Document 0dvy1doZJKgGEmOKV5vea8dM

> ROUGH DRA7T - ll/LP^te . OU3I33 es asrvnaaiMESEAi,-.?vuz?z& a s a s & ir&.rlah .?3Sfc ^r-^V "^NiFr. ^iatro*ictoa problem * xzr. 1 recess XT* Nature of the Probles rioocarch-and-aedlea:. Inptffc T* Sest on Monsanto VX* rXect on Customer VXX- Involvement with other producers :* Sources of Contaginatica Jh-- Scdtre IX. Recent technical changes ehich hare oc the contamination X. Courses at Action XI* Recommended Course at Action XU. Implementation of the Heeoneaded Course at Action A* Immediate Action (12-1-69) 3. Interin 1-3 aonths ** C* Short term - .2-6 months D* Long ters (1-3 years) 1* Research medicai Manufacturing 3* Engineering ' A. Market . 5 - Retent. Environmental Control - '* T . tagsl a. Rutile Relations 9* 0 ^ 21 217. Coat at ;,i-*EV^t^*?*g2^rS;23r*S^ S ;.,V.: -'"-**'*':' -r^ 2 7 :Jutui'e - PCS SHTIHQnQiTAL ?QH2TiaU ABAISSEOT PIAH Introduction Cn 15 October the "AD HOC* Camittee consisting of Messrs. M* Parrar, ?. Hodges, 3. John, V. Hichard, and 3* Wheeler Issued a report sums rising the polychlorinated biphenyl (PCS) pollution problems from the Icaown available indorsation to date. Out of this report case considerable Indorsation, conclusions, and recemendations which we have attespted to tie together Into a plan of action In this document. Our objective has bees to taiee a reasonable and responsible approach to the entire problem. Before we get into the proties, we should clarify the meaning of PCS, the nature of the entire line, and how these tie into our product line Monsanto entered the Aroclor marJeet in 1930 by acquiring Swain BIcctrical CbpRy_op teamen irMay it stir Anttiston, Alabama plant, r~-* first Lead if Artclsr* *11*1 incidentally->vrw-ay irocicr 1254 -- vest out of Anniston, Alabama to (S' in 1931; ;Since that tine the - --- X**----- -- -- ---- snkst has grown to 170 to 200lT4warldwide_ ~ Chemical Biphenyl Monsanto Product Line Mata?* of Material at Ambient Solid Mono chlore biphenyl 2lCphT*rpob*"**+,*%1 ' dpCi ptricX.tioroTciphenyl .2002Qumterchlsrobiphenyl Pentachlorobiphesyl Aroclo? 1221 Aroelo? 1232 Aroclor 12b2 Aroclor 1246 Aroelo? 125b iCrdTHeptaehlorpbipfaeayl jt Tphiyl^ Aroelo? 1260 * Aroelo? 1262 % Aroelo? 2263 iroelor 12715 . thin liquid (oil) thin flash water. oily type fluid material Thicker - traasoissi oil Heavy-Mclasa es TMcic - tar Very thisic - liquic Solid t - 3- Total possibility are 210 theoretically possible chlorinated bi-h \*A Santcwas or terphesyl Solid Aroclcr 5*60 Solid /%* Y/j* if// 0 Lamage to the ecological system by contaisination from polychlorinated Uipheayl (?C3). Sciensiveness The problem involves the entire United States, Canada, and sectiers of Surope especially the United Kingdom and Sweden As the investigaticn a (j) broadens other areas of Surope, Asia and Latin America will sorely become involved Srldenoe of cantagrlnation have been shown if seme of the very remote parts of the world* The Involvement could and most likely will follow the DDT investigations* XT. Mature of the Problem Professers Wldsark and Jensen of the Institute of Analytical Chemistry at Stockholm, Sweden, In November 1966, -announced and confirmed flhdln: PCS in fish, birds, and eggs. Subsequent findings were made In 1967 1: Great Britain* In Palmary 1969, Professor Blsebrough of the Uhiversi of California published as article in the San Francisco Chronicle * relaying his findings of PCS In the envlrossaent of the United States. Monsanto confirmed the presence of PCS's In sld-1969 and confirmed, the adequacy of work by Vldmazk and Jensen and ethers; truly, the PCS'a a worldwide ecolological problem* - ft - Km Analysis indicates the environmental presence of the 5 and higher -ohlartsated biphenvl? which take the appearance si JLrorlor 123^ Aroclor 1260. 1Ve have strong Indications that Arcelor 2242 or at Isas: ... part of it degrades biologically* Since the Arcelor 1242 contains ar- 7 percent of the 5 chlorine biphenyl or higher we cannot rule out the possibility that the observations may be a concentration affect of the higher chlorinated biphenyls of Apodor 124a. To date there have been no reports of finding Aroclor 1242 present in the environment (except outside the effluent of our plants where we kr. Arcelor 1242 is present). The seriousness of the problem can best be spelled out as follows: 1. Pish - Marine or aquatic species concentrate PCS in the fatty * J f r tissue. Toxic is snail quantities (does to 5 ppi) to sensitive na life such as shrimp, 2. Birds - Predatory species feeding on the marine or aquatic life ca further concentrate PCS to possible harmful effects. Specifically in birds PCS can affect the calcium metabolism leading to egg she! imperfections which prevents proper batch of' the young. In fact, Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCS's in controlled tests. 