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December 22, 1998

Development Minister Poul Nielson
Ministry for Foreign Affairs
Asiatisk Plads 2
1448 Copenhagen K

Fax number: +45 3254 0533


Dear Minister Poul Nielson:

It has been some time since our last correspondence. In the time since your last letter on 18 August the international coalition of groups working to prevent Danida from burning pesticides in Mozambique has grown with the addition of local citizens activist organization – Livaningo. Livaningo has formed from citizenry in Matola and Maputo, wishing to halt the project in their communities. In the last months the coalition and Livaningo has sponsored the arrival of two toxics activists and one incineration expert to Maputo to alert the local population to the concerns regarding incineration of hazardous wastes. We have also sent three representatives, one each from Mozambique, South Africa, and Denmark to Copenhagen to meet with your staff and the Environment Committee of the Danish Parliament. Livaningo has additionally held numerous meetings with officials in Mozambique.

Despite these many and costly efforts to communicate our concerns, they remain, for the most part ignored. It appears that Danida is still stubbornly committed to moving forward with the project -- this, even in the complete absence of a proper public hearing process and a proper Environmental Assessment; even when it is clear that there are preferable alternatives that will not degrade the global and local environment with dangerous "persistent organic pollutants" (POPs); even when there has been a clear violation of the Lomé IV treaty with respect to importation of hazardous waste into Mozambique.

Therefore, we have had little other recourse than to try to take the issue beyond Denmark and Mozambique and begin a process of appealing to the global community of nations and other non-governmental organizations (NGOs) concerned with inappropriate aid, toxic trade, "persistent organic pollutants" (POPs), and environmental democracy.

To be clear, our unaddressed concerns can be summarized as follows:

1) Danida’s heavy-handed, undemocratic, exclusionary process being imposed on the populace of Mozambique and the global NGO community.

2) The misleading manner in which the Danida project has been "sold" to the Danish public and Parliament as being a one-time project simply to rid Mozambique of dangerous pesticides when in fact the major costs of the project have to do with building a permanent hazardous waste station and a permanent capability to burn hazardous wastes in Mozambique.

3) The Danida policy to proliferate the global production of "persistent organic pollutants" (POPs) in Africa via the promotion of hazardous waste combustion at a time when a global need has been recognized to phase out POPs as rapidly as possible.

4) The refusal by Danida to explore viable, commercially available, non-POPs producing alternatives to burning hazardous wastes.

5) The Danida and Mozambique government’s apparent lack of concern for perpetuating the transboundary movement of hazardous wastes, particularly into a non-OECD country.

6) Your steadfast intransigence in going ahead with a program which is not supported or supportable by the public or by the facts and is often in contradiction with Danish national policies with respect to the points above.

In the course of the letter that follows we will discuss in more detail these concerns, addressing the comments you have made in your letter of 18 August as well as your answers to the questions put to you by the Environment Committee of the Danish Parliament.

At the outset we wish to also remind you that the references in your letter to the Basel Action Network (BAN) alone as author of our coalition letters must be corrected. BAN is but one member of a growing coalition. BAN was simply chosen as the focal point for correspondence for a coalition which now includes, Greenpeace International, Waste Not, Greenpeace Denmark, Essential Action, the Environmental Justice Networking Forum (EJNF) and Livaningo in Mozambique. This response as do all of our previous letters and positions, come from all of the greater coalition partners.

Towards Transparency and Community Involvement -- Proposal for a True Public Hearing and New Environmental Impact Assessment

As mentioned above, Livaningo has joined our coalition following the visit of some of our members to Mozambique to alert local citizenry to the risks and alternatives to hazardous waste incineration. Members of this new organization had never heard of the proposed incineration plan and the risks involved until visited by toxics activists Bobby Peek (Environmental Justice Networking Forum, South Africa) and Ann Leonard (Basel Action Network and Essential Action, USA) and Dr. Paul Connett. Dr. Connett is Professor of Chemistry at St. Lawrence University. He is one of the world's leading experts on the environmental impacts of incineration. He has traveled to over 40 countries to study incinerator-related issues and has published dozens of scientific papers on incineration. He called the public involvement and EIA process in this case a "sham."

The most disturbing finding of the coalition mission to Mozambique was that almost none of the residents of Matola or Maputo had ever heard of the plans to incinerate hazardous wastes nor knew of the risks involved.

