Document 44X6v6JVQqrVnrb8kYEQbg6yQ

A CASE STUDY* POLYCHLORINATED BIPHENYLS / by William Papageorga Monsanto Induatrlal Chemicals Co. St. Louis, Missouri January 1975 Written for Che study on Decision Making for Regulating Cheaicals in Che Environment, Environmental Studies Board, National Research Council, National Academy of Sciences,undertaken at Che requesc of the U.S. Environmental Protection Agency, Contract No. 68-01-2262. NAS-NAE - DEC 2 41975 LIBRARY 7 NPCOOOl627o 207956 CASE STUDY P O LY CH IO R IK A T m BIPIIFMYT.c Nature of Decision Monsanto Company management decided to terminate the sole of commercial mixtures of polychlorinated biphenyls for all applications except for use in closed systems as a dielectric fluid in capacitors and transformers for which no acceptable fire resistant alternative materials exist. This decision was made voluntarily and is not basod on any state / or fedoral legislation. Chronology During the period 1968-1969 several laboratories throughout the world were developing analytical methodology for identifying and quantifying polychlorinated biphenyls. This activity followed a report in which Doctors S. Jensen and G. Widmark of the University of Stockholm had claimed that unknown peaks observed in chromatogrphs developed dur ing pesticide analyses were due to the presence of poly chlorinated biphenyls. Reports from these laboratories alleged that polychlorinated biphenyls were present in the environment. 'The material' being discovered was reported to resemble commercial material containing highly chlorinated NPC00016271 i 207957 2 isomers. Also, about this same time, some investigators attributed the inability of some species of wild bird* to properly reproduce becauce of poor egg hall formation to the presence of polychlorinated biphenyls, a premise, in cidentally, that ha not been supported by subsequeat tudies. During this same period of time, Monsanto initiated studies to be carried out by an independent laboratory to attempt to determine the effect of polychlorinated biphenyls on test animals. When it became apparent that polychlorinated / biphenyls were, in fact, present in the environment and that there might be some substance to the allegations of harm to the environment, the first phase of the sales termination program was initiated, resulting in the discontinuance of ales of polychlorinated biphenyl to "open type" uses. "Open type" uses were defined aa those which offered minimum opportunity for control and could result in relatively easy entry into the environment. These applications included coating, sealants, waxes, plasticizers, pesticide extenders, adhesives and inks. Alternative fluids were developed and were promptly offered to users to replace the polychlorinated biphenyls in fire resistant industrial hydraulic fluids and in carbonless copy paper coating systems. ^ ..---'CT"*:v*rtj?"T'- NPC0001627 2 207958 -3- - During 1S7D incomplete reports from Japan indi cated that illness in humans had occurred, possibly because of the presence of polychlorinated biphenyls in cooking oil extracted from rice bran. It now appears that the illness might have resulted from a contaminant in the polychlorinated biphenyls, which were manufactured by a Japanese company. The Japanese reports, when interpreted and verified, raised the possibility, albeit a remote one under U. S. food pro cessing conditions, of direct contamination of human food by heat transfer fluid. Monsanto terminated sales of poly/ chlorinated biphenyls as heat transfer fluids for systems used in processing food for human consumption. As a result of Monsanto's sales termination pro gram, polychlorinated biphenyls were sold only as fire resistant fluids for use in closed systems. These were (a) dielectric fluids in capacitors and transformers and (b) heat transfer fluids in systems not used in human food processing. __ Monsanto's final act in its sales termination program was to ceaso all sales except for dielectric fluids in capacitors and transformers. In addition, as this program proceeded, steps, were taken to.replace the higher chlorinated * mixtures with the less persistent lower chlorinated mixtures. Aroclor 1240 and Aroclor 1254 were no longer z1^ ! i-.* Sfc SKGS5S35KE NPC00016273 207959 -4to the heat transfer applications. Aroclor 1260 was replaced by Aroclor 1254 in transformer fluids. Aroclor 1016 was developed to replace Aroclor 1242 as the preferred capacitor fluid. Objectives The objectives of Monsanto Company's management in arriving at the polychlorinated biphenyl marketing policy were and continue to be as follows: 1. Minimize the potential for the entry of poly-/ chlorinated biphenyls into the environment. 2. Eliminate the potential for the entry of poly chlorinated biphenyls into human food. 3. Retain those applications of polychlorinated bi phenyls which involve closed systems offering opportunity for control and in which the fire resistant end dielectric properties of polychlori nated biphenyls are necessary. 