September 8, 1999
Thornton, Ontario

The International Air Quality Advisory Board recognizes that municipal waste incinerators are a major source of numerous toxic substances being continuously released into the environment.[1] The Ontario Environmental Protection Act has defined standards of allowable emissions which are designed to protect human beings and the environment from excessive contamination. [2]

There is much debate about what levels of contamination should be considered acceptable . [3 ] But the very fact that any level of contamination will be tolerated as "safe" is a tacit acknowledgement that, despite sophisticated emission filtration systems, modern municipal incinerators do release toxins into the environment. And they do so continuously.

It should be noted that these toxins -- dioxins, heavy metals, and others -- are persistent. That is, they remain in the environment for very long periods of time. And they are cummulative. As more and more are released, they increase the level of toxicity in the environment.

A specific amount of contaminant may be considered by toxicologists in theory to be non-threatening and therefore "safe". These amounts are employed to define standards of allowable emissions. However, the appropriateness of these standards and therefore of their long-term health implications in real-life circumstances have not been demonstrated. [4] [5] [6]

Risk assessments do not take into account the real-life, continuous build-up which occurs over time due to the persistent and cummulative nature of these toxins; nor do they take into account the fact that toxins from incineration are added to toxins generated from other sources in the environment. And they certainly cannot take into account the adverse effects on health of incinerator releases which occur in amounts that are unknown. [5]

Operating at maximum efficiency, a waste incinerator releases into the environment a large number of known toxic materials.[7] If this occurs despite state-of-the-art, "Best Available Technology", what can be expected when operational interruptions occur due to malfunctions, breakdowns, or accidents? These events are generally referred to as an "upset". Interruptions can also arise due to the availability of new technology and the more stringent emission standards usually mandated. The incinerator may have to be shut down, and subsequently re-started.

It is precisely at such start-up and shut-down times and during upsets that the amounts of toxins created and/or released into the environment are greatly increased, thereby magnifying the cummulative impact on health of toxicity levels considered "safe" under emission standards. [7] [8] Standards do not include emissions during upsets or malfunctions. [5]

A letter by Neil J. Carman, Ph.D., Clean Air Program Director, Austin, Texas, to the Ontario Ministry of Environment & Energy, September 14, 1995, [8] is very revealing:

"I am a former government air pollution inspector of industrial and municipal facilities including incineration units in the state of Texas. As a regional field inspector for the Texas Air Control Board during more than a decade, I observed numerous operational problems and deficiencies with incineration equipment, including state-of-the-art incinerators. Problems occurred day and night!

"Most of the incinerators in our territory experienced mechanical and operational problems which were often linked to human error. ... What is most unfortunate of all is that virtually all incinerators do not perform on a normal basis nearly as efficiently as during trial burns when operational conditions are idealized as much as possible. Once the trial burn is complete, normal daily operations will tend to become complacent and sloppy. Without government inspectors on hand on a routine basis, sloppiness will seriously erode the efficiency of the incineration process .....

"I observed this problem in all the units I inspected. Even new incinerators may have malfunctions and upset events producing especially high levels of harmful and dangerous air pollution. This is when dioxin and other exceptionally toxic substances will be created and emitted in higher than normal rates into the air. But as an incinerator ages malfunctions tend to become part of the normal routine of daily operation. (Italics added)

"I am quite skeptical of the ability of incinerators to operate in full and continuous compliance with the most stringent permit requirements. It is technically remote to achieve even 80% continuous compliance.

"My greatest concern is for the public who live downwind -- even several miles away from large incinerators -- because they will inevitably suffer over time as I observed from the fallout of particulate matter, unburned hazardous chemicals, a rain of acid gases including hydrochloric acid, and dangerous heavy metals to which human beings and particularly children should not be unnecessarily exposed.

"All incinerators are ultimately doomed to have failures in all aspects of their process. My experience revealed that no matter how good the technology, how well trained the personnel, and how effective the process monitoring systems, there will be major failures leading to high levels of emissions during major upset events. Simply stated, the potential is that the communiy will be poisoned slowly but surely until the incineration is permanently halted.

"Incineration ... of garbage is merely trading one set of manageable problems for another set of more difficult problems."

