Document 6RGa8EBKvaRrj6YO1DRxZ7LB6

FIFRA Docket No. 415, et al. NO. DATE THE DOW CHEMICAL COMPANY EXHIBITS - 2 DESCRIPTION STATUS 1019 1020 1021 1022 1023 1024 1025 1026 1027 1028 1029 1030 1031 1032 1033 1034 1035 1036 TCDD 3-Generation Reproduction Study, Murray, et al., 1978 %21-Day Postnatal Survival In Frequency of Hydronephrosis in Wistar Rats 1,2,3 Hertiable Hydronephrosis ina Mutant Strain of Brown Norway Ratsl>2,3,4.' 11 by Bennett J. Cohen, R.W. DeBruin, and W. J. Kort Proceedings of the Society for Experimental Biology and Medicine "Spontaneous Hydronephrosis in the Rat, by Alvin L. Sellers, et al. Investigative Urology "Congential Renal Strucutral Alterations in a Mutant Strain of Rats, by Emilio A. Machado and Bismarck B. Lozzio " Laboratory Animal Care "Spontaneous Pathologic Findings in Long-Evans Rats, by J.M. Kihlstrum and G. R. Clements " Transcript of Proceedings, in the Matter of FIFRA Scientific Advisory Panel Twenty-Sixth Meeting, September 20, 1979 "' Statistics with Applications to the Biological and Health Sciences by Richard D. Remington and M. Anthony Schork " "Letters" (Choice of the Number of Sampling Units in Teratology") (Statistical Analysis and Choice of Sample Units) " Selection of the Experimental Unit in Teratology Studies, Joseph K. Haseman and Michael D. Hogan 11 Selction of Appropriate Experimental Units in Teratology " The Litter Effect as a Variable in Teratologic Studies of the Albino Rat " Selection of the Valid Number of Sampling Units' and a Consideration of their Combination in Toxicological Studies Involving Reproduction Teratogenesis or Carcinogenesis, C.S. Weil " Ltr dtd March 28, 80 to B.A. Schweitz by J.A. John, Toxicology Research Laboratory, the Dow Chemical U.S.A. " Dose Level of TCDD EX 85 Bionetics 1968 " Dose of TCDD EX 61 Collins and Williams (1971) The Reproductive Endocrine System of Nonhuman Primates -- A Model for * Prediction of Toxicity, by William C. Hobson, Gene B. Fuller, and Frederic Coulston " Laboratory Studies on the Immune Effects of Ha'logenated Aromatics, Michael " I. Luster, Robert E. Faith and George Clark FIFRA Docket No. 415, et al. a THE DOW CHEMICAL COMPANY EXHIBITS - 3 NO. DATE DESCRIPTION 1037 Investigations ofn the Effects of 2,3,7,8-Tetrachlorodibenzo-pdioxin (TCDD) on Parameters of Various Immune Functions, by Robert E. Faith and Michael I. Luster 1038 4-16-80 Memorandum to Dioxin Meeting Members in re 2,4,5-T/Dioxins: Analytical Collaborators Meetin June 15, 1976 1039 Laboratory Report 1040 Laboratory Report 1041 Laboratory Report 1042 Memorandum dtd August 1, 1975 to Drr Ralph Ross, EPA Criteria & Evaluation Division from Larry J. Anderson, Accident Invstigation Officer Pesticides Branch 1043 Liver Samples Tables 1044 Liver Samples Table (Larger copy of page #017941) 1045 Liver Samples Table (Larger copy of page #107945) STATUS In 1046 4-17-80 Principles for Evaluating Chemicals in the Environment 1047 " Memorandum to Participants of Dioxin Meeting dated Dec. 13, 1973, from Criteria and Evaluation Division of EPA 1048 1049 1050 1051 Report of the Advisory Committee on 2,4,5-T to The Administrator of the Environmental Protection Agency Disappearance of TCDD From Grass Following Field Treatment With Esteron 245 Herbicide Tables - Residues of 2,4,5-T and TCDD found in grass samples collected shortly after treatment with ESTERON 245 Herbicide (3 gal/A equivalent to 12 lb. 2,4,5-T per acre). Bioaccumulation of 2,3,7,8-Tetrachlorodibenzo-para- Dioxin 1052 IG(7) Residues: Animal Products 1053 4-18-80 WATER (Table) In 1054 " National Monitoring Program for the Assessment of Pesticide Residues In Water - H. R. Feltz, William T. Sayers, and H. P. Nicholson 1055 " Summary of Water Residue Studies Reported by Thomas Dixon (Table) 1056 " (Corrected) Summary of Storet Water Sampling for 2,4,5-T and Silvex 1057 Letter to Federal Reg, Section dtd 9/15/78 from ITT Roger Tollefson II (P~0 t d 6 NO. DATE 1058 4-22-80 1059 1060 1061 1062 FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION Unidentified High Molecur Weight Chlorinated Compounds In Vietnamese Fish and Interference With The Analysis of TCDD by Robert W. Baughman STATUS In Letter to Mr. John R. McGuire, USDA dated October 19, 1977 from Barbara Blum, Acting EPA Administrator " USAF OEHL Technical Report - The Toxicology, Environmental Fate and Human Risk of Herbicide Orange and Its Associated Dioxin " Memorandum from Dr. Robert Baughman, et al. Harvard University Department of Biochemistry and Molecular Biology dated March 1, 1977 in re Human Milk Monitoring: Preliminary Results For Twenty-five Samples " 1063 ( ' 164 1065 1066 1067 1068 4-23-80 1069 1070 1071 , T72 Report of the Panel Convened to Review the Results of EPASponsored Studies to Determine Tetrachlorodibenzodioxins (TCDD) in Human Milk Samples Letter to Mr. Richard L. McConnell, Kirkland & Ellis dated April 2, 1980 from Robert S. Murphy, HEW Air Pollution from Pesticides and Agricultural Processes by Robert E. Lee, Jr., Ph.D. Air Monitoring System Laboratory Residue Findings dated July 13,1972 Letter to Ms. Sandra C. Strassman-Sundy dated February 12, 1980 from Herbert L. Hetzler, The University of Iowa Memorandum to Tom Dixon dated Dec. 20, 1979 from Aubry E. Dupy Pesticides Monitoring Laborarory, NSA/NST1 - My thoughts of the Future Direction of the Dioxin Program by Aubry- Dupuy' Jr., Ph.D. and Mr. Tom Holloway, Dioxin Project Manager Note-to Michael Dellarco, EPA dated September 10, 1979 from Aubry Dupuy, Jr., Ph.D. Memorandum to Dupuy, Gross & Harless dated Sept. 4, 1979 from Tom Hollaway, in re to Summary of the August 3, 1979 Work Session at the Pesticide Monitoring Laboratory, Bay St. Louis, Mississippi Tab!es Z lO l FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1073 4-23-80 1074 1075 " " 1076 1077 " " DESCRIPTION STATUS Memo to Tom Hollaway dated July 20, 1979 from Robert Harless in re Results of Capillary Col urns GC7HRMS Analyses Performed On Extracts of Water, Sediment, Still Bottoms, and Fly Ash for 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) Residues In Letter to Mike Dellarrco dated January 24, 1980 from Michael L. Gross " Memo to Michael Dellarco dated Sept. 6, 1979 from Aubry E. Dupy, Jr., Ph.D. in re Decoding of Sample Extracts Shipped to RTP and University of Nebraska for TCDD Analysis on 9/5/79 Letter to Dr. Michael Gross, U. of Nebraska dated Sept. 5, 1979 from Aubry E. Dupuy, Jr., Ph.D. Letter to Ms. Pat Ott dated Dec. 6, 1977 from Michael L. Gross U. of Nebraska-Lincoln 1078 4-24-80 (. r 1079 1080 V 1081 1082 1083 1084 1085 1086 { Memorandum to Dave Redford USEPA, SAD from Robert Harless dated March 19, 1980 in re Dioxin Monitoring Program Comparison of Criteria For TCDD Detection Memorandum to Mr. Richard L. Reising from Dr. Edward 0. Oswald dated May 9, 1978 in re Analysis of Fortified Human Milk Samples at the Sub Part Per Trillion Levels DIOXIN Toxicological and Chemical Aspects The Trace Chemistries of Fire- A Sorce of Clorinated Dioxins Handwritten Memo to Dr. Oswald from Robert Harless dated 2-26-79 " Memorandum to Mike Dellarco from Robert Harless dated August 23, 1979 in re Results of Capillary Column GC7HRMS Analyses Performed On Extracts of Human Milk, Water, and Sediment for 2,3,7,8-TCDD Residues Memorandum to Ms. Carolyn Offutt from Robert Harless dated April 24, 1979 in re Results of CApillary Column GC/HRMs Analyses Performed on Extracts of Human Milk for 2,3,7,8tetrachlorodibenzo-p-dioxin TCDD Residues Memorandum to Ms. Carolyn K. Offutt from Edward 0. Oswald, Ph.D. dated November 8, 1978 in re Results of GC/MS Analyses Performed on Extracts of Human Mother's Milk for Parts Per Trillion (PPT) Levels of 2,3,7,8-Tetrachlorodibenzo-paradoxin (TCDD) c2mo $ NO. 1087 1088 DATE 4-24-80 4-25-80 1089 1090 1091 1092 II II II II 1093 II -r 4 1095 1096 1097 11 II II II 1098 1099 1100 1101 1102 II II II II II FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Map In Analytical Methodology for 2,3,7,8-Tetrachlorodibenzo-p-Dioxin and Its Application By the U.S. Environmental Protection Agency To Human and Environmental Monitoring II Letter to Dr. Aubry Dupy dated May 2, 1978 from Richard L. Reising II Memorandum to Dr. Edward 0. Oswald from Mr. Richard L. Reising dated May 22,1978 II Oregon Water and Sediment Study Preliminary Results II Memo to Mr. J.B. Homolya from Robert Harless dated March 28, 1980 in re Preliminary Report for the Quanitifications of Tetrachlorodibehzo-p-dioxin Residues in Extracts of Samples Collected From a Minicipal Incinerator II Handwritten Memo dated 11-21-78 to Dr. Oswald from Robert Harless in re GC/MS Analyses of MTF Human Milk Extracts from TCDD Residues ACB-75 II Letter to Russell E. Train dated March 30, 1976 from Thomas 0. Tiernan, Wright State University II Letter to Ms. Carolyn Offutt dated March 23, 1979 from Thomas 0. Tirenan, Ph.D. transmitting copies of a quarterly report II Ltr to Ms. Carolyn Offutt dated April 30, 1979 from Thomas 0. Tiernan II transmitting Table Results of Analyses of EPA Beef Fat Sample Extracts Ltr to Ms. Carolyn Offutt dated May 8, 1979 from Thomas 0. Tiernan in re Results of Analyses of EPA Beef Fat and Human Milk Sample Extracts for Tetrachlorodibenzo-p-Dioxin By Wright State University Memorandum dated March 27, 1979 to Dr. T. 0. Tiernan, from Dr, M,L, Taylor in re Telecon with Ms. Carolyn Offutt II II Letter to Mr. Michael Dellarco dated February 22, 1989 from Thomas 0. Tiernan, Ph.D. Ltr to Mr. David Watkins, dated Feb. 5, 1980 from Thomas 0. Tiernan n h Identification of Polychlorinated Dibenzo-p-Dioxin Isomers Found In Fly Ash Chlorodibenzo-p-Dioxin and Chlorodibenzofurans are Trace Components of Fly Ash and Flue Gas of Some Municipal Incinerators in the Netherlands h 3 -0 1 0 3 NO. DATE 1103 4-25-80 1104 II 1105 II 1106 II 1107 II 1108 II 1109 4-30-80 1110 II u n II r ,12 II 1113 5-1-80 1114 II 1115 5-6-80 1116 II 1117 5-7-80 1118 II 1119 II 20 II THE DOW CHEMICAL COMPANY EXHIBITS FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation DESCRIPTION STATUS Results of Beef Fat (PHASE I) Positives Reported by Tiernan Laboratory Report # 331365 In II Laboratory Report # 331381 II Map of Southern Missouri II Memorandum to Edwin L. Johnson dated Sept. 5, 1979 in re Region 10 Request for TCDD Analysis of Oregon and Washington Samples of Elk and Deer Fat II Theoretical Calculation of Formulas Indistinguishable from TCDD (m/e 322) at 10,000 Resolving Power Note to Ed (Preliminary Data - Not for Public Release) 3-26-79 II II The Dioxin Issue (The Pendulum and the Toxic Cloud) Memo dtd June 13, 79 to Chief, HEB, Dr. Jack Griffith from FSC - Iowa Center Subject: Soil Samples Freedlund Farm, w/attachments II II Ltr dtd Oct 2, 79 to Mr. Tom Holloway, Mr. Mike Delarrco, SPR from Michael L. Gross II Episode Summary for Reports Involving 2,4,5-T II Pesticide Episode Report Dioxin Implementation Plan Monitoring Programs II II Letters Submitted to EPA in Response to 2,4,5-T RPAR: Mo. Ill Effects from Registered Uses II Letter to Mr. Paul Painter, Field Investigator, EPA dated Dec. 4, 1979 in re Damage claims allegedly resulting from application of 2,4-D and 2,4,5-T on the Trenckmann property near the County Line Dickerson and Houston Counties in Tennessee from L. B. Davis, Davis-Frazier Agri-Consults, Inc. II Letter dated Sept. 14, 1978 to Mr. Frank Davido in re Herbicide spraying in Houston County, Tennessee from Robert N. James, Houston County Department of Public Health II Memorandum dtd Sept. 5, 1978 to Chief of Human Effects Monitoring Branch " EPA from Pesticide Incident Response Officer in re Phenoxy Herbicide Spraying Near Nashville, Tennessee Follow-up Investigation - Potential Health Effects of 2,4,-D and 2,4,5 -T " Aerial Applications in Tennessee FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation m THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE DESCRIPTION STATUS 1121 5-7-80 1122 5-8-80 1123 " 1124 5-9-80 Laws and Regulations Governing Pest Control Operators and Applicators of Restricted Use Pesticides - Tennessee Department of Agriculture Division of Plant Industries Handwritten notes in re Field study Complaint - No. Civ.-78-47 William Alan Pumphrey, Elizabeth Young Pumphrey and W. A. Pumphrey vs. Richard Black, Thompson Hayward, Arkansas Kraft Corporation and Omnielight Helicopter, Inc., In the Circut Cort of Perry County, Arkansas Guidelines on Analytical Methodology for Pesticide Residue Monitoring In 1125 1126 1127 I ; 128 1129 5-12-80 The Biologic and Economic Assessment of 2,4,5-T - A Report of the USDA States-EPA 2,4,5-T RPAR Assessment Team Handwritten document dated 7/11/79, 8 pages Code of Federal Regulation 40 - Protection of Environment Part 100 to 399 The Responses of Tomato Plants To Vapors of 2,4,-D and or 2,4,5-T Formulations at Normal and Higher Temperatures Toxicity of 45 Organic Herbicides to Cattle, Sheep, and Chickens 11 1130 5-14-80 1131 1132 1133 1134 1135 1136 1137 .. (' Location Map: Coos Bay District Showing approximate location of streams monitored during the FY 1977 BLM Herbicide Spraying Program Review of BLM Herbicide Stream Monitoring Study A Report of Herbicide Usage and Related Procedures on State Owned Forest Lands - August 1, 1978 wi thdrawn Letter to Ms. Patton dtd Nov. 19, 1979 from Office of State Forester Salem, Oregon signed by Carl W. Smith Toxicity Summary Sheet - Static Toxicity Tests The Science of 2,4,5-T and Associated Phenoxy Herbicides Toxixology of Phenoxy Herbicides The Science of 2,4,5-T and Associated Phenoxy Herbicides Physiological Effects of Phenoxy Herbicides in Higher Plants II ^-O L O S V % ( ______________ NO. DATE 1138 5-14-80 1139 II 1139a 1140 II 1141 1142 1143 1144 1145 5-16-80 1146 5-20-80 1146a II 1147 5-20-80 1148 1149 1150 1151 1152 II II II II II FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS The Science of 2,4,5-T and Associated Phenoxy Herbicides Residues and Fate of Phenoxy Herbicides in the Environment In Determination of Vapor Pressures of Some Phenoxyacetic Herbicides II by Gas-Liquid Chromatography by David J. Jensen and E.D. Schall Purdue University Ltr to Mr. John Zackrison Report on Investigation of dtd May 15, 1980 in re Corrections in Possible Herbicide Damage For Norma equationsII McMillin of Rose Lodge, Oregon Memo to Bill Kosesan dated Sept. 22, 1977 from Tom Harrison Department of Agriculture, State of Oregon Memorandum to Ed Schroeder & Art Goodman dated March 2, 1977 from Janet McLennan in re Domestic Water Supply for Homer and Norma McMillan Interoffice Memorandum to Art Goodman dated March 10, 1977 from James Kirk, Oregon Health Div. in re Protection of McMillin's domestic water supply against herbicide contamination Summons No. 31866 In the Circuit Court of the State of Oregon to Evergreen Helicopters, Inc. in re Gary Green and G'isela Green vs. Evergreen Helicopters, Inc. and Oregon Corporation Map (Alsea Quadrangle Oregon) Map Map Civil No. 73-302- In The United States District Court For The District of Oregon- Amended Complaint in Jean Anderson, Ph.D., and Ugo Pezzi vs. Phil Wickham, Dale Robertson, Theodore Schlapfer, and Earl Butz Civil No. 73-302-In The District Court of The United States For The District of Oregon - Depostion of Ugo Pezzi Letter to Thedore A. Schlapfer dated Dec. 5, 1972 from Ugo Pezzi USDA Forest Service Environmental Statement Calendar Year 1973 Zone Vegetation Management Project Using Selective Herbicices Letter to Theodore A. Schlapfer dated March 22, 1973 from Ugo Pezzi II 11 II 11 II II II Siskiyou, Siuslaw, and Umpqua National Forests - Calendar Year 1973 Pacific Nrothwest Region U.S.D.A Forest Service- VEGETATION MANAGEMENT WITH HERBICIDES II lO lQ 'fe * NO. 1153 DATE 5-21-80 1154 1155 1156 1157 1158 5-22-80 n ^" 1160 1161 1162 1163 1164 1165 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Letter to Mr. Costle,EPA Administrator dated May 3, 1978 signed by F. Farrell Higbee Executive Director National Agricultural Aviation Association In Exploratory Analyses of Data Contained In and Collected for the Draft Report "Investigation of Six-year Spontaneous Abortion Rates In Three Oregon Areas in