On Danida’s website it is stated:

"Denmark has a long­standing tradition of actively involving individuals, non-governmental organizations and associations and businesses formally and informally in formulating and implementing environmental policies."

Yet in the only "hearing" that was ever held in Mozambique according to Livaningo’s inquiry, only the collection of the pesticides and not their localincineration was ever discussed, and no project documentation was made available in any language -- not even the diminutive (32 page) Environmental Impact Assessment (EIA). This approach can hardly be considered "actively involving individuals...non-governmental organizations" in "formally and informally ... formulating and implementing policies." Rather the public involvement in this project has been a misleading token effort which seemed designed to merely check the "public involvement box" in Danida’s specifications rather than truly involve impacted stakeholders in the decision-making process.

Now, the officials of MICOA have agreed to revise their EIA. However from statements made by these officials it appears this exercise is being undertaken while the outcome has been pre-determined -- that local incineration will proceed. They have been quoted in the press as saying that the project is going ahead according to plan, while the EIA is being revised! Such an approach is unacceptable and shows that there is no intention of having a fair EIA process.

Further, neither MICOA nor Danida has yet accepted our proposal to hold a true public hearing on the issue, allowing international experts to participate and fully exploring all of the risks and all of the available options. This is a necessary component of any EIA process.

We as a coalition, will not view the revised EIA process as a legitimate one unless the following reasonable requests are met:

1) That no further work be undertaken on the project until the EIA and the public involvement process is completed.

2) That the coalition together with MICOA, and DANIDA, has the right to agree or veto the choice of firm employed to do the EIA.

3) That the coalition has the right to agree or veto the terms of reference of the EIA.

4) That the EIA process must involve at the outset a series of public hearings where international experts can be brought in from all viewpoints to testify as to the risks and alternatives of the project.

We hope you agree that there is no longer any reason to rush this project forward and deny the public and all stakeholders the same right of participation that they would receive in Denmark. While we urge you to continue the aggressive search for new stockpiles which likely remain hidden throughout the country, the urgent part of the project -- the safe containment of the majority of the pesticides, has been completed. It is time now to go back and allow the public the chance to understand and reconsider the risks and available options for destroying those pesticides. There can be no honorable excuse for ignoring the principles of environmental democracy any longer in this case.

On Waste Importation

With respect to the potential for waste importation into the country of Mozambique, our fears are now based on much more than speculation. The recent discovery of letters signed in 1996 by current Mozambique Ministers authorizing certain foreign and domestic waste trading companies to import hazardous wastes in open defiance of the legally binding international law.

These letters signed in 1996 by current Mozambique Minister of Environment Bernardo P. Ferraz and current Minister of Finance, Tomas Augusto Salomao grant authorization for project "Waste Recovery" involving direct foreign investment from the company International Waste Group and direct investment by national company AMODEL LDA

Yet such agreements are a violation of international law binding both Denmark and Mozambique. In 1989 Mozambique and Denmark ratified the Lomé IV Convention. Article 39 of that legally binding treaty expressly prohibits Mozambique from importing hazardous wastes from any country outside its territory. The letters also indicate a willingness by Mozambique to flout the Bamako Convention and numerous OAU resolutions condemning the international trade in hazardous wastes.

 It was only following the release of these letters by Greenpeace and subsequent media inquiries, that the Mozambique government saw fit to nullify the authorizations. However to date we have no information as to how much hazardous waste was imported since 1996, where it came from or where it went.

Given that international waste traffickers have been attempting for many years to gain permission to export wastes to Africa, we are very skeptical of any claims that no hazardous waste was actually delivered in the two years since permission was granted. Furthermore, once a waste is placed in a barrel and a label is put on that barrel it is very easy to re-characterize hazardous wastes from industrial sources outside of the country as obsolete pesticides or any other type of material. Is Denmark sure that imported hazardous wastes have not already been stockpiled in Mozambique since 1996 and that they might not be destined now or later for the cement kiln operation? By your own admission, as a full inventory and audit of hazardous wastes in Mozambique has not yet taken place, we doubt that Denmark can make assurances that imported hazardous wastes do not already exist in the country of Mozambique as a result of the deal outlined in the discovered letters.

The efficacy of agreements made now with Denmark (which we have yet to see) assuring that the cement kiln not be used for imported hazardous waste must be questioned given the ease with which an international agreement -- the Lomé IV Convention (Article 39) was ignored, and the real possibility that wastes have already been imported and might be reported as domestically generated hazardous waste.

