Document 5LQ6E9pn7wqxm5ELQ82YKayxN

PCB White Paper By: Dan* S. My*ra St*nl*y D. Mytra J.J. K*lly PCB Infofmatlon C*nt*r S.D. Myiti, Inc. PURPOSE Whi w* have done in (hit report n to take the arguments, and the fact* behind those arguments, of ow oppooenu (thote who think PCB* are dan gerous) from their own literature and we have presented both their arguments and conclusions to show that their conclusions are not justified by the facts available to ihem. By this method of reasoning we hope to show that the conclusion of the environmentalists that PCB* must be banned, or even more tightly regulated in transformers and capaciutors than they are now, is based on facts that do nor support their conclusions. 8ACKQROUNO INFORMATION Production of Polychlorinated Biphenyls began in the U.S.A. in 1929 by Swann Chemical Com pany. In 1933, Monsanto bought out Swann Chemical and became the sole producer of PCBs for transformers and other uses. The reasons for this monopoly lay in the fact that the standards for purity as set down by Ocncral Electric Com pany -- the first ones to apply PCBs to electrical equipment -- were so high that no one else wanted to enter into the business. As a result of these standards, the PCBs produced In America under MonsantoCompany's trade name of Aro- clor^_ were the purest of any PCBs produced in the world. PCBs were manufactured primarily because of their excellent dielectric and heat transfer quali ties, not to mention their non-flammability Not only did their non-flammability capabilities make them suited for use in capacitors, but also made them ideal for use in areas where public safety was concerned, such as, m transformers inside t public buildings. ' This set of user, coupled with the unusual sta bility of the compound, have led to the calling of PCBs as the "wonder chemical of the century." They greatly aided America's industrial expan sion since the early I930's. It has been said ihai Russia's industrial successes could net have oc- 18 NATIONAl ENOINEta HONS 216418 A ugust, !982 l Material Category Purpose Conditions Asphalt Emulsionwith Fiber Waler repellancy and rein Fractunng of top felt plys. glass or Polyester Membrane forcement of aged asphalt underlying felts still sound BUR Lite Expectancy Limitations 3 to to years depending on product quality, installation techniques and a reflective coating Severely affected by trapped root moisture: requires smooth/prepared surface, should not be used it deck movement Is causing roof splits Reflective White and Aluminum Coatings Protect root agatnat U V ex posure; reduce interior tem peratures; extend serviceable coating/roof performance New BUR or new coating/ reinforcement systems re quiring additional protection; energy conservation t to 5 years depending upon Strictly preventive design product quality end cover should not be utilized to age rate solve roof deficiencies Proprietary Coatings Usually as preventive mainte nance protection; some prod ucts developed as weather ing seal and/or remedial capability Wide variety of conditions depending upon product formulation Varies widely; manufacturer's guaranteesuggested (Includ ing labor to replace coating if defective) Careful and thorough scrut iny of manufacturer's reputa tion, integrity, and proficiency advised prior to purchase Cold Process BUR (Felts and Factory Formulated Adhesive) Overlay existing roof that has aged beyond other cor rective techniques Sound deck and roof sub strate; not more than one roof system on deck; exist ing roof cannot be correc tively maintained S to 10 years depending on application techniques and specification quality Severe! y a ffected by trapped moisture: shou Id have insula tion underlayment; prefer ably mechanically fastened to