Document 2NB342VaLB6XXmKxkBZk6r3L7

CONFIDENTIAL Date: October 2, 1969 Subject: REPORT OF AROCLOR "AD HOC" COMMITTEE To: Howard S. Bergen, Jr. James E. Sprlngate Prom: M. N. Ferrar P. B. Hodges,Secretary E. V. John W. R. Richard E. P. Wheeler, Chairman HONS 036720 TOWOLDMON0048983 -4- 4 i RECOMMENDATIONS (Continued) 8. Assign one Individual from the division full-time for three to six months to coordinate division and Corporate Staff department efforts. 9. Establish special budgetary account to allow implementation of these recommendations and the continuation of the toxicological research effort now underway and continuing until June, 1971. . HONS 036725 TOWOLDMONOQ48988 BASIS FOR RECOMMENDATIONS 1. Notification of All Customers 24* 1969 the San Francisco Chronicle pubYrShed A "scare . story following an Interview with Dr, Robert Risebrough of the University of California, The latter had recently published in Nature the finding of polychlorinated biphenyls in fish* birdB and eggB in the California coastal areas. On March 3* 1969* the Functional Fluids group sent a letter to the 31 major Aroclor customers in the transformer and capacitor applications. The letter included a copy of the Chronicle story and a Mon santo statement concerning the situation. This was intended to announce to these customers that the polychlorinated biphenylB might be in trouble and implied that the customers Bhould make every effort to prevent lose of these materials to the environment. There has been subsequently some follow-up with at least General Electric and Westlnghouse. It has been recognized from the beginning that other functional fluid uses could lead to losses of the Aroclors to liquid waste streams from the customers1 plants. Losses could occur from spills* unusual leakage of large volumes and daily losses of smaller volumes. It has also been recognized that there could be vapor losses but it haB been felt that these were perhaps of less significance than the vapor losses in plasticizer applications. The concern for vapor losses rises from the published proposed theory that even minute quantities of vapors are eventually transferred to the water environment and accumulated therein; Another possible BOurce of air environmental con tamination 1b the eventual destruction of materials which have Aroclors in them. Of particular signifi cance might be the burning or partial incineration of waste or used products containing the Aroclors. HONS 036726 TOWOLDMONOQ48989 BASIS FOR HKCOMMENDATION (Continued) supporting efforts where the individual's Background or expertise would make it appropriate. For example in connection with the follow-up with the federal agencleB in Washington, Dr. Kelly would expect to be present for any contact with USFDA officials. Other members of the Medical Department would be made available for contacts with the pollution control agencies or those laboratories or univer sities where toxicity appears to be of interest or concern. Certainly Dr, Keller and Scott Tucker should accompany anyone making visits where the specific question of analytical techniques was to be discussed. This still leaves a number of man months to be de voted to the other laboratories or agencies which have up to this point not made their specific interest known. Equally if not more Important ie the effort which must be made relating to the contacts with custo mers. The committee does not believe that this can be handled by district marketing representatives without supplying such "local" individuals with a complete background of the problem. 9. Budgetary Considerations The committee recognises the restrictions placed on those currently involved by mandates to operate within normal or proposed reduced budgets. It should be clear, however, that the product groupB, the Division and the Corporation are faced with an extraordinary situation. There can not be too much emphasis given to the threat of curtailment or outright discontinuance of the manufacture and ales of this very profitable Beries of compounds. If the products, the Division and the Corporation are to be adequately protected, adequate funding is necessary, ------- HONS 036732 TOWOLDMONOQ48995