 Further, a recent story appearing in Development Today (10/98), revealed that one Danida official confirmed that incinerating imported wastes from neighboring countries was part of the original intent of the Danida project. If this is true, it shows equal disregard on the part of Danida for the Lomé IV Convention. But this alarming assertion might explain why Danida ever considered building a permanent capability for burning hazardous waste in Mozambique when in fact no assessment has been made for its need domestically.

 In your letters to the coalition you have consistently downplayed the seriousness of our concern regarding waste importation. In your letter of August 18 you wrote:

 "It seems that no evidence will rule out BAN’s [Basel Action Network, member of NGO coalition that works to end the international waste trade] lack of trust in Mozambique’s commitment to adhere to the international conventions which it has ratified; Mozambique’s willingness to enforce national laws; the intentions of the government and the cement factory to adhere to the signed agreements concerning misuse of the supplied equipment; and the fact that no AMODEL-plan can be implemented if it violates national or international regulations."

Yet Denmark seems to have been unaware that the Mozambique government violated international law in 1996 and only a few months ago, and after you wrote the above passage, was forced due to adverse publicity, to revoke the waste importation authorizations. Was Denmark aware of this blatant illegality with respect to hazardous waste and why do they have confidence now that Mozambique will not in future ignore other multilateral, national or bilateral agreements?

To further heighten our alarm, Danida engaged the services of a company (Waste-Tech) whose parent company (Enviro-Serve) was very recently actively seeking to import wastes into Namibia from the USA, again in contravention of the Lomé IV Convention (Article 39).

Deeds will speak louder than words with respect to erasing the concerns about waste importation. Once a full investigation and disclosure of the nature of the agreement with AMODEL/International Waste Group and its operations is revealed; once an inventory of hazardous wastes currently existent on Mozambique soil has been accomplished; once Mozambique has actually acceded to the Bamako Convention and ratified the Basel Convention Amendment (Decision III/1) (which we note you now agree is not the case), then our fears will be justifiably allayed. Finally, we are very happy to note your from your comment that Mozambique is now in the process of acceding to the Basel Ban Amendment (Decision III/1) and the Bamako Convention.

While on the subject of the Bamako Convention, we must note that your quotation from it, which states that hazardous wastes "be disposed in the state where they were generated" is taken out of true context. Not only does it ignore the paragraph dealing with precautionary action excerpted below, but ignores the fact that these pesticides were not generated in Mozambique. In fact, had the Bamako Convention been ratified at that time many of these pesticides would have been considered hazardous wastes prior to their import into Mozambique (Article 2, para 1, (d)).

On Incineration Technology and POPs

Once the Bamako Convention has been ratified then we expect that its provision with respect to Precautionary Measures will also be adhered to:

Each Party shall strive to adopt and implement the preventative, precautionary approach to pollution problems which entails, inter-alia, preventing the release into the environment of substances which may cause harm to humans or the environment without waiting for scientific proof regarding such harm....(Article 4, para 3 (f))

Certainly retrofitting a cement kiln to burn hazardous waste which is known to produce dioxins, furans as well as heavy metal pollution can hardly be following the precautionary principle prescribed by the Bamako Convention.

You write that you cannot understand the direct link between the specific disposal operation in Mozambique and the international POPs treaty negotiations. In this regard perhaps it would be wise and fitting for your Ministry to discuss this issue with the Danish Ministry of Environment which is very active in the international POPs negotiations. Dioxins and furans, two of the inevitable bi-products of combustion of halogenated hydrocarbons (e.g. many obsolete pesticides) are on the very short list of those substances to be first targeted for elimination under the new POPs treaty.

Cement kilns are well known to be major global contributors to dioxin and furan formation. One recent study estimated that cement kilns burning hazardous waste as fuel are responsible for 23% of the global dioxin and furan loading. When one realizes that there are relatively few cement kilns burning hazardous waste, this figure looms very large indeed.1 You should make reference to your government’s own work in regard to the hazards and risks of cement kilns with respect to the Danced series of reports and scoping documents in regard to the Jupiter, South Africa proposed hazardous waste incineration via cement kiln there.

It is incongruous to argue on the one hand for the goal of eliminating POPs and at the same time argue for the promotion of new incinerators which will increase these dangerous POPs around the world. In this regard it appears that the left hand of the Danish administration is working against the efforts of the right hand. The POPs issue is of critical importance as the POPs treaty will require that many other pesticides such as DDT will need to be phased out, requiring programs for their destruction.