substrate; deck weight load capacity must be considered Urethene Foem Systems 1 Single Ply Systems Lightwaight resurfacing of existing aged roofing sys tems; provide or enhance insulation capability and benefits Adequately sloped building requiring additional roof in sulation capability; light weight roof weatherproof ing system is necessary Overlay existing root thal has aged beyond other cor rective techniques: provide lightweight system without roof removal Sound deck and roof sub strate; minimal roof projec tions: existing root mat cannot be correctively maintained 2 to 10 years depending upon insulation deneity. cost ing quality, and method of installation (manufacturer's guarantee advised inchiding labor to replace system if detecitve) , Requires expert installation expertise, severely affected by moisture conditions dur ing application; system is totally dependent on surface coating product quality ( 1 to to years (manufacturer's guarantee advised including' labor to replace system if detective) UtLr root technology, first generation problems antici pated. usually requires ex pert installation knowledge; careful scrutiny of manufac turer's reputalion, integrity, and proficiency advised pc>' T" *c*"ee v h B"iw* j*r* o AM"? OAC^kMJAftO*s wsC MOMS 216*19 Auovrr, 1912 Material Category ghworpolpilir Purpose - bomMont Water repeltancy and rain- Fracturing of top felt ptys, forcement of aged asphalt underlying felts still sound BUR Ufa Expectancy Limitation* 3 to 10 years depending on product quality. Installation techniques and a reflective coating Severely affected by trapped root moisture; requires smooth/prepared surface; should not be used if deck movement is causing roof splits BaileeMrs WhWi and Protect roof against U V ex New BUR or new coating/ 1 to 5 years depending upon Strictly preventive design posure; reduce interior lem- reinforcement systems re product quality and cover should nol be utilized to quiring additional protection; age rate solve roof deficiencies coating/roof performance energy conservation i t Proprietary Casings Usurity aspreventive maintenanosprotection; somaprod uct* developed as weather ing seal and/or remedial capability Wide variety of conditions depending upon product formulation Varieswidely; manufacturer's guarantee suggestedflnetwdlag labor to replace coating H defective) Careful iny of mr tion, into advised ihornuoli scrut 1 <*fl? Cold Process BUB (Paris Overlay existing root that end Factory Penwetaled has aged beyond other cor Adhesive) rective techniques Urethane Post Lightweight resurfacing of existing aged roofing sys tems; provide or enhance insulation capability and benefits Sound dock and roof sub strate; not more than one roof system on deck; exist ing roof cannot bo correc tively maintained Adequately sloped building requiring additional roof in sulation capability; light weight roof weatherproof ing system to necessary 5 to 10 years i on application techniques specification quality 2 to 10 years depending uponinoutottondonate, cost ing quality, and matnod of installation (manufacturer's guarantee advised factoring labnr to replace system n Several morstui tion ur ably m to sub load i consid , T" o W Requires expert instanauu.. expertise; severely affected by moisture conditions dur ing application; system is totally dependent on surface costing product quality T Overlay extoting roof that Sound dock end roof sub 1 to 10 year* (manufacturer's New foot technology; first has egad beyond other cor strate. minimal roof projec guarantee advised including generation problems antici rective techniques; provide tions: existing roof mat cannot labor to replace system if pated. usually requires ex- Hghtweight system without be correctively maintained