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Pamela Miller’s Blog

Environmental Injustice in the Arctic: Toxic Flame Retardants Threaten Human Health

November 29, 2013

How could the Arctic, seemingly untouched by contemporary ills, so innocent, so primitive, so natural, be home to the most contaminated people on the planet? I had stumbled upon what is perhaps the greatest environmental injustice on earth.”—Marla Cone, author of Silent Snow: the Slow Poisoning of the Arctic

More than 25 years ago, scientists made the unexpected discovery that levels of persistent organic pollutants (POPs) in the breast milk of Nunavik Inuit women in Arctic Canada were seven times higher than in the breast milk of women of southern Quebec.  This discovery prompted international action to address POPs contamination as a global issue because it demonstrated the capacity of these chemicals to harm people who live in a region of the world that is far distant from areas of production and use.

Read more.

Updates on POPRC from Rome, Italy

Rome, Italy, October 2013 –

Original drawing by GeorgeAnne Sprinkle

Original drawing by GeorgeAnne Sprinkle

We have some big news from Rome:

We were successful in advancing several chemicals her at the POPs Review Committee:

        • Hexachlorobutadiene (HCBD) recommended for global elimination by the Committee and will now be considered by the full Conference of the Parties of 179 nations (this means it passed the difficult 3-stage reviews in Annexes D, E, and F of the Convention.
        • Chlorinated naphthalenes recommended for global elimination as with HCBD.
        • Pentachlorophenol advances to Annex F of the Convention from Annex E of the Convention (the toughest hurdle)
        • Decabromodiphenyl ether (a brominated flame retardant)—advances from Annex D to Annex E of the Convention, meaning that the Committee agrees that it meets all (of the scientific criteria of persistence, bioaccumulation, long-range transport and adverse effects.
        • Dicofol—a pesticide related to DDT will be held for one year (our biggest disappointment.

 News Release from IPEN – International PoPs Elimination Network

UN Expert Committee: Pentachlorophenol is one of the world’s worst chemicals

Agrees to incorporate climate change impacts in toxic chemical evaluation

(Rome, Italy) A UN expert committee recommended global action on pentachlorophenol – a pesticide used for wood treatment including utility poles. The Committee justified its recommendation for the Stockholm Convention due to pentachlorophenol’s persistence, bioaccumulation, long-range transport, and its toxic impacts. Governments around the world will decide on the recommendation in 2015.

“This is the beginning of the end of pentachlorophenol,” said Pam Miller, Alaska Community Action on Toxics. “Pentachlorophenol has global health implications since it is found in the bodies of people throughout the world including Indigenous Peoples of the Arctic. Now governments and the private sector need to get to work to eliminate this toxic chemical.” Read more.

Pamela Miller’s testimony to POPRC, October 2013, in Rome, Italy.

Thank you, Mr. Arndt, Chairperson of the POPRC, for the opportunity to present an intervention of Alaska Community Action on Toxics, Inuit Circumpolar Council, Pesticide Action Network, and IPEN. My name is Pamela Miller, Executive Director of Alaska Community Action on Toxics.

We observe that there is sufficient, definitive evidence that PCP-PCA warrant global action, that the substances, especially considered together, meet Annex E requirements. Therefore, we urge you to move these forward to Annex F consideration.

Studies have demonstrated toxic effects at environmental levels in aquatic species. In wildlife and people, concentrations are well within the range of observed in vivo and in vitro developmental, endocrine, and neurological effects. Particular the most compelling evidence of PCP in breast milk, blood, amniotic fluid, and other human tissues throughout the world, including peoples of the Arctic—warrants swift global action. Read more.


Fall Newsletter articles on work at the Stockholm Convention meeting in Geneva May 2013.

Pamela Miller, Executive Director, Alaska Community Action on ToxicsA Dispatch from Geneva—

Why are the Deliberations of the Scientific Review Committee of the Stockholm Convention on Persistent Organic Pollutants (POPs) Important?

Geneva, Switzerland, 2012 – Chlorinated naphthalenes, hexabromocyclododecane, hexachlorobutadiene, pentachlorophenol, short-chained chlorinated paraffins—these are not household words that come tripping off the tongue. However, they are among the chemicals under consideration this week in Geneva at the international meeting of POPs Review Committee of the Stockholm Convention on Persistent Organic Pollutants (POPs). Decisions are being made this week that have important implications for global environmental health—the health of all of us and particularly the health of people living in the Arctic. Since this is a very technical meeting and this is my first blog post, I have struggled with how to write this. Here it goes…

Pamela Miller, Executive Director, Alaska Community Action on Toxics, and colleagues at the IPEN POPRQ8 meeting October 18, 2012 in Geneva.I am part of a small group of NGOs (non-governmental organizations), collaborating organizations of the International POPs Elimination Network (, who participate in these week-long meetings each year. We participate in plenary and work group sessions throughout the day and evening, offering scientific evidence to advance consideration of the chemicals. We also provide the perspective of civil society to ensure the application of the precautionary principle and the scientific integrity of the work of the Committee. We are up against a large contingent of representatives of international chemical corporations, including the major manufacturers of pesticides and other industrial chemicals.