3. Mac 'There is no harmful effect known to man or other mammals af* 40 years of production. Investigations are underway by various sources. STA 0219*3 4-. Political and Public potion - PC3*s are falsely with DDT because PCS's show up in the analysis for 80?. PGS's are linked * other permanent type chlorinated hydrocarbon pesticides* This becomes particularly serious slnee about every article, of food in country is being examined for a trace of these materials. "'J)Ay^ 5^) ^ 'iT rr-*- ( ALDRIN ffiDSlN c: 300 .a a KBTACHLOS a O a UMOANE 3fc> -a a * WTACHLCR 90XIOE -a c: SOT a. a Qp o-ci-a H 000 a c: Qp oa Hg 1 Stracanai Mannaia oAfta ^ % i 4 *r- xm \ > \*i yS'. it f. PEfmCJPBp Heptachlor I Undm 7 Hathoxyohtor o #p OPT y pp* DDB *\ | 9 PP* DpD tMdrlh / Dleldrin ; .*> >i?..; =; _ ,, Effect oa Monsanto ,* **. r ^ B u s i n e s s potential at stake on a worldwide basis; Fluids Plasticisers Total/year ' 70*T 13. ' "tier *6-5f s.?. 3*8 lbs. *ST *2-3* 8.?. 10*8 lbs. $22S 43-UJT 8.? Already competition la using certain data against us In competitive situations. A. Legal liability Direct lawsuits are possible. The materials are already present in nature having dene their "alleged damage". All customers using the: products have not b e officially notified about known effects ncr cur labels carry this information. These are only a few of the possible legal implications which would best be covered by the legal department. B. Public Image The corporate image of Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environ ment will be adversely affected with increased publicity. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond questioning. This combined with certain scare publications is cert to give an adverse image. Ouiltyfassociation (with DDT) will pro* vail as the background while actual facts may be sparse. CsstoMtr Hel.* STR M l f 4 * Some customers who presently use these eaterlals will be "scared o to other competitive products. Products associated with the same name or "trademark" will be adversely affected le., Theminoir Pydraul and Araclor. Competitors will use the information for *er. influence on Monsanto products* Customers m i l seek other "cuts* rather than become involved. VX- Effect on Customers. and Ultimate Ccrsumra ""one of the unique* features of ?a*s is their fire resistance. Here the basic decision whether to risk lives due to fire or risk extinction zfJ some species of birds* In this ease the ?C3 would probably be accepted as a necessary pollutant and tolerated under controller conditions. A. Slectrical Industry - Capacitors and Transformers use Aroclcr because it is the best inexpensive dielectric fluid available. B. Pood Processing - Bulk "deep frying* units for potato chips, fish, and doughnuts use the fire resistance fluid as an indirect heating medium.* C. Die Caster -- and other hot metal working industries fire resistano fluids to protect the worker? Affects a wide range of plastics and adhesives because the ?C3 serves as the plasticiser. -- -- A wide-range of paints and coatings are affected. The "Carbonless" carbon paper used so widely would disappear. 7 E . Involvement With Other Producers Although Monsanto is most probably responsible for the U.S. cantaninat: and Jointly responsible with MCL for .the TJfclted Kingdom problem, we cannot accept responsibility for the world. There are five known producers in the free world, several possible producers ^ the ire: curtain and couple of additional companies aatdng overtures about entering the business. Monsanto representatives have on one occasion discussed this problem with a couple of these producers but.they expressed no great concern. In fact, it Is highly possible that one = these manufacturers is damp* -g his waste into the Rhine River. certa any astion taken by re prrdasar will most assuredly affect the other It is rtZrear pcsrihio Thnt a ;slat plan of action could he develops but will most probably have to be spearheaded by Monsanto- It is als -likely that producers of other chlorinated products used with ?C3rs will be dragged Into the investlgatica * Sources or Contamination Although there may be seme sail and air contamination involved, by fa; the nest critical problem at present is water contamination. To our Jacwledge to date the contamination can be broken down into two gener .eategaies, open and indirect pollution A. Open pollution - Cur sarufactaring facilities sewered a sineable quantity of PCS'* in a years tine 1. Fluids Fluids are probably the most open source of pollution because their nobility. They also say be the least serious because th are generally the lower chlorinated materials. 