Document 0gJJMjK8nxa586x7xL0y4BrNR

bcc: R. N. Brell-RBREL J. M. D1 Angelo-Atlanta W. B. Papageorge-WPAPA January 21, 1971 Mr. Hugh W. Lowrey ni yfti*. nr nr Manufacturing jn^ ^Tnrtiiran Cnattrun. 1M. -JTTT 3333 10th Avem.e, North Birmingham, Alabama 35201 Dear Sir: Thanh you for your Inquiry eonoerning our polychlorinated terphenyl products and their statue with the U. S. Department of Agriculture. As you might luagine, we are quite concerned with the wording or PR notice 70-23 aid have discussed this with the authors of that notice. Early In 1970 honsanto, after having carried out extensive evaluations of PCB's and their effect on the environment, came to the concluolon that PCB's did Indeed have a detrimental effeot on the environment and that they should not be sold Into open system applications. At this time we requested In writing, that the VI.S.D.A. cease to reg ister Insecticides containing PCB's. Further, as you know, we with drew PCB's fron. plasticizer areas. Parallel to thl3 study of PCD's, we have tried repeatedly to find some evidence that PCT'n (poly chlorinated terphenyls) had some ecological significance. At the time that wo reached cur decision to withdraw PCB's from the market, we had not uncovered any evidence that POT'8 were even found In the environment. At the time of this writing, we have still not found any evidence that PCT'a can be found In the environment, in spite of the fact that our search has continued, if not intensified. When the U.S.D.A. PR notice 70-25 was published Btatlng that "there are accumulating data on the chronic toxicity of the polychlori nated biphenyls and polychlorinated terphenyls to fish and birds and the contamination of the environment by these chemicals" Mon santo stated to the U.S.D.A. that if such data existed It would certainly be in the beBt Interest of ell concerned to publish the data. The U.S.D.A.'s response was that no data on polychlorinated terphenyls actually existed; that a qulok look at the chemical structure indicated that the two products v.ere chemically similar and therefore would be considered as one with rcopeot to ecological problems. MONS 069762 As stated above, Monsanto's extensive searoh for PCT's has not shown these materials to be present In the environment, 1'uvther, we believe that there are definite reasons which could explain this - such as the extremely low solubility of these products in water. Accordingly, Monsanto Is preparing a formal complaint to the U.3.D.A, protesting its hasty publication of statements concerning polychlorinated terphenyls and their lack of ability to be able to back up their claims. I hope this rather lengthy statement adequately explains our stand on U.S.P.A. PR notice 70-25. If you desire additional information on this subject, please do not heslsate to oontact us. Very respectfully. Willis S. Clark Product Specialist, Plasticizers WSC/gls HONS 089763