defective) peri installation knowledge; root removal careful scrutiny of menulac- turer's reputation, integrity, and proficiency advised -f HONS 216420 currcd had h not been for PCB*. What then, went wrong? In 1M6. Swedieh teitatitt was trying to deter mine the level or DDT to flab. He fowod tome un identified chemical ie Me mdlee. Tbit unknown chemical turned out to be PCBt, That PCBt had been found in the envirofml ihouW have oome u no turprtw tlnee they are to liable and they were uted in nich a multitude of product! (e.g, paintt. adhctivet, ceulklni compound!, plaitietten, inki, iubneanu, carbon!mi copy paper, aalanti, coating!, dwat control agent*. heat tramfer lyncmi. hydraulic tyttenu, etc.|. THI PRIMARY EVIDENCE The bl| blow to PCBe. however, canie two yean later in Japan. It >u raponad that PCBe, ej a contaminant, pot into tome rice oil. which was then told to the turroundlng population. Thia rice oil wu uted for eooklat purpoeee for a period of pproxiraeteiy 100 deyt. Up to IJOO people ware tdverwly effected from the lagwtion of tbit cooking oU contalaiai PCB. Tboec effected ate 710 ml. to 4.411ten of oil oomaiaiap 0.Jg of the contaminant, with the evtrape cotuurapUos beiap epprcndmately 2g.` Theee effeeu were erroneouily reported ee being caueed by the PCB. The rympiMM of thie `oil dieeeee" <"Yuho") he ve been detcribod at folowt: dermal dbordmi. Including iwcUlag of the ryeilde. acaeform ervp- tiont aad pigmentation of tbe aailt, game aad llpt aad an incraaied dbcharge from tba cym was obicrvad. The people abo complained of IMng* like headechet, indefinite ttomach ache, nemh- ate* or pain la the caremAiet. cotuldt, gad bronchttlt-Uke tymptom*. Oalat In the height aad weight of boyi "decreaeed ttgnlftonntly" after b- geeting tbit contaminated oU.* BabW* bom to women with Yuaho had abnormal tkia pigmenta tion aad tome anatomical aboormaiMai. How ever, "thaw wart not parmaaeM. aad poataatal body ltd nntil tppttfvd mmI la thate aad other Yueho dtOdrm."* (NOTE: AH of thate lymptom* wart eBagad to he earned by PCBt. The allegation! have proven to he hit*. But, on tbe hntii of "Yueho." the Coqprma of the U.S.A. patted legitlatloo to keguiam andBaa PCBe- TOBCA). Theee, then ware thrMaemm ewodnted with Yuiho -- Uioamae that would make the world warn to rid itteif of the "rite od eootamlaeat" that earned bB theee peoMame. (Thli iempeabdly true, iloce tbe roMta of the rooumlnioii oo humaai. were ptephliaB) ponioyed la a picture book). That rnmeminent that woe flm thooBbt to cauee the Yueho dteeaM woe ftnt diegmead to be Kaaachlor 400. e Japan*** PCB to the amount of up to WOO ppm. Thai beano the atovamaat that eventually u PCBt banned lo Japan, Sweden. Canada end tbe Ualtad Stetw. THC DEFENSE ` At U often the caw with Initial finding! aad the accompanying announcement*, not eh tbe fact* In thli eaw were ie at flret. Kaaechior 400 wet preecnt but It we* not tbe meet toxic (If It even it toxic it ell) chemical Involved. Polychlorinated Dibenzofuruu (PCDFi) t partial oxidation by product of PCBt, were rowed to be in concentra tion* of up to 500 time* that normally found in Japan*** PCB.' Nor only thii, but the tetrachloro- and pcmachloro- fraction!, which have through animal toxicity nudiee, bam determined to contain the more toxic leomcn, were found ia high concentration*.' PCDFi effect the thymut, ikin (acne), liver and hematopoietic lyitcm to e much greeter degree than PCBt, end are 1000 timte more potent ei encymelndueeri.' In addition to chit, PCDFi were chronically re-' tamed in the liven of Yueho victim*. Three Yutho patient* eventually died (two ia IPdP, oae la IP7J); thaw death* were not attributed to the Ingcition of the contaminated PCI*, la the tbiut* obtained at eutopty, PCDF* were