There are many reasons why malfunctions, accidents and breakdowns have occurred at incinerators around the world. Some were entirely beyond the control of the incinerator operator. Others, perhaps, might have been avoided had the operator been more diligent. [9] [10] The objective here is not to criticize or to lay blame but rather to demonstrate that no matter what the cause or explanation for an "upset" may be, the end result is always the same - significant additional pollution of the environment, beyond the "safe" levels. These unforeseen releases are often referred to as "emission excursions". And because continuous monitoring for heavy metals, for dioxins, and for many other toxins is not available [11] [12], the full extent of incremental contamination by these materials during a shut-down, start-up, or breakdown is unknown! The following illustrates the many possible causes of an upset.

Nature has a way of asserting itself, particularly if a tall object is available as a conduit for lightning during a thunderstorm. Lightning strikes at incinerators do occur, due to the height of the stack, and can cause an automatic shutdown of the controlled burning process. [13] Boilers and associated "plumbing" systems - which are an integral component of the process to convert waste to energy - operate under severe conditions of heat, pressure, and corrosive elements, and are also prone to failure. [14] [15] Explosions, sometimes massive, have been associated with lightning strikes and boiler failures. [13] [16] [17] [18] Filtering systems can be rendered ineffective under such circumstances.

Approximately 25% by weight of the total waste brought into an incinerator remains after incineration in the form of ash. About 10 % of this is collected in the baghouse filtering system as "fly ash", and consists of a concentration of the many toxins that would otherwise have been released through the stack. Therefore as the filtration systems improve over time, the fly ash becomes more and more toxic due to higher concentrations. In Ontario, fly ash is classified as a hazardous waste. [2] Due to the harsh environment in which they operate, "baghouse" systems are a recurring problem and upon partial or total failure can lead to the release through the stack of concentrations of toxins that are far in excess of allowable emissions. [19] [20]

Maintenance, replacements, and upgrades of equipment are normally performed under more orderly conditions, and, admittedly, will seldom result in a catastrophic situation. But these types of situations may nevertheless also require from time to time the shut-down and re-start of an incinerator. It is on these occasions that combustion occurs at less than optimal temperatures and filtering systems consequently fail to meet emission standards. [21]

Neil Carman has suggested in his letter to the Ontario Ministry of Environment and Energy that it is technically remote to achieve even 80% continuous compliance with prevailing emission standards. Commonplace events such as the above, during which unknown amounts of certain toxic materials are added to the existing level of contaminants in the environment, constitute a threat to the health of a community.

The Nature of Dioxins in the Context of Waste Incineration.....

To appreciate how serious the release of these unknown amounts of known toxins can be for the health of a community, we can examine one particular class of toxins - dioxins. Dioxin is the name generally given to a group of super-toxic chemicals whose toxicity is second only to radioactive waste. They are a byproduct of a large number of chlorine-based industrial processes, including herbicide and pesticide manufacturing, and predominately waste incineration [3]. "About 70% of the airborne dioxin deposited in the Great Lakes comes from incinerators that burn municipal or medical waste." [22]

There are over 100 different chemicals in this class, [12] and many are actually created during the incineration process. [7] [23] One in particular, TCDD, is so toxic that the toxicity of other chemicals such as PCBs are measured in relation to it. [3] The US Environmental Protection Agency (EPA) and a number of similar bodies have considered TCDD to be perhaps the most powerful synthetic chemical carcinogen ever identified [3].

Sponsored by the EPA and the Chlorine Institute (an industry group), toxicologists and biochemists convened in 1990 to consider the "Biological Basis for Risk Assessment of Dioxins and Related Compounds". Studies showed that "dioxin’s effects were exerted, through ... the genetic system, on protein synthesis." [24]

"The EPA acknowledges that the...hazards of dioxin go far beyond the risk of cancer.... The expected non-cancer effects include:

* disruption of endocrine hormone systems, especially those related to sexual development;

* disruption of critical stages of embryonic development, for example of the nervous system;

* damage to the developing immune system...

"These are all intergenerational defects; they are imprinted for life on the developing fetus by the effect of dioxin on the mother and sometimes the father." [24] It should not be assumed, therefore, that damage is not occuring because the effects of these toxins are not visible immediately.

In a manner similar to contamination with heavy metals, such as lead or mercury, or contamination with pesticides such as DDT, the buildup of dioxin in the body is gradual. Being virtually indestructible in most environments, it is excreted from the body very slowly [25]. Continuing exposure over time is therefore cummulative, and results in higher concentrations which become in their potential effect more and more destructive.