Relation to 2,4,5-T Spray Areas" " Forest Spray - Miscarriage Investigation, Alsea, Oregon: Questionnaire " Evaluation and Study Plan Memorandum to Field Studies Coordinator from Health Statistician in re Mini Survey of Licensed Physicians Practicing in Alsea Study and Control Areas dated 8-27-79 (handwritten) " Emergency Action To Stop Spraying of Herbicides 2,4,5-T and Silvex Press Conference Statement - by EPA Deputy Administrator Barbara Blum Thursday, March 1, 1979, Wash.,D.C. USEPA Press Conference by Barbara Blum, Deputy Administrator Barbara Blum - Also Responding: Steven Jellinek, Ed Johnson, Charles Duncan, Marlin Fitzwater - 1:08 p.m. Thursday March 1, 1980 (transcript) " A Scientific Critique of the EPA Alsea II Study and Report with the " November 16, 1979 Supplement, dated October 25, 1979- Oregon State Univer sity- Environmental Health Sciences Center (Pamphlet filed in Expando) Plot of Monthly Spontaneous Abortion Index for the Study and Control Areas " Oregon, 1972 - 1977 Plot of Monthly Spontaneous Abortion Index for the Study and Control Areas " Oregon, 1972 - 1977 Plot of Monthly Spontaneous Abortion Index for the Study and Control Areas " Oregon, 1972 - 1977 (With Control Data Shifted 6 Months) Exploratory Analyses of Data Contained In and Collected for the Draft Report "Investigation of Six-year Spontaneous Abortion Rates in Three Oregon Areas In Relation to 2,4,5-T Spray Areas" " New Zealand - An Evaluation of the "Preliminary Report of Assessment of a Field Investigation of Six-year Spontaneous Abortion Rates In Three Oregon Areas In Relation To Forest 2,4,5-T Spray Practices'.1. Dept, of Health, Wellington, New Zealand - May, 1979 Press Releases " An Evaluation of the Statistical Methods Used In EPA's "Report of Assessment of the Field Investigation of Six-Year Spontaneous Abortion Rates In the Three Oregon Areas In Relation to Forest 2,4,5-T Spray Practices" (the Alsea II Report) dated May 26, 1979 " ^ J0>[0 *1 a DATE 5-22-80 " 11 " " 5-23-80 ^ 11 5-29-80 " " FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Letter to Benjamin P. Holder, M.D., Dow Chemical, U.S.A. dated March 19, 1979 from Morton A. Stenchever, M.D., University of Washington, Seattle, Washington, Department of Obstetrics and Gynecology In Letter to Benjamin B. Holder, M.D. dated March 15, 1979 from Kenneth R. Niswander, M.D., University of Calivornia, Davis Dept, of Obstetrics and Gynecology School of Medicine " Panel Report - Panel to Dixcuss the Epidemiology of 2,4,5-T New York " City, July 10-11, 1979 Letter to Douglas M. Costle dated May 15, 1979 from Gordon W. Burt " Associate Professor, University of Maryland Draft Report: "Preliminary Assessment of A Field Investigation of " Six-year Spontaneous Abortion Rate In Three Oregon Areas In Relation to 2,4,5-T Spray Areas." and to "Exploratory Analyses of Data Contained In and Collected For The Draft Report' Investigation of Six-year Spontaneous Abortion Rates in Three Oregon Areas in Relation to 2,4,5-T Spray Areas." by Robert C. Duncan Letter to John and Debbie Marano dated Aug. 15, 1977 from Michael Watson " Toxicologist, EPA Seattle,Washington Request from EPA - Post-Questionnaire Strategy: Alsea Oregon Miscarriage " Investigation Memorandum dated Feb. 27, 1979 from Harvey L. Warnick in re Briefing by Clemet Associates on Preliminary Risk Assessment for 2,4,5-T Memorandum dated July 6, 1977 to Harvey L. Warnick to Frederick W. Kutz, " Ph.D. in re Environmental Monitroing Data on 2,4,5-T, 2,4,5-TP(Silvex) Erbon, and Ronnell List of Air Sampling Sites of the Surban Air Monitoring Study for Pesticides The Science of 2,4,5-T and Associated Phenoxy Herbicides by Rodney W. Bovey & Alvin L. Young Proprietary Data - Rebuttal Analysis, 2,4,5-T, Dietary Exposure Veon 245 label Estimate of Maxium Possible TCDD Residue In Rice NO. 1180 1181 1132 DATE 6-6-80 II II 1183 6-17-80 1184 6-24-80 1185 II 1186 1187 1188 1189 1190 1191 II II II II II II 1192 6-25-80 1193 U 1194 1195 1196 1197 1198 II II II u II FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION Inspections by Mike Peoples (handwritten) J. Yowell Notes (handwritten) Record of Communication dated May 1, 1980 in re 2,4-D and 2,4,5-T Application to Thomas Beasley from James R. Yowel STAI US In II II Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death 2,4,5-T Publication II Developmental Toxicity of 2,4,5-T II Comparison of the Embryotoxicity of Purified and Technical Grades in Dihybrid and CD-I Mice II Retrospective Study ofthe Relationship between Agricultural Use of 2,4,5-T and Cleft Palate Occurrence in Arkansas 2,4,5-T Teratology Study II Overview - 2,4,5-T Program Handbook of Teratology by James G. Wilson and F. Clark Fraser Replication Values for Mean Fetal Weights Memo from Director National Center for Toxicological Research to Dioxin Project Manager Criteria and Evaluation Divison, EPA in re Dioxins Relative Risks to Man and the Environment dtd Dec. 17, 1975 Memo dtd January 30, 79 in re Request for Contract Negotiation with Dr. Michael L. Gross for Dioxin Assays in Human Fat Ltr dtd March 10, 80 to Brooks Air Force Base in re paper on the concentration of TCDD in the body fat ..., from Lawrence B. Hobson, M.D., Ph.D. II II II II II 11 Tables: Concentration TCDD Tables: Fat Biopsy - Air Force Volunteers Fat Assays for Dioxins II U TCDD (Dioxin) Content of Human Fat: Progress Report (3/12/80) II Memo dtd January 9, 80 "Results of Capillary Column GC-HRMS Analysis for the Determination of 2,3,7,8-TCDD Residues in University of Nebraska Sample Extracts II <=>Z [ *7 NO. 1199 DATE 6-25-80 1200 1201 1202 1203 1204 THE DOW CHEMICAL COMPANY EXHIBITS FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation DESCRIPTION STATUS Ltr dtd June 26, 79 to Dr. Lyndon Lee, Veterans Administration from Michael L. Gross In Comparison of University of Nebraska and EPA Results on the Analysis of Human Adipose for the VA 11 Memo to Dr. Lawrence Hobson, Veterans Administration dtd May 29, 80 in re "Review of VA Study of TCDD in Body Fat of Vietnam Veterans " Determination of Tetrachlorodibenzo-p-dioxin (TCDD) in Human Adipose Tissue " Paper in re Veterans Administration Study " Memo dtd February 20, 80 from Robert Harless, to Mike Dellarco Thru R.G. Lewis "Results of Capillary Column GC/HRMS Analysis Performed on Extracts of Human Adipose Tissue for 2,3,7,9-TCDD Residues " 1206 1207 6-27-80 1208 1209 1210 7-1-8Q 1211 7-3-80 1212 1213 7-7-80 1214 1215a-fc " Toxicology of Chlorinated Dibenzo-p-dioxins, by B.A. Schwetz Memo dtd August 22, 1978 to Acting Director, HED from Pharma cologist, Toxicology Branch in re Dr. McNulty's Primate Teratology Study Mote to Bill Murray dtd 2 Aug 78 Memo dtd Nov 9, 1978 subject Toxicity of TCDD Metric Weight Conversion Table EPA Monitoring Studies -- A Case History of Dioxin, by' Carolyn K. Offutt Critique if Segments of Letters Which Relate To The Adequacy of Analytical Methods for TCDD In Environmental Samples Underlining Exposure Questionnaire & responses Chart Charts (( FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. 1216 1217 1218 1219 DATE 7-7-80 1220 1221 1222 1223 1224 ( 1225 1226 1227 1228 1229 1230 7-15-80 I P 1a 1231 1231a 1232 7-16-80 1233 l ___________________DESCRIPTION_____________________________________ STATUS Package of Questionnaires re smoking (Swedish) " Translation of the Swedish Questionnaires Death Certificates and the Tumor Diagnoses " " The Case-referent (case-control) Study In Occupational Health Epidemiology by Olav Axelson, M.D. " The Merck Manual of Diagnosis and Therapy " A Dictionay of Symptoms by Dr. Joan Gomex " Sample Data Sheet (Water Sample) 11 Symptoms -- The Complete Home Medical Encyclopedia " Letter to Mr. Steve Van Strum dtd June 26, 1980 from James M. 11 Witt, Estension Specialist in Chemistry & Environmental Toxicology Oregon State University The Merck Manual of Diagnosis and Therapy 11 Letter to H. Michael Wehr, Ph.D. dated July 17, 1980 from William S. Argonza " Letter to Department of Public Health , Attn: Mr. William S. " Argonza, dated Oct 18, 1980 from Robert A. Reynolds, GHT Labora-.'rv tories Agricultural Analysis The Science of 2,4,5-T and Associated Phenoxy Herbicides Rodney W. Bovey & Alvin L. Young " Fate of Silvex Following Oral Administration To Humans Water Quality Following Aerial Herbicide Spraying " " Silvicultural Chemicals and Protection of Water Quality " Silvicultural Chemicals and Protection"of Water Quality PB-271 923 Chemical Brush Control and Herbicide Residues in The Forest by L. A. Norris " Ltr to Mr. William Seward, Dow Chemical U.S.A in re Siuslaw " 2.0 U l e NO. DATE 1234 7-16-80 1233 1236 1237 7-17-80 1238 1239 " 1240 1241 7-23-80 1242 1243 1244 1245 1246 7-25-80 1247 1248 9-4-80 1249 11 1250 " FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION Degradation of Herbicides in the Forest Floor by Logan N. Norris STATUS In Sampler Sheets Letter to Mr. Douglas M. Costle dtd Nov. 13, 1978 from John R. McGuire U. S. Park Service Preliminary Report on Potential Drift of 2,4,5-T in the Alsea Oregon Area by W. E. Yates In Residue Reviews Vol. 49/ Pesticide Volatilization Persistence of Foliar-Applied 2,4,5-T In Woody Plants by Homer A. Brady 2.4.5- T Residues in Storm Runoff from Small Watersheds Letter to Major James W. Tremblay USAF Environmental Health Lab. from Michael L. Taylor, Wright State University Test GfidsTj Major Flight Paths, and Total Kilograms of Herbicides Disseminated on 210 Hectares of Test Area C-52A Disappearance of TCDD From Si Is of Grid I Field Studies On The Soil Persistence and Movement of 2,4,-D, 2.4.5- T and TCDD Absence of TCDD Toxicity to a Rodent Population Following Massive Field Applications of 2,4,5-T Herbicide Soil Taxonomy- A Basic System of Soil Classification For Making and Interpreting Soil Surveys The Science of 2,4,5-T and Associated Phenoxy Herbicides USDA Report of the Forest Service Fiscal Year 1977 Memo to M. Rupert Cutler, Assistant Sec. U.S. Forest Ser. in re 2,4,5-T Project Proposal, Rouge River, R-6 from John R. McGuire Chief of USDA Forest Service' Memo to Chief dtd June 20, 1980 in re Final Report -NAPIAP Proposal FS-974 from Frank J. Kopeck Deputy Reg. Forester FIFRA DOCKET NO. 415, et al. e 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. 1251 DATE 9-4-80 1252 It 1253 II 1254 1255 II II 1256 1257 1258 1259 II II II II 1260 II 1261 9-5-80 1262 II 1263 il 1264 1265 II II DESCRIPTION :STATUS Ltr to Mr. Ernie Shanks dtd May 28, 1980 from Ross W. Williams Forest Supervisor In Memo to Herbicide Monitoring Task Force dtd Feb. 13, 1978 in re Herbicide Monitoring Program from C.R. Batten Director of Communications, Calif. Forest Protective Assoc. Memo to Staff Director, TM and FI DM Dr. Benjamin Spada, PSW Dave Graham, WO, FIDM dtd Aug. 31, 1978 in re Cooperative Agreement for Administrative Study of 2,4,5-T Release Spray Project from Hugh C. Black, Regional Wildlife Ecologist Project Design Report on Aerial Application Procedure and Spray Deposit Sampling Herbicide Study, Blodgett Forest by David B. Drummond & John W. Barry Reference Slip dtd 7/23/80 to Mike Dellarco, EPa from Dave Graham Forest Service Ltr to Ralph Ross, Assistant to the Administrator Agricultural Research USDA dtd July 24, 1980 from Michael J. Dellarco Ltr to Aubry DuPuy, Pesticide Monitoring Laboratory dtd Sept. 13, 1978 from Hugh C. Black, Regional Wildlife Ecologist FR Vol 40, No. 248 dtd Dec. 24, 1975 Title 40, Chapter 1, Subpart D - Part 141 National Interim Primary Drinking Water Regulations Ltr to Honorable William G. Mil liken Governor of Michigan dtd Oct. 17, 1979 from Sherwin Gardner Acting Commissioner of Food & Drugs Texas Herbicide Regulations 176.26.00.001-.010 - Texas Department of Agriculture Rules and Regulations on Mixing and Application of Pesticides for the Enforcement of The Louisiana Pesticide Law Memo dtd May 1, 1979 from USEPA Economist, Economic Analysis Bra nch to Harvey Warnick, Project Manager Memo to Mr. C. L. Dunn from E. N. Woodbury dtd June 3, 1969 Syracuse University Research Corporation - Life Sciences Div.- Report on 2,4,5-T Residues in Rough Rice & Rice Straw dtd Jan. 26, 1970 S Oi c3 FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1266 9-5-80 1267 9-15-80 1268 1269 il II 1270 II 1271 9-23-80 1272 II 1273 II 1274 1275 II II 1276 1277 1278 1279 1280 II II II II II 1281 1282 1283 II II 11 DESCRIPTION STATUS Syracuse University Research Corporation - Life Sciences Div. Pesticide Analyses Laboratory Report on Silvex Residues in Rough Rice and Rice Straw Comparison of Diagnoses by Kociba, Squire, Haberman, and Goodman Concerning The TCDD 2-Year Diet Study Intramandibular Tumors In Mice Experimental Production of Intramandibular Carcinoma In Mice by Mechanical Damage Tongue Lesions of Male Rats of The 2,4,5-T Study as Diagnosed by Montali Federal Regulatory Agency Approaches to the Assessment and Control of Risk from Carcinogens, by Robert E. Albert, M.D. The Carcinogen Assessment Group's List of Carcinogens, July 14, 1980 Department of Labor "List of Substances Which May be Candidates for Futher Scientific Review and Possible Identification, Classi fication, and Regulation as Potential Occupational Carcinogens Pages 39 - 43 of Trancript of Sept 4, 80 Hearing The Carcinogen Assessment Group's Risk Assessment on (2,4,5Trichlorophenoxy) Acetic Acid (2,4,5-T), (2.4,5-Trichlorophenoxy) Propionic Acid (Silvex), 2,3,7.8-Tetrachlorodibenzo-p-Dioxin (TCDD) How the Risk is Derived From Intake of Beef Fat Carcinogen Assessment Group's Preliminary Report on Population Risk to Ambient Coke Oven Exposures Ltr. dtd June 14, 79 signed by David G. Hawkins w/attachments The Carcinogen Assessment Group's Updated Quantitative Risk Assessment on Ethylene Dibromide (EDB) Memo dtd 26 Oct 77 to Victor Kimm, DAA Water Supply from Roy E. Albert, CAG's Review of the Proposed Trihalomethane Amendment to the Interim Primary Drinking Water Regulations Upper Limit Risks Associated with Regulation of Carcinogens Final Report: NTA Cdtd April 22, 80). Comparision of Estimated Average Daily Dietary Intake of Aflaxtoxin and TCDD In In II II II II II II II II II II II II II II u II =2.0 i f 6/ FIFRA Docket No. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. 