Document 102mR5a5225oJdLMO7NR8vXVE
DISCONTINUATION OF THERMIHOtf FR SALES
* Would go to Vico Presidenfca/Buslneaa Croup Directors only plus Specialty Product# Croup field sales/Regional Managers.
1. 0. *Why has Monsanto decided to discontinue Therminol FR heat transfer fluid sales?
A, We have previously written to all Therminol FR heat transfer fluid customers alerting them to the precautions necessary In handling and using these PCB-containlng products. Earlier this year we stopped selling Therminol FR fluids for new heat trans fer fluid systems. We also discontinued sales of make-up Therminol FR fluid to food-related applications and worked with these customers In converting FR fluid to non-PCB heat transfer liquids (e.g., Therminol 55 and Therminol 66). We have now de cided to discontinue all Therminol FR heat transfer fluid sales In the U.S.A. and Canada because there are serious problems associated with the possibility of accidental leakage of PCB from heat transfer systems. '
2. Q. Who within Monsanto decided to (liscontinue Therminol FR heat
transfer fluid sales?
-
A. This decision was made by Monsanto's corporate management and
affirmed by Its Board of Directors at their monthly meeting In
December, 1971.
3. C. *Does this action mean Monsanto is getting out of the heat transfer business?
A, No. The sales ban applies only to the FR series of fluids (Thermlr.ol PR-Lo Temp, Therminol FR-0 and Therminol FR-1). The FR series Is the only one that contains PCBs. All other Therminol heat trans
HQNS 0*f3AB8
-2-
fer fluid* (Thermlnol 55, 66, 77 and 88) are PCB-fre*.
4. Q, *Are you banning sale* of all Thermlnol fluids? A. No. Not all Thermlnol fluid* contain PCBs. Thermlnol PR series (i.e., FR-Lq Temp, PR-0 and FR-1) are the only ones containing PCBs. All other Thermlnol fluids (l.e., Thermlnol 55, 66, 77 and 88) are PCB-free.
5. ft. *What replacements are available from Monsanto for Thermlnol PR fluids?
A. The most likely Monsanto replacements are Thermlnol 55 or 66. We must advise you that none of Monsanto's remaining Thermlnol heat transfer fluid* are fire resistant. We suggest you work closely with your Insurance company in converting from Thermlnol* FR fluids so that you make a carefully considered Informed de cision. A* stated in our letter of December 15, 1971, Monsanto has a team of engineers available to be of assistance to you In making your decision. They may be contacted by telephone at (314) 694-2514 or by writing Dr. Cummlng Paton, Monsanto Company, P.0. Box 14617, St. Louis, Missouri 63178.
6. Q. *What other fire resistant heat transfer fluids are available from Monsanto?
A. Unfortunately we have none available and will not have one availa ble in the foreseeable future.
7. ft. *What other fire-resistant heat transfer fluids are available in the U.S.A. or Canada?
HONS 043489
-3-
A. The only fire resistant heat transfer media we know of are high pressure water and molten salts. Both of these systems have dis advantages which may rule them out as replacements for many existing Therminol PR systems.
8. ft. *Could X obtain PCB fluids outside the U.5.A. or Canada? A, PCBs are manufactured in Prance, West Germany, Italy and Japan. The decision on imports is yours to make. We would suggest, however, you consider such a course of action very carefully.
9. ft. Will Monsanto's ban on PCBs for sale in heat transfer systems apply world-wide?
A, Yea, as soon aB the decision can be implemented.
10. Q, Will a world-wide ban on Therminol PR sales go into effect immediately?
A. As promptly as it can be implemented.
11. ft. Have any of your competitors in PCB manufacture announced a similar
ban?
,
A. Not to our knowledge. However, we believe they are considering
restrictions on PCB sales. Bayer has already made an announcement
to this effect. Furthermore, certain European countries (e.g.,
Sweden) have taken action limiting the imports of PCBs, Other
countries could well follow suit,
IS, ft. *Why has Monsanto acted so precipitately on Therminol PR sales? A. We do not consider our action precipitous.
MONS 043490
.4.
13. Q. Why 18 Monsanto giving overseas customers longer to convert than Its U.S.A. and Canadian customers?
A. Implementing a decision of this kind on an international basis takes time.
14. Q. This latest policy on Therminol PR sales is not consistent with Monsanto's previous differentiation between "open" and "closed" PCB systems. Why is Monsanto changing its policy.
A, We are concerned about accidental leakage over which we have no control. Our policy has not changed.
15. Q. By banning Therminol FR sales, is Monsanto admitting that PCBs
are the toxic, dangerous chemicals that many scientists, ecologists
and writers have been suggesting for over two years?
A, The extent to which PCBs are toxic and dangerous is a relative
and complex matter. We believe this action and our previous
aotlons concerning PCBs have been reasonable and rational. We
believe we have acted as reasonably as any manufacturer could on
learning an increasing amount Of previously unknown information
about one of its products,
'
16. Q, The FDA recently stated (PDA Press Conference September 29, 1971) that the alarm over PCBs is greater than the facts Justify. PDA also rejected an outright ban on PCBs as some critics have called for. The PDA does not believe PCBsare an imminent hazard. In view of these FDA statements why has Monsanto acted so precipitately in apparent contradiction of FDA?