The Stockholm Convention is a living treaty that includes provisions to add new chemicals that meet scientific criteria for persistence, long-range transport, adverse effects, and bioaccumulation. The POPs Review Committee makes determinations about whether chemicals meet these criteria. I came prepared for this meeting with over 50 scientific papers, focusing on the chemicals that I was the designated “lead” for within our IPEN team—these included pentachlorophenol and hexachlorobutadiene. Pentachlorophenol (PCP), is a widely used wood preservative and historically as an agricultural pesticide. Due to its widespread use and disposal, PCP is now detected in air, water, and soil throughout the world, as well as in the blood, urine, seminal fluid, and breast milk of people. Hexachlorobutadiene is mainly a by-product produced in the manufacturing of certain chlorinated solvents such as perchloroethylene, an industrial solvent used for dry cleaning.

When the Committee made favorable (!) decisions on pentachlorophenol and hexachlorobutadiene, advancing them to the next stage of evaluation, I ended up focusing on another substance, short-chained chlorinated paraffins (SCCPs). Short-chained chlorinated paraffins (SCCPs) are industrial chemicals used in metalworking, paints, adhesives and sealants, plastics and rubber, flame retardants and in fracking fluids. Exposure to SCCPS has been linked with cancer. These chemicals are found in Arctic marine mammals such as beluga whale, seals, and walrus. SCCPs have also been found in the breast milk of Arctic Indigenous women. I have a personal interest in this matter because I grew up in the small town in Dover, Ohio that bears the dubious distinction of having the largest manufacturer of SCCPs in the United States, Dover Chemical—now among the most severely contaminated sites in the country. My brother Jerry died at a young age of cancer and there seems to be a cluster of cancers and illnesses in our neighborhood—so it is personal to my family and to me. In February of this year, Dover Chemical was charged $1.4 million in an enforcement action by the EPA and Department of Justice for violations of the Toxics Substances Control Act. And now, I find myself in this international scientific meeting and deeply concerned as well about the fact that SCCPs contaminate a place and people that I also care about in the Arctic.

Pamela Miller, Executive Director, Alaska Community Action on Toxics with colleagues at IPEN POPRQ8 meeting October 2012 in Geneva.In prior meetings, the Committee had already determined that SCCPs met the required scientific criteria and yet, they decided at this meeting to take no action on this substance. This is after delaying action for the past 6 years. For me, this was the most disappointing decision of the Committee meeting. As my colleague Mariann Lloyd-Smith of IPEN said:

“This raises concerns about scientific integrity and whether commercial considerations are a higher priority than the Stockholm Convention’s goal of protecting human health and the environment.” – IPEN POPRC8 Press Release October 19, 2012

We are not giving up! After this meeting, we will continue our work to ensure the global elimination of SCCPs. In the meantime, we celebrate the significant progress on the other nominated chemicals.


The Stockholm Convention is particularly significant as a means to protect the health of the Arctic environment and people because it addresses persistent, toxic chemicals that can migrate long distances on wind and ocean currents. POPs tend to accumulate in the fat-rich food webs of northern environments. Arctic Indigenous Peoples have among the highest levels of POPs contamination in blood and breast milk of any population on earth, even though most of these chemicals have never been produced in the Arctic. Exposure to low levels of POPs can harm human health, including interference with learning and development, diseases of the immune system, reproductive disorders, and cancers. The Convention is strongly based on the precautionary principle.

Arctic ecosystems and indigenous communities are particularly at risk because of the biomagnification of persistent organic pollutants and that contamination of their traditional foods is a public health issue.” —from the Preamble of the Stockholm Convention

The Stockholm Convention was adopted by governments from around the world in 2001 and entered into force in 2004 when 50 nations had ratified the treaty. Currently, the Convention includes more than 180 nations or “Parties” that agree to work together toward global elimination of the world’s most dangerous chemicals. The Stockholm Convention is a living treaty that includes provisions to add new chemicals that meet scientific criteria for persistence, long-range transport, adverse effects, and bioaccumulation. In addition to the initial list of twelve chemicals included in the Convention, the “dirty dozen” (aldrin, chlordane, DDT, dieldrin, endrin, heptachlor, mirex, toxaphene, hexachlorobenzene, PCBs, dioxins, and furans), the Parties agreed (in 2009) to add 9 new substances and an additional pesticide, endosulfan, was added in 2011. The U.S. has not yet ratified this important treaty and does not participate constructively in its implementation. The scientific committee of the Stockholm Convention, the POPs Review Committee (POPRC), works to determine whether chemicals that are nominated for inclusion under the Convention meet the scientific criteria and warrant global action.

Follow the link to the October 19th, 2012 press release of the International POPs Elimination Network here.

Additional Resources:

At their 2009 Conference of Parties signatories to the treaty agreed to phase out nine additional highly dangerous chemicals, the first time new chemicals have been added to the original twelve. In 2011, nations agreed to phase out the antiquated insecticide endosulfan.

Alaska Community Action on Toxics and other organizations belonging to the International POPs Elimination Network (IPEN) were instrumental in ensuring the addition of the nine new chemicals in 2009 and endosulfan in 2011.



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