1284 DATE 9-23-80 1285 II 1286 II 1287 1288 II II 1289 II 1290 9-26-80 1291 1292 II II 1293 II V 1294 II 1295 II 1296 II 1297 II 1298 9-30-80 1299 II 1300 II DESCRIPTION STATUS Assessment of Estimated Risk Resulting From Aflatoxins in Consumer Peanut Products and other Food Commodities Anticarcinogenic Effects of 2,3,7,8-Tetrachlorodibenzo-p-dioxin on Benzo(a)pyrene and 7,12-Dimethylbenz(a)anthracene Tumor . Initiation and Its Relationship to DNA Binding, by Gerald Cohen, et al. In 11 Lack of Tumor-Promoting Ability of Certain Environmental Chemicals in a Two-Stage Mouse Skin Tumorigenesis Assay by D.L. Berry, et al. II Pesticide Risk Analysis Methods Attached, Defended at ACS Seminar II Memo dtd Feb 23, 79 to Harvey Warnick, from Elizabeth Anders Subj: Carcinogen Assessment Group's Risk Assessment on 2,4,5- Trichlorophenoxy Acetic Acid (2,4,5-T), and 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) II Aflatoxins in Corn II Chart II Pages of Transcript Nos. 10142 - 10152 (2,4,5-T Hearing) II Pages of Transcript Nos. 10182 - 10186 " Memo from Director', HED (TS-769) to Director, SPRD (TS-791) dtd Feb. 22, 1980 in re Identification of Pesticide Possibly Contaminated With Chlorodioxins Kearney Experiment (Chart) 2,3,7,8-TCDD Molecule (Chart) Environmental Significance of Chlorodioxins II II II II II The Dioxin Story: Is 2,4,5-T Safe? by Phillip C. Kearney Svenska Dagbladet - Aug. 17, 1977 - "Cancer Connection Possible" II II Ltr to Dr. Charles Poole USEPA dtd Oct. 24, 1979 from Lennart Hardell M.D. Report by Regional Hospital in Umea, Oncological Center II II 3 . f[ FIFRA DOCKET NO. 415, et al. 9 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1301 9-30-80 1302 1303a 1303b 1304a 1304b 1304c 1304d 1304e 1304f 1305 ( " 06a&b " 1307a&b " 1308a 1308b 1309a&b " 1310 1311 1312 1313 1314 1315 1316 1317a ^ 1317b 1317c DESCRIPTION Report - Oncological Center in Lund and Umea - Regional Hospital dated March 1979 Report - Oncological Center In Lund and Umea dated April, 1979 Questionnaire In The Study By H a r d e n , Sandstrom (In English) " ............. " " (In Swedish) Article"All These Lies To Defend Hormoslyv" " "The Public Opinion Stops Herbicides" " "The Death of Hormoslyv" " "Just the First Step" " "All Political Parties agreeon Ban ofHormoslyv" " "The Experts Will Have ToBow" - "Hormoslyv isbeing Banned The Phenoxy acid Problem In Sweden (In Camera) (In Camera) Instructions to the Interview (In Swedish) Instructions For Completing QuestionnaireForm (InEnglish) (In Camera) (In Camera) (In Camera (In Camera) (In Camera (In Camera) (In Camera) (In Camera) Article "Hormoslyv Process: InvalidityAmong RailwayEmployees" 11 "Spread Lies and Poison" " "Phenoxy acids-- A New Environmental Scandal" STATUS In " " " " " " " " " 11 " " 11 " " 11 " foli 0 DATE 1317d 9-30-80 1317e 1317F 1317g 1318a 1318b 1319 10-1-80 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Si 1vex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Article "Hormoslyr Causes Cancer" 11 "Hormoslyr Increases The Cancer-Risk" In " "Poison In The Forest" " "Stop The Poison" Hard toDeny-Facts by Lennart Harden (In Swedish) , ,'v Hard toDeny Facts by Lennart Harden (In English) Mortality Among Rubber Workers by Richard R. Munson and Kenneth K. Nakano 1320 10-7-80 1321 1322 f 1323 1324 1325 1326 1327 II II 1328 10-8-80 1329 1330 L Memo dtd Aug. 21, 1980 to Gunter Zweig, Ph.D. from Robert E. Lee, Ph.D. in re 2,4,5-T and Silvex Usage Related Information " Index to Articles On Pesticide Residues In Total Diet Samples (In Expando) Memorandum for the file - dtd Feb. 25, 1980 in re FDA's Findings of 2,4,5-T, Silvex, and TCDD In Raw Agricultural Commodities, Animal Feeds, and Total Diet Studies for 1972-1977 " " Memorandum to Steven P. Bayard, CAG from Gunter Zweig, Ph.D., dated June 16, 1980 in re Estimation of Exposed Population Size and Duration of Exposure " Differences In Numbers of Workers and Hours of Exposure In June and September CAG Report " Memo dated May 1, 1978 to Acting Chief Toxicology Branch, EPA from R.D. Schmitt, Ph.D., Toxicology Branch in re Update of Food Factor Tables ; Residues of Silvex in Sugagcane and Its Factory Products Resulting From Applications of Kuron Herbicide dtd April 21, 1971 Residue Study of Phenoxy Herbicides In Milk and Cream " " " Economic Comparisons of Alternatives For Improving Honey Mesquite-- " Infested Rangeland (In Expando) Record of Communication dtd 4/28/80 to Dr. Paul D. Chlenbusch, Dept. " of Agronomy Kansas State University from William Schutte Economist EPA in re 1978 Kansas Pesticide Usage Survey Accuracy Letter to EPA Document Control Officer dtd Sept. 13, 1979 from Roger L. Mitchell, Vice Pres, for Agriculture Kansas State University " 0 (1 7 FIFRA DOCKET NO. 415, et al. 9 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1331 10-8-80 1332 1333 1334 II It II 1335 1336 II II DESCRIPTION STATUS Letter to William D. Schutte, USEPA dtd June 10, 1980 from Will R. Jeffrey, District Conservationist, USDA In Structural Characteristics of Beef Cattle Raising In the United States It TCDD Residues By Animal - Beef Fat Phase I II Average Residues In Beef Fat Phase I Study Under Alternative Assumptions (PPT) II Livestock and Meat Situations - May 1980 II Summary of personal Communication with Jean Pennington dtd 8/25/80 II 1337 10-9-80 Report of Official Sample of Economic Poison 1338 " Impact of 2,4,5-T On Blodgett Forest 1339 Ltr to Dr. Dave Graham EPA dtd Aug. 29, 1980 in re Results of Mr. Bob Harless' analyses of the quality control samples in the Blodgett Forest Study 1 .j 40 Memo to Mike Dellarco, EPA Dioxin Project Manager dtd Aug. 14, 1980 from Robert Harless in re Addendum to Memorandum dated May 12, 1980, Results of Capillary Column GC-HRMS Analyses Performed on Extracts of Deer (USDA Study) for 2,3,7,8-TCDD Residues 1 1341 Blodgett Forest Study - Deer Samples ' 1342 USFS Blodgett Forest Deer Study Summary 1 1343 Memo to Hugh C. Black, USDA Forest Service dtd April 14, 1978 from Logan A. Norris in re Protocol for Sampling Deer for TCDD Residues ' 1344 Memo to The Record dtd Sept. 1, 1978 signed by David G. Graham, Pesticide Specialist'. USDA Forest Service in re Trip Report -- Aug. 14-15, 1978 2,4,5-T Deer Exposure Study--California ' 1345 Memo to David Graham, Forest Insect and Disease Management Forest Service dated Aug. 17, 1978 from Ralph T. Ross, Acting Assistant to Deputy Director in re Limitations of the Analytical Procedure for the Analysis of 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) In Environmental Samples 1346 Herbicide Residues In Blacktail Deer From Forests Treated with 2,4,5-T and Atrazine 147 The Effect of Plant Growth Substances and Natural Products on RNA and DNA Synthesis in Leukocytes 1348 Teratogenic Effects of the Plant Hormone Idole-3-Acetic Acid In Mice and Rats S xn NO. DATE 1349 10-10-80 1350 1351 1352 1353 1354 1355 " ff 1356 1357 1358 1359 1360 1361 1362 1363 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Synthesis and Identification of the 22 Tetrachlorodibenzo-p-dioxin Isomers by High Performance Liquid Chromatography and Gas Chromatogr aphy - T. J. Nestrick, L. L. Lamparski, and R.H. Stehl Letter to Dr. Warren Crummett, Dow Chemical dtd Jan, 3, 1979 from David Firestone Ltr to Document Control Officer, U.S.EPA in re Additional Information Concerning the Presence of Chlorinated Dioxins In The Environment: Ltr to Dr. Philip H. Abel son, Edigor Science dtd May 16, 1979 "A Closer Look at the Alchemy of Fire, L,L. Lamparski, T.J. Nestrick, & S.S. Cutie1 Dioxin Study dated February 27, 1979 Ltr to Dr. Etchyl H. Blair, Vice President, Director, Health and Environmental Sciences Dow Chemical Company dtd June 14, 1979 from L. B. Rogers In " Dispute over Dow Chemicals' Theory of Dioxin Traces '' Debate Continues over Dow's Dioxin Theory " Handwritten notes from John Strouss Dow Chemical Company " Ltr to Mr. Bob G. Caldwell dtd January 12, 1979 from Howard A. Tanner, Director of State of Michigan Department of Natural Resources " Memo to Joseph J. Merenda, Director Assessment Division, 0TE/0TS from Frank D. Kover, Assessment Division, 0TE/QTS in re Status REport 8EHQ-1178-0209 dtd Feb. 8, 1979 " Laboratory of Environmental and Toxicological Chemistry, U. of Amsterdam " "Chlorianted Dibenzo-p-Dioxins and Related Compounds In Incinerator Effluent: A Review of Measurements and Mechanisms of formation Tetrachlorodibenzo-p-Dioxin Quantitation in Stack-Collected Coal Fly Ash " by B.J. Kimble and M.L. Gross Analysis of Fly Ash from Municipal Incinerators for Trace Organic Compounds, G.A. Elceman, R.E. Clement and F.W. Karasek " 1364 TCDD Distributed from Use of 2,4,5-T and Silvex II Rot f^ 0 9 THE DOW CHEMICAL COMPANY EXHIBITS FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation NO. DATE DESCRIPTION 1365 10-14-80 Transcript of FIFRA Scientific Advisory Panel dtd Aug. 16, 1979 1366 II Technical Data Sheeii - Product Stewardship Guidelines for Safe Handling of 2,4,5-Trichlorophenol 1367 II Ltr to C.E. McCoy dtd August 26, 197r from Ralph R. Langner Industrial Hygiene Service, 607 Building Dow Chemical Co. 1368 II 2,4,5-T Hearing - Miscellaneous Data - J.M Theis 1369 11 In Camera 1370 II In Camera 1371 II TCDD Specification For 2,4,5-T Products 1372 II In Camera 1373 II In Camera 1374 II In Camera 375 II BIOPA 1449 in re 2,4,5-T - Holland dtd Feb. 5, 1979 1376 10-16-80 1377 II 1378 II 1379 II 1380 11 Guidelines for Carcinogen Bioassay In small Rodents Proposed System for Food Safety Assessment - Final Report of the Scientific Committee of the Food Safety Council, June, 1980 FR Tuesday, August 22, 1978 EPA Pesticide Programs Proposed Guidelines for Registering Pesticides In The U.S., Hazard Evaluation: Humans and Domestic Animals Determination of Chlorinated Dibenzo-p-dioxins and Debenzofurans In Various Materials by W.B. Crummett and R.H. Stehl Probi li ties of Detecting a Real Increase In Incidence of Tumors In Chronic Animal Cancer Studies 1381 iv jq-ip 1382 il 1383 il Origins of Human Cancer, Hiatt*. Watson, & Winsten - Gold Spring Harbor Conferences on Cell Proliferation Determination of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin In Diamond Alkali 2,4,5-Trichlorophenoxyacetic Acid (2,4,5-T) Chloracne Studies Conducted on 2,4,5-Trichlorophenoxyacetic Acid Sample From Diamond Alkali Used In The Ba'onetic's Study STATUS In II II II II II II It II II II ll ll fl II II II II II C^ I & s ke FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS i O . 1384 1385 DATE DESCRIPTION 10-17-80 Carcinogenicity Testing With Special Reference to the Value and Interpretation of Long-term Studies in Laboratory Animals: Discussion Paper prepared by FJCR II FR, Vol 39, No. 203 October 18, 1974 STATUS In II 1386 II Current methods employed in testing for carcinogenic activiry by Francis J. C. Roe II 1387 II Lecture to Association of the British Pharmaceutical Industry (9,6,76) Title: Definition of a Carcinogen II 1388 II FR Vol. 45-- No. 15, p. 5001-5296 (1-22-80) (Filed in Expando) II 1389 II Toxic Chemicals and Public Protection - A Report to the President by the Toxic Substances Strategy Committee dtd May 1980 II 1390 II Trends in Cancer Incidence and Mortality In the United States, 1969-76 by Earl S. Pollack and John W. Horm II 1391 10-22-80 ^ ^92 II 1393 II 1394 II Teratological Potential of 2,4,5-T by James G. Wilson, Ph.D. Use of Rehesus Monkeys in Teratological Studies, James G. Wilson Environmental Chemicals As Potential Hazards to Reproduction Current Status of Teratology - General Principles and Mechanisms Derived From Animal Studies II II II II 1395 II Teratology - The International Journal of Abnormal Development, 4/1980 II 1396 II Sources of Error that May Confound Teratologicity Test (Handwritten) II 1397 II Regulating Pesticides n 1398 II 2,4,5-T and @ 20mg/kg/day, ds 7-13 it 1399 II Laboratory Report 1400 II Ltr to Dr. V.K. Rowe dated Nov. 25, 1970 from James G. Wilson, Ph.D. 1401 II Report on 2,4,5-T Acid ii ii ii 1402 II Monkey Fetus Autopsy Record ii 301 ^4 9 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1403 10-27-80 1404 1405 1406 'V 1407 1408 10-28-80 1409 4410 1411a 1411b 1411c 1411 d 1412 1413 1414 1415 10-30-80 DESCRIPTION STAT0S Ltr to Mr. Thomas Hollaway, EPA dtd Sept. 7, 1977 from Michael J. Traynor, Dow Chemical Co., in re Dow Long Term TCDD Feeding Studies In Rats In Dow Redefines Word It Doesn't Like 11 A New Area of Concern in Teratology by James G. Wilson " Report - Results of Tolerance Studies of 2,4,5-Trichlorophenoxy Propionic Acid (Silvex) in Pregnant Rats " withdrawn Prenatal Effects of 2,4,5-T, 2,4,5-Trichlorophenol, and Phenoxyacetic " Acid In Mice i Review of Manuscript (Report) titled: Chronic Oral Toxicity of 2,4,5-T, Batch No. 503, Control No. 153574B- Short "2,4,5-T" - In A Reproduction Study Covering Three Generations of Sprague-Dawley Rats, Dated May 2, 1978 (Handwritten) Handwritten Report No. 6681-29 " Dead Storage #1521 - K-66681-(29), TCDD 3 Generation Reproduction Study of No. 1 of 14 " Dead Storage #1521 - K-66681-(29), TCDD 3 generation reproduction Study of No. 2 of 14 " Dead Storage #1521 - K-66681-(29), TCDD 3 generation reproduction Study of No. 3 of 14 " Dead Storage #1521 - K-66681 - (29) TCDD 3 generation reproduction Study of No. 14 of 14 " Historical Pregnacy Rates of Control Animals " Perinatal Nephropathies by James E. Gibson " The Effects of Various Doses of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin Administered with 2,4,5-Trichlorophenoxyacetic Acid On Rat Fetal Development - Manuscript 1971 " False-Positive and False-Negative Rates for Carcinogenicity Screens " Thomas R. Fears, Robert E. Tarone, and Kenneth C. Chu FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1416 10-30-80 1417 II 1418 II 1419 II 1420 II DESCRIPTION Choice of the Number of Sampling Units in Teratology The Statistics of Teratology Reduced Interlitter Variability In Rats Resulting from a Restricted Mating Period, and reassessment of the "Litter Effect" Principles and Procedures of Statistics - With Special Reference to The Biological Sciences , Robert G.D. Stell The Analysis of Variance, Henry Scheffe 1421 1422 1423 1424 1/195 (' 1426 1427 1428 1429 1430 1431 1432 10-31-80 1433 1434 1435 10-31-80 1436 L Analysing Qualitative Data, A.E. Maxwell, M.A., Ph.D. Some Methods for Strengthening The Common Tests Z-Statistic to Test Trends Workshop D - Statistics, Chairman: C.N. Park "Insensitivity of Test For Reproductive Problems", by B.A. Schewtz, K.S. Rao Sample Size Required to Detect Increase Over Control Incidence Chart Handbook of Teratology - Research Procedures and Data Analysis Drugs and Chemical Associated with Intrauterine Growth Deficiency Kenneth L. Jones, M.D., and Gerald F. Chernoff, Ph.D. Reproductive Tract Anomalies in Mice After Prenatal Exposure to DES The Fetal Alcohol Syndrome - Sterling K. Clarren, M.D. and David W. Smith, M.D. Memorandum of Record dtd Sept 13, 1979 Figures showing Study Area and Controled Area Comparison of Two Proportions Based on the Z-test Recalculation of Table 4,p. 17 of Dr. Agresti's Direct Testimony STATUS In II II II II 2 0 1 S .3 t 5 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. 1437 1438 1439 DATE 11-4-80 11 11 1440 1441 1442 li 11-5-80 II 1443 II 1444 11-7-80 1445 1445 11 11 1447 11 1448 II 1449 II 1450 1451 11 II 1452 1453 II 11 DESCRIPTION STATUS The Environment and Disease: Association or Causation In Case Control Studies II Foundations of Epidemiology - Abraham M. Lilienfeld, M.D., M.P.H., D.Sc. Department of Epidemiology The Johns Hopkins University School of Hygiene and Public Health II The Lancet - Saturday 21 September 1974 - Reserpine and Brest Cancer II Case Studies II Comparison of the Coding of Death Certificates Related to Cancer-' In Seven Countries, Constance Percy, MS Alice Dolman II What Proportion of Cancers Is Attributable to Occupation: Statistical and Social Considerations(Presented at the American Society for Preventive Oncology, Chicago, March 6-7, 1980) II Pathology - 43 Mesenchymal Tumors of Soft Tissues, Richard Shuman W.A.D. Anderson II Tumors of the Soft Tissues 11 Cancer A Comprehensive Treatise - Biology of Tumors: Surfaces, Immunology, and Comparative Pathology, Frederick F. Beckerr tl Management of Primary Bone and Soft Tissue Tumors - Recent Developments II In The Classification of Soft Tissue Sarcomas, Franz M. Enzinger, M.D. Cancer and Occupation: Status and Needs of Epidemiologic Research, Philip Cole, M.D. II Book Title: Persons at High Risk of Cancer, J.F. Froumeni, II Occupation, Philip Cole, M.D. and Marlene B. Goldman II The Evolving Case-Control Study, Philip Cole II British Medical Journal, Sept 30, 1950, Smoking and Carcinoma of the Lung, Preliminary Report by Richard Doll, M.D., M.R.C.P.