found ia high concentration*. No PCDFi were found in the tlwuw of two control*, `'although PCB eonccmreUofti of about l-l .5 ppm were found in the adlpow tiwa* aad Hver fat (of the control*)."' The PCB/PCDF ratio In the rtc* oi was about 200. while the ratio of PCB/PCDF found lo the adlpow tiwuet at autopey were 2, J and II, e conliderabit difference. ` By the md of IF77, Ji daeeifled death! of Yueho petienu had bam recorded. Eleven death* were from otopiaunt which it 4.J death! more than would normally he expected." However, tbit 4.S could miity be aro or aot attributed to Yntbo. *inw tba data wer* aot ig*-edjutted.11 la fact, a booklet prepared by the Haaard Evalaetioo Syatam of the State of California, oot of the itrictett *tat*t wttk reepeet to environmental beam, die* * [FTP mdy (Urehe, *t el.) "theevt- dance it aot cooduetve that PCI* earned thaw PCE LAW it EASED ON "YUEHO" Now i* the tiaw to ia* what b prewnliy bring aid about tba ntevance of Yutho m the ttady of the tonkfcy of PCI* and thrir pnwlbli hmnm *ffacu. W* wfl begin tbb mardw with t gnot* from Jota P. Brown, Jr., PftD, htamger of the Uf* Sdene* Branch of O.E.'* Corporate Etamrch aad Development at be ecpWm the hrtieveaet of Butt* PCB* aad Yutho togathw. "...ken the PCDFi that were chronieaBy retained In the bvtre of the ehrooknUy-01 vtetimt. In them vic tim*, the average dot* of the PCB/PCO (Poly chlorinated Quatraphmyi*)/PCDP mixture tngmted wn 2.0*.. which b be* than the PCB body burdm being carried by many wenbagly eormal (U.S.) eapadtor workare today. Thee, k would appear that tba toak agent rwpneelbli for Yueho dleeaw wu* PCDF. not PCB."'* Dr. Etnnu Kimbrough, M.D. e Toxicolol at the Ceawr for Dteeaee Control ia Atlanta. Oeqegta, eke ha* bam on* of the government'* tter etama agaiaet PCBt wa* involved to the fol lowing dialogue la North Carobat court caw la 1FTP:" QneWlaa! But, Dr. Kimbrough, did you parUcipote ia the preparation! of report by a mb- Avovn.1911 MOMS 216421 committee of the Department of Health. Educa tion aad Welfare, July. 1976T Or. Klmhraogh: Yea. Qweadua; And let me ask you if I'll mad from that itudy and ask you if this it a fair statement. "The complexities aad unoenaintms associated 1th the moat recant reports of the Yusho laddent in Japan make It extremely difficult to quan tify powiblc human health effects resulting from exposure to KB* aiooe." In other words. Doc tor. isn't it true that (bate is a Kroon suspteson now that the other chemicals that pot iato that rice oil otbtr than PC is are the ibinfi that caused the problems? Dr. Ktahreaghi They eortaihly caused port of the problem. We don't know whether they caused all of the problem, but they are very tonic. Qamdsn: And by the tame token we don't know whether PChe caused any of the problems bareuse of the prceeooc of those other rhnntrail. I'm talking about sdeniiflc. Or. Kimbrough: Inlht Yusho inesdeat, no." A I MO report issued by the State of California kmearch Division contains many each sutomenu. One of them says that "H b thmefore con sidered highly probable that some of the causa of Yusho toxicity is due to the actions of PCDf (TUt some repon flonlly concludes this: "a ro> view of the available literature on PCI, PCDOe (Poiycfaiormated Dibenxo Dioxins), and PCDFa indicntm that enpoaure 10 these substaaom. even la ndcrogram quantities, cun lead to extremely serious human health effects."" What to the source of this cooeoltnsd reasoningT Their bibtiogiupby of 51 sourem la cooatkutad of IWe aeticks on PCI, all five sourem dal specifically with the Yusho ioddnai, aad 4< ankles deal with PCDDt and PCDFt. They admit that PCie have no proven record of human health problems, but because they "look sBks." PCDPh aad PCDDs, they group aJ three