious waste a year. In addition, Minnesota has 20 crematories and a commercial medical waste incinerator.

          Minnesota also ranks second in the number of municipal solid waste incinerators with 13, including the massive Hennepin incinerator in Minneapolis. Altogether, the Minnesota incinerators burn three million tons of waste a year. Only New York incinerates more trash.

          According to Commoner, nearly all of the dioxin emitted from these incinerators could be eliminated, either by intensive recycling or with landfills. Commoner estimates that switching to these methods could save cities $350 million a year. By the same token, black bag medical waste can also be safely recycled, while the red bag medical waste can be sterilized through autoclave technology and then landfilled.

          Not surprisingly, the EPA has shown little interest in moving toward the elimination of dioxin-spewing incinerators. Instead, the agency has adopted the strategy of pollution control, relying on scrubbers and other expensive technological fixes that cannot reduce dioxin emissions to zero. "The Clinton administration and some of its acolytes in the Washington environmental community, like the Sierra Club and the Natural Resources Defense Council, are spending their scarce resources jousting in court over the meaning of things like 'maximum control technology' and not even discussing real pollution prevention, which requires not emitting dioxin to begin with," charged Dr. Peter Montague, director of the Environmental Research Foundation in Annapolis, Maryland.

          Montague points out that many of these national environmental groups endorsed the repeal of the Delaney Clause, which prohibited the addition of carcinogens to processed food. The zero tolerance standard of Delaney will be replaced by a risk-assessment strategy that allows supposedly safe levels of carcinogens in the food supply. But risk assessments, particularly in the case of chemicals such as dioxin, vastly underestimate the actual cancer risks by looking at the health consequences of individual sources of pollution, instead of examining what Commoner calls the "entire ecosystem of carcinogens."

          "This is the painful lesson that ecology teaches," Commoner said. "The danger of dioxins is vastly greater than the risk assessments have led us to believe; it threatens entire populations with unacceptable risk of cancer and poses grave hazards to fetal development."

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