& A. Bradford Hill, Ph.D., D.Sc. II Smoking and Cancer of the Lower Urinary Tract, Philip Cole, M.D., II Richard R. Monson, M.D., Hedda Haning, M.D., and Gilbert H. Friedell, M .D. Questionnaire 11 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation NO. 1454 1455 DATE 11-7-80 1456 1457 1458 1459 1460 11-12-80 1461 THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Chart In Exposure To Phenoxy Acids In Cases and Referents Divided by Occupation Exposure to Phenoxy Acids among cases and controls after dis solving of the matching. Subjects with high-grade of exposure to Chlorophenols are excluded. Epidemiology of Hodgkin's Disease, Nancy Gutesohn and Philip Cole Letter to Dr. Larsson dated Feb. 28, 1980 from L. Tomatis, M.D. Nature Voi. 264, Nov. 25, 1976 Dr. Luigi Dardanoni, "TCDD" Case Studies of Selected Area - Wide. Environmental Exposures," Presented at the NAS Workshop on Plans for Clinical and Epidemiological Follow-Up After Area-Wide Chemical Contamination," Washington, D.C. (March 17, 1980) Preface by Dr. Pocchiari (Director, NIH, Rome) The History of the Seveso Accident, G.M Fara, University of Milano 1462 1463 1464 1465a 1465b 1465c 1466 1467 Letter to J.H. Davidson dated June 21, 1977 from Lewis Shadoff " Synopsis of the Information Released Regarding the Chemical Release " In Milan, Italy, at the Givaudan Plant, Which is a Subsidiary of the Hoffmann Laroche Company Experience of the Accident of Seveso " Letter to Dr. Gehring, Dow Chemical Company dated Dec. 12, 1977 from " Dr. Reggiani Letter to Dr. Gehring, Dow Chemical Company dtd Dec. 22, 1977 from " Dr. Geggiani Letter to Dr. Geggiani dtd Jan. 6, 1978 from Dr. Gehring " Medical - Epidemiological Commission, Prof. G.M. Fara, Coordinator " Milan, August 27, 1976 Board' on Agriculture and Renewable Resources Commission On Natural Resources - A Report of the Ad Hoc Dioxin Advisory Group National Academy of Sciences, 1977 " OfjtS' FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation NO. DATE 1468 11-12-80 1469 ' THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION "Dr. Luigi Dardanoni/"Dermatologic Effects: Chloracine in Seveso," Presented at the NAS Workshop on Plans for Clinical Epidemiological Follow-Up After Area-Wide Chemical Contamination," Washington, D.C. (March 18, 1980) Accidentia! TCDD Contamination in Seveso (Italy): Epidemiological Aspects, F. Pocchiari STATUS In 1470 Human Health Effects From Accidental Release of TCDD at Sevesco (Italy) 1471 " Report on Seveso Facts and Controversies 1472 11-13-80 Chart 1473 1474 ,475 1476 1477 1478 1479 1480 1481 11-14-80 1482 " 1483 Experience of the Accident of Seveso by L. Bisanti, F. Boneti, F. " Caramaschi, G. Del Corno, C. Favaretti, S. Giambelluca, E. Montesarchio V. Puccinelli, G. Remotti, C. Volpatio and E. Zambrelli Localized Contamination with TCDD - Seveso, Missouri and other Areas, G. Reggiani " Graph (showing Pregnancy loss) " Spontaneous Abortions In The Territory of the C.S.Z. Brianza Di Seveso " 1,2,3 Teratoepidemiology, Marcus A. Klingberg and Cheri M. Papier Pathological-Embryological Investigations In Cases Of Abortion Related " To The Seveso -Accident FR,Aug 22, 1978, Part II, EPA - Pesticide Programs,Proposed Guidelines for Registering Pesticides In The U.S.; Harzard Evaluation: Humans and Domestic Animals Minutes of work group meeting about the results of embryo-morphological Studies In Abortion cases in connection with the Seveso Accident on 10th July 1976 held in Lubeck on the 24/25 Feb. 1977. The Merck Manual of Diagnosis and Therapy, David N. Holvey, M.D. Critically Acute Chloracine Caused By Trichlorophenol Decomposition Products Evaluation of Trichlorophenol Plant For Chloracne Hazards, Informative Summary With Conclusions ^6 0 NO. DATE 1484 11-14-80 1485 " 1486 " FI FRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION The Chloracne Problem-Biochem's Contribution Report on the Chloracne Problem Meeting on 3/24/65 Occupational Chloracne Caused By Aromatic Cyclic Ethers ~~IN In " " 1487 11-14-80 1488 11-17-80 1489 1490 1491 S 492 1493 11-18-80 1494 1495 1496 1497 1498 1499 1500 1501 1 502 '03 Results of Human Skin Irritation and Sensitization Studies On H-1500 an^Herbicidal Composition Containing 55% Sodium Salt of Silvex In Investigation of the Immune Capability of Workers Previously Exposed " To 2,3,7,8-Tetrachlorodibenzo-para-Dioxin (TCDD) Mortality Study of Persons exposed to dioxin accident tin Germany 1,1 TCDD Accident at a Chemical Factory in the Netherlands Acne chlorina, porphyria cutanea tarda a jine projevy celkove itoxikace pri vyrobe herbicid Toxic Effects of 2,3,7,8 tetrachlorodibenzo 1,4 dioxin in laboratory workers, R.M. Oliver Extraction Efficiencies of Polychlorinated dibenzo-p-dioxins and Polychlorinated dibenzofurans from Fly-Ash, RM.M. Kooke, J.W.A. Lustenhouwer, K. 01ie and 0. Hutzinger Municipal Waste -(Charts and figures) Computer printout Hutzinger's Fly Ash "Isomer Specific" CDDs Analyses In Camera In Camera Handwritten Notes (1 page) Letter to Dr. 0. Hutzinger dtd Aug. 19, 1980 from B.J. Kimble, Ph.D. Quantitative Determination of 2,3,7,8-Tetrachlorodibenzo-pdioxin Residues by Gas Chromatography/Mass Spectrometry Graph Ltr to Dr. 0. Hutzinger dtd Feb. 13, 1980 from C.E. Holloway FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation n THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1504 11-18-80 1505 11-19-80 1506 1507 II II 1508 II 1509 1510 II II 1511 11-2T-80 DESCRIPTION The Formation of ChlorodibenzO-p-Dioxins by Air Oxidation And Chlorination of Bituminous Coal, Nels H. Mable and L.F. Whiting An Unsolicited Proposal GSRI Proposal No. 329-1-76-15, A Quality Assurance Program 2,4,5-T Ad Hoc Task Force Meeting Summary, Nov. 19, 1974 Memo to Dr. Ralph Ross dtd Aug. 1, 1975 from Larry J. Anderson In re Rangeland Treatment Memo to Files and Attendees dtd June 27, 1980 from Dioxin Program Coordinator Criteria and Evaluation Division in re Dioxins: Beef Sample Collection Meeting Ad Hoc Task Force (Meeting Summary) Interim Results of 2,4,5-T/TCDD Residue dtd Aug. 5, 1975 Interim Results of 2,4,5-T/TCDD Residures Monitoring Program-Briefing Memorandum dtd Aug. 1, 1975 Chart STATUS In II II II II II II 1512 11 1513 II 1514 II 1515 II 1516 II 1517 11-23-80 1518 II 1519 II 1520 21 II II Range Forage Production and Consumption Following Aerial Spraying of Mixed Brush Soil Ingestion by Cattle Grazing Crested Wheatgrass Vegetational Areas of Texas Motley County, Texas Cottle County, Texas Ltr to J.H, Davidson, dated July 8, 1975 in re EPA Ad Hoc Task force Beef Sampling from M.E. Getzendaner Memorandum of Telephone Conversation between: Patrick O'Keefe and David Firestone dated July 7, 1977 Memorandum to Bill McCredie from Bruce Grefrath dated Jan. 23, 1979 in re Summary of the Dioxin Implementation Plan (DIP) Meeting On January 16, and 17, 1979 The Determination of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) In Human Milk Beef Fat Phase I Animal II H II II II II II II II II FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation ! NO. DATE 1522 11-23-80 1523 1524 1525 1526 1527 1528a 11-26-80 28b 1529 THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Statement of Lewis A. Shadoff On 2,3,7,8 Tetrachlorodibenzo-pDioxin (TCDD) In The Environment 8/4/76 Memo to the Files dtd March 5, 1976 in re Dioxin, Patrick E. Phillips In " Description of Beef-Fat Monitoring Samples " Map of Missouri (only 1 copy too large for reproduction)(Original file) . 11 Memorandum to Mr. William Barthel from Environmental Hazards Activity Cancer and Birth Defects Division Bureau of Epidemiology In re 2,3,7,8-Tetrachlorodibenzodioxin Contamination of Salvage Motor Oil Used in Dust Control Spraying, Lincoln, Missouri " " Notes of Interviews and Conversations of EPI-75-17-1 dated Aug. 21, 1974 " in re Bliss Salvage Oil Company, Interview with Russell Bliss, El 1isvilie, Missouri Transcript of Case No. 79 10064 - United States District Court For " The Eastern District of Michigan, Southern Division - The Dow Chemical Company, et al. v. Barbara Blum & Douglas M. Costle dated Apr. 6, 1979 EPA Oregon 2,4,5-T Study Areas (Maps) " Chart 1530a 1530b 1531 12-3-80 1532 Ltr to Mr. Andrew Gordon dtd Nov. 19, 1980 from Charles W. Warren, Ph.D. 11 Dept of Health and Human Services, Public Health Service Center for Disease Control, Atlanta Georgia Seasonal Variation In Spontaneous Abortions, Charles W. Warren, Ph.D., Julian Gold, MBBS. Carl W. Tyler, Jr., M,D,, Jack C. Smith, MS, and Allen L. Paris, MD. Analytical Techniques for 2,3,7,8-Tetrachlorodibenzo-p-dioxin Detection " In Environmental Samples after the Industrial Accident at Seveso Memo From the Ecological Monitoring Branch dtd Oct. 24, 1978 to Mr. Richard Reising SPRD in re Request for Review and Evaluation of Region X Deer and Elk Fat-TCDD Study Design l, S o (35 FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation t THE DOW CHEMICAL COMPANY EXHIBITS 1533 DATE_______________________ DESCRIPTION_____________________________________________ STATUS 12-4-80 1978 Elec. Row Asplundh Crews - Potential Duration of Exposure to Spray Mixtures Containing Some 2,4,4-T (In Manhours) 1535 12-5-80 1535 1537 " 1538 1539 '>40 1541 1542 1543 1544a 1544b 1545 1546a 1546b 1547 Toxicology Research Laboratory Health and Environmental Research Dow Chemical Company U.S.A (Structure) Percutaneous Penetration of Some Pesticides and Herbicides In Man Letter to Federal Register dtd February 14, 1979 from John F. Hall, Director " Forest Industry Resource and Environment Program, National Forest Products Association in re Rebuttable Presumption Against Registration and Continued Registration of Pesticide Products Containing 2,4,5-T Letter to J.D. Gnegy, Westvaco Corp. dtd July 5, 1978 from J.D.Walstad Weyerhaeuser Company " Estimate Field Sampling Procedures Interoffice Communication dtd June 29, 1979 from W.H. Lawrence, Weyerhaeuser in re to Experimental Designand Critical Path Work for 2,4,-D Exposure Study Solid Adsorbent Collection and Gas Chromatographic Determination of the propylene glycol butyl ether esters of 2,4,5-T in air " Evaluation of 2,4,5-Trichlorophenoxy acetic Acity Butoxy Ethanol Ester During Field Application Northeast of Johnstown, Pennsylvania " Letter to William H. McCredie dtd January 16, 1979 from Edward A. Kazamarek " of Georgia Pacific Corporation Exposure of Forest Herbicide Applicators to 2,4,5-T 11 Handwritten letter dated 6/30/79 to Dr. Levy from Scott Shepard Letter to Dr. Braun (handwritten) dated 7/6/79 from Scott Shepard " Ltr to FR Sec. dtd Feb. 14, 1979 in re 2,4,5-T RPAR " Ltr to EPA 0PP(handwritten)dtd 9/14/78 from Frank Sed Sedmera Letter to Mr. Richard Wasserstrom, National Forest Products Association dated Feb. 5, 1979 from Werner H. Braun, Group Leader, Biotransformation Toxicology Research Laboratory " 11 oc 3a FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DATE__________________________ DESCRIPTION STATUS 1548 12-5-80 ' 1549 12-8-80 1550 II 1551 II 1552 1553 1554 1555 6 ( 1557 1558 II II II II II II II 1559 II 1560 II 1561 12-11-80 1562 1563 1564 "55 II II II II Exposure Measurements of Applicators Spraying (2,4,5-Trichlorophenoxy) Acetic Acid In the Forest The Metabolism and Sistribution of 2,4,5-Trichlorophenoxyacetic Acid In Female Rats \ NewiZealand Journal of Agricultural Research Voi. 15, No. 3 Hexachlorobenzene - Accumulationand Elimination HCB in sheep after oral dosing In II II Pesticide Residues - Residues in Poultry Tissues from Low Level Feeding of " Five Chlorinated Hydrocarbon Insecticides to Hens Pharmacokineties of Mirex in Goats. 1 Effect on Reproduction and Lactation Ltr to Dr. Curt Mason dtd June 5, 1979 from T. L. Lavy Professor (Withdrawn) University of Arkansas Division of Agriculture Letter to William H. McCredie, National Forest Products Association dated Feb. 28, 1978 from E.A. Kazmarek. In Analysis of Technical and Formulated Products of 2,4,-Dichlorophenoxy Acetic Acid for the Presence of Chlorinated Dibenzo-p-Dioxins Estimation of Risks of Irreversible, Delay Toxicity II II Journal of Business Administration - Resource Policy International Perspectives II Fundamental Carcinogenic Processes and Their Implications for Low Dose Risk Assessment , K.S. Crump, D.G. Hoel, C.H. Langley and R. Peto OSU's Herbicide Connection by Phil Kesling Memo to M. Rupert Culter, dtd June 14, 1978 from John R. McGuire in re Draft Response to Affidavits--Herbicides in the Oakridge and Rigdon Ranger Districts of the Willamette .National Forest Agriculture's Strange Bedfellows: CAST-Industry Tie Raises Credibility Concerns Letter to Michael Newton dtd May 16, 1973 from Robert A. Poss Chief, Pesticides Branch Herbicides and Their Place In Our Environment Dr. Mike Newton Photodecomposition of Chlorinated Dibenzo-p-Dioxins II II II II II II II SC3f FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation f THE DOW CHEMICAL COMPANY EXHIBITS o00 pC--\1J NO. DATE 1566 12-11-80 1567 II 1568 II 1569 1570 1571 1572 1573 1574 1575 1576 1577 II II II II II II II II DESCRIPTION STATUS Letter to Bill Parker dtd March 30, 1978 from Dean Branson, Environmental Sciences Research Dow Chemical U.S.A. Atmospheric Transport of Sprays from Helicopter Applications In Mountainous Terrain by W.E. Yates, N.B. Akesson, R.E. Cowden Agricultural Engineering Department U. Of California In II 2,4,5-T Alternatives Silvex - Proceedings Southern Weed Science Society Vol. 25, 1972 - Drop Size Affects Absorption of 2,4,5-T by Six Hardwood Species, Homer A. Brady Analytical Report - Determination of Phenoxy Herbicides In Urine From Esteron 245 Sprayers Absorption of Silvex Esters Through The Skin of Human Volunteers Human Health Research Review Committee Meeting Minutes - Apr. 23,1979 Silvex Human Exposure Study - dated 2/15/79 (Handwritten) Survey of 2,4,5-T/Silvex Aerial Applicators Telephone Interview Questionnaires dated Oct.-Nov. 1980 Women Applicators Computer Printout - 1970 Annual Averages, Current Population Survey (CPS) Weedone2,4,-TP Weed and Wood Plant Herbicide (Labels) & Weedone 2,4,5-T Woody Plant Herbicide Letter to Arnie Schaffer dated June 26, 1979 in re Correlation of Urinary 2,4,5-T with Exposure from John C. Ramsey, Ph.D. II 11 II II II II II II II II 1578 12-16-80 1579 1580 1581 1582 II II 11 II 1583 II TCDD Report by S. Hussain, L. Ehrenberg, G. Lofroth and T. Gejvall, " Radiobiology Department, Wallenberg Laboratory, University of Stockholm " Sweden A Survey on the Mutagenicity of Various Pesticides II A Review of the Genetic Toxicology of Chlorinated Dibenzo-p-Dioxins by J.S. Wassom, J.E. Huff and N. Loprieno II Bladder Cancer, A Symposium II Thresholds for Environmental Cancer: Biologic and Statistical Consideration, Marvin A. Schneiderman, Pierre Decoufle, and Charles C. Brown II Science, Vol. 202, No. 4372, (Dec. 8, 1978, "Models for Carcinogenic Risk Assessment II (3 A 4' I NO. DATE 1584 12-16-80 1585 II 1586 II 1587 II 1588 II 1589 1590 1591 1592 1593 II II II II II 1594 1595 II II 1596 12-17-80 1597 II 1598 II 1599 II FIFRA DOCKET NO. 415, et al. 2,4,5-T & Sii vex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS Hepatic Macromolecular Binding Following Exposure to Vinyl Chloride , P.G. Watanabe, J.A. Zempel, D.G. Pegg & P.J. Gehring In Dose-Dependent Fate of Vinyl Chloride and Its Possible Relationship to Oncogenicity In Rats by P.G. Watanabe and P.J. Gehring II Metabolic Thresholds in Assessing Carcinogenic Hazard, P.J. Gehring, P.G. Watanabe, J.D. Young and J.E. Lebeau II Orgins of Human Cancer; "The Relevance of Dose-dependent Pharmacokinetics in the Assessment of Carcinogenic Hazard of Chemicals, P.J. Gehring, P.G. Watanabe and J.D. Young II Toxicology and Applied Pharmacology, "Resolution of Dose-Response Toxicity Data for Chemicals Requiring Metabolic Activation: Example-Vinyl Chloride", P.J. Gehring, P.G. Watanabe, and C.N. Park II Proposed System for Food Safety Assessment , "Final Report of the Scientific Committee of the Food Safety Council", June, 1980 II The New England Journal of Medicine, "Aryl Hydrocarbon Hydroxylase Inducibility and Bronchogenic Carcinoma" II Annals of Internal Medicine, "Xeroderma Pigmentosum" II Combination Effects in Chemical Carcinogenesis (Experimental Results) II Cancer Research, "A Comparison of the Effects of 3-Meth.yl-4dimethyl ami noazobenzene, 2-Methyl-4-di methyl ami noazobenzene, and 2-Acetyl aminofluorene on Rat Liver DNA Stability and New Synthesis II The Function and Mechanism of Promoters of Carcinogenesis II Induction and Repression of Microsomal Drug-metabolizing Enzymes by Polycyclic Hydrocarbons and Phenobarbital: Theoretical Models II Handwritten notes dtd 10/15/73 in re Meeting to discuss Sil vex II Handwritten Memo to M. Levy & to D.D. McCollister dtd 7/8/74 II R. & D. Report titled Study of the Pharmacokinetics and Metabolism of 2,4,5-T (2,4,5-Trichlorophenoxyacetic Acid) in C57BL/6S and F2 Outcross Mice II Letter dated Feb. 26, 1974 to Marguerite L. Leng from George E. Lynn II ( AO!3 3 <? NO. DATE 1600 12-17-80 1601 1602 1603 1604 1605 1606 1607 1608 1609 1610 161.1a 1-27-81 1611b 1612 1613 1614 1615 1616 ( 1617 FIFRA DOCKET NO. 415, et al. 2,4,5-T/Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS DESCRIPTION STATUS IBRA Annual Scientific Meeting In Comparative Studies on the Absorption of H-Thalidomide in Rabbits and " Rats, George R. Keller and David A. Blake The Fate of 2,3,7,8-Tetrachlorodibenzo-p-dioxin following Single and " Repeated Oral Doses to the Rat, J.Q. Rose, J.C. Ramsey, T.H. Wentzler, R.A. Hummel and P.J. Gehring Letter to P.J. Gehring dated July 10, 1972 from B.A. Schwetz " Letter to The New York Academy of Sciences dated Aut. 8, 1978 from P.J. Gehring, D.V.M., Ph.D. & B.A. Schwetz, D.V.M., Ph.D. 11 The Fate of 2,4,5-Trichlorophenoxyacetic Acid (2,4,5-T) Following Oral Administration to Man " Letter to Dr. J.D. Kohli dated Sept. 21, 1972 in re Pharmacokinetics of the Oral Administratiron of 2,4,-D and 2,4,5-T To Man from James Q. Rose, Metabolism Unit Chemical Biology Research Environment and Birth Defects, James G. Wilson Casarett and Doull1s Toxicology, "Teratogens" by Raymond D. Harbison Memo to M.L. Leng dated May 9, 1972 in re Telephone Conversation With Mr. Curtis Wherry from B.A. Schwetz, D.V.M., Ph.D. Letter to Dr. P.J. Gehring dated Aug. 12, 1977 from A.K. Aldridge KRATOS MS50 Mass Spectrometer Servicing Manual. KRATOS MS50 Mass Spectrometer Operating Instructions Revised USFS Blodgett Forest Deer Study Summary dated Jan. 26, 1981 Memo to Mike Dellarco, PO dtd May 12, 1989 from Robert Harless In re Results of Capillary Column GC/HRMS Analysis Performed on Extracts of Deer (USDA Study) for 2,3,7,8-TCDD Residues Ltr to Dr. Lyndon E. Lee, Jr. dated Aug. 29, 1979 signed by Prof. Michael L. Gross TCDD In Veterans Adipose Tissue II Memo to Michael Dellarco, EPA, SPRD dated August 28, 1980 from Danny McDaniel Chemist, TAC in re Description of Sample Shipped to Robert Harless on 8/27/80. VA Extracts sent to Harless for Analysis 3 . 