logathsr and can them bndltt (NOTE: li b tMe type of reasoning that has kd to the unreasoning and uareaionabk prmsart of the radical environmentalist that wil eventually cam oar ooaaeiy KOOBAM.OOO.OOO.OC -- or I50jg0JB for every man. woman and child In the eoamry ledayltt) A INI sepase prepared by the Hasnrd Evahsadoa Syessm of the Bmie ofCalifornia ttaim that "It b aas dear how mach the hmkh effects ob served la Yaaho ilnimt can be exlrepotaied to oncenational eipoourb for the foilouaag 1. The aewigi emonet of PC (Kaaoddee 400) Ihgmtad was mrlmiied to he 1 g--w aad the minimum, 0,5 grams (Kuraiauat el al-. IPTIk Thb b a higher doe* than has bean reported In most occupational mpoanrm. la addHian. the PCis were logeeted as sppcesd to inhaled or skin absorbed a* b the ease with ecrapatisnal expo*arm. 2. The contaminated oil contained "used" (oxidised) Knnachior 400. the exact chemlml composition of which is unknown. 5. Frying of foods aritb the riot oil could have produced further new compounds which may have altered the toxicity of the PCBs or the toxic ity of potiibk contaminants. 4. Yusho oil was shown to contain high con. castrations (2500 ppm) of 41benzolwins 5. Itsportsd eoneentration of PCBs In the oil may not have ben accurst* enough to permit a rigorous quantitative analysis sines the methods for L*| PCBs in foods war* not fully de veloped at the that." The National Institute for Occupational Safety A Health (NIOSH) puMbtad a criteria document oaPCBtia Iff?. They my that: The relevance of the Yaaho episode to occupe- pci ttpcNvi It conpfOflM btouw' (D the ail eras kgaeiedj and (Z) h Contained luge concentrations of Bhwnofersns compared with those In tbs PCBs 10 which workers senesally have bean exposed la their occupations, lu ralevanes b further rcmprnmlieil because the effects otasrvid from daily lagmiion of 1-IS mg of PCBs (1*5,1ST) were peculiar aad excessive com pared to ibose oboomed ia workers exposed by in. hakdon of PCBs 1-5 mg/M* (120. 125), ootwithnsndlag that the amounts absorbed may have Nrmnhskee, information obtained from the Yaaho episode to relevant to the study of PCB toxicology and orfnational exposure. The infor mation established that PCBs can be kuasmitied from mother to fetus, and, to tht milk, from mother to child. It also establishes that some PCB compounds are attminand from the body relattvsfy rapidly, aad that othan may require ycart for dimInattoe." After NIOSH cam* to thb conclusion ihai Yaaho could not be used to delermine PCB toxic ity, they turned around, and in the same docu ment, ntti that the "toxic effects from ingesiion of PCBs have haan wall documented in The authority for this uastmeat? Forty foot mans -- rnwry staple footnote referring to the early Japanme ttudtoe of the Yusho incident, whm nh of the affacu were muneuusly sttribmadtoPCBs. CPA - THC AOCNCY TASKED BY CONONKBB TO CONTROL PCBa FlaaBy. what has BPA said about YushoT Please aose the dates as you rand the coackmons PA tPTg -- Sukaaqusm investigations (Have shown that the "Yaaho Oil") tad boss more than half yyroiyead to PCQs, aad that thb PCB-PCQ mixture oomaiaed 0.2JW (2500 ppm) of PCDFi It won the PCDPs that wwe chroaieally retained ia ttattvsrs of chronkally*UI victims. The tease oils were i maslysed ia 1*7* PA l*T - Became of the relativeiy large expoeare of the Yacho viatlma to PCDFt It is in appropriate to use this data to make quantitative estimates to the TOXIC homed posed by PCBe to Comparethaee first taro matemeato with EPA'i 1*7* statement. CPA 1*7* - Knowledgei of PCB loxkiiy it 10 Natwmal Eftatxssa RONS 216422 bwcd primarily on <* Yuaho Japan incident In lMf (NOTE: Why has tbt EPA contradicted It' teir here, and ukt podtion contrary to U racognind scientific evahsationt of