It is not acceptable that destruction technologies will be chosen that will produce more POPs (and some of the most dangerous) while attempting to eliminate others. And this is particularly true for those parts of the world that have not already invested in this misguided waste disposal technology. Thus in our view Denmark is, perhaps unwittingly, promoting a very dangerous precedent for the destruction of global POPs stockpiles by the establishment of permanent self-defeating POPs producing technologies.

Contrary to the statement in your letter, our coalition has never argued for incineration in Europe or anywhere for that matter. As we pointedly stated, our use of past examples of export to Europe for incineration were used for "export-from-Africa" cost comparisons only. There is already a very large anti-incineration movement all over the North of which Danida seems to be unaware. The paper prepared by Danced, entitled "The Use of Hazardous Waste as an Alternative Fuel in Cement Kilns - A Working Document" (February 1997) documents a number of the cases of specific community struggles against cement kilns as well as the environmental impacts of them on communities and the environment. There are many more such case examples available.

Your claim that groups like those in our coalition should work on incinerators in the North implies that this work is not ongoing and building in momentum. But environmental gains in the North, such as the cancellation of incinerator projects, must not be translated into environmental losses for the South. Our coalition stands committed in opposition to the transfer of obsolete and increasingly discredited technologies from the North to the South.

Misleading the People of Denmark

In your letter of July 10 you stated that of the 42 million DKK budget (at that time) that only 3.3 million was to be used for actual incineration costs. As 17.8 million were to be used for collection and road transport, this still left 20.9 million DKK (roughly half of the project cost) to be utilized for so-called "capacity building" -- the cost of incineration equipment and for the construction of a hazardous waste station. Yet the presentations of this project to the Parliament of Denmark and the very title of the project itself says almost nothing about a goal of establishing a permanent hazardous waste station and incinerator in Mozambique as a form of capacity building. Rather the project is continually sold as a means to rid Mozambique of obsolete pesticides. Yet if disposal of pesticides were really the objective then it is very obvious that export would likely be the preferred option.

As we have noted before, we do not believe that the hidden agenda of establishing a permanent hazardous waste handling station and a permanent incinerator is in the best interests of Mozambique and we cannot consider this to be a building of capacity for environmentally sound management of hazardous waste. Even if we were to accept that incineration was a real solution for hazardous waste, which we do not, that could never be determined to be an appropriate conclusion for Mozambique until a thorough environmental audit of the Mozambique hazardous waste situation was accomplished. Following that, however, it will always be much more appropriate to first apply clean production methods to reduce and prevent hazardous waste generation rather than establish "capacity" for something (hazardous wastes) that societies everywhere are realizing they can do without.

Despite your vigorous, repeated complaints about our budget estimates, common sense dictates what your report and your letter of July 10, already told us -- thatif one is concerned just about the destruction of obsolete pesticides at hand and one is willing to look at the export option, then it will not be necessary to build a hazardous waste station, it will not be necessary to purchase incineration retrofitting equipment, it willnot be necessary to train and hire and pay hazardous waste specialists during the months of the burning, the job of the "turnkey consultant" will be vastly minimized and it will not be necessary to undertake the numerous extremely costly and time consuming test burns to assure compliance with the EU incineration directive. These costs should be enormous in comparison with simply packaging the waste (which will have to be done anyway during road transport) and placing it on container ships for export to a country like Denmark. Once in Denmark, the waste could become the object of a much needed pilot project to destroy it using non-combustion technologies.

In your answers to the Parliament regarding looking at costs of the export option you continue to refuse to look beyond the simple fact that FAO has provided you with an estimate of the cost. According to industry sources this figure is unreasonably high but even with that figure the entire costs we suspect would be far less than your scenario of building permanent waste stations and burners. In any case it is inappropriate for you to claim that the FAO figures are correct without first checking them in the marketplace. Further it is inappropriate for you not to report the true costs of all available options.

Instead of continuing to deny the accuracy of our cost estimates for an export solution we would ask that you please simply provide us with some cost estimates of your own for the export option for disposal of pesticides without the subsidiary, and in our view, inappropriate exercise of building a hazardous waste station and retrofitting and continually monitoring a cement kiln incinerator. The fact that you have steadfastly refused to produce such a budget indicates to us that you have, for political reasons, and not for environmental or economic ones, refused to truly assess the export option.