Several years after construction of a municipal waste incinerator near Oxford, New Jersey, nearby Hackettstown Community Hospital reported colo-rectal cancer rates in men that were 31.7% higher than the national average, and breast cancer rates 32.3% above the national average. The severity of bronchial attacks among school children required hospitalization in many instances. [26]

Dioxin became well known following the Vietnam war when it was identified as constituting the principle ingredient in the defoliant Agent Orange [3] [27]. Love Canal, Niagra Falls, N.Y. [3] [28], Sevesco, Italy [3], and Times Beach, Missouri [3] [29] have all been catastrophically exposed to dioxins. Bizarre health effects noted at these locations have included birth defects, autism, liver disease, endometriosis, reduced immunity, chronic fatigue syndrome, and various nerve and blood disorders [3].

Another class of known toxins released in unknown amounts during upsets are the heavy metals. Like dioxins, these materials are extremely toxic [30], and exposure to them is cummulative. [31] There are many heavy metals, including lead, zinc, copper, mercury, and cadmium.

Mercury, for instance, is a neurotoxin generally, and also interferes with fetal development. [32]

The effects of mercury poisoning are well known and include dizziness, blindness, speech disturbances, paralysis, personality changes, deafness, and death. [31]

The use of mercury in manufacturing is regulated in Canada both federally and provincially, and guidelines have been set by the Ontario Ministry of Environment & Energy and by Health Canada to restrict consumption of foods containing mercury in amounts in excess of specified limits. Efforts are underway by all jurisdictions of the Great Lakes basin to ban or phase-out use of mercury in the area. These jurisdictions include the US EPA, the federal and provincial governments in Canada, and the International Joint Commission [33].

Sources of mercury include batteries, dyes, electronics, fluorescent lights, plastics, and many other products commonly found in municipal waste. Mercury in bodies of water is converted into methylmercury, which is 5 to 20 times more toxic than inorganic mercury - so its concentration in foods (especially fish) is significant. "The smallest trace of mercury in lake water (a few parts per trillion) can render fish unsafe to eat... Mercury can [also] be absorbed by vegetation.... The net effect of incineration is to greatly accelerate the environmental release and biological uptake of mercury ..." [31]

The experience of a small New Jersey community illustrates the devastating effects of heavy metal contamination as a result of an upset at a facility associated with a municipal waste incinerator. "A 35,000 gallon spill ... into a stream ... last summer revealed cadmium levels 566 times the World Health Organization’s guideline for drinking water, lead [levels] 840 times the Environmental Protection Agency’s ‘action level’ in drinking water, and mercury [levels] 61 times its ambient water quality criterion for protection of human health."[26]. Fish in the area were subsequently declared inedible.

Caution as a Matter of Policy.....

As described earlier, upsets are commonplace and occur for a variety of reasons. Such interruptions of optimal incinerator operating conditions result in the release of heavy metals, dioxins, and other toxins above and beyond the levels allowed under prevailing standards of toxic emissions considered "safe". These materials, we know, are extremely toxic [30] and cummulative in their impact on the health of present and future generations, even at low levels. Fines for violations of emission standards do not lessen the environmental impact of upsets.

Given our inability to continuously monitor incinerator emissions for certain toxins, we are unable to determine what quantities of these materials are emitted during an upset. As a result we are unable to define the extent to which waste incineration, operating under both normal and abnormal circumstances, contributes incrementally to the ill health of a community.

The few scientific studies completed of the long-term health effects on people residing near incinerators have found increased incidences of cancer, and other health problems [6] [34] [35]. These investigators have stated that further research is necessary.

Recognizing this fact, many municipalities and other jurisdictions have elected to pursue more flexible and prudent solutions to their waste management problems - they have defined standards and adopted guidelines and policies which ban incineration and/or emphasize programs of intensive waste reduction, re-use, and recycling [5] [21] [22] [25] [36] [37] [38] [39] [40] [41] [42] [43]. Such programs have received significant support from the public over recent years, resulting in an increasingly meaningful reduction of waste to be disposed of by problematic means such as landfill and incineration.

Further reductions and diversions of waste are posssible. Progress is ongoing, and accelerating, through the concerted efforts of various groups of concerned citizens.