YixhoT) Ooo> not this la* itatcmett (when compared with EPA'i earlier miftiu aad tht statement by ill tht "luthorlila" that determined!) of PCt losicliy from Yutho i> sdcatirtcallr inap propriate) (ril ui that th* caw tfaiiut PChi, it "bawd primarily on no rridanct ai allV* TMt It what EPA hat laid, whether willingly or not. The evidence it here. Our rvlet regulating PChi an bawd on ihli fallscyl Thli ii whai the Congress mun know; thii ii what the public ihould know: ihai PChi are not a health problem to human kind! In I9T6-7T, Congress pawed the Toxic Subnancet Control Act (TOSCA). The only ipadAc chemical lined In thii law wai PChi -- baeart upon one wnator'i amendment to the original TSCA law became of whai happened In Japan io 1961 and 10 political preware brought about by publicity of the event. Thii low prohibited the tale, distribution or manufoctwre of PChi efter 1979. Mooeonto, the only U.S. manufoeturer, ended lu productloa of the chemical in 1977. After that time, PCht were to he coutroied. The EPA ended op with thii regulation Job, and mt down nilee watch, in pan, eatd that transformers with leu than 50 ppm PCh could be ooneldered e noa-PCh object. The radical envaronmewaHm. working through the Envlronmeaml Defease Fund (EOF) tuod EPA for aBowiag any ppm of PCh. (EDP vi. EPA DC Or No. 79-1500 Act 501990. October 50, 1990). The court ruled In revor or the EDP and laid that Congrew maa-dated a ban (0 ppm) on PChi In ttiaaformen and capacitors. EPA hot taM that transformer* and tapoetton were "doted lyitemi" bat the court riled hi feror of EDP. recogalriag that tnanformen and capacitors do sometimes leak or Fall. EEI (Edison Electric laetltate), ae a Mead of the court, told the conn that the rating lift the elec trical Industry of America two dioieaa; they oouid either operate illegally (which they would am do) or they would have to shat down ell eperabane ' Immediately. The court decided that tide might not be each e good Mm to k pave EPA II months, till October, I9C2 ip addrew tbmt two huetiiofui 1. PPM level of PCh to be ngelaisd; and 2. KulmofoparntiOPofTomhy mriosed" de vices conulaiag any Kb. Since Coogrem pamed T08CA, idesmfytag PChs at a priority pohutaat to be rtgulaied, the EPA mutt set oa tht mandate of Congrew. Therefore, the solution to this proMcm mam go bock to the source of the problem: Congreu. Congreu must be made aware of the growing body of literature that coenpieiety exonerates electrical grade PCh from the health aad environ mental probtemi h hat allegedly caukad. WHY ANIMAL STUDiCt AM USED The conienm of those who study PChs are in agreement that the Yutho event cannot, scientif ically. be the basic for condemnation of PChs. What. then, is the basil for the ban oa PCBiT A review of the bieratare alludes to a lack of cpMemtooflc evidence to tapport their poekJoe. (Note: They ere wihlng)y Igaoraal of over 15 tpidemioloflc ttudiuMl And the raatoa why they ft wlUtagly Ignoraat of thaw 15 erodim? he rnme they can not find any evidence -- anywhere to support tbt conclusion they have predetrr. mined to nakel That's right. If they can't And evidence to support theit coodustons -- tet's "create out own cvldeoce." Hence -- animal studies!) Therefore, the people fighting PCh turn to animal studies to build their cate." Due to tka superabundance of animal studiat, it would he repetitious aad hence boring to eke all those studis bare. We wil conceni ounalvm, there fore, with looking at the rendu of the more . repreeeatatlvt and widely eked stadias. ANIMAL DOSAGES la order to naderttaad the rmuks of tbmt aakaal tmu. a oomparartw kaoeriadps of doeapes is aeedad. Tbt NtOSH criteria dnrumeai due a 1973 paper praeeated before the EPA la a action al bearing oa PChs u smlmeriag that the "gener al U.S. population; has a deary make of PChi of between 10-20 ag/day.''