0 1 3 */- FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY.EXHIBITS NO. DATE 1618 2-4-81 1619 1620 1621 1622 1623 1624a 1624b 1624c 1624d 1624e DESCRIPTION STATUS Memorandum to D.E. Van Ormer, Ph.D., H. Spencer, Ph.D., & J.E. Preston, Ph.D. from K.L. Bailey, Ph.D. & L. Anderson, Ph.D, dated Feb. 23, 1979 in re Rat Three-Generation Reproduction study Using 2.3.7.8- Tetrachlorodibenzo-p-dioxin (TCDD) 99 Purity Submitted by the Dow Chemical Company in 1978 Dow Study (1) In Memorandum of Conference dated Feb. 17,18,19 & 20, 1970 in re Teratology Study (2,4,5-T) being conducted on the contaminant 2.3.7.8- Tetrachlorodibenzo-p-dioxin " Memo to Acting Director, Criteria & Evaluation Div & Director of OSPR dated May 31, 1977 from Pharmacologist, Metabolic Effects Branch In re Validation of 2,4,5-TCP, Reproductive Studies " NTP Technical Bulletin, Vol. 1, Dec. 1980, Issue 3 Handbook of Teratology, 4 Research Procedures and Data Analysis " Environment and Birth Defects, James G. Wilson Results of Surveliance GLP inspection Conducted for EPA by R.A. Korsakas Memorandum to Eugene S. Spivak, from Acting Directir, Field Investi gations Branch dated Nov. 27, 1978 in re Request for Inspection of Dow Chemical, Mipland, MI Ltr to Mr. Melvin Robinson, FDA Investigator (handwritten) by Larry Cheoupek List of People present during final discussion Evaluation and Lab Audit of the Analytical Laboratories of Dow Chemical Co. 1625 1626 2-9-81 1627 1628 Environmental Protection Agency Review of TCDD Data on Dec. 12-14, 1978 Multiple Risk Factors in Environmental Cancer, Irving J. Selikoff, MD & E. Cuyler Hammond, Sc.D. Abestos Volume 2: final report of the advisory committee Dapers commissioned by the committee Ltr dtd April 15, 1980 to Dr. Larsson, Sweden, from L. Tomatis, MD FIFRA DOCKET NO. 415, et al. 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. DATE 1629 2-9-81 1630 II 1631 II 1632 2-11-81 1633 II 1634 II 1635 1635 II il DESCRIPTION STATUS Chart II Chart II Occupational Epidemiology- Richard R. Monson, M.D., Sc.D. In 2,4,5-T, Trichlorophenol, and Soft Tissue Sarcoma II Editorals - News Reports of Medical Meetings: How Reliable are Abstracts? The New England Journal of Medicine Vol. 303, No. 5 p. 277 & 278 II Letter to Judge Finch dated December 2, 1980 from Irving Shain,- Chancellor " University of Wiscousin-Madison Advisory Commi.tte on Pesticides - Report on 2,4,5-T II Further Review the Safety for Use In the U.K. of the Herbicide 2,4,5-T - Advisory Commietee on Pesticides 11 THE DOW CHEMICAL COMPANY EXHIBITS - BENEFIT SEGMENT 4000 2-26-81 4001a " 4002 " 4003 " 4004 3-4-81 4005 " 4006 3-5-81 4007 Effects of Weed Trees and Shrubs on Conifers-- A bibliography With Abstracts " prepared by Ronald E. Steward USDA Forest Service, Timber Management Resear*ch dated Dec. 17, 1979 The American Game Policy and its Development 1928-1930 - Wildlife Management Institute 1971 " CEANOTHUS In Douglas-Fir Clean-Cuts: Nitrogen Accretion and Impact on Regeneration " Nutrient Losses in Leaching and Erosion by Intensive Forest Harvesting by John G. McColl and David F. Grigal " Effects of Weed Trees and Shrubs on Conifers--A Bibliography with Abstracts " An Analysis of Major Pesticides Used In Protection of Timber from Damage in The Lake States ) " First Year Report Cooperative Brush Control Study Herbicides For Shurb and Weed Tree Control In Western Oregon ^ 0 13 FIFRA DOCKET NO. 415, et al. 5 2,4,5-T & Silvex Cancellation THE DOW CHEMICAL COMPANY EXHIBITS NO. 4008 DATE 3-13-81 4009a-d 4010 4011 4011a 3-17-81 4012 3-13-"81 4013 4014 4015 4016 3-17-81 3-19-81 4017 4018 4019 4020 4021 4022 3-20-81 4023 4024 4025 4026 DESCRIPTION STATUS Memo dated May 30, 1980 to Oregon NWFA Co-Operatives in re EPA Questionnaire from Rick Koven In Tabulations of Bids Forest Service - USDA Pacific Northwest Region Final Environmental Statement Vegetation Management With Herbicides " Vegetation Management With Herbicides - Western Oregon - Final Environmental Statement 1978 Vegetation Management with Herbicides - Western Oregon Logging Work Injuries in Applachia CPSC Draft Document Seven Immediate-Impact Consequences Resulting from The Use of A Chainsaw To Control Brush " Snag Characteristics and Dynamics In Douglas-Fir Forests, Western Oregon " Reforestation Efforts in Western Oregon - Hearing before the Subcommitte On Forests of the Committee on Agriculture House of Representatives July 8, 1977 " Plantation Damage Evaluation dated May 22, 1979 by Paul E. Buffam " Letter to Ted Paulsen dtd July 22, 1980 from Cynthia McCain, GroundWork, Inc. " Silvicultural Use of Herbicides in Pacific Northwest Forests by H. Gratkowski " Report by the U.S. Department of Interior Bureau of Land Management Medford District dAted Feb. 22, 1980 11 Timber Yields and Economic Analysis Technical Background Papers, 1978 Herbicide Environmental Statement Fire Analysis Report - Mack Lake Fire - May 5-8, 1980 " " Memo to Regional Foresters dated Feb. 17, 1981 from Gary E.- Cargill Opening Remarks to Prescribed Fire for Line Officers Workshop, Feb. 2, 1981, Marana, Az. " FR. Vol. 45, No. 161 - Carbon Monoxide; Proposed Revisions To The National Ambient Air Quality Standards " Petition of The Natural Resoruces Defense Council, Inc. For Control of " Fine Particles 7 Tittabawassee carp had most dioxin p -*ick-ivvo Ooicy V Bottom-feeding fish in the Tit- samples were taken and the EPA tabawassee River showed the high will attempt to identify the source of est levels ofchemical contamination the dioxin contamination. in the Great Lakes, according to a re While she would not definitely say cently released Environmental Pro that the Tittabawassee will get con tection Agency study. tinued EPA attention, she said, "It Carp in the Tittabawassee showed seem s more th a n likely th a t our levels ofthe suspected carcinogen di e ffo rts w io u ld in c lu d e th e T i t oxin ranging from 12 to 525 parts per tabawassee." trillion (ppt). The levels were found during sampling of the fish in 1985 M idland D aily News during a national dioxin study con ducted by the EPA. 2,3,7,8-TCDD, the most toxic fo ra ofdioxin, is a by-product ofherbicide production. Dow C hem ical Co. claims dioxin is created everywhere as a by-product ofcombustion. An advisory warning people not to eat bottom feeding fish, such as carp and suckers, has been in force for the Tittabawassee River since 1978. The advisory on sport fish, such as wall eye, was lifted earlier this year. USPS 347-700 P.O.Box 432 Published by Midland Publishing Company, Inc. Midland; Michigan 48640 Sunday. Second clam poataav . Post Office Single copy 3&f;by per week; by motor route $7.80 per month; by mail where carrier or motor route not avail* able $95 per year in Michigan. $110 per year outside Michigan. For service error* plume your carrier or 635*7171 before 6 p.m., weekday* and before 10 a.m. Saturday. Beaverton, Coleman, Clare and Gladwin area reader* may call toll free on 435-2380. Postmas te r Send address change* to Midland Daily New*. P.O. Box432, Midland, Michigan 46640. According to EPA spokeswoman Anne Rowan, fish monitoring will For Home Delivery Phone 835-7171, Cir continue at some of the sites where culation. Ot Ballot b o x S -AGrtK3 IOt i L o ^ S I Is dioxin danger overblown? 14, - T o ta l votes: 29 Yes: 34% (10) "It is enough and was enough a few years ago". . . "The dioxin dan ger has been greatly overblown " .. . "You can bet on it. " N o: 66% (19) "We 're just awakening from years of ignorance". . . "Dowreally shows their disregard for human health by building a boat launch down from where ^ey discharge dioxin into the river . . . "Once you've eaten all those walleyes, it's too late then, isn't it?''. .. "Ifyou believe it is overblown, you We bought every lie Dow has done" . . . ` `I f anything, it's covered up. " = Today's question: If television evangelist Pat Robertson runs for president, 0 will you vote for him? i! Call 754-3100 to vote yes and 754-6300 to vote no, before 7 a.m. tomorrow. Your vote s automatically will be recorded. Add a comment if you wish. L o t t e r y ________________________________ ' Tuesday daily lottery number: 645 Daily four: 5753 THE DOW CHEMICAL C O M P A N Y 3EN N E TT BU ILD IN G 2030 D O W CENTER M ID LA N D , M IC H IG A N 8640 N o v e m b e r 1, 1979 Dear Reverend Roos: ^ r I really appreciate the fact that you, as a stockholder, would write and r e q u e s t inforrriation a f t e r seeing the article in the New York Times, and I am happy to respond to your request. If you r e al ly w a n t to u n d e r s t a n d w h y the i m p l i c a t i o n s are written about this product, you need to understand a little history. The product 2,4,5-T is an agricultural herbicide that we have manufactured for over thirty years. It has been a very effective product in killing noxious weeds and brush in roadways and under power lines, and in certain agricultural applications such as pasture land and rice. It is true that this p r o d u c t c o n t a i n s an im pu ri ty know n as dioxin, but at a level below 0.1 ppm. In pure form, dioxin is q u i t e t o x i c to g u i n e a pigs. T h e _ p n ] y k n o w n ,,efleet..on . p w'-'O have, b e e n e x p o s e d to m o r e c o n c e n t r a t e d d o s e s is a skin r a s h, k n o w n as c h l o r a c n e. D i l u t i o n of 2 , 4 , 5 - T to its use concentration lowers the 3Tbxin content to levels far below 0.1 ppm, and its effect is n o t perceptible. T h e r e is n o p r o d u c t t h a t w e m a n u f a c t u r e t h a t w'e h a v e m o r e toxicology and health data on than 2,4,5-T, and we consider it extremely safe. Unfo rtunately for the product, the U.S. government r e q u i s i t i o n e d its use in the V i e t n a m Wa r to d e f o l i a t e the j u n g l e s in the s e a r c h for the V i e t Cong. It, therefore, became a symbol of the Vietnam War that some people have become obsessed with destroying, along with anything else related to that unfortunate experience. The hostility raised toward this product by the aftermath of' the V i e t n a m W a r g a v e it a h i g h p r o f i l e . T h i s w a s p i c k e d up by a lot of the extreme activists among the environmen talists who are opposed to using any kind of chemicals for agricultural pruposes. You have undoubtedly seen many TV programs condemning the use of ch emicals in agriculture. These activists have learned the trick of the Hitler-type p r o p a g a n d a in G e r m a n y ; t h a t is, if y o u tell a lie o f t e n enough people will begin to believe it. The news media have been willing channels for certain quacks who make claims not backed by any data, because they are not con- 2.0 L3 i v e r e n d Roos -2- N o v e m b e r 1, 197 9 cerened with the truth and their only intent is in doing aw ay wTit h a g r i c u l t u r a l c h e m i c a l s . B e c a u s e 2 , 4 , 5 - T is on e of the oldest and safest one known, if it can be destroyed, the never ones for w h ic h there is less data can be more easily destroyed. Serious scientific scrutiny of the data allegedly supporting claims concerning miscarriages in northern California and Oregon,some months after spraying the forests, shows no valid relationship between the spraying and miscarriages. There is one other piece of information you need to know. There is a flourishing bu s i n e s s in no r t h e r n C a l i f o r n i a and other no rthwestern states in g r o w i n g m a r i j u a n a in open spaces and in the forests; in fact, it has been found that the marijuana plants grow to a greater height there than many other places. Single plants grow 12-15 feet in height and have a market value in the "dope" busi ne ss of about $1000. Law officials in Ca li fo rn ia have estimated the value of the crop, in three northern California counties alone, at $900 million. Marijuana is very re ad il y de s t r o y e d by 2 , 4 , 5-T, and the U.S. Forest Service has been using it to kill underbrush, and the marijuana is also killed. Less than three week s af t e r the F';l susoe r.-bec the u s e o f 2, 4, 5- T i r f o r e s t a p p l i c a t i o n , a Saclaiiiento n e w s p a p e r n o t e d in a f e a t u r e st o r y on M a r c h 18 that, " m a r i j u a n a g r o w e r s set for p r o f i t a b l e '79 s e a s o n . " So, R e v e r e n d Roos, th er e is a lot that d o e s n ' t a l w a y s m e e t the eye in a single newspaper article. There are some very strong f o r c e s c o m b i n i n g to d o a w a y w'i t h o u r a g r i c u l t u r a l c h e m i c a l business. We are absolutely convinced that 2,4,5-T is a safe product, b u t th es e p e o p l e w?ill s t o p at n o t h i n g , fo r th e r e a s o n s c i t e d above, to p r e v e n t its use. As a stockholder, I think you should be interested in under standing this situation. If you are i n te re st ed in scientific documentation, we will be glad to furnish it to you. We would also be delighted, if you were interested in coming to Midland, Michigan to have you visit our toxicology labs an d t a l k to o u r s c i e n t i s t s a b o u t th e s a f e t y of 2, 4 , 5-T. kmd 2.0 t Midland begins river water use * *\ i f _ MJdUnder* began drinking and 'using a mixture of Lake Huron and Tittahawasaee R ivy water ling 8.9 million gallois, the same as for the same bourg* Fri day and Thursday, today- The water superintendant anti| The city water department ! cipatea pumping, and treatment went to the river Friday night operations at the West Main for additional water to supple- Street station will add two million ment the supply which the city gallons per day to help meet |jie obtains from the Saginaw Mid- city's water demands. b land Lake Huron pipeline.