As a substitute, therefore, the technology of incineration remains an undesirable solution to the continuing municipal waste crises everywhere. It is, in practice, a technology that cannot consistently meet the "safe" standards of environmental and health protection. To ignore the experience of decades from all over the world, in favor of a convenient "solution", may be considered by some as evidence of bad judgment. But given the viable and more environmentally sound options, it is probably more a matter of over-looking the obvious -

1. International Air Quality Advisory Board, "A Policy Statement on the Incineration of Municipal Waste." Windsor, Ontario, 1996. Can be found on Website: http://www.ijc.org/boards/iaqab/incin.html

2. Combustion and Air Pollution Control Requirements for New Municipal Waste Incinerator, September, 1996, under legislative authority of Environmental Protection Act, Part V, Section 27, and Part II, Section 9. Province of Ontario.

3. Campbell, Jonathan L. "What is Dioxin," Toxic Alert. Found on Website: http://www.cqs.com/edioxin.htm

4. Standards Department Branch, Environmental Science Standards Division, Ontario Ministry of Environment, "Environmental Risks of Municipal Non-Hazardous Waste, Landfilling and Incineration," 1999. Summary.

5. "Health Risks of Emissions from Municipal Waste Incinerators Using Best Available Technology (BAT)". Appendix 1 of "Developing a New Solid Waste Management Strategy," Office of the Commissioner, Region of Halton, Ontario, August 1996. Found on Website: http://www.region.halton.on.ca/PPW/Waste/wastemmtstrategy/memorandum.htm

6. Johnson, Barry L., Assitant Surgeon General and Administrator, Agency for Toxic Substance and Disease Registry, U.S. Department of Health and Human Services. Congressional Testimony on "Health Impacts of Incineration" before the U.S. House of Representatives, January, 1994. Found on Website: http://www.atsdr.cdc.gov/cxcx4.html

7. Rowat, C.S. "Incinerator Toxic Emissions: A Brief Summary of Human Health Effects with a Note on Regulatory Control," 1994. Found on Website: http://www.rowatworks.com/Science/IncineratorToxic/index.html

8. Carman, Neil J., Ph.D. Clean Air Program Director, Lone Star Chapter of the Sierra Club, P.O. Box 1931, Austin, Texas, 78767. Letter to Ontario Minsitry of Environment & Energy, September 14, 1995.

9. The Environmental Protection Agency (EPA) cited the municipal waste incinerator in Indianapolis, Indiana, with over 6,000 permit violations between June 1989 and May 1991. Found on Website: http://www.workonwaste.org/wastenots/wn209.htm

10. In relation to three incidents of "catastrophic failures" of the Biddleford, Maine incinerator, State of Maine toxicologist, Robert Frakes: "Based on information provided by the DEP (Maine Department of Environmental Protection) and on our calculations, it appears that certain subgroups of the population may have been exposed to unacceptable levels of lead and, to a lesser extent, dioxin." The operator of the site was fined $300,000.00 "for a history of lax operation symbolized by the periodic ash showers that blanketed the city last year." Journal Tribune, July 7, 1989. Found on Website: http://www.workonwaste.org/wastenots/wn142.htm

11. Connett, Paul, Ph.D. "Municipal Incineration: A poor solution for the twenty-first century," 4th Annual International Management Conference, Waste-to-Energy, Amsterdam,1998. Found on Web site: http://www.phys.sinica.edu.tw/~dushoff/essential/conspeech.html

12. U.S. Environmental Protection Agency, Air Pollution Technology Branch. "Real-Time Monitoring of Dioxins and Other Trace Organics," June, 1999. Excerpt: "...current methods to get a single dioxin measurement require a lengthy and costly sampling effort followed by an equally lengthy and costly analytical effort. The infrequent (often annual, or less) facility samplng and delayed analytical results preclude efforts to understand and prevent emissions as well as assure the public that a facility is operating appropriately." Found on Website: http://www.epa.gov/appcdwww/crb/empact/index.htm

13. Lancaster New Era, Lancaster, PA, August 1, 1995. The plant in Lancaster Co. had frequent lightning strikes. One strike resulted in a boiler explosion that killed 2 men. Found on Website: http://www.workonwaste.org/wastenots/wn341.htm

14. Star Ledger, Newark, NJ, February 27, 1992. A boiler shut-down due to premature tube failures occurred in a one-year old facility. Found on Website: http://www.workonwaste.org/wastenots/wn191.htm

15. Star Tribune, Minneapolis, Minnesota, May 23, 1991: "Equipment failure or possibly an explosion in a boiler cause...shutdown. Garbarge kept smoldering, sending dense smoke pouring out of the building and triggering fear of a fire." Found on Website: http://www.workonwaste.org/wastenots/wn153.htm

16. "The Greater Detroit Resource Recovery Facility," a case study, University of Michigan School of Natural Resources, November, 1989. An explosion occurred in the incinerator a few months after it opened. Found on Website: http://www.workonwaste.org/wastenots/wn98.htm

17. Akron Beacon Journal, Ohio, Dec. 21, 1984, reported 3 workers killed in a shredder explosion in Akron facility. Found in "Waste Not" newsletter, Paul & Ellen Connett, eds., October 12, 1989. Also reports that in 1989 a worker was killed in a shredder explosion in a West Palm Beach plant.

