Mongoven, Biscoe & Duchin/Behind Enemy Lines

This article was first published as "Behind Enemy Lines"in PR Watch, Volume 3, No. 2, Second Quarter 1996. It original article was authored by John Stauber and Sheldon Rampton and is used here with permission. As with all SourceWatch articles, feel free to edit and revise.

The excerpts below are taken from a series of confidential "Update and Analysis" reports written for the Chlorine Chemistry Council by PR research firm Mongoven, Biscoe & Duchin.

"They are taking us more seriously than we sometimes take ourselves," commented Charlotte Brody, a registered nurse and director of Citizens Clearinghouse for Hazardous Waste. "I think of myself as jaded," Brody said after reviewing the leaked documents, "but it still takes my breath away to see a professional, totally amoral directive that editorial visits be done because the scientific information that Devra Lee Davis has is too dangerous to go unfiltered."

Brody was also struck by MBD's "recommendations that the chlorine industry should go to health groups and sign them up to defend the benefits of chlorine, without telling them what they are really signing up for, and before we can get to them and talk about how dioxins and other endocrine disrupters are harming their health. MBD doesn't suggest going out and talking about why dioxin isn't as dangerous as we say. Instead, it's a much more clever and insidious strategy, where they sign up people with cystic fibrosis to defend the benefits of chlorine chemistry by suggesting to them that without chlorine there will never be a cure for their disease. They don't even bring up dioxin, but they falsely suggest that we would bring an end to pharmaceutical research."

At the same time, Brody sees grounds for optimism in the fact that a corporate whistleblower had the courage to risk the consequences of releasing MBD's documents to the public. "Things like these documents appear because someone feels it's awful to walk around pretending it's just business. One of our hopes is that people aren't from cyborg land."

The following are extracts from documents by the secretive PR firm of Mongoven, Biscoe & Duchin (MBD) were leaked to the public by a whistleblower. MBD Update and Analysis CONFIDENTIAL For: Chlorine Chemistry Council Date: May 18, 1994 Activist Update: Chlorine

NRDC and U.S. PIRG Join Forces to Recruit and Train Anti-chlorine Activists for Protracted Battle

U.S. PIRG's Green Corps is collaborating with NRDC's Clean Water Network (CWN) on a project to recruit and train activists in an anti-chlorine campaign that is initially targeting the pulp and paper industry.

The move by CWN to bring Green Corps into a more active role in the anti-chlorine battle appears to be part of an overall strategy devised by the network's participants to broaden the anti-chlorine attack by recruiting and training enthusiastic young activists to carry the anti-chlorine banner on several fronts. . ..

Green Corps is a three-year-old environmental training project of Ralph Nader's U.S. Public Interest Research Group (U.S. PIRG) and is based in U.S. PIRG's offices in Washington, D.C. .. . [PIRG] follows the Greenpeace line on chlorine chemistry but, according to its staff people, it has no formal affiliation with Greenpeace except through the Clean Water Network.

While that may be true in the strictest interpretation, there is a long-standing close association and history of cooperation between NRDC, U.S. PIRG, the Sierra Club and Greenpeace on a variety of issues. . . . CWN, a project of the Natural Resources Defense Council (NRDC), claims chlorine causes birth defects, reproductive problems, cancer and other human- and animal-health problems. The network, based in NRDC's offices in Washington, DC, has a staff, publishes a monthly newsletter and claims to have several hundred groups associated with it. It is a highly active group that meets monthly to exchange information among members and to give direction on clean water issues.

Originally CWN was most active on issues arising out of the Great Lakes but it is now expanding into a much broader area of activism with particular emphasis on chlorine chemistry. . . . It is expected to expand its assault by using its constituent groups and other NRDC resources to press attacks on other areas of chlorine chemistry--product-by-product, step-by-step, application-by-application. . ..

All of this is consistent with what a key person on chlorine issues at Greenpeace said is Greenpeace's plan to orchestrate a grand strategy that encourages various environmental groups to concentrate on specific aspects of chlorine chemistry where they can be most effective.

The idea behind the strategy is to give Greenpeace a strong lead on the issues but to use various groups--some of which are more acceptable to the mainstream--to appear to lead specific issues, thus giving the overall campaign the appearance of a widespread, generally accepted grassroots uprising against chlorine chemistry.

CWN is an important element in the Greenpeace strategy because it provides a forum for Greenpeace to communicate and coordinate the various parts of its anti-chlorine efforts and to recruit activist groups and their members to carry a big share of the battle.

Greenpeace Says Dioxin is a Public Health Emergency and Calls for Global Chlorine Ban

Greenpeace, as expected, has called the EPA draft Dioxin Reassessment Study justification for a global chlorine ban. It says the study clearly indicates a national public health emergency. . ..