< Ewing anticipates it will be William C. Earing water de late today or early Sunday'before partaient superintendent, report- ; 'he river-lake water will spread ed the pumps at die West Main throughout the entire city. Street treatment station went into operation i t f p.m. Friday. At 9 p.m., the first river water, after being treated with chemicals, was fed into the distribution By then, he added, the mixture will be about one - half river water and one - half lake water, " Midlanden should not be able to tell any difference as far as system. the taste of the water," he said. By 4 a.m. today, thf winter " It might be a little harder department was nbje to shunt water than they have been used the first river WHtpr into the to using," Ewing said in reservoir on Bay City Rood; explaining the river water is G ty officials decided Friday to ; j harder than the lake wjjer. go to the river tor additional i Ewing reported the quality qf water after being unable to build j the river water was found good igj the reserve spppty jn the res- when pumping operations began, ervoir from the city's suppfy Of "As far as taste is concerned, llfclii1-Itt H lirri ' pirrlinr since; we ran into no problems " heavy industrial demands*kept Pumping and treatment of the the water oonsuipption up. water at the treatmei^ j l a n t will Ewing said no appreciable; ,continue until Sunday*uiflight. change in the level of the res- Then, the treatment facilities ervoir had been noted at 7 a.m. will be shut down for eight hours today, the; water in reserve fotal- ! See WATER Page 9 0^0 I Ht Zero discharge not __ i By KATHY GRAY . . t Ck~i`vr*o *?* ; tection Agency and DNR, Dow noto Daily News staff writer linesHienewcells in the landfill with As a part ofthe SecondWorld Con a 100-mjlimeter thick polyethylene ference on the Great Lakes, Dow liner on top ofthree other protective Chemical Co. made a presentation layers of clay and sand and a pum today on the waste management ping system underneath it all to program at its Midland facility. catch any leakage from the cells. The th re e -d a y conference on "We minimize waste at the source Mackinac Island is designed to-dis w henever possible th rough upj- cuss the quality of the Great Lakes graded processing, recycling or rec and contaminants which threaten lam ation," Calvin said. "Secondly, the five lakes around Michigan. we treat the waste that is produced Dow's waste management policy, w ith a fully in teg rated , on-sit'e according to Michigan Division Re treatment and disposal system." search and Development Director Calvin did point out that with all Donald Calvin, is made up ofseveral the advances made at Dow, there elements including minimization or still is public concern about the ani- recycling, treatment and eventually ounts still discarged. ' long-term storage. "Zero discharge is an unachiev Dow's waste goes through a .num able goal because of our increasing ber of treatments before it is finally ability to detect even minute quan either burned, stored or*discharged tities of compounds in the environ into the Tittabawassee River. Any ment," he said. "What we must re liquid waste th a t is not recycled member though ... th at environ undergoes biological treatment be m ental protection is achieveable fore the solids ^resent to the landfill only through thoughtful dialogue and the liquid sent through a second between all concerned parties." filtra tio n u n it before being dis He added that the public is being charged into the river. needlessly alarmed in many cases by Dow's wastewater discharge per reports of"trace quantities in the en mit issued by the state Department vironment ... We need to focus on of Natural Resources allows the dis basic toxicology concepts such as charge of small concentrations of a no-effect levels, and the fact that it is number ofcompounds into the river, the combination of toxicity and de including a minute amount ofdioxin gree of exposure th a t creates the (10parts per quadrillion). hazard." A nother aspect of Dow's-waste In conclusion, Galvin shpwed a management program is its incmfer- picture taken on the first day of the ator, Calvin told those attending the walleye fishing season at the crowd conference. The incinerator contains ed and newly dedicated Bob G. Cal anti-pollution equipment such as a dwellboatlaunch,just a fewhundred scrubber and e le c tro sta tic p re yardq .downstream from where Dow cipitators. discharges into the Tittabawassee. In addition to all burnable waste, Even though restrictions on sport Do^r also burns some radioactive fishing on the Tittabawassee were waste as well, primarily from the lifted earlier this year, fishermen company's analytical labs. The re have been warned since 1978 not to sulting ash is buried at Dow's Sal eat bottom feeding fish on the Tit zburg landfill. tabawassee. According to data re- The last component ofDow'swaste leased last year by the EPA, the most - program is its landfill. As recently dioxin-contaminated fish was found required by the Environmental Pro- in a TittabawasseeRiver carp. V -O IH 2 - Businesses say liability trial costs staggering fh OLFvroo to G'-oS-- > 2r> By ROB REHG Daily News staff writer Do Chemical Co. spent more than $1 million the past two years successfully defending 11 product liability lawsuits that went to trial. "At these rates, a defendant can ciansto demonstrate that doctors are not alone in their desire to alter the liability system. Davis told the group that the aver age cost ofsuccessfully defending 11 product liability lawsuits that went to trial in 1984and'85 was $150,000. timately are settled "for much less than they cost to defend." Besides the financial cost to com panies, the litigous nature oftoday's society has "a very chilling effect on businessm en" and stifles en trepreneurs because, "The risk of and suffering damages. G. William Sefton, press secretary Davis noted that is common for de for Citizen's Liability Action Com fendants to use structured settle mittee, said his group is renewing a ments which are paid out over many petition drive to lim it how much years. In those cases, a $250,000 money attorneys can receive from award can actually mean a person damage awards. will receive three times that much not even afford to win," says Ronald The only other case that went to litigation is allowed to override the money because of compounding in Michael Lefkiades, a Michigan Davis, manager of Dow's litigation tria l in the same two year period benefit ofthe product," Davis said. terest. delegate on the White House con section in its legal department. Davis and several local business representatives formed a panel which met Wednesday at Saginaw's St. Luke's Hospital to discuss liabi ended with an $800,000 judgment against Dow. In 1985. there were 423 product liability claims filed against Dow. "That's roughly eight suits a week," ' Several panel members said the legal system must be made less at tractive for people to file frivolous claims, and over generous jury awards should be prevented. "The point is a person can get a lot of money without an astronomical jury award,"Davis said. W ednesday's panel included ference On Small Business Affairs, said it is important for doctors and businesses to apply constant pres sure on lawmakers until changes are made to liability laws. lity problems confronting their em Davis said. ployers. "The vast majority" are claims The prbgram was arranged by a that Lack merit, Davis said, but still coalition of Saginaw County physi- a re expensive to defend and u l One ofthe best remedies, the panel stressed, would be to place a maxi mum cap on what can be awarded injured parties in punitive or pain members of school districts, tavern owners, architectural firms, General Motors Saginaw Division and physi cians. "Legislators understand things in numbers and pressure -- plain and simple,"Lefkiades said. L ro w ra x p ia iu releases sulfur trioxide vapors About one pint of sulfur trioxide vapors wasreleased at a DowChemi- > cal Co. plant building in Midlands Thursday. According to Dow spokesman Pat .. Goggin, the vapors were released a t ; the Dowfax plant a t about 5 a.m. Thursday. The material, which is a surfactant or water solubility e n -. hancer, was released when a fran- , gible(preesurereleasedevice)failed. The m aterial creates a thick fog and the repair and clean up was a slow process, Goggin said, because workers were having difficulty see ing the affected areas. Once the re lease was detected by a remote- . controlled computer, the processw as. Btdpf>ed and the scrubbir*,"which clean the area were activitated. No workers were in the area when the ' release occurred. The release was contained pri-' marily within the Dowfax building although some got into the outside atmosphere because of the plant doors being opened and closed by workers cleaning up the area. The city and fire department were alerted to the release and Dow gave ' the all clear to both departments at noon Thursday. m < r f V 3 ',1 Vinyl chloride leaks from Dow Sarnia pif SARNIA, Ontario (AP) -- Nearly 13,000 pounds of colorless toxic chemical vapor leaked into the at mosphere from a Dow Chemical Co. lbsidiary plant here, Dow officials y. The leak a t the Dow Chemical mada Inc. plant in Sarnia, across ne St. Clair River from Port Huron, Mich., occurred about 10:30 p.m. Monday, company officials said. The leak, which lasted 24minutes, included 7,700 pounds of vinyl chloride vapors and 5,280 pounds of hydrogen chloride vapors, The De troit News reported today. Dow spokeswoman Sandy Carlton said th e vapor release posed no danger to Michigan and Canadian residents. Police and other disaster officials in Michigan were not no tified ofthe accident, the News said. Dennis M. Drake, a compliance official in the state Department of Natural Resources'Air Quality Con trol Division, said Tuesday night he was unaware ofthe vapor leak. The leak occurred when an in strument failed at the plant, causing a pressure upset in the vinyl chloride finishing section of the plant, Ms. Carlton said. A pressure safety valve dispersed the vapor, but the plant was shut down to minimize environmental impact, she said. The leak "might have extended to the river, but if it did, its potency would have been diminished," the spokesw om an said. Vinyhchloride, a used in the producti chloride plastic resin, w to manufacture pipe and garden h es. Hydrogen chloride, a lvng itant, is used to produce t chloroethane, an industrial solve > and silicon for microprocessors. 9 h J O'* V f Vapors from leak within safe levels, Dow says -* T n P r i I S , Free Press Staff and W ire Services Any chemical vapors that hit Michigan after a leak at a Dow Chemical Canada Inc. plant in Sarnia, Ontario, would have been within safe levels, the company said Wednesday. And the Ontario Ministry of Environment said it had no reports of ill effects from the leak. But a spokesman for the American Lung Associa tion of Michigan said, "Releasing 3% tons of pollut ant is not a mipor thing." he spokesman, Alex Sagady, referred to 7,700 of vinyl chloride vapors that leaked intermit ir about 25 minutes Monday night at the myl chloride is a carcinogen shown to cause a form of liver cancer," he said. "It is very . ingently regulated in the United States. But with out knowing the form and the temperature of the leak and the way it was released and the ground-level concentrations, I can't really evaluate it." Dow said about 5,280 pounds of hydrogen chlo fTre&S * ride vapors leaked with the vinyl chloride from the River would have ranged from 17 parts on the plant, about 60 miles north of Detroit. Canadian side to nine parts on the west side, the Dow Dow said the vapors were leaked when equipment statement says. failure caused a pressure problem. Jim Janfe, acting manager of the Sarnia office of the Ministry of Environment, said: "It was a 1 n which appears to have happened becaus e (equipment failure), and some safety valves w t . . . ;f. The safety valves are there to help keep a major problem from happening." Vinyl chloride is a colorless gas used in making plastic resin. Hydrogen chloride is a colorless gas used to make industrial solvent and silicon micro processors. Dow says in a statement that the American Conference of Governmental Industrial Hygienists "The levels determined would not be sufficient to cause any chronic or long-term results and ail exposure of several thousand p.p.m. would be Ac quired for acute health effects," said Dr. Ian Arnold, medical director of Dow's health center, in Dow's statement. Dow said its guidelines for hydrogen chloride limit exposure to 25 parts per million in a one-hour period and that the peak concentration for the leak was 38 parts per million over the plant. Peak concentrations over the St. Clair River would have ranged from 30 parts per million on the east side to 16 parts per million on the west, Dow said. puts the occupational short-term exposure limit for No one monitors the air around the plant and there vinyl chloride at 10 parts per million parts of air, and was no independent confirmation of the nature or that Dow calculations showed the highest concentra amount of the leak. Dow and the ministry calculated tion of vinyl chloride reached 22 parts per million how much pollutant was in the air from the amount of over the plant. Peak concentrations over the St. Clair the chemical Dow said was released. 6 ) /-zloof DETROIT FREE PRSS/TUESDAY, MAY 20, 1986 9 % ------------------------------------------------------ -- ------------------------------------ ;--------- m Dow loses bid to end `flyover' surveillance UPlandAP WASHINGTON - The U.S. Su Supreme Court roundup mATI The court upheld a former govern ment policy of cutting off some Soci|[ preme Court ruled Monday that use of Security benefits to divorced spousa airplanes to look for evidence, whether | of a backyard marijuana patch or cori porate pollution, does not violate the ! Constitution's ban on searches made ! without warrants. In companion cases from Michigan Agency of a Dow plant in Midland. , Dissenting in both cases were Jus Both cases made their way to the tices Lewis Powell, William Brennan, Supreme Court to test the contention Thurgood Marshall and Harry Blackthat the flyovers were illegal under the mun. Constitution's guarantee that people Also Monday: have the right to "be secure in their over 60 who remarry. It ruled 6-3 th at the policy did not violate the Constitu- i tion. The court ruled against a L o | | Angeles area couple who challenge! the policy. The case is Bowen vs. | Owens. | and California, Dow Chemical Co. vs. persons, houses, papers* and effects, The court let stand a ruling that The court granted the Reagan a<J- j | United States and California vs. Cir- against unreasonable searches." people applying for police jobs may be ministration a hearing in its bid to liniif< i i aolo, the justices said the Fourth required to have a certain number of eligibility for Social Security disability i | Amendment's guarantee of privacy ! does not extend to open areas that can i be seen from a hill or an airplane with I the naked eye or photographed with traditional types of cameras. `The Fourth Amendment protec tion of the home has never been ex tended to require law enforcement officers to shield their eyes when pass ing by a home on public thorough fares," the court said. "The Fourth Amendment simply does not require the police traveling in the public air ways . . . to obtain a warrant in order to observe what is visible to the naked eye." IN THE DOW CASE, "open areas of an industrial plant complex with nu merous plant structures spread over an area of 2,000 acres. . . (are) open to the view and observation of persons in aircraft lawfully in the public air space," the court said. Dow had argued that allowing such searches would make it impossible to protect its plant from corporate spies seeking tradesecrets. A Dow spokeswoman said the com pany's initial reaction was "disappoint ment." "However, we are pleased the Su preme Court felt the case had enough college credits, even if the rule hurts more blacks than whites. The justices, without comment, rejected a challenge to a requirement that applicants for the Dallas police force have at least 45 hours of college credits. The case is Davis vs. Dallas. benefits. The court said it will review a Washington ruling that the govern-, ment improperly denied benefits tb disabled individuals. The case is Bowen vs. Yuckert. Free Press Staff Writer Dollyi Katz contributed to this report. ' 1 ! : : The cases dealt with aerial searches, one by police in Santa Clara, Calif., that turned up a backyard marijuana patch belonging to Dante Ciraolo, and the other by the Environmental Protection merit to actually hear it," said Vicky Suazo. "The decision is extremely close, so we'll wait to hear what information we get from (reading) the actual decision." L* b 1 Q~ ir '. GRAMd e p a rtm e n t o f S t a t e ^ ^ mI X 7/>X! 5 C2. V ACTION: A s w - b a ^ r ^ I a s ^ ^ S S S 01 ' RPTD- 1X701 CISCPAC/POLAD '*.'ifi-Y A m em bassy PHNOM PENH 412 1. ) 2 9 6 3 C23 JOINT BTATE/DEPENSE MESSAGE ;> Y``' .iV;:. `4'*#..