2 Electrical Electrical customers have in the past sewered their wastes. 3* Heat Transfer Heat transfer customers have sewered their objectionable and their spilled material. 4 -Industrial Stese fluids have generally bees sprayed into drains, washed down sewers and generally regarded as very harmless All of the fluids have had the *|irkf constituent damped an dirt roads dedusting agent" which inadvertently found its way back tcjShe stream these manufacturers is dumping his waste into the Hhine Hirer. Certaiarry action taken by one producer vfll mcaf assuredly afreet the other*. I?: is wsfcls*%rpessit-ls"'t.bitz -Joint plan of'aotisn esald^be dereloped but will most probably have to be spearheaded by Monsanto.- It is also -lively that producers of other chlorinated products used with ?C3's will be dragged into the investigation. * Sources of Contamination Although there may be some soil and air contamination involved, by far the most critical problem at present is water contamination. Is our knowledge to date the ccatari nation can be broken down into two general .categories, open and indirect pollution. A* Open Pollution - Cur manufacturing facilities sewered a slseable quantity of ?C3's in a years time. 1. Fluids Fluids are probably the most open source of pollution because c their mobility. They also may be the least serious because the are generally the lower chlorinated materials. 2. Slectrioal Flectrioal customers have in the past sewered their wastes. 3. Heat Transfer Heat transfer customers have sewered their objectionable and their spilled material. A. -Industrial These fluids have generally been sprayed into drains, washed down sewers and generally regarded as very harmless. All of the fluids have had the constituent dumped os dirt roads dedusting agent* which inadvertently found its way back to the stream. c - 3 - C. Indirect m Shipping containers and the cleaning thereof for subsequent use a source cf contaminatieni 1. Fluids a. Slectrical - Disposal of '''burned out" transformer and capacitors nay find its nay back to streams. Scrap units (new) are generally disposed of in lapd fills but could possibly get basic to the stress. b. Heat Transfer - Leaks could contaminate. e. Industrial - Cress product contamination carried cut of a air compressor. Kesldnal material carried os parts. 2. Plasticisers a* Process Contamination from Washing (1.) Environment Contamination Swimming pool paints Incineration cf wax .coatings Traffic paints (2.) Product Contamination STR 021949 Coating for tank lining 2 .. Certain adhesives Recent Technical Changes Which Hare Bearing qb the Contamination A. Fluids The sources of pollution were pointed out as they hare been in tr past because we are dealing with that ouastitr af material in ch: r -9- environment today which was deposited over the past forty years, we it-,state-.that responsible people throughout the is&?*-*?y- hare .corrective action to reduce csptagjnation in the last two years. There - --have also been technical advances which have brought about the use cf lower chlorinated biphenyls which may be an advantage because to date : low chlorinated ones have not been identified present in nature. 1. Sleetrical - 2ie large customers have established collect systems the waste is recovered. Incinerators are being investigated and built for the disposal of the materials. 'There has been a shift away from the higher chlorinated types products and could probably '-shift almost entirely away from those products. 2. Heat Transfer - System have been tightened up and redesigned to confine the contents Here^to^1the trend has bees to shift away from the higher chlorinated materials. 3* Industrial - Seeing ponds have been built by the large mamfactur to catch the material and decant off the PCS for reprocessing. Th trend here as the other fluid areas has been towards the lower chlorinated materials. h. Plants - The plants effluent has been passed through limestone vh: provides surface to catch seme of the material. But high concen trations can be found in cur effluent (that is relative to those findings in nature causing the problem). 