While you allege international legal constraints for this option not being practical, you fail to note that export has been the global norm for dealing with obsolete pesticides. We would ask therefore that you look at the actual market prices for such exportation from other companies around the world that are offering such services as well as the actual waste exportation events that have already occurred. Our own preliminary research indicates that actual prices may differ markedly from the FAO estimate (see examples below). Further we would ask that you give a price estimate for simply removing the pesticides to an adequate storage facility in Denmark until such time as Denmark can make the necessary arrangements to utilize non-combustion alternative destruction methods.

Your claim that GTZ had difficulty in exporting hazardous pesticides from Mozambique due to "MARPOL as a major obstacle" flies in the face of numerous instances in which pesticides and other hazardous wastes have sailed on ships all over the world. Indeed GTZ successfully exported 300 tonnes of pesticides from Mauritania to Royal Dutch Shell for disposal in Rotterdam in 1995-6 at the cost of $555,000 dollars.2 According to AVR, the Dutch incinerator company involved in the incineration of those wastes, (noted for price comparison purposes only and not endorsement of technology), the usual price they expect for such operations today is around 1,000 US$/tonne including transportation and supervision and incineration.3 The FAO reports that in 1997 some 370 tons of pesticides stocks were removed by the FAO from Zambia and the Seychelles at the cost of 1.3 million dollars with GTZ and Dutch government financial assistance.4 The FAO also reports that they had 260 tonnes of obsolete pesticides stocks collected and exported from the Republic of Yemen for incineration in the Rechem facility in the UK.5

Its time to give the public a true cost estimate for the export option for destruction of the obsolete pesticides (without the unnecessary costs of waste station and incineration construction/retrofitting).

Alternative Disposal Options

As we have stated, incineration technologies are not appropriate for the destruction of POPs. We have provided you, at your request with three different established technologies that are likely to be more appropriate for the destruction of the stockpiles. Now we provide you with a letter from one of the companies – ECOLOGIC, explaining that they would be very happy to enter into an arrangement with Denmark to destroy these pesticides in a process which would not produce dioxins and furans as by-products. A copy of this letter is attached. We would ask that you please follow this offer and pursue as many of the other non-combustion hazardous waste disposal companies available around the world as you wish.

Your statement that such technologies, while you find them of interest, will not be used in the current project, is not justifiable. There is no reason these de-toxification technologies should not have received adequate attention from your department as one of the most environmentally beneficial options available, and there is no reason they cannot be assessed for use now. We would suggest a pilot project for their use to take place in Denmark under close monitoring and control. In this way Denmark can once again establish itself as environmental leaders and not proliferators of dirty technologies.

On Waste-Tech

You claim that the contracting of Waste-Tech happened after the human rights commission launched its inquiry into its Port Elizabeth facilities. Yet, there existed plenty of evidence at that time for Danida to make the right decisions about the companies it engaged. Waste-Tech has been operating for some time in South Africa and had established a known track record. As early as February 5, 1997, Danish authorities accompanied the Environmental Justice Networking Forum, community representatives and officials from the Department of Water Affairs and Forestry in a visitation of the infamous Umlazi landfill site run by Waste-Tech. Among many alarming discoveries made during the visit of what was supposed to be a low-toxicity disposal site were containers of highly toxic mercury waste left unattended and unprotected. Further, if evidence of illegality was needed, their parent company Enviro-Serve was active at the time in promoting waste trade into the ACP (African, Caribbean and Pacific) group of states such as in Namibia in contravention of the Lomé IV Convention’s Article 39. We believe there was and remains sufficient evidence to terminate any remaining Waste-Tech contracts at the earliest legal possibility.


We would hope that Danida would honor the idea that local communities should be involved in projects which impact them from the beginning. In light of the fact that such local residents are now claiming that this has not been the case, we would sincerely hope that Danida will agree to hold a true public hearing on the disposal operation and various options that are still available. We sincerely hope that our coalition will be able to frame the terms of reference of the new EIA and help decide who should conduct it. We would hope that Danida would find the necessary funds to accomplish theses prerequisites for any such project.

Further, we would hope that the surfacing of letters signed by current Mozambique Ministers to ignore international law and engage in the international trade in hazardous wastes finally will elevate your concerns with respect to the strong possibility that hazardous wastes have already been imported into Mozambique and that the Mozambique government might be willing to ignore international law again. Before moving forward in any type of waste management arrangements with Mozambique, that a full examination of this past waste trade deal be undertaken and that the Bamako Convention is acceded to, that the Basel Ban Amendment is ratified and that both of these agreements are implemented in national legislation.