`t/vk.. />* -rf^',rC'v ' | Enbt.1- 5 8 ? . - <f'"ll.J ;. DOD lo o k in g i n t o m a tte r u r g e n t l y .'j X '1'3'" USIA '* / ' vi e w p ro b a b le ERV c h a rg e s germ w a rfa re r e q u e s t Embassy view s NSC ' - ' ' " X . . TVJD -^ bow p u b l i c r e l a t i o n s a s p e c t t h i s program sh o u ld b e s t b e h a n d le d . J/ D ept Jr?'. 7 Y Y / ~ V. . ,. UA-<#': , .\ / \ $ e u g g e s * you c o n s id e r t h a t fo llo w in g be u n d e rta k e n p r i o r u se d e f o l i a n t : NSA h / e/JH', .. ( 'Vi'!.. - r " * -iSCfijv OSH'" '* w j r f C f w f t l a s : ' S i n c e p la n e s m ast be flow n by U .S . p i l o t s , GVN m ig h t' ARMY " NAVY AIR RMR b e fo re o p e ra tio n commences, s t a t e p u b lic ly they have re q u e ste d ; V; i t a n d ` t h a t program u n d e r OVN d ir e c t i o n and c o n t r o l . ,^v' fee*! Itc*.'' X v -.. . t. 2V; T his p o i n t t o be Biade I n c o n te x t p u b lic n o tic e t o V ia t- v .YttX - h X y i amase- c i t i z e n s e x p la in in g d e f e n s iv e p u rp o se program and a d v is in g rr.: ' -- ...................*33&. - -in h a b ita n ts o f-a re a s -to-be a ffe c te d -re n ece ssary -precautions^ ni I F rfl Such n o tic e should s p e ll o u t th a t th is d ra s tic program n ecessi t a t e d a s one o f s te p s defend)V iet-N am from VC atbjfC k, t h a t i t w ill have no harm ful e f f e c t on humans o r liv esto ck s, e tc . 1ST 3* D e f o lia n t n o t be u s e d n e a r C aabodlan b o r d e r ^ a n d RKG a h o u l d be Inform ed in advance. / Embassy comment r e q u e s te d . No f i n a l d e c is io n p e n d in g y o u r r e p l y , b u t p rep arato ry step s being taken. ,\ ___________ r , ( X _____________ A X X . % SK X "*"** r l. i FE sTT /yn: OT-tood tn n 1 1 /7 /6 1 . \ PE teta M i ,S t m g g . DOC/lSA - H r. Bundy ^ T?/VE - N r. C o t t r e l l OS-5 FE /P,- Hr. K *nellOV ] SEA-- M r A nderson 0 ffs W W P * M X DSOA&IHtD - / RIPXOOUCnON ROM conr is TxoHiamo UNUSS "UMOASSIHIO-. LO, mu. S. U V to .SteOa.3 n b n W4i*JBjT? i/^O.__ ws. to V *. ^ 2 0 14 # U N ITE D STATES E N V IR O N M E N T A L PROTECTION AG ENCY O FFIC E OF PESTICIDE PROGRAMS W A SH IN G TO N , DC 20460 FREEDOM OF INFORMATION REQUEST RESPONSE IN IT IA L RESPONSE X A D D 'L RESPONSE NO. REQUEST IDENT. NO. 3726-93 DATE NOV 3 0 I993 T?r 1. D O We are enclosing records you requested. We believe that they fully respond to your request. These records plus those that will be sent later fully respond to your request. See item 3. D 2. Records you requested are not immediately available. We have ordered copies and will forward them to you as soon as we receive them. Please allow several weeks for delivery. C! 3. As explained in an attachment to this form, records you requested cannot be released to you. If item 2 above is not checked, we have enclosed all requested records available for public release at this time. D 4. Records you requested are available from another agency. We have forwarded your request to that agency; a copy of our letter of transmittal is attached. D 5. Records you requested have been published and are available from the source identified below. RECORDS REQUESTED: Records concerning 2,4-D, 2,4-DB, and 2,4-DP and dioxins. RECORDS ENCLOSED (or source o f public documents): Items from the public docket concerning 2,4-D, 2,4-DB, and 2,4-DP and dioxins, four bibliographies of all product chemistry studies submitted on 2,4-D, 2/4-DB and 2,4-DP, and an Affirmation of Non-multinational Status. Please complete and return this form. See REMARKS below. RECORDS T H A T W IL L BE FORW ARDED LATER: Additional records concerning 2,4-D, 2,4-DB, and 2,4-DP (approximately 3000-4000 pages) have been collected and are being reviewed in order to remove any confidential business information that these documents may contain as well as B docket items and selected studies from the bibliographies. RECORDS TH A T ARE NOT A VA ILA B LE FOR PUBLIC RELEASE: REMARKS: I will begin to process the B docket items (D-13956B through 13960B) and any items you select from the enclosed biblio graphies after I receive a completed Affirmation of Non multin at io na l Status. Please note that it will take several months to process these studies. Studies are on microfiche. See the cover letter about fees relevant to your request. Michael Yanchulis (703) 305-6440 EPA Form 1550-9 (5-81) .S. GPO: 1993-342-137/80114 EXPLANATION OF THE AFFIRMATION OF NON-MULTINATIONAL STATUS Pesticide information that is responsive to your recent FOI request includes information that was submitted to EPA by pesticide applicants or registrants under the Federal Insecticide, Fungicide, and Rodentidde Act (FIFKA). In the 1978 amendments to FIFRA, Congress expressly limited who may receive this information and how it may be used by recipients. These limits, expressed in FIFRA section 10(g), were imposed by Congress to protect registrants of pesticides in the U.S. against unauthorized use of their health and safety data by competitors to obtain pesticide registrations in foreign countries. (Those who obtain pesticide registrations in foreign countries are called "Foreign or Multinational Pesticide Producers" in section 10(g), abbreviated "Multinational" herein.) FIFRA section 10(g) therefore requires EPA to avoid knowingly disclosing this information to a Multinational, or to agents or employees of a Multinational. Numbered paragraphs (1) and (2) of the "Affirmation of Non-Multinational Status" are designed to allow EPA to implement this requirement. Section 10(g) also requires each person who seeks to obtain this information from EPA to affirm that he or she does not intend to, and will not purposefully or negligently deliver (or cause delivery of) the information to a Multinational. Numbered paragraph (3) of the Affirmation is designed to allow EPA to implement this requirement. The remainder of this explanation is provided to further assist you in understanding section 10(g) and the implications of signing the Affirmation. Section 10(g) makes it unlawful for a person requesting registrant-submitted pesticide information to furnish a false or misleading Affirmation ofNon-Multinational Status to EPA;such violations are punishable under 18 USC1001. Thus, for example, it is EPA's position that it would be unlawful for a person to execute the Affirmation while having the intent to publish (or otherwise to deliver in any way to a Multinational in its entirety) a previously unpublished toxicity study submitted by a registrant. This is because the information delivered likely could be used to satisfy a data requirement imposed by a foreign country as a condition of producing, distributing, selling, shipping, or using the product in that country. However, section 10(g) would not restrict an intent to publish or deliver brief excerpts from such information or summaries or critiques of it, identified as such, since these likely would not be useful in satisfying data requirements imposed by other countries. Of course, the prohibition does not apply to publication or delivery of information that is already freely available to the public (such as data that has been published) or to publication of data with the consent of the registrant that submitted it to EPA. It is less dear whether the statute imposes any other duties or prohibitions on persons once they have received the information from EPA, and EPA has taken no position on this issue. Some firms who have submitted data to EPA, however, argue vigorously that section 10(g) governs the use or disdosure of data by persons who have obtained it from EPA. Accordingly, you should be aware that if your disdosure of data obtained by you from EPA results in its becoming available to a Multinational (in a form that enables it to be used to satisfy foreign data requirements), it is possible that the firm that submitted it to EPA may seek relief against you in court, and may argue in court that you were required by section 10(g) to guard against disclosing data to a M ultinational or allowing such disdosure. You may therefore wish to take steps to avoid inadvertent disdosure of the data by keeping it in a secure place. Before publishing it or deliberately disdosing it to others, you may wish to seek legal advice. October 1984 AFFIRMATION OF NON-MULTINATIONAL STATUS This affirmation is required by the EPA interim procedures to implement Section 10(g) of the Federal Insecticide, Fungicide, and Rodenticide Act. Section 10(g) is reproduced on the reverse side for your reference. I have requested access to information submitted by an applicant or registrant under the Federal Insecti cide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.) to the Environmental Protection Agency. I hereby affirm that: (1) am not a business, or other entity engaged in the production, sale, or distribution o f pesticides in countries other than the United States or in addition to the United States; and I am not an employee or agent of any such business or entity; (2) I do not seek access to the information for purposes o f delivering it or offering it for sale to any such business or entity or to any o f its employee or agents; (3) I w ill not purposefully deliver the information (or negligently cause it to be delivered) to any such entity or to any o f its em ployees or agents. I am aware that I may be subject to criminal penalties under 18 U .S.C 1001 if 1 have made any state ment o f material facts knowing that such statement is false or if I w illfully conceal any material fa ct D ate__________________________ Signature_______________________________________________ Organization___________________________________________________________________________________ O Iamnot requestingaccess on behalfof someoneelse. . I am requesting access on behalf o f someone dise. M y client is: RETURN THIS FORM TO: Freedom of Information (A^9$), Office of Pesticide Programs, U.S. Environmental Protection Agency, Washington, D.C. 20460 O & For office use only: RIN 2 " 7 J ~ c} 3 Date mailed 30 !990 Caseworker /_ / s __________ ( 11/88) ? n rz 7 The Federal Insecticide, Fungicide, and R odenticide A c t as Am ended Public Law 92-516 October 21, 1972 as amended by Public Law 94-140 November 28, 1975 and Public Law 95-396 Septem ber 30, 1978 7UCUU F.L.fJ 2 St. 31. Records " SEC. 1. PR O TECTIO N O F T R A D E SECRETS AND O TH ER IN FO R M ATION. "(g ) Disclosure to Foreign a n d M ultinational Pesticide Producers.-- " (1) The A dm inistrator shall not knowingly disclose inform ation subm itted by an applicant o r registrant under this Act to any employee o r agent o f any business o r other entity engaged in the production, sale, o r distribution o f pesticides in countries other than the U nited States o r in addition to the U nited States or to any other person w ho intends to deliver such d ata to such foreign o r m ultinational business or entity unless the applicant or registrant has consented to such disclosure. The A dm inistrator shall require an affirm ation from any person who intends to inspect d ata that such person does not seek access to the d ata for pur poses o f delivering it or offering it for sale to any such business or entity o r its agents o r em ployees and will not purposefully deliver o r negligent ly cause th e d ata to be delivered to such business o r entity o r its agents o r employees. N otw ithstanding any other provision o f this subsection, the A dm inistrator may disclose inform ation to any person in connection w ith a public proceeding under law or regulation, subject to restrictions o n the availability o f inform ation contained elsewhere in this A ct, which inform ation is relevant to the determ ination by the A dm inistrator w ith respect to w hether a pesticide, o r any ingredient o f a pesticide, causes unreasonable adverse effects on health o r the environment. " (2) T he A dm inistrator shall m aintain records o f the names o f per sons to w hom data are disclosed under this subsection and the persons o r organizations they represent and shall inform the applicant or registrant o f the names and affiliation o f such persons. " (3) S ection 1001 o f title 18 o f th e U nited States C o d e shall ap p ly to any affirm ation m ade under paragraph (1) o f this subsection. ow 2 ,4-D pecial Review Public Docket umulative Chemical Index 05/18/93 PAGE 1 5091A 09/22/86 Campt, Douglas, D. EPA Letter to Gilfmore, Inc. 09/22/86. Notifies that EPA is considering initiating a Special Review of the use of pesticide products containing 2,4-D. 2 pages. D- 5129A 12/03/86 Tinsworth, Edwin F. EPA Letter to Union Carbide Agricultural. 12/03/86. Notifies that EPA is considering initiating a Special Review of the use of pesticide products containing 2,4-D; 2,4-DP & 2,4-DB. 3 pages. D- 5140A 07/01/86 EPA Report. 07/86. 5 pages. Chemical Information Fact Sheet for 2,4-D. D- 5181A 05/18/87 Barrons, Keith Pentwater, MI Letter to Douglas G. McKinney, EPA. 2,4-D effects dog if exposed. 1 page. 05/18/87. Concerns how D- 5256A 08/01/86 EPA Report. 08/86. 5 pages. Chemical Information Fact Sheet for 2,4-D. D- 5305A / / EPA Report. Undated. 2 pages. Tolerances For 2,4-Dichloropheoxyacetic Acid. D- 5306A 11/24/80 EPA Report. 11/24/80. 2 pages. Preliminary Quantitative Usage Analysis of 2,4-D. 2 , 4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 2 D-- 5307A 09/09/86 Meeting Minutes Meeting held on 09/09/86 Meeting requested by [Not given in minutes] Subject: Discussed 2,4-D Research Data. 30 pages. Participants: Hunt, Milt, EPA Eisenbrandt, Dave, EPA Cook, Ralph, EPA Dr. Moore, EPA Kimm, Vic, EPA Barnes, Don, EPA Conyers, Emory, Dow Chemical Bomar, C.P., Industry Task Force D- 5308A / / Johnson, Stephen L. EPA Report. 07/08/87. A Set of Scientific Issues Being Considered by the Agency in Connection with the Peer Review Classification of 2,4-D as a Class C Oncogen. 2 pages. D- 5309A 07/15/87 Gemert, Marcia van EPA Memorandum. 07/15/87. in mice on 2,4-D. 2 pages. Forwards Review of the Pharmacokinetic study D- 6651A 01/09/87 Davis, Warren Union Carbide Agricultural Products Co. Letter. 1/9/87. Reply to 12/9/86 notice from EPA. States that including 2,4-DP and 2,4-DB with the proposed special review of 2,4-D is inappropriate. 4 pages. From the author, on 01/14/87 D- 6652A 12/30/86 Averbach, Ing. Aharon Compania Quimica S.A. Letter. 12/30/86. Notes that the company is a basic producer of 2,4-D. Inquires about the status of 2,4-D in the United States. 1 page. From the author, on 01/14/87 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 3 D- 6660A 11/12/86 Conner, John D. McKenna, Conner & Cuneo Letter. 11/12/86. Comments on the review of th Kansas epidemiology study by Dr. Brian MacMahon. 2 pages. Attachment: 9/29/86 "Review of Hoar et al and related literature" by Brian MacMahon, 7 pages. From the author, on 11/12/86 D- 6867A 01/05/87 Kulakowski, Lois Tucson, Arizona Letter. 1/5/87* 2,4-D. 1 page. Asks for immediate halt to use of Atrazine and D- 6868A 12/15/86 Barrows, Keith Bradenton, Florida Letter. 12/10/86. Comments on recent 2,4-D data. Sent to the author, on 12/15/86 1 page. D- 6869A / / Meeting held on 01/15/87 Meeting requested by -[information not in minutes] Subject: Upcoming meeting of SAP to discuss oncogenicity of 2,4-D Participants: Tinsworth, Edwin, EPA Akerman, James, EPA Hunt, Mel, Dow Chemical Conyer, Emery, Dow Chemical D- 6877A 01/27/87 Baldi, A. Aceto Agricultural Chemical Corporation Response to EPA's letter concerning the Special Review of 2,4-D. 1 page. From the author, on 02/10/87 D- 6941B 01/20/87 Hazleton Laboratories America MRID 400618-00 and 01. 