3* Plasticizer Quite opposite to fluids the tread in plasticiser Arcelor has been to higher chlorinated biphenyls. In plasticizers the lower chlorinated biphenyl will not be an acceptable solution however the lower chlcri terphenyK-caaId offer a possible sc 10 Courses cf Action A* So thing .. We eansit deny the findings and tie acquisitions by the various agencies. IT ire took no action we would. likely face numerous suits. Ve would'let government tolerances be based on public and polUcal pressure along with any experimental or developed data which they nay generate. Ve would moat lllcely be forced cut of this business, ether product areas would be adversely affecoedr Ve would project an image as an Irresponsible member of the business world. Project poor customer relations. The only advantage to this technique offers is it reduces the cost but this too must be weighed against potential less of business. 3. Discontinue Manufacture of All Polychlorinated Biphenyls (PCS) Although we all realize this could be an eventually tmfortunately the solution is net this simple/ Assuming we did stop manufacture immediately the pollutants are present In the environment, the liability is present and possibly by the shifting to the lower chlorinated materials and the recovery techniques the contamination may already be reduced to an acceptable level. Obviously the entire business would be lost without any or very few substitutes to be offered, ether product areas would be affected. Financial loss could be considered due to raw material contracts customer contrue* and royalty -- secrecy contracts. Competition would take advantage on all frosts. Ve would be admitting guilt by our actions. Loss of capltol investment in the plant* associated utilities and asso ciated processes. Ve would possibly gain a little public image on this actios ST 02l l C. Bespend responsibly admitting that there Is growing evidence of environmental, contamination by the higher chlorinated biphenyls' and take action as new data is generated to correct the oroblem. Shis approach m i l d enable os to phase out the higher chlorinated 'nJrflJ*tir'f*e^e-raVl:*s.'*,i*a. apfyv,*.>a^r.p, plications where they a w n#'o longer aepessarr ,** or really desired* *Veeould caadglse the corporate- iaage by publicizing this act* Ve would reduce a taown pollutant. 'Additionally ve could gala "precious ~tlse seeded to develop sew products and Investigate farther the- lower chlorinated materials. As sew research data Is generated our course nay te altered considerably. Certain United actions nay reduce or Unit the problem. IC _ Hec^ssiezided Court a ef A otic:; Based .63 the Isfcz9atls3 a*LIa*lw tads? the only recnmendaticn we can honestlx ak* Is respond responsibly admitting that there is growing -- -- - evidence of environmental contamination by the higher chlorinated biphenyls and take action as sew data is generated to correct the problem ttt, implementation of the Recommended Coerce of Action A. Immediate (2? 12-1-69) 1* Set up a tasic force under a project manager or the equivalent .responsible for initiatingj directing and implementing all actio: that Monsanto decides ta take. This includes sufficient budget necessary ta cope with the iaaedlate problems* This task farce should include representatives from Medical, Legal, Research and the two involved Marketing Groups and Public Relations and must conduct liaison with MCI and other locations Involved in the prob lea. 2* Decide- on timing and content of any public and/or customer nctif cation of p<3 problem* 3. Interim {within 3 months) Fluids * ?lastici2ers 1, Confirm Aroclor 125A/Aroclor 1. Announce differential between 2260 are found in the envi flulds/plast!alter uses* ronment. 2, Pttblieis* the dirrteslt m l . 2, Announce safety of other P C 3 r Casio. chlorinated terphenyl, . 3. Protect other ?C3/chl* terph. 3* Educate customers on. control effluent for all products* Announce plans ta reformulate A* certain Therminols and Pydraul where control of the product is difficult* Initiate program to develop- A 225A & 1260 substitutes - 13 - 5. Enphasise better control over 5* Investigate with marsuf& ether Arcelor 225b.