December Straw Ballot comment
Criterion 8.1.5 Elimination of Chlorine in Processing Packaging Materials (JC Straw Balloted December 2014)
Manufacturer shall confirm with a supplier letter that any fiber used in packaging was not bleached with chlorine compounds. This requirement applies to the bleaching of fiber materials (including recovered fiber) and their fabrication into packaging for server products declared to conform to this standard, and not to prior uses of the fiber.
Comment Response
This requirement is unnecessary and could lead to unintended consequences for packaging manufacturers who need disinfectants in their processes. Elemental chlorine has been phased out for the most part as a bleaching agent for pulp and paper in favor of alternative chlorine compounds. Again, no information or data was provided to lead one to require foreclosure of chlorine compounds from this use, since chlorinated compounds are currently widely used to produce safe and bacteria free packaging materials.
The intent of this criterion is to prevent the creation of dioxins and furans from chlorine compounds used as bleaching agents. Further research will be conducted on dioxin and furan creation from alternative chlorine compounds, and availability of non-chlorine alternatives for disinfection, and presented to the JC for consideration.
Research Findings:
1) Alternative chlorine compounds generate dioxins and furans, although to lesser extent that chlorine gas.
Replacing elemental chlorine with chlorine dioxide in bleaching processes significantly reduces the generation of dioxins, but does not eliminate them. (Note: In late 1990s U.S. mills were required to replace elemental chlorine by the Cluster Rule.) 1
The Worldwatch Institute (Paper Cuts, 1999) reported the following for mills 2 :
Bleaching Process
Standard chlorine
Elemental chlorine free
Totally chlorine free/Processed chlorine free
1 Environmental Paper Network, The State of the Paper Industry, 2007.
2 ConservaTree at http://www.conservatree.org/paper/PaperTypes/CFDisc.shtml
Releases of Organochlorines (dioxins & chlorinated toxic pollutants)
35 tons/day
7-10 tons/day
None

2) Alternatives to chlorine compounds are available, including oxygen, hydrogen peroxide and ozone. A report by the Environmental Paper
Network cited the following summary by the Environmental Defense of the environmental advantages of bleaching alternatives.
3
3) Definition of terms (ordered by preference of NRDC) 4 and Conservatree
3 Environmental Paper Network, The State of the Paper Industry, 2011.

i) ii) iii) iv) v)
Processed chlorine-free (PCF): Contains recycled content produced without elemental chlorine or chlorine derivatives, although one or more fiber components may have originally been bleached with chlorine or chlorine derivatives. Any virgin pulp is TCF. (Note: preferable to TCF because includes recycled content. TCF only refers to 100% virgin paper.)
Totally chlorine-free (TCF): Virgin paper produced without chlorine or chlorine derivatives (the bleaching process uses oxygen-based compounds).
Enhanced ECF with ozone or hydrogen peroxide: In addition to removing more of the lignin from the wood before bleaching, substitutes ozone or hydrogen peroxide for chlorine or chlorine dioxides as a brightening agent in the initial stages of the bleaching process (the final or near-final stage uses chlorine dioxide).
ECF with extended or oxygen delignification (Enhanced ECF): Removes more of the lignin from the wood before bleaching, thus reducing energy and chemical use during bleaching (the final stage uses chlorine dioxide).
Elemental chlorine-free (Traditional ECF): Replaces elemental chlorine with chlorine dioxide in the bleaching process.
4) According to the World Resources Institute, since the 1990s, most paper mills in North America and Europe, plus modern Chinese mills, have switched to elemental chlorine free or totally chlorine-free paper. Totally chlorine free is either unbleached or bleached with oxygen, ozone, and/or hydrogen peroxide. Elemental chlorine was used in approximately 20 % of kraft pulp production worldwide in
2005, a decrease from 90 % in 1990.
5
The 2011 State of the Paper Industry Report by Environmental Paper Network reports that about 75% of the bleached kraft production globally is elemental chlorine free. Only 5-7 percent of virgin pulp production is totally chlorine free, due to higher capital investments in technology. Note that deinked pulp used for recycled paper is typically brightened with hydrogen peroxide.
Proposed change to criterion in response to balloter comment: none.
Proposed change to criterion in response to research: JC might consider change to criterion based on availability of TCF.
Options:
1) Keep current required criterion (eliminate chlorine compounds)
2) Change required criterion to elemental chlorine and add optional criterion for chlorine compounds
3) Change required criterion to elemental chlorine (and do not add optional criterion)
4 http://www.nrdc.org/cities/living/chlorine.asp
5 Worldwatch Institute Vital Signs, Paper Product Levels Off, January 20, 2015.

Draft Changes to Required and Optional Criteria
8.1.5 Elimination of Elemental Chlorine in Processing Packaging Materials (JC Straw Balloted December 2014)
Manufacturer shall confirm with a supplier letter that any fiber used in packaging was not bleached with elemental chlorine compounds.
This requirement applies to the bleaching of fiber materials (including recovered fiber) and their fabrication into packaging for server products declared to conform to this standard, and not to prior uses of the fiber.
Optional 8.2.x Elimination of Chlorine Compounds in Processing Packaging Materials (JC Straw Balloted December 2014)
Manufacturer shall confirm with a supplier letter that any fiber used in packaging was not bleached with chlorine compounds. This requirement applies to the bleaching of fiber materials (including recovered fiber) and their fabrication into packaging for server products declared to conform to this standard, and not to prior uses of the fiber.