Document 5LYg7Z9ryeNd2D5r7m3ygGJy0
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HONSANTO INDUSTRIAL CHEMICALS COMPANY, EUROPE FUNCTIONAL PROLUCT GROUPS
PROCESS AND PRODUCT TECHNOLOGY DEPARTMENT
P .J .A . Marsh* Brussels
J .N . Haggart, Brussels 6* Turvrer, Brussels T . F isch er, Dottikon*
DK> Cox* Brussels
R*A. Baxter* fhiabon
V . B. Papageorge* 6 t. Louis W. R* Richard* S t* Louis
P v J *** *'F " 8tT'4etrtw-- r " ' B .G . Tibbotts, St* Louis J* T . Garrett* St* Louis
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l) V is it tot Swiss Federal Dept* o f Public Health (Toxic Products)* Bern,
Date:
A p ril 17th, 1973
Present:
Dr. B. Stoll D r, (Miss) Piado J .N , Haggart
T . Fischer
R .A . Baxter
Dept, of Public Be<h
- Brussels - Fab .Suisse Dottikon - Ruabon
Objective: To review present position o f Swiss authorities on PCBs and Pentachlorophenol.
Introduction:
Previous contacts with the Swiss a u th o ritie s (see report by 8 . Turover Feb, 22nd, 1972) had been through Dr* Meyer who had now
been replaced be D r. S t o l l . D r. S t o ll had only recently taken up h is appointment and did not know the d e ta ile d background to some of the Swiss decision s r e la tin g to P^Bs. Miss Piado is the Swiss rep resen tative on the OBCD subcommittee dealing with unintended chesiicais in the environment. They were both concerned with the
operation o f the new Swiss law which requires that a l l chemicals used by the pub lic should be registered and categorised according
to th eir to x ic ity .
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Dr* S t o ll explained that the use of PCBs in Switzerland had been completely prohibited sln co Dec* 23rd 1071. They now realised th at th is r e s tr ic tio n was too sevore and a new d ra ft regulation pro posed
1* That ch lorin ated biphenyls containing not sore than 2 chlorine atoms would be permitted fo r any ap p lica tio n *
2 . PCBs containing 3 or more chlorin e atoms would continue to be prohibited except for
a) in apparatus used fo r research purposes
b) transformers and la rg e capacitors
m) small capacitors u n til December 1976 _
Miss Piado agreed th at these regu lation s d iffe r e d in some respects from the OfSCD proposals* These la te r had been agreed by the sub committee and were now to be put to the sa in committee. I f agreed they then required r a t if ic a t io n by the Council o f OBCD. At that t is e i t would become mandatory fo r member cou n tries to observe the OBCD regu lation s but i f th e ir own requirements were more severe t KciT thin would be a ccep ta b le I t seems lik e ly th at the Swiss proposal to ban sm all cap acitors a ft e r 1976 w ill therefore stand* The p o sitio n on the d ich loro biphenyls is not so c le a r c u t . The Swiss regard the as presenting no environmental hazard on the advice of Dr* Bosshardt and seem to have accepted th e ir fre e use on the basis o f industry rep resen tation s. OECD have made no d is tin c tio n so fa r between d iffe r e n t PCBs a n d 'it is not c le a r how the Swiss expect to be free to use dichloro diphenyls*
PCBs w ill continue to be placed in category 1 the most to x ic category even though i t is agreed that th e ir acute oral to x ic ity might have suggested a much lower category* The basis o f the c la s s i fic a tio n was claimed to include assessment of environmental and other long term hazards and benzene was quoted as another compound that was placed in a higher category than i t s scute t o x ic it y would suggest* However they regard the c la s s if ic a t io n of PCBs as being of l i t t l e sig n ific a n c e because o f the other re strictio n s which they are imposing. They regard th e ir current measures as being capable or change in the lig h t o f experience and fu tu re developments. They expect new products w ill be produced to replace the PCBs and apparently the Japanese OECD delegate sta tsd that they ftad rBoU r m a n l prnd>^,^fl fo r a l l applic a t io n s .
On the a p p lic a tio n o f the new law gen erally they are cle a rly over whelmed by the.paper work but w ill expect to work through the backlog making s u ita b le m odification s as they go along in con su ltation with industry*
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Pcntachlorophenol
Pentachlorophenol lu presently placed in category 3 which in In lin e with the U>5 Qa The Swiss authorities are considering what restrictio n s to place on the dioxin content but have not yot reached any decisions. They w ill be guided by Dr* Bosshardt* comments and expect to reach ew e preliminary conclusions by the sod o f 1973*
2) V is i t to : "" "
Present:
Dor Kldgenoaslschen Forsctungsanstalt (Plant Protection l aborat ory) % Vgdenswil
D r. R .F * Sosahardt Chef do la b .
Dr* Boeehardt had recently published an a r t ic le In the ZUricher Zeitung c a llin g fo r a very low le vel of tetrachlorodiboneodioxin 0*06 pjm in 2:4:5 T and other chlorophenol derivatives including pentachlorophenol He i s concerned with analyses and se ttin g of levels of p esticid e residues and became Involved in PCBs and now PCP largely
through analyses o f chlorinated bodies In Swiss cheese* Apparently in 196B FDA pointed out that Swiss cheese imported into the U.S.A* con tained unduly high le vels o f chlorinated hydrocarbons- Bosshardt eventually tracked th is down to the use of Dieldrin as an Insecticide' applied to cowsheds to prevent attack by wood boring insects* Through th is work he becane advisor to the Swiss Federal Dept, o f Public Health on possible hazards associated with PCBs and more la tte r ly dioxins. On his advice (he claims) the Swiss imposed their 1971 ban on PCBs. Prom a study o f the lite ra tu re he now fe e ls that the lower chlorinated FCIfe are biodegradable although he has done no experimental work himself* He was Interested in Monsanto work confirming the view and recognised the Importance of experimental demonstration of biodegradability under natural conditions e .g .p o n d experiments*
On dioxins he had proposed a low le vel o f 0*05 ppm fo r TCDD in 2 :4 :5T on the basis o f high to x icity and lik e ly persistence* He did not regard TCDD in penta as a real problem but was much more concerned about hexachlorodibenzodioxin. He feels that a level for hexaehloro should be Set which takes into account the relative to x icity and s t a b ili t y . He was not ready to propose a figu re at present because o f lack of data on s ta b ilit y and persistence but expects to put forward a figure shortly vhleh may bo modified la te r in the lig h t o f experience. I t seems likely th at th is maximum le vel w ill be a few parts per m illion* Dr* Bosshardt known the Dow group a t Horgen which i s a few miles away and may well be givin g then support in introducing th eir low dioxin pentachlorophenol *
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D r. Bosehardt v u not able to give complete d e ta ils of his a n a ly tic a l aothoda fo r dioxins but described in general terse that he separated out a neutral fra ctio n cleaned up an alumina column or TLC p la te and then ran Q .L .C . with confirm ation of peak id e n tity by mass spectrom etry Most o f his work had been conoemed with 2 i4 j 3T and he agreed that his claim to be able to detect 0.01 ppn TCDO in pentachloropbenol was o p t ia la t lc although 0.09 ppm was quite p o s s ib le .
Bosshardt i s s very approachable and engaging character who admits t h a t ha overstates h is case in order to achieve some a c tio n . Be probably has a good deal o f in flu en ce w ith the Bern a u th o ritie s but no g r e a t in te rn a tio n a l s ta n d in g . His la b o ra to rie s appear w ell equipped and his a n a ly tic a l work g en erally sound. I t w ill be worth while maintaining contact with him.
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