** 1 aimtallitri of the ak, NIOSH ays, may add ap a another T/pg/day (lOOpf/a) a 50 Htera/mla. .. Tak ing maakaum Agara, an average person a the UA wil aka fat 27/pg/dny, a fa a 154 pound person, a approaimaiely .J9/|4/kg of body wdght/dey. Whichever Agurm an aaad, h stU works oa a he aheat 0,01 grama tauka/ycar. Now waapan this with the amounts fed theec IDllMbe Or. Keimte Kimbrough, the toaktdogin wide ly puoud by MrironaseaullMi coucarned about ada. la one eaptrimem a 1975, Dr. Kimbrough aad Dr. Linda asperimaied ea hALh/ci male nUce. The aria were fa Asodor 12)4 over eleven moatta. The averse PCh Make was 49.S mg/kg/day; the egtdvatam of ova 2.5 pounds tar aa sverapt parson, a 19,111 dmm what one. at the would be amaetad to eat. AdepnUbrnsh was idem!fled la the hvas of thme mice. "Tbeer Moot, according a ike taken, may a may not he psecuraaa of malignant Intone. lo the foUoerlng year. Dr. Klmbrongh fed Aro- da 1260 (0W Chlorine, by wright; Aroda 1242 would be 42W chtartae. by wdgbt) a 200 ran in their diet fa 21 oaahe. The amount con sumed was from 5-10 mg/kg/31 amahs. " This it 2040 dmm what an average person (154 pounds) would coneumc ia that same period. On 170 rau, devmed nodules wen found oa the liven. Twenty-six of tbeer were hepaacurdaocalc (com pared a owe a the oomroi group) aad the other 144 bad "Imrrmilder aodatm that were deinihad ns rbararserisrir of aeoptamSc aadaUe a synnaymtaBl). IppayMIt aodMm. The amben said that 'neoplastic nodules art pan of ike spue- tram of respnasf a bepatocardnopm aad mutt August. 1912 HONS 216423 be Included in the evaluation of tumoriacoei*....... Hence came the cry that PCBt might cause cancer (Note: that it, cancer of the liver), (tee page 10). Monsanto had previously con ducted teiu with Aroclor 1260. at well at with Aroctors 1242 and 1254 in which liver injury *ai produced, but no cancert were teen. They, there fore. did a reexamination "of the original liver tlidet from the Monianto ttudiet at well at addi tional liver tectiont from aH rati in the Monianto 2-year feeding ttudiet."" The tlidet were inde pendently examined by Prof. W. Richter of the Unfvcrtlty of Chicago, by Dr. D. Gordon of Induttrial hio-Tett Labi, and by Prof. Parvit Pour of the Eppiey Inttituie for Rctaerch in Cancer. Dr. Pour alto examined tectiont of liver from the rau in Dr. Kimbrough'* tiudy. No cardaomat were teen in Moommo'i rau, and Dr. Pour did not agree with Dr. Kimbrough`t diagnoela of liver cancer in her nit." So, at the very lean, thit tiudy of Dr. Klmbrough't that hat been died ae proof of the potential carcinogenicity of PCBr haa to be viewed wtth ecnout reecrvatiom. Another 1*74 wady done by Linder, Oalnee and Kimbrough involved feeding rau Aroclor 1254 at 5 ppm or Aroclor 1260 at 100 ppm level. The itudy covered e "two-generatloo period'* and oo effecu oa reproduction wore obeerved." Aaorher of the "Mg guru" of the environmen tal group* opposing PCS u*e it Dr. 1. R. Alien. Although he hnttlso done uadi** oa rtu, he and hit co-worker* are died sect often with reepect to their experimenu oa rheme monkey*, la thdr 197) cxpariaMnu, Arodor 1241 oe Aroclor 5440 wat fad to the moakeyi for 12 weeki. Bach ect of monkey* had accmt to 400g daily food (apply laced with NO ppm and 5000 ppm of PCI, retpnctivdy. This mmai that in n 2) week period, theta monkeyi received lOg and Itlg, rmpectively. it would taken U.S. reddeat 1,014 and 17,047 yean, rmpectively to coaeami thU much PCS. The reeulu foe both groupa will be put toaethw for ikli cue pan. The monkeyi loat, oa an aver age, benreea 19 and 2*m of thdr body weight, they lorn bad, had puffy facet, adamaiou* hpt. and twoBen iyaUd* with