MONS 043491
-5-
A. We respect the opinion of PDA and are aware of it. The PDA, however, is not a corporation engaged In the manufacture and eele of products, and its opinion on this subject does not govern our decision. Again, we do not feel we have acted precipitously.
17. Q.* We do not dispute Monsanto's reason for Its decision on
Thermlnol PR fluids; our strong criticism of Monsanto con
cerns the lack of warning by Monsanto that they were going
to ban Thermlnol PR sales. Why were we given no warning.
A. Our previous communications should have alerted you to the
possibility of this decision on our part. We believe warnings
were given. We communicated our decision that no new heat
transfer systems would be sold Thermlnol PR. Sale of Thermlnol
PR to food-related applications was discontinued. In addition,
we have encouraged remaining customers to consider converting
to a non-Thermlnol PR fluid either before or at the time for
the next "make-up".
.
18. Q.* We believe it is impossible to convert all Thermlnol PR systems in the U.S.A. and Canada on the day your decision was received. That means heat transfer systems are still operating on PR fluid; why canjt we have another drum or two to last until such time as we can shut down our plant for conversion?
MOWS 043492
-6-
A. Monsanto believes that lee-way in the matter of filling Therminol FR orders after Its decision was communicated could lead to stock piling, which we believe la unwise under the present circumstanoes One of the key reasons for establishing a team of engineers at Monsanto Is to give advice and assistance to aid customers in arriving at Informed decisions on how to handle such situations. Assistance may be obtained by calling (314) 694-2514 at Monsanto's St. Louis headquarters.
19* ft. From recent PCB production figures given out by Monsanto, there are other applications besides heat transfer for PCBs, What action has Monsanto taken on PCBs in these other applications?
A, Simply enumerate the actions.
20. ft. We see that dielectric applications are by far the biggest user of PCBs. Shouldn't they be the ones to be shut down?
A. Based on the information available to us at this time we believe the risk of accidental escape from this use la slight. Our opinion on this may change. .
21, Q. I buy PCB for both dielectric and heat transfer uses. Why can I get one but not the other?
A. Because, in our opinion, the risk of accidental leakage and possi ble resulting contamination is less in one use than in the other.
HONS 0A3493
7-
22. ft.* How long will the engineering team be available to help on con versions?
A. We would hope most customers will have converted to non-PR fluids In the first four months of 1972. However, the engineer ing team supplements the ongoing team of Monsanto heat transfer fluid specialists. Monsanto's heat transfer fluid specialists are always available for reasonable periods to assist customers.
23. Q. Is there any possibility Monsanto's replacement heat transfer fluids may be discontinued as abruptly as Therminol FR?
A. We do not consider our decision abrupt. We have no present plans for discontinuing sales of replacement fluids, but our customers should anticipate that we will react responsibly to new Information about our products as we have with PCBs.
24. ft.* What evidence do you have that Therminol 55 and 66 will not give
similar problems to the ones that have arisen with Therminol FR?
A. We will send you bulletins on Therminol 55 or 66 which contain
relevant data on this subject. '
.
25. ft. What la the attitude of FDA and USDA on Therminol 55 and 66 as
replacements for Therminol FR?
A.
nows
-8-
26. Q. Your letter of December 15, 1971 states that refunds on returned Thertninol PR fluids will not be given after March 1, 1972. Does this mean I must convert to another fluid by then?
A. The decision on when and to what to convert is yours. The re fund policy applies only to unopened drums of Thermlnol FR
. you may be carrying as inventory in your warehouse,
27. Q, I Just filled my TheiminoIFR system in early 1971, The fluid is in excellent condition and could probably be reclaimed by Findett to be as good as new. Will you allow me credit if I return the drained fluid by March 1, 1972?
A. No.
28. ft. Are you banning TherminoiFR fluids because Monsanto admits liability in the Holly Farms lawsuit?
A. We admit no liability in the Holly Farms lawsuit. We point out that Holly Farms sued the user of PCB heat transfer fluid as well as Monsanto.
29. Q. 1 have read of the Holly Farms lawsuit against Monsanto. Have you other lawsuits pending on PCBs. If any, what are they about?
A. Questions concerning lawsuits should be directed to our Law Dept.
30. Q. Does Monsanto know of any cases where plant employees have suffered illness or harm because of PCBs and Thermlnol FR in particular?
A.
HONS 0<*1V5
-9-
31. Q. What should I tell my employees If they ask why we are switching from Thermlnol FR to a more hazardous fluid as far as fire safety is concerned?
A. The decision is yours. Perhaps you might Indicate that the material is no longer available.
32. q. Does Monsanto consider PCB to be a toxic and dangerous substance to humans and wildlife?
A. The question Is not susceptible of a simple yes or no answer. We can refer you to scientific information from which you may draw your own conclusions.
33. Q. Monsanto has made great play in its press statements on the safety aspects of PCBs with respect to their use in dielectrics. In heat transfer, we chose Thermlnol FR solely on the grounds of safety where we could protect the lives of our employees, neighboring citizens and valuable property. Why does Monsanto discriminate on safety? Why use safety as an excuse for continued PCB sales In one area and not in another?
A. Because, In our opinion, the risk of accidental leakage and possible resulting contamination is less In one use than In the other.
3A. . Was any pressure put on Monsanto by government agencies, environ mental groups or other quasl-offlclal groups to ban Thermlnol sales?
A. The decision was the Independent Internal decision of the top management of this company.
HONS 043496