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The document details a 1994 scenario where the U.S. pulp and paper industry faced pressure to eliminate chlorine bleaching due to the production of dioxins and other organochlorines. It contrasts the positions of the EPA, which proposed the 'cluster rule' to integrate air and water regulations, Greenpeace, which advocated for totally chlorine-free (TCF) processes, and industry players who argued that elemental chlorine-free (ECF) substitution was a more economically viable solution. The text explores the technical differences between ECF and TCF, the estimated costs of compliance—ranging from $4 billion (EPA) to $10 billion (industry)—and the potential for a voluntary 'covenant' to guide the industry's environmental future.

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  • The pulp and paper industry's use of chlorine in bleaching produces organochlorines, including dioxins, which are linked to cancer and other health issues despite the industry producing less than one pound of dioxin per year in 1994.
  • The U.S. EPA proposed the 'cluster rule' in November 1993, a first-of-its-kind integrated regulatory approach combining Clean Water Act and Clean Air Act elements to reduce pollutants across the industry rather than by single-media.
  • There is a significant discrepancy between EPA and industry estimates regarding the cost of implementing a 'high' ECF standard for 90 U.S. bleached kraft mill facilities; the EPA estimated $4 billion, while some industry estimates reached $10 billion.
  • Greenpeace advocated for the immediate adoption of totally chlorine-free (TCF) technologies, arguing they were already feasible and economic in Germany, Austria, and Sweden.
  • Industry representatives proposed 100% chlorine dioxide substitution as a more affordable alternative to the cluster rule, estimating the total cost at $1.2 billion (between $2 million and $25 million per facility).
  • The document identifies three types of industry responses: Alpha Company (an environmental leader using ozone bleaching), Beta Company (an average performer upgrading to meet the cluster rule), and Gamma Company (a financially distressed firm facing $9 billion in dioxin-related litigation).
  • A proposed 'Forum on the Environmental Future of the Pulp and Paper Industry' aimed to establish a voluntary program of long-term goals and an informal 'covenant' to shape future regulation, avoiding the rancor of traditional debates.
  • The U.S. pulp and paper industry in 1993 was a major economic sector with sales of $129 billion, representing 4.5% of U.S. manufacturing output, operating over 500 facilities across 42 states.

Cite the original document

APA
World Resources Institute (1994). CHLORINE AND THE PAPER INDUSTRY. https://pdf.wri.org/bell/case_1-56973-133-0_full_version_english.pdf
Chicago
World Resources Institute. CHLORINE AND THE PAPER INDUSTRY. 1994. https://pdf.wri.org/bell/case_1-56973-133-0_full_version_english.pdf.
Wikipedia
{{cite report |author=World Resources Institute |title=CHLORINE AND THE PAPER INDUSTRY |date=1994 |url=https://pdf.wri.org/bell/case_1-56973-133-0_full_version_english.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{worldresourcesinstitute1994chlorine, author = {{World Resources Institute}}, title = {{CHLORINE AND THE PAPER INDUSTRY}}, institution = {World Resources Institute}, year = {1994}, url = {https://pdf.wri.org/bell/case_1-56973-133-0_full_version_english.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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