Due to the enormity of the amounts of obsolete pesticides and other POPs stockpiles that are being discovered or will be phased out all over the world it is essential that Denmark not rush forward in the establishment of dangerous precedents in dealing with the problem. Finding new pesticides stockpiles is hardly an excuse to amplify a misguided program or technology. Now that the pesticides have been collected, the "emergency" phase of the program is over and questions of how best to rid Mozambique of the obsolete pesticides can be explored with less urgency, in a more educated way and with greater transparency.

We believe this case offers both Mozambique and Denmark an excellent opportunity to be global champions of applying proper waste management practices to the issue of obsolete, banned and phased-out hazardous chemicals. Toward this end, we hope that you will begin to work with us in civil society beginning with taking a step back and reviewing all available options.

Your letter of 18 August, repeats a theme that our coalition promotes the "best as enemy of the good." This statement implies that the "best" of which we speak, is somehow unattainable and unrealistic and that the cement kiln disposal of toxic waste in Mozambique and the promotion of incineration technology in Mozambique as "capacity building" is somehow "good." The statement also implies that you have in good faith been involved in a "good" and fair scoping process involving stakeholders. We would strongly disagree with all of these inferences.

Despite our disagreements, the one thing with which we do agree, is that the obsolete pesticides stockpiles now threatening Mozambique should be rendered harmless. Within that area of agreement we remain confident that numerous avenues for discussion remain where even more specific agreement can be found. However that will only be the case, if the door to true public involvement is finally opened to us. We are simply asking you to truly explore other options with us. We are certain that if you do, you will realize that there are alternatives that will satisfy all of our concerns.

Sincerely yours,

Antonio J.L.M. Reina
Livaningo Coordinator
Av. Karl Marx, 1452

Tel: 258.1.430.665

Livaningo Representat

on behalf of the following organization representatives:

Jim Puckett
Basel Action Network (BAN) Secretariat
c/o Asia Pacific Environmental Exchange
1827 39th Ave. E.
Seattle, Washington 98112 USA
Phone/fax: +1 2067206426

Dr. Paul Connett
WASTE NOT, and Professor of Chemistry
St. Lawrence University
Canton, NY 13617

Chris Albertyn
Environmental Justice Networking Forum (EJNF)
Pietermaritzburg, South Africa
Phone: +27 331949073
Fax: +27 331455841

Marcelo Furtado
Greenpeace International
Sao Paolo, Brazil
Phone: +55 1130612934
Fax: +55 112825500

Jacob Hartmann
Greenpeace Denmark
Copenhagen, Denmark
Phone: +45 33935344, +45 33938660
Fax: +45 33935399


1. Letter from ECO-LOGIC Company offering their detoxification services to Denmark.

Fax Copies sent to:

Minister Bernardo P. Ferraz
Ministry for the Coordination and Environmental Affairs
Av. Acordos de Lusaka, 2115
C.P. 2020 - Maputo
Phone: +258-1-466059/ 465708
Fax: +258-1-465849

Steen Gade, Chairman
The Parliaments Committee on Environment and Planning
1240 Copenhagen K
Fax: +

Mr. Svend Auken
Minister of Environment
Hoejbro Plads 4
1200 Copenhagen K
Fax: +45 3332 2227



1. Louis B. Brzuzy and Ronald A. Hites, "Global Mass Balance for Polychlorinated Dibenzo-P-dioxins and Dibenzofurans, Environmental Science & Technology Vol. 30, No. 6 (1996), pgs. 1797-1804. A recent "mass balance" study of U.S. (not global) dioxin emissions is Valerie M. Thomas and Thomas G. Spiro, "An Estimation of Dioxin Emissions in the United States [PU/CEES Report No. 285],"(Princeton, N.J.: Princeton University, Center for Energy and Environmental Studies, December, 1994).

2. "Environment: Mauritania’s Toxic Pesticides Incinerated in Holland," by Ramesh Jaura, IPS wire service, September 2, 1997.

3. E-mail from Alwin Booij, Managing Director of AVR International to the Coalition, September 14, 1998.

4. "Africa Environment: Obsolete Pesticides Accumulate in Tanzania," by Judith Perera, IPS wire service, October 24, 1997.

5. "FAO: Huge Stocks of Obsolete Pesticides Threaten the Environment and Public Health in Developing Countries," Press Release of FAO, June 5, 1996. From FAO website, http//:


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