The dioxin reassessment began in 1991. Greenpeace began its U.S. anti-chlorine campaign based on potential birth defects in late 1992. . . . Greenpeace says action is needed to ban chlorine in incinerators, paper and plastic because levels of dioxin currently found in the bodies of the general human population, in the food chain, and in the environment are "already in the range at which severe effects on reproduction, development, and the immune system occur."

Greenpeace says the U.S. EPA study, a draft summary of a three-year scientific reassessment of the toxicity of dioxin, "confirms that fetal developmental and immune system damage are among the most serious health threats from dioxin exposure." Greenpeace, which obtained a draft of the report before its scheduled release in June, called for immediate action to restrict major industrial uses of chlorine and chlorinated chemicals, which create dioxin when produced, heated, processed, or burned.

"The U.S. EPA's findings indicate a public health emergency from dioxin that is not going to go away until industry's addiction to chlorine is broken," said Greenpeace's Rick Hind. "We need emergency action to eliminate any further discharges of dioxin, and that means a comprehensive phaseout of chlorine and chlorine-based chemicals."

Greenpeace says the largest dioxin sources are incinerators burning chlorinated wastes, pulp mills that use chlorine and chlorine dioxide bleaches, and the manufacturer of PVC (or vinyl) plastic; but all other sectors that use or burn chlorine also result in dioxin formation. Greenpeace said that the EPA should take emergency action to address these three priority areas, while long-term plans are initiated to phase out all other chlorine-based processes. . ..

The U.S. EPA's study indicated that there is no safe level of dioxin exposure and that any dose no matter how low can result in health damage. New findings on the mechanism of dioxin toxicity show that tiny doses of dioxin disrupt the action of the body's natural hormones and other biochemicals, leading to complex and severe effects including cancer, feminization of males and reduced sperm counts, endometriosis and reproductive impairment in females, birth defects, impaired intellectual development in children, and impaired immune defense against infectious disease. . ..

Currently many industrialized nations allow industries to release dioxin within "acceptable discharge limits," but since any dose of dioxin is hazardous, no discharge can now be considered "acceptable." Further, dioxin is so persistent that even small releases build up over time in the environment and in the human body. . ..

INFORM Unaffected by Reassessment

Bette Fishbein, solid waste research analyst at INFORM, says the EPA's dioxin reassessment will not alter INFORM's position on incineration. . ..

INFORM is a widely respected environmental research group based in New York City. It mainly focuses on identifying, researching and evaluating pollution caused by people, governments and industry. It also tries to develop "solutions" to the pollution problems it studies.

The organization has a solid history of working with corporations, citizen groups, major environmental organizations and governments at all levels. Although it is a relatively small organization with a small budget, it is very well regarded by mainline environmental organizations, government agencies and industry. Some of the more radical grassroots environmentalists think it is too friendly with industry. . ..

The organization's leaders are most effective at reaching lawmakers at the municipal, state and federal levels. It is currently very influential on legislation dealing with solid-waste management and hazardous-waste reduction and its influence is growing. INFORM's personnel, expecially President Joanna Underwood, testify frequently on environmental issues before state and federal legislative and regulatory bodies.

INFORM has 1500 individual members. It also receives support from corporations and government agencies.

Cattlemen Form Industry Group on Dioxin

The National Cattlemens Association (NCA) is coordinating a group of affected industries to respond to the EPA's report on the reassessment of dioxin.

The group--called the Dioxin Working Group--currently includes the National Milk Producers Federation, American Society of Animal Science, National Broiler Council, National Turkey Federation, International Dairy Foods Association, American Sheep Industry, National Pork Producers Council, American Meat Institute, National Renderers Association, American Farm Bureau Federation and the National Food Producers Association.

Representatives from the working group met on May 13 with Lynn Goldman, EPA's assistant administrator of prevention, pesticides and toxic substances, and EPA's political point person on dioxin. . . . At the meeting Goldman said that "we've always known that dioxin is toxic" and she said she was pleased that the report "gave us proof." . ..

The industry groups have met with United States Department of Agriculture (USDA)/Animal Research Service and Food Safety and Inspection Service to discuss USDA's plans for looking at levels of dioxin in cattle. . ..

The Dioxin Working Group also is talking to hill staffers about its view of the report and it has met with other groups that are affected by the report, such as (the Chemical Manufacturers Association ) and the Incinerator Industry to ascertain what each is doing and what messages they are sending out. At this time, the dioxin source industry groups are concentrating on questioning the toxicology data the report relies on. . ..

NCA and its allies in the working group have a history of strong relations with the Agriculture department, and it's certain they will use these solid ties to put pressure on EPA through Agriculture to make sure the final report is responsible, particularly the last chapter.