4. Avoid major disruptions in commerce and industry resulting in unwarranted adverse consequences to society in general, ~ i li NPC00016274 207960 -5 Informa tion E^rly reports available to Monsanto Company re peatedly referred to the detection in environmental samples of the presence of the higher chlorinated polychlorinated biphenyl mixtures. The absence of the lower chlorinated mixtures, which were used in greater quantities, led to some early misunderstandings relating to the polychlorinated biphenyl types and their applications which were the possible sources of entry into the environment. Also, early reports of effects on wildlife were speculative in relating presence of polychlorinated biphenyls to noted harm? e.g., soft egg shells, dead sea birds and baby seals. Subsequent analyses of the data have not supported the early conclusions. The only observable effects to wild life, fish and birds, have resulted from research studies conducted at exposure levels not found in the environment. The only exception reported was the sensitivity of juvenile shrimp to extremely low concentrations of polychlorinated biphenyls. From all available information the following im pressions were derived: 1. Polychlorinated biphenyls of higher chlorine con I i tent were present in the environment. NPC00016275 -62. No known harm to wildlife has been conclusively documentedt but the potential for harm at high concentrations of polychlorinated biphenyls did exist. 3. The food chain could possibly be adversely affected by the presence of polychlorinated biphenyls based on the allegations relating to the Japanese inci dent. % Information on what the unavailability of poly chlorinated biphenyls has cost the ultimate user is not available. ..Conversion costs to alternate materials has in f some cases been considerable; a.g., heat exchange applica tions have required extensive equipment modifications to per mit use of flammable alternate fluids as well as the installa tion of fire detection and control equipment. Gome appli cations, although small in volume, still lack a satisfactory alternative material; e.g., immersion fluid for optical microscopy, ingredient in investment casting wax formula tions and component in military systems. The decision to restrict the sales of polychlori nated biphenyls ha3 resulted in a decrease in the amount of 1 *" :'* * ** -*** " * " -`f^e '* r material manufactured by Monsanto Company by approximately NPC00016276 207962 * -7- 50 per cent. One Monsanto production unit has been dis mantled and about 75 jobs (production, maintenance, admin istrative, engineering, shipping) have been eliminated. The cost of controlling effluent losses at the remaining produc tion unit, installation of facilities to produce a less persistent mixture for capacitor application and the in stallation of an incinerator to destroy scrap polychlori nated biphenyls has exceeded $2,000,000.00. The cost of controlling effluent losses at.the capacitor and transformer / plants using polychlorinated biphenyls is not available. One of the key considerations in arriving at the decision to continue to supply polychlorinated biphenyls as dielectric fluids in capacitors and transformers was the fact that in these applications the fluids are hermetically sealed in metal containers permitting a high degree of control of escape into the environment. Another major consideration was the important role these capacitors and transformers have in the efficient generation, transmission and distribu tion of power with reduced risk of fire and explosion and in compliance with specific laws, codes and insurance restric tions mandating fire resistant liquid content. 'TV NPC00016277 I 207963 8 I m p l m e n t a tior, Implementation of the restricted sales policy did create some localised hardships for the users of polychlori nated biphenyls. The costs involved in developing alterna tive materials or in sacrificing performance in their appli cations would be impossible to quantify. There have been reports of fires in heat transfer systems which wore converted to alternative flammable fluids. The number of fires and extent of damage is unknown. Te risk of fires still exists and is exemplified dramatically by the potential hazards that are associated with installa tions such as off-shore gas and oil producing platforms. During 1974 investigators with the EPA laboratory in Duluth, Minnesota, reported that the concentrations of polychlorinated biphenyls in the Milwaukee River are decreas ing. Also in 1974 studies by Woods Hole Institute of Ocean ography personnel indicate that the amount of polychlorinated biphenyls in the Atlantic Ocean is decreasing. Observations, Comments. Recommendations The lack of reliable data relating to the fate and effect of the many isomers of chlorinated biphenyl in the environment continually frustrated the decision making process. NPC00016278 207964  **>'1 * Unproven d a i m s of t o t d nondcgradability, carcinogenicity, teratogenicity, mutagenicity and extremely high toxicity created emotional unwarranted concerns. The availability of more information could perhaps have helped define which commercial mixture and which appli cations were undesirable. Lacking this data, the termina tion of sales was made on a broad rather nondiscriminatory basis. For example, it can be seriously challenged whether the use of polychlorinated biphenyls in immersion optical microscopy results in environmental problems. Also, the use of these materials in selected heat transfer systems, properly maintained and operated, could in all probability be justified based on the highly desirable fire resistant property of the fluids. flPC000l6279 aar: ' 207965