18. Miami Herald, October 6, 1991, reported a boiler explosion in the Dade County plant. Found on Website: http://www.workonwaste.org/wastenots/wn258.htm

19. Portland Press Herald, Maine, August 27, 1988, describes that some communities "...were showered with a greyish-white powdery ash...". Also see reference 10. above.

20. Davis, Phil, Birmingham Friends of the Earth. Report on Municipal Waste Incineration. A report in response to Wolverhampton Metropolitan Borough Council’s proposals for a new municipal waste incinerator, Autumn, 1994. Found on Website: http://sun1.bham.ac.uk/c.m.tarpey/phil.htm

21. Report and Recommendations on the Burnside Waste to Energy Facility, prepared by the Environmental Assessment Administrator and submitted to the Minister of the Environment, June 29, 1994, Halifax, Nova Scotia. The report included "...predicted requirements for shutdown and startup for maintenance or servicing requirements will result in air emission excursions beyond regulated limits. It is estimated that this condition could exist for 5% or 18-20 days per year...There is considerable concern that these periods of ‘uncontrolled’ emission discharges may pose a significant threat to the environment and to the health of some individuals living in the vicinity of the facility...The lack of specific information in this area is viewed as a critical flaw in the planning process for the proposed WTE facility." Excerpts can be found on Website: http://www.workonwaste.org/wastenots/wn295.htm

22. Zeroing Out Dioxin in the Great Lakes: Within Our Reach. Center for the Biology of Natural Systems, Queens College, City University of New York, Flushing, NY, 1996. A summary of main ideas can be found on Website: http://qcunix1.acc.qc.edu/CBNS/newrep.html Select: [ 1. Press Releases ]

23. Lehman, M., Ostrowski, E., Rochow, G., & Van Dyke, R. "The Correlation Between Heavy Metals and Dioxin Emissions in a Municipal Waste Incinerator," Michigan Technological University. Posted after 1995. Found on Website: http://bigmac.civil.mtu.edu/public_html/classes/ce459/projects/t11/r11.html

24. Commoner, Barry, Ph. D., Director for the Center for the Biology of Natural Systems, Queens College, City University of New York, Flushing, New York. "A Turning Point in the Political History on Dioxin." Keynote address at the Second Citizens’ Conference on Dioxin, St. Louis, Missouri, July 30, 1994. Found on Website: http://www.workonwaste.org/wastenots/wn298.htm

25. Friends of the Earth, London, England. "Don’t Bury It or Burn It: Alternatives to Landfill and Incineration," May 1997. Found on Website: http://www.foe.co.uk/camps/indpoll/newdburn.htm

26. Caldara, Anna Maria. "A Big Incinerator and a Small Town, The New York Times, November 9, 1997. Found on Website: http://www.eclipse.net/~frgmoses/NYTimes.htm

27. Boger, Gilbert, M.D., Letter to the Editor, Journal of the American Medical Association, November 30, 1979, Vol. 242, No. 22, p. 2391.

"10-month study of 78 Vietnam veterans who claimed exposure to Agent Orange yielded many findings:

85% Persistent rash 51% Diarrhea 19% Children born with gross birth defects

80% Extreme Fatigue 47% Loss of Libido 17% Inability to concentrate

73% Depression 45% Violent Rages 13% Wives with one or more miscarriages

71% Joint Pain 45% Swelling 3 died of cancer

69% Dizziness 44% Hypersomnolence 10% had been treated for cancer

60% Numbness 41% Anorexia 10% Hepatitis

59% Nausea 35% Headaches 8% Suicide attempts

59% Stiffness 31% Constipation 8% Dyspnea [shortness of breath]

55% Tingling in nerves 24% Abdominal pain 5% Jaundice

54% Blurred vision 23% Brown urine 5% Galactorrhea [milk from breasts]

53% Rash aggravated 21% Bouts of sudden 4% Gynecomastia [breast enlargement]

by sunlight lapses of memory

"Sinus bradycardia and premature ventricular contractions were not infrequent...There were reports of sterility; semen analysis showed low sperm counts and abnormal forms...This group of veterans has in general been chronically ill. Patients complained of frequent infections and allergies...The aforementioned information is intended to create an awareness of a substance known as dioxin."