Second Citizens' Conference

Gateway Green Alliance is sponsoring the "Second Citizen's Conference on Dioxin: A Training Program and Times Beach Reunion" to be held July 29-31, 1994 in St. Louis. . ..

Panel discussions will address dioxin's "Mechanisms of Action" for affecting living organisms. A second panel will explore long term "Health and Environmental Effects." Greenpeace scientists will conclude the afternoon session with a discussion of how industry can function without chlorine chemistry.

Other sessions at the conference will share the theme of "citizens being told that dioxin was less harmful than it was later found out to be." . . . Former Times Beach residents will explain what happened to them. A researcher from the University of Milan will describe the 1976 explosion in Seveso, Italy and the results of recent studies. The session will close with an "Update on Vietnam Veterans and Agent Orange." . ..

U.S. PIRG to Check Out Dow and [Chemical Manufacturers Association]

Ralph Nader's Washington, DC-based U.S. PIRG is looking into Dow and CMA's PAC spending "to see what 'informal channels' were used to 'moderate' positions in Congress" on the Clinton plan to study a phase-out of chlorine-based chemicals.

PIRG's reference is to a letter from Dow's Richard Sosville in which he pledged to work within "formal and informal channels" in Washington to "moderate this position."

PIRG says its report "should shed some light on the industry's influence--and in an election year, force some members of Congress to stop short before selling out to the special interests."

Memorandum to: Clyde Greenert/Brad Lienhart From: Jack Mongoven Date: September 7, 1994 Re: MBD Activist Report for August

Attached is a brief report on anti-chlorine groups' activities in August along with our characterization of those activities. Recommendations regarding the individual activists were forwarded with the original detailed reports. Also attached is a list of all the recommendations we provided [the Chlorine Chemistry Council] in August as to how best to counter the activists. The main recommendation--to mobilize science against the precautionary principle--still applies and dovetails with the long range objectives regarding sound risk assessment.

It is obvious that the battleground for chlorine will be women's issues--reproductive health and children--and organizations with important constituencies of women opinion leaders should have priority. . ..

It is important in all cases to stay ahead of the activists, e.g., get to the New Orleans media and opinion leaders before the Chemical Week Chlorine Conference and the same in each of the cities where [the Women's Economic and Development Organization] will hold conferences this fall.

Let me know if you need more, e.g., we maintain calendars of anti-chlorine events and could include same if you would like.

Summary of MBD Recommendations to CCC (Chlorine Chemistry Council) August 1994

from Joining Anti-Chlorine Movement
 * Special efforts should be made for the [November 1994, New Orleans] ChemicalWeek conference on chlorine. KPR (Ketchum Public Relations) should work with journalists, especially those who will be covering the conference, and CCC should work with ChemicalWeek about the tactics Greenpeace and its allies employ to gather media attention. Mobilize the attendees and communicate (by written and verbal communication) the threat the radicals pose and how to deal with it.
 * Take advantage of the schisms [within] the Administration, i.e. within EPA and among EPA, USDA and FDA on the risk assessment section of the Dioxin Reassessment. CCC should quietly work with the industry coalitions to ensure that USDA and FDA are perceived to have the support of strong constituencies. . ..
 * Engage [Ketchum Public Relations] to reach out to editorial boards to highlight flaws in the risk assessment portion of the dioxin reassessment.
 * Engage a broad effort on risk assessment within the scientific community, even in groups which have taken positions against chlorine.
 * Accelerate the program to bring about agreed-upon risk assessment policy and the deployment of vehicles of sound science.
 * Take advantage of the opportunity . . . to highlight the need for some established criteria on risk assessment which will be widely accepted by scientists, industry, the people and governments.
 * Move quickly to take advantage of the visibility of the shortcomings of the current system by having scientists and Congressmen ready to call for the process on risk assessment CCC and [Chemical Manufacturers Association] would like to see put in place.
 * Schedule, through [Ketchum Public Relations], editorial board meetings in Dayton prior to Department of Health and Human Services Devra Lee Davis speech to a forum on breast cancer sponsored by Greenpeace and [the Women's Economic and Development Organization] to be held in Dayton, Ohio, in October.
 * Enlist legitimate scientists in the Dayton area who would be willing to ask pointed questions at the conference.
 * Continue existing CCC public relations and communications programs to counter activists' claims of the evils associated with dioxin as a weapon against chlorine chemistry.
 * Also, use the grassroots extremists charges against the role of science in shaping public policy as a call to arms within the professions whose credibility and relevancy are at stake.
 * . . . Urge the Vinyl Institute to begin immediately to build alliances on the PVC issue, beginning with those with an obvious economic stake, e.g., home builders, realtors, product manufacturers, hospitals and others who are immediately targeted.
 * Form an alliance on PVC issues with the Mid-States Oil and Gas Association which is concerned about expansion of the activist anti-PVC program in the Gulf of Mexico and is seeking allies in the chemical industry. . ..
 * Bring the state governors in on the issue of risk assessment by communicating the benefits to them from being able to rely on a national standard.
 * Establish third-party entities devoted to developing these standards in the near future.
 * Take steps to discredit the precautionary principle within the more moderate environmental groups as well as within the scientific and medical communities. . ..
 * It is especially important to begin a program directed to pediatric groups throughout the country and to counter activist claims of chlorine-related health problems in children. . ..
 * Prevent Medical Associations