& .1260 the feasibility-of alts ./-hsed/ ' :."v: products. t* 0* iju* customer ecssacu or vr-- need for effluent control of all products* 7. Determine ecapoaitioB of a.U PCS'3. Develop . ccnprehensive Program C* Short Term (within the nest 22 months) 1. Research - Zspand program Tar more meaningful biodegradation Medical studies and confirming analytical results. Sspand tonicity studies. Follow developments concerning publicity and those developments covering political Implications of ?C3 contamination. 2 Marketing - Ulscontinue or substitute replacement products ror those applications of iroclors 22$b and 1260 where the Aroelcr remains mobile. Work with oustoners to clean up plants on other Aroclors. Report the habitual violators or *de nothings* to the product group* Reclaim or safely dispose of fluids/ Consider renaming products that do not contain ?G3* Follow an: report market developments such as customer disposal systems. Fallow and report any political or public feedback which, may affect the contamination problems and must be coordinated with Medical Research and Legal* _ 3 Production - Clean up plants and stop gross contamination, b. Legal - Define our present position recommend reasonable actl that will not undue2y alarm the market but reduce the exposure In terms of liability. Coordinate recamaenrfacienA -vkth Market fr - 14 - . Fib ;.s- putHolts actions abate beHeved advaatag ecu Certainly discussions should be held vith other producers vithl same period to determine their planned course of actios if any D. " Lang Range Tentative Outline (Proa 1 year to 3 years) Realising that the comprehensive program most be outlined the *Lcsg Range Tentative Catlire" is meant to serve aa a guide: All aspects or this program should revie* quarterly by Organic Management, 1* Research-Medical Continue biodegradation studies and analytical support Isomer distribution Tonicity and metabolism studies Water soluble removal Incineration analytical support Confirmation analytical * - Contract academic research for reference Develop ne* and improved forma lationa 2. Manufacturing a Process Research and Development (1*) Identification of typical Arcelor isomers (2) Develop control for effluent composition * (3.) Test substitute formulations etc. (4,) Develop ne* processes b. Clean Up plants e. Modify processes to meet market heeds a* Develop and set up os plant locations incineration systems b Design ne* processing equipment as necessary 4-* Marketing a. Specify alternates or changes b. Customer- liaison r - 15 - , Sat rsclalai or sispesai txC -fluids a* mart on same association proviens 5. Patent Investigate trademarks registered Cover with patents ary work felt patentable 6* SnvIronmental Control Develop cheap dlspesal systems for customers a. Incineration or pyrolysis b. **2iadegradatian unit etc. c. Consultants In pollution control 7 "Legal Investigate and deiine cor position, on Royalty secrecy agreements. Contracts - 3sv Material and Customer 8. Public Relations Portray to public positive actions at correcting the contamination problem. Release periodical statements covering our-position* Probability of Success C' - I S XTT. Cast of Program aw,.the. oasts hare been clearly defined at. this ti However* a cast estimate of $220,000 for toxicological work alone has been presented* Tentative figures Indicated under the worst ecnditicr the entire program could run as high as $2.0-2.SL At this stage It 1 err difficult If not Impossible to develop a reasonable cost figure b one point is clear It will be larger than the normal research budget c handle. Per this reason, assuming the approach Is acceptable, we shai be forced to ask for additional appropriations to fund the program. X7. Puture Follow developments 'on the problem as they unfold. Develop an aggressive research program to confirm or deny findings an: better understand the problem. Develop costs for the implementstlcn of the Recommended course of action. ' Develop specific actions with each department involved Submit the actions with coats for approval - Develop - timetable to solve the overall problem. Prepare for "preeipitious pullout* or drastic legislative action alth we do not feel this Is a likely possibility. A R S CK '( ______ d o yqrHzaa DOIIAIB -c SOPTT AMS UBtlTT? 73. ^_` d is c c n tzk s " HANUPACTUHS JP ?C3 I DOIXABS i SSS?CKSI5I3 AgrOAdS1 D0I2JU t 70 n 72 73 r 70 71 *i 72 73 70 71 72 73 I i FRGFTTS * PHCBABTOTT OF SUCCESS *. i " 70 i TX ` 72 I. I 7 /? CTI fR.h- _ D OTHiHCr L - ^"P&- TDl-iCHT;W!j M M J O & a V f D frf.i S PHSjLB aoit *, p?,o6/> r V r r a r s o c< i)t /