Document 0w2gKKwkZN1570zv0bRy342x

w. 3. Clark - Qcneral Offices April 21, 1 >71 SWIPT AND COMPANY, LTD R. N. Brail Pstet Marsh - Brussels --Pogwfc M. J. Harrison London ,. )' I have Just received a rather torrid letter l'rom Mr. Marks of Swift and Company, Ltd. 1 have sinoe talked with Pater Marsh and he has brought me up to data on your aotlvltias with this gentleman and It sounds like you have things under control, or at least as wall under control as is possible under the circum stances. 1 have Just drafted a letter to Mr. Narks trying to placate him and telling him you are active on the problem. A copy of siy letter Is attached. While Swift's problems are evidently more related to acute toxicity than to environmental problems, I thought some comments on terphenyls and their eoological significance might be helpful to you at this time. As you know, we made our decision last spring to withdraw PCBs from open system applications. Need less to say, this deolslon was made only after much deliberation and evaluation of the data avallabla to us. Baaed on this atudy, ws concluded that It would be In the beet interests or Monaanto, our customers, and the environment to atop selling PCBs into open system applications. We believe that this wee a good deolslon baaed on the fects available at that time. All during our evaluation of PCBs In the environment, we attempted to find some evidence that polychlorinated terphenyls (PCTe) ware alto affeotlng the ecology. At no time did we find these materials In the environment. Sinoe last spring, we have continued to search for PCTe in the environment and our findings are still the earns. PCTe do not show up in the lakes, streams, flah, birds or other natural states. MQNS 098562 K. J. Harrison -2- April 21, 1^/71 While Monsanto would like to be able to say that we have a oomplete explanation as to why chlorinated terphenyls do not appear In the environment, thla Is not the cast. We believe that In general, they reaict bio degradation to a degree similar to the PCBs. However, we do know that the chlorinated terphenyls arc much, much leas soluble In water than their chlorinated bi phenyl analogs. This would certainly make them lees available In the streasaa and lakes, and thus less likely to enter the rood chain. Further, Judging fro* l) the slse and configuration of the two mole cules, and 2) the relative solubility data of chlorin ated clphenyl and chlorinated terphenyl in organic sol vents like hexane, one would certainly be lead to the conoluaion that the chlorinated terphenyls should be less soluble than chlorinated biphenyls In the fatty tissues of animals. Hart again, thla would make It more difficult for the chlorinated terphenyls to enter the food chain. Our ourrent Kb content In our chlorinated terphenyl line is less than o.4^ by weight. We are bringing a plant modification project on stream at the end of this year which will reduce this level to approximately o.Oljt. We are confident that this Is a level which will not cause any environmental problems. When Monsanto made Its decision last spring to withdraw chlorinated biphenyls from open system applications, and to leave chlorinated terphenyls on the market, we con sidered all the information which waa available to us at that time. The comments given above summarised some of ths thinking that want Into that decision. Since last spring, we have continued our studies and our evaluations, and have not ae yet formed any new data which would tend to change our deolslon. We fully expect that the chlorinated terphenyl products will remain In our product line. MGNS 096563 M J Harrison -3- Aprll 21, 1171 1 hops these consents will oe helpful to you In your discussions with Swift. Let me know if 1 can provide any additional assistance. /dOw Willis S. Clark MONS 098564