pumleut exudatet around the eym. At aacropey, mteadve alopecia, acaaferm todoat of the tkia, tuhouewenut edema and Ivu hypertrophy with fatty infUtration were evident." Another ttady by Alien oa 12 female rhmui monkeyi fad 26 ppm Arodor 1246 la an unepedfled did tamed up tome reproductive problem*. The lumen* weight of the moakeyi wat 5.4$. If theta moakeyi etc )0Qg of food a day, two-thirdt of the amount ued la the experiment oa 1*75 mookeyt, than eftm the two mnwh feeding dm*, they consumed about .4)7.3 mg, or I.M mg/kg/day. This it equivalent to >472 timet what 154 pound penoa would normally eat." Airin'* 1*74 etndy, done in conjunction with Deborah Ranotti, hat been died at an example of what will happen wtth tow doeet over e long time period. At Am glance, it would team to At that category, for they fed (he rhenu moakeyi 2.5 and 5-0 ppm Aroclor 1241. But then it turnt out that the total amount of PCBi fid the female monkeyi wet 110 mg and M4 mg rmpectively. Thit wat over a tlx month period. Taking 4 kg at the average weight (in the 19T4 experiment, the avwuge might mu 5.6 kg -- 6 kg wiR make the Humbert more cootarvalivt). Thit workt out to JO mg/kg/t mot. tome 426 to U2 timm the mount aa average U.S. redden! wooid contume. In fan. it would take a 154 pound women 21) yean to coniume (bat much (adjusted for weight) given a normal diet -- well peat a women * nor mal childbenring day* And that wat what thii tiudy tented for: Reproductive problem* Con ception! did occur, tomt abortion*. a Mill birth aad other vnrinut ptubrimt alee occurred The babrii that did tar-rive ihowad sign* of PCS toilehy after 2 moutht. (Acne, twoUea eyelid*, incrmiad tUa pigamtatlea)." The fodowiag eehmel ttudrii have been in cluded in thit paper not became their retulu or tan meUmdt thow much deviation from the preriouety cited ttudrii, bur baeaut* NIOSH in dude* them la that! criteria document end we wiah to give our oppoaenu' argument* enough opoeur* eo (hot they cannot criticize our potition by mytag we Mew down draw oun. Allen, 1*75, rhmut mowkeyi. Cave them tin gle 14 mg/kg dote ofthe above mixture. It would toko *a average U.S. rwideni I2C yean to contame thit mack PCS. "No overt dimeal effecu were teen la the mated moakeyi .,. Only the adipoie trim* aad adman had high PCI auayi, aad microecoptcaUy, except for t a*oderaie prokferetioe of bepatocytic SER, all tittuet were *ormal."" Sruckaar, 1*7), rate. Gave them a tingle doac by oral toubatioo of sMbm 2.5 g/kg or 6.0 g/kg Arodor 1242. A 2.5 g/kg doec for o 70 kg mtn (154 pouodt) it 4.6 ouocei, or 175 g. Both group* got tick aad the 6 g/kg group eventually died. "The coaditieut of the mu reedriag the lower doeogt gradually unproved after the Ant 24 boan add wo* normal at the ead of 72 boon-*"' heresy, Cobh end Cherry. 1*74, rail. Thit wat oa inhalerine itudy la which the rau luhtrid air that eoatahud 2.54 m^/Ucct PCS (2500 timm the allowable amauat for bumaat), for tto hour*. "During expoeure there were repeated tpitodet of bHaUag add mtrriru Sigat of irritaiion dieappuared after ceetatioa of the expoture. During the mhiiurut 14-dey obemvatlon period, food and waut coneumprion aad growth of the rau ware cowsklerad by (ha nutbon to have been itmilar to theae ofthe eomrori. No groat pathological ebaagm were teea when the rau were killed 14 day* tfter removal fromexpeeun.*1" Them aaxi three ttudiet caa be found In booklet puMiahed by tbe State of California. No mg/kg amouau ware givoa in the nporu, aad no rroadard for dotei mining that from PPM teem* to work adaqaatriy ia thoae rater where both ore known, to only PPM Aguret will be given. Any. wiy h it the reeuiu of thaee teeu that ore importeat. Conctuno* re appear to September orwe HONS 216424 National EHOiNUe