Document 5k8qY135Q4NY7k3D9qXnv6yY8

P. Park Pi. Keller E. Tucker PPARK JFQ JFQ Risebrough in a recent paper ''Nature", Vol. 220, Dec. l4, 1968, has attacked chlorinated biphenyls in three ways: (1) a pollutant - widely spread by air-water; therefore an un controllable pollutant. (2) a toxic substance - with no permissible allowable levels causing extinction of peregrine falcon by induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. O) a toxic substance endangering man himself; implying that the peregrine falcon is a leading indicator of things to come. As outlined in Science,Vol. l63>, Pg. 5^8, Environmental Defense Fund (EDF) is attempti"ng_t'o v.rrite new legal precedents in conservation lav; by hearings and court action. In the Wisconsin case, water quality standards are at issue. "A substance shall be regarded as a pollutant if its use results in public health problems or in acute or chromic (injury) to animal, plant or aquatic life". -Wisconsin is one of 7 states which now have federally approved water quality standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Water-.Quality Standards Branch, DDT would fit the definition of a pollutant upon a shewing that it is harmful to aquatic life. ` These people in EDF are saying we must not put stress on any living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim "enzyme inducer" activity is the real threat of DDT and PCB's and are using these arguments to prove that very small amounts of chlorinated hydrocarbons are "harmful". Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations. (a) Monsanto is preparing itself to identify trace ppb quantities of chlorinated biphenyls in water samples, in concentrated collected air samples, and in animal tissues.. We will know whether we have been falsely identified and accused or not. We will eventually know where any pollution is taking place and the extent of the pollution. 4 DSW 201134 STLCOPCB4059198 E. Wheeler -2- March 6, 1969 (b) We are not prepared to defend ourselves against the accusa tions made of enzyme and hormone activity, the isolation of enzymes or metabolic products, the indirect accusation of cancer, or the splitting of genes, when this accusation is ) made. Whether we can defend this route or not needs further ( discussion. ' ~ :: : ----- ------------- (c) Through the Industrial Bio-Test program we are to establish the long term allowable limits of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. We may be able to answer reproductive abi 1 ity in_ some animals. DDT has been under attack for some years because of its chlorine content, its persistent ability to be identified, and the wildlife problems attributed to it. We will still be under the same attack by the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where.does this leave us? Under identification and control of exposure - we will be able to identify and analyze residues as well or better than anyone in the world. VJe will probably find residues other than DDT and PCB's. VJe will probably wind up sharing the blame in the ppm to ppb con centration level. We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. VJe can work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users. But, vre can't easily control hydraulic fluid losses in small plants. It will be still more difficult to control other end uses such as cutting oils, adhesives, plastics and NCR paper. In these appli cations exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl is shown to have some long termi enzyme or hormone activity in the ppm range, the appli cations with consumer exposure would cause difficulty. ('Risebrough has taken known Aroclor samples and claims to have ievidence of enzyme and hormone change. Here there is no question of identifjcation. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which have exposure problems. Since Risebrough's paper in "Nature", Dec. 1968 has Just been published, it is timely, perhaps imperative, that this paper and its implications be discussed with certain customers. This is a rough one because it could mean loss of business on empty and false claims by Risebrough. VJell prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical and legal departments must take place now. The DSW 201135 STLCOPCB4059199 E. Wheeler -3- March 6, 1969 position of DDT manufacturers should be determined as a guide. We are being accused of the same things attributed to DDT. I have written this memo to clarify some of the issues. May I please have comments. Thanks, . ms Att. W. R. Richard DSW 201136 STLCOPCB4059200