 * Create panel of eminent physicians and invite them to review data regarding chlorine as a health risk and as a key chemical in pharmaceuticals and medical devices.
 * Publish panel's findings and distribute them widely to medical associations and publications.
 * Stimulate peer-reviewed articles for publication in the [Journal of the American Medical Association] on the role of chlorine chemistry in treating disease. . ..
 * Convince through carefully crafted meetings of industry representatives (in pharmaceuticals) with organizations devoted to specific illnesses, e.g., arthritis, cystic fibrosis, etc., that the cure for their specific disease may well come through chlorine chemistry and ask them to pass resolutions endorsing chlorine chemistry and communicate their resolutions to medical societies. . ..

NWF Says Chlorine is a Threat to Human Reproduction

One of the most significant recent developments in the anti-chlorine campaign is the National Wildlife Federation's (NWF) publication of Fertility on the Brink, which attributes fertility and reproductive problems to exposure to chlorine-based chemicals. The report depicts widespread and devastating effects on the reproductive, endocrine and immune systems of humans and animals as a result of exposure to an environment permeated with chlorine-based chemicals. The NWF uses the issue of fertility as a vehicle to play on the emotions of the public and its concern for future generations. . ..

The NWF is highly respected by mainstream environmentalists, conservationists, industry and government. That respect combined with the vast resources NWF controls, provide the NWF substantial influence on national policy decisions related to environmental and consservation matters.

The NWF printed 1,000 copies of Fertility on the Brink, which is almost depleted and a second printing is expected. . . . The publication of and demand for Fertility on the Brink may signal that the claims of destructive health problems attributable to toxic exposure has become more widely accepted by the public and will probably become a larger issue. . ..

Risk Assessment Based on the Needs of Children

Anti-chlorine activists are also using children and their need for protection to compel stricter regulation of toxic substances. This tactic is very effective because children-based appeals touch the public's protective nature for a vulnerable group and that makes it difficult to refute appeals based on its needs. The tactic also is effective in appealing to an additional segment of the public which has yet to be activated in the debate, particularly parents. . ..

The tone of the debate will focus on the needs of children and insist that all safeguards be taken to ensure their safety in development. For most substances, the tolerances of babies and children, which includes fetal development, are obviously much lower than in the general adult population. Thus, "environmental policies based on health standards that address the special needs of children" would reduce all exposure standards to the lowest possible levels. . ..

Dioxin and Risk Assessment. ..

Anti-chlorine groups will probably devise tactics which promote the adoption of the "precautionary principle." The principle, which shifts the burden of establishing a chemical's safety to industry, is unlikely to be adopted. The debate over the "precautionary principle" will elevate the dioxin issue to a more conspicuous level. . ..

This is a critical time for the future of risk assessment as a tool of analysis. The industry must identify the implications posed by the "precautionary principle" and assist the public in understanding the damage it inflicts on the role of science in modern development and production. . ..

Breast Cancer, Fertility and Reproductive Problems Caused by Pesticides. ..

Devra Lee Davis is expected to direct the Clinton Administration's policy governing breast cancer and we expect her to try to convert the breast cancer issue into a debate over the use of chlorine. As a member of the administration, Davis has unlimited access to the media while her position at the Health and Human Services (HHS) helps validate her "junk science." Davis is scheduled to be a keynote speaker at each of the upcoming. . . breast cancer conferences. . . sponsored by Women's Economic and Development Organization (WEDO). . . . Each conference is expected to emphasize a regional interest. . . . Topics include "Environment and Breast Cancer," "Organochlorines, Pesticides and Breast Cancer" and "Environmental Justice."

Other SourceWatch Resources

 * Mongoven, Biscoe & Duchin
 * Race-baiting Strategy Helps Keep Shell Pumping in Nigeria
 * Mongoven, Biscoe & Duchin/Women and Children First: On the Front Line of the Chlorine War
 * Mongoven, Biscoe & Duchin/Mission Despicable