28. "Occidental to Pay $129 Million in Love Canal Settlement". U.S. Department of Justice release, Dec. 21, 1995. Found on Website: http://www.usdoj.gov/opa/pr/Pre_96/December95/638.txt.html

29. "Toxic Town: Cleaning Up Times Beach, Missouri," CIPRA Online News & Intelligence, Awards Nominees page, 1997. Found on Website: http://207.153.210.138/c98_toxic.htm

30. Agency for Toxic Substances and Disease Registry, U.S. Department of Health and Human Resources, "Top 20 Hazardous Substances, ATSDR/EPA Priority List for 1997." Found on Website: http://www.atsdr.cdc.gov/cxcx3.html

31. Clean Water Action, "Mercury Rising: Government Ignores the Threat of Mercury from Municipal Waste Incinerators," September 6, 1990. Found on Website: http://www.workonwaste.org/wastenots/wn115.htm

32. Agency for Toxic Substances and Disease Registry, U.S. Department of Health and Human Resources. "Media Advisory Regarding Updated Toxicological Profile for Mercury," April 19, 1999. Found on Website: http://www.atsdr.cdc.gov/press/ma990419.html

33. Sang, S. & Lourie, B., "Mercury in Ontario: An Inventory of Sources, Uses, and Releases," Proceedings of the 1995 Canadian Mercury Network Workshop. Found on Website:
http://www.cciw.ca/eman-temp/reports/publications/mercury95/part9.html

34 Elliott, P.; Shaddick, G.; Kleinschmidt., I.; Jolley, D.; Walls, P.; Beresford, J. & Grundy, C. "Cancer incidence near municipal solid waste incinerators in Great Britain," Journal of Cancer, Vol. 73, 1996, pp. 702-710. Study on data of 14 million people living near 72 municipal waste incinerators in the UK. They found a higher than expected incidence of liver cancer and indicated further study was needed.

35. Rapiti, E.; Sperati, A.; Fano, V.; Dell’Orco, V. & Forastiere, F. "Mortality Among Workers at Municipal Waste Incinerators in Rome: A Retrospective Cohort Study," American Jounal of Industrial Medicine, Vol. 31, 1997, pp. 659-661. The study found an almost 3-fold higher incidence than expected of stomach cancer in workers employed more than 10 years. They said more study is needed.

36. American Public Health Association. "Resource and Solid Waste Management". American Journal of Public Health, Vol. 80, February, 1990, pp. 230-231. Can be found on Website: http://www.enviroweb.org/publications/rachel/rhwn215.htm

37. Waste Management Advisory Council, City of Orillia, "The Orillia Waste Line," a community newsletter, May 1999. Now has a Waste Diversion Site. Over a 2-year period, the city reduced waste to landfill by 24% and increased its recycling by 36%.

38. Jackson, John. "Resources - Not Garbage: Municipal Waste in Ontario." Prepared for the Environmental Agenda for Ontario Project, March 1999. Found on Website: http://www.web.net/cielap/swaste.htm

39. Holtman, Elizabeth, Comptroller. Burn, Baby, Burn: How to Dispose of Garbage by Polluting Land, Sea, and Air at Enormous Cost. New York City Comptroller’s Office, Office of Policy Management, January, 1992.

40. Basu, Radha. "Philippines: Landmark Law to Throw Out Waste Incineration," from World News-Inter Press Service, May 1999. Found on Website: http://www.oneworld.org/ips2/may99/04_07_004.html

41. Montague, Peter, Ph.D. "New Alternatives to Incineration". Rachel’s Hazardous Waste News, October 7, 1992. Found on Website: http://www.enviroweb.org/pubs/rachel/rhwn306.htm

42. Environmental Action Barrie. Products and education at their Enviromart. Holds regular depots for plastics recycling.

43. Wastewise Centre: Centre for waste education, repair, reuse (flea market) and recycling. Georgetown, Ontario. Mrs. Diane Van DeValk, Manager.