01/06/87. "Oncogenicity Study in Mice with 2,4-Dichlorophenoryactic Acid (2,4-D)", Volumes I through III. 1,797 pages. From Conner, John D., McKenna, Conner and Cuneo on 02/06/87 2 , 4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 4 D- 6956A 01/13/87 Auerbach, Janet EPA Record of 1/13/87 telephone call to Milt Hunt, Dow Chemical, to announce that the Agency was willing to discuss more specifically the constortium's offer to make risk reduction proposals for 2,4-D. 1 pg. D- 6957A 01/15/87 Meeting held on 01/15/87 Meeting requested by -not given in minutes Subject: Risk reduction proposal on 2,4-D. Participants: Hunt, Milt, Dow Chemical Company Conyer, Emery, Dow Chemical Company Auerbach, Janet, EPA D- 6970A / / Estetter, Dan Areata, California Letter. No date. Requests cancellation of registration of pesticides containing 2,4-D and Atrazine. 1 page. From the author, on 02/27/87 D- 6981A / / Five form letters from individuals requesting cancellation of pesticides containing 2,4-D and Atrazine. 5 pages. D 6982A / / Cox, William and Alice Santa Clara, California Letter. 01/01/87. Protests the use of 2,4-D by the National Forest Service. 1 page. D- 6994A / / Published articles on 2,4-D and reviews of literature. From the authors, on 02/19/87 81 pages. D- 7043A 02/27/87 Nelsen, Joel California Citrus Mutual Letter. 02/27/87. Comments on 2, 4-D. From the author, on 03/05/87 1 page. 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 5 D- 7176A / / Agriculture Canada Bulletins and reports. CAPCO Notes of 1/23/87, 1/26/87 & 3/4/87. 2 memoranda from Pesticides Directorate and 2 toxocological reports. 132 pages. D- 7188A / / Clark, Rebecca University of Cincinnati 2/87 "Critical Review of the Literature: Toxicological Properties of 2-Ethylhexanol." Literature Review, 23 pages, and Toxicological Profile, 16 pages. From Wilson, Ronald, Industry Task Force on 03/19/87 D- 7280A 03/12/87 Riley, Louis E. and Janice Touchet, Washington Letter. 03/12/87. Transmits copy of testimony submitted to a Restricted-use herbicide hearing held at Pasco, Washington. 1 page. Attachment: Testimony. 2 pages. D- 7956A 06/30/87 Boodee, Mark T. EPA Letter. 06/30/87. Transmits requested list of tolerances for 2,4-D. 1 page. Attachment: Incoming correspondence and list of tolerances. 3 pages. Sent to Mider, R.H., New York State Electric & Gas Corp. on 06/30/87 D- 816.1A / / Conner, John D. McKenna, Conner, and Cuneo Letter. 07/21/87. "FIFRA Scientific Advisory Panel -- From the author, on 08/19/87 2,4-D." 2 pages. D- 9093A 03/23/88 EPA Federal Register notice. 3/23/88. "2,4-D, 2,4-DB, and 2,4-DP; Notice of Proposed Decision not to Initiate a Special Review." 6 pages. 2 ,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 6 D- 9172A 05/18/88 Conner, John McKenna, Conner, Cuneo Letter. 05/18/88. Notes that comments addressing the requirement for additional oncogencity testing will be submitted by the Industry Task Force on 06/03/88. From the author, on 05/23/88 D- 9207A 06/03/88 Conner, John McKenna, Conner & Cuneo Letter. 6/3/88. Submits comments of the Industry Task Force on 2,4-D. 1 page. Attachments: 36 pages. From the author, on 06/03/88 D-10669A 02/25/89 Dole, Jessica Portland, Oregon Letter. 2/25/89. Urges EPA to restrict the use of 2,4-D. Attachment: Article, "Restrict Risky Herbicides," 1 page. 1 page. D--11031A / / Meeting held on 08/25/89 Meeting requested by [not given in minutes] Subject: To discuss possibility of joint sponsorship of meeting on weight of evidence of carcinogenicity of 2,4-D. Participants: Graham, John, Harvard Symposium on 2,4-D Page, Donald L., Industry Task Force II on 2,4-D Yetzin, Jerry, Task Force II Bond, Greg, Dow Chemical Rees, Jerry, National Association of Wheat Growers Stuckey, Richard, National Association of Wheat Growers Williams, Margery, National Association of Wheat Growers Hill, Richard, EPA Farland, William H., EPA Andersen, Janet, EPA Bloom, Jill, EPA 2 ,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 7 ^-'11034A 08/31/89 Hill, Richard EPA Memorandum. 8/31/89. Subject: "Agency Position on 2,4-D Review." Explains that the EPA will not co-sponsor a review of 2,4-D. 1 page. D-11134A 10/13/89 EPA Federal Register Notice. 10/13/89. Consideration for Special Review." 3 pages. "2,4-D, 2,4-DB, 2,4-DP; Status of D-11135A 09/01/89 EPA Pesticide Fact Sheet on 2,4-D for Special Review. 10 pages. D-11136A 09/01/89 EPA Pesticide Fact Sheet on 2,4-DB for Special Review of 2,4-D. 6 pages. D-11137A 09/01/89 EPA Pesticide Fact Sheet on 2,4-DP for Special Review of 2,4-D. 5 pages. D ^1165A 12/04/89 Conner, John D. McKenna, Conner & Cuneo(Industry Task Force II) Letter. 12/04/89. Letter committing to develop data for 07/06/89 Special Data Call-In. 1 page. D-11369A 02/05/90 Meeting held on 02/05/90 Meeting requested by John Graham Harvard School of Public Health Subject: Notes from the 2/5/90 Meeting with John Graham on Release of Report from Harvard Workshop on 2,4-D. Participants: 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 8 D-^lsesA Continued Graham, John, Harvard School of Public Health Schifrin, Emily, Harvard School of Public Health Hill, Dick, EPA Burnam, Bill, EPA Blondell, Jerome, EPA Auerbach, Jan, EPA Andersen, Janet, EPA Bloom, Jill, EPA Bayliss, Dave, EPA Hiremath, Charlie, EPA Jill Bloom, EPA Auerbach, Jan, EPA Hill, Richard, EPA Andersen, Janet, EPA Blondell, Jerome, EPA Burnam, William, EPA Bayless, David, EPA Hiremath, Charlie, EPA Graham, John, Harvard School of Public Health Schifrin, Emily, Harvard School of Public Health D-11370A 01/31/90 Harvard School of Public Health Report. January, 1990. The Weight of the Evidence on the Human Carcinogenicty of 2,4-D. 65 pages. D _1533A 03/06/90 Conner, John D. 2.4- D Industry Task Force. Letter to Bert Baker, EPA. 03/06/90. Request for extension of time to submit aquatic plant growth studies. (2 pages). Submission of nine mutagenicity studies. See D-11543B (MRID 414098-01 through -09). 2 pages. D-11543B 03/07/90 2.4- D Industry Task Force Reports. 1990. Nine mutagenicity studies. MRID 414098-01 through -09 (Microfiche). From Conner, John, 2,4-D Industry Task Force 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 9 D^"1965A 06/08/90 Zumwalt, E.R. U.S. Navy Letter to Douglas D. Campt, EPA. 06/08/90. Discusses the potentially dangerous contaminants in 2,4-D formulations. 26 pages. D-11966A 08/15/90 Campt, Douglas D. EPA Letter to E.R. Zumwalt, U.S. Navy. 08/15/90. Responds to Admiral Zumwalt's 6/8/90 letter concerning potentially dangerous contaminants in 2,4-D formulations. See also D-11965. 2 pages. D-12232A 10/27/78 Krumel, K.L. and R.F. Arnold Dow Chemical Report. 10/27/78. "A Study Of The Formation And Removal Of Impurities In The Semi-Hydrous Process For 2,4-D". CBI has been deleted from this version. 57 pages. D-12233A 10/27/78 Krumel, K.L and R.F. Arnold Dow Chemical Report. 10/27/78. "A Study of the Formation and Removal of Impuri ties in the Semi-Hydrous Process for 2,4-D." 61 pages D-12330A,'12/04/90 Campt, Douglas D. EPA Letter to E.R. Zumwalt, U.S. Navy. 12/04/90. gated version of the Krumel Report (D-12232). 1 page. Transmits a new expur D-12766A 07/08/91 Bloom, Jill EPA Letter to S. Freeman. 07/08/91. Forwards National Cancer Institute's epidemiologic studies of pesticide use and cancer incidence in Nebraska. 1 page. d L .O IC .3 L 2 , 4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 10 D-n3308A 12/11/91 Meeting Minutes Meeting held on 12/11/91 Meeting requested by [Not given in minutes]. Subject: Discussed O.M. Scott's product registrations for the 1992 and 1993 growing season. 1 page. Participants: Bloom, Jill, EPA Waldrop, Walter, EPA Kelty, Michael, O.M. Scott Crow, David, D.C. Services D-13310A 12/11/91 Meeting Minutes Meeting held on 12/11/91 Meeting requested by EPA/Industry Task Force II Subject: Discussed toxicology data requirements of the Special Data Call-In of July 6, 1989 and the 2,4-D Registration Standard. Minutes: 2 pages. Attachments: 116 pages. Participants: Dumas, Richard P., EPA Bloom, Jill, EPA Van Gemert, Marcia, EPA Rowland, Jess, EPA Swentzel, Clark, EPA Brennecke, Lucas H., EPA Protzel, Alberto, EPA Waldrop, Walter, EPA Coombs, Judith, EPA Fenner-Crisp, Penny, EPA Sette, Bill, EPA Dorsey, Larry, EPA Barolo, Dan, EPA Rossi, Lois, EPA Auerbach, Jan, EPA Hammond, Larry, DowElanco Quast, John, Dow Chemical Armbruster, Jim, Agro-Gor Wilson, Ron, John Wise & Assoc. Akkari, Khalid H., BASF Corp. Mahlburg, Bill, Nufarm USA Charles, Jeff, JayMark Cunny, Helen, Rhone Poulenc Ag. Co. o ov 2 , 4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 11 v 13314A 11/12/91 Conner, John D. McKenna & Cuneo Letter to Judy Coombs, EPA. 11/12/91. Requests a meeting to discuss issues which need to be resolved before the Task Force initiates certain 2,4-D toxicology studies. See D-13310 for meeting minutes. 3 pages. D-13335A 01/06/92 Bloom, Jill EPA Note to the Files. 01/06/92. Makes corrections, on behalf of Larry Hammond (DowElanco), to 12/11/91 meeting minutes (D-13310). 1 page. D-13383A 01/06/92 Conner, John D. McKenna & Cuneo Letter to Jill Bloom, EPA. 01/06/92. Supplements Agency's minutes from the 12/11/91 meeting with the EPA/Industry Task Force II. See also D-13310. 3 pages. D-13384A 01/06/92 Conner, John D. McKenna & Cuneo Letter to Jill Bloom, EPA. 01/06/92. Requests an extension of time in which to submit mouse and rat studies. 4 pages. D-13439A 01/17/92 Housenger, Jack E. EPA Letter to John D. Conner, McKenna & Cuneo. 01/17/92. Responds in part to Mr. Conner's request for an extension of the deadline for submission of 2,4-D rodent carcinogenicity test data. See also D-13384. 2 pages. D-13445A 02/14/92 Housenger, Jack EPA Letter to John D. Conner, Jr., McKenna & Cuneo. 02/14/92. Requests information in support of the extension request for 2,4-D rodent carcinogenicity data. 4 pages. 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 12 D-"3944A 10/30/92 Otten, Richard Hunt-Wesson, Inc. Cover letter. 10/30/92. Submits cover letter for regulatory action in support of reregistration of Para chlorophenoxy acetic acid. 1 page. D-13956B 10/01/90 Landvoigt, Dr. CHEMSERV Industrie Service Study. 10/90. Submits study entitled " Summary Analysis of 2,4-D Detailing the levels of substituted dioxins and benzfurans found in the samples. 3 pages. For cover letter see D-13944. D-13957B 10/01/90 Landvo igt, Dr. CHEMSERVE Industrie Service Study. 10/90. Submits study entitled "Determination of Dioxins and Bensofurans in 2,4-D, 2,4-DCP, MCPA, 2,4-DP, CMPP and 2,4-DPB by GC/MS." 3 pages. For cover letter see D-13944. D-13958B 10/05/90 Tiernan, Thomas Wright State University Study. 10/05/90. Submits study entitled "Analysis of Sample of 4-Chlorophenoyacetic Acid." 3 pages. For cover letter see D-13944. D-13959B 05/23/90 Ruiz, Rennie Hunt-Wesson, Inc. Study. 05/23/92. Submits study entitled "4-CPA Magnitude of Residue Study." 3 pages. For cover letter see D-13944. / to'? 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 13 D - ^ e O B 06/06/90 Ruiz, Rennie Hunt-Wesson, Inc. Study. 06/06/90. Submits study entitled " 4-CPA storage Stability Study." 3 pages. For cover letter see D-13944. D-13962A 11/12/92 Grant, Duane Idaho Grain Producers Assn. Letter to Linda Fisher, EPA. 11/2/92. ongoing review of 2,4-D. 2 pages. Submits concerns with regard tc D-13994A 09/30/92 Hein, N. D. DowElanco Letter to Anne Lindsay, EPA. 9/30/92. Submits request to amend 2,4-D registrations to incorporate as terms and conditions of those registrations the agreement reached between the task force and EPA. 8 page cover letter; 4 attachments, 80 pages. D-13995A 09/30/92 Letter Shearer, Karen Rhone-Poulenc Letter to Anne Lindsay, EPA. 9/30/92. Submits request to the EPA to amend its Technical/MUP 2,4-D registrations to incorporate terms and conditions as outlined between 2,4-D Task Force and EPA. 33 pages. D-13996A 10/02/92 Letter Shearer, Karen Rhone-Poulenc Letter to Anne Lindsay, EPA. 10/2/92. Requests amendment of registered 2,4-D products incorporating the indicated change on page 7 of attachment 4. 1 page letter; 47 page attachment. D-13997A 09/30/92 Champion, James Riverdale Chemical Company Letter to Anne Lindsay, EPA. 9/30/92. Requests EPA to amend the company's technical and manufacturing use product 2, 4-D registration as per agreement reached between the Industry Task Force II and EPA. Cover letter 5 pages; 5 attachments 72 pages. 2,4-D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 14 d ~-<3998A 09/30/92 Champion, James NuFarm USA, Inc. Letter to Anne Lindsay, EPA. 9/30/92. Requests the EPA to amend NUFARM USA, Inc.'s technical and MUP registrations for 2,4-D. Cover letter 5 pages; 6 attachments, 71 pages. D-13999A 10/01/92 Mealman, W. E. Agro-Gor Corp. Letter to Anne Lindsay, EPA. 10/1/92. Request to amend Agro-Gor Corporation's Technical/MUP registrations to incorporate as terms and conditions as per agreement between the Task Force and EPA. Cover letter 7 pages; 6 attachments totalling 76 pages. D-14000A 10/01/92 Fisher, J. R. OMV Gruppe Agrolinz, Inc. Letter to Anne Lindsay, EPA. 10/1/92. Request the EPA to amend Agrolinz, Inc.'s Technical/MUP Registrations for 2,4-D. Cover letter 9 pages; 6 attachments, 67 pages. D-14001A 10/05/92 Mealman, W.E. PBI/Gordon Corp. Letter to Anne Lindsay, EPA. 10/5/92. Requests EPA to amend PBI/Gordon 's technical/MUP registrations as per agreement reached between the Task Force and EPA. Cover letter 7 pages; 6 attachments, 73 pages. D-14012A 12/28/92 Miller, Joanne EPA Letter to Larry Hammond, DowElanco. 12/28/92. Formalizes an agreement with the member companies of the Industry Task Force II on 2, 4-D Research Data which modifies a component of the registration amendments for Technical/MUP registration. 5 pages. D-14015A 11/06/92 Conner, John D., Jr. McKenna & Cuneo Law Offices Letter to Daniel M. Barolo, EPA. 11/6/92. Submits three items from the Industry Task Force II on 2,4-D Research Data for forwarding to the SAB/FIFRA SAP 2,4-D Panel. 696 pages. < D ial Review Public Docket lative Chemical Index 05/18/93 PAGE 15 , ,3A 01/18/93 Letter Tice, Howard W. Kansas Assoc, of Wheat Growers Hutchinson, Kansas Letter to Dan Barolo, EPA. 1/18/93. Submits comments on reregistration process for 2,4-D. 1 page. to64A 02/19/93 Letter Housenger, Jack E. EPA Letter to Howard W. Tice, Kansas Assoc, of Wheat Growers. 2/19/93. Submits EPA's response to Mr. Tice's letter of 1/18/93 (D-14063). 3 pages. 4094A 03/15/93 Conner, John D., Jr. McKenna & Cuneo Letter to Jill Bloom, EPA. 3/15/93. Requests meeting with EPA concering a 2,4-D mouse study. 4 pages. 4095A 03/24/93 Conner, John D., Jr. McKenna & Cuneo Letter to Jill Bloom, EPA. 3/24/93. Submits summary of the EPA and 2.4- D Task Force March 18, 1993 Meeting, as prepared by Larry Hammond, Chairman of the Technical Committee, Industry of Task Force II on 2.4- D Research Data. 5 pages 4096A 03/18/93 Meeting Minutes Meeting held on 03/18/93 Meeting requested by Larry Hammond 2,4-D Task Force Subject: Reduced weight gains in male mice carcinogenicity study. 15 pages. Participants: Jill Bloom, EPA Jess Rowland, EPA Marcia Van Gemert, EPA James Bus, not stated Clark Swentzel, not stated Ronald D. Wilson, not stated Larry Hammond, 2,4-D Task Force >, 4 - D Special Review Public Docket Cumulative Chemical Index 05/18/93 PAGE 16 D --* 4096A Continued William Mahlburg, Nufarm USA Jeffrey Charles, Nufarm/ Jay Mark Consulting Karen S. Shearer, Rhone-Poulenc Legal Judith Coombs, EPA Richard P. Dumas, EPA D-14113A 04/08/93 Conner, John D., Jr. McKenna & Cuneo for 2,4-D Task Force II Letter to Jill Bloom, EPA. 4/8/93. Submits male mouse bodyweight data and proposal for initiation of the male mouse oncogenicity study. 55 pages. D-14123A 04/27/93 Letter EPA Letter to Larry E. Hammond, DowElanco. 4/27/93. on male mouse oncogenicity study. 4 pages. Transmits comments *** END *** 3 , 4-D Registration Standard Public Docket Cumulative Chemical Index 10/27/92 PAGE 1 { 9592A 09/01/88 EPA Report. 9/88. Guidance for the Reregistration of Pesticide Products containing 2,4-Dichlorophenoxyacetic Acid (2,4-D) as the Active Ingredient. 105 pages. (Available from NTIS: PB89-102396). D- 9651A 09/01/88 EPA Report. 9/88. EPA Index to Pesticide Chemicals - 2,4-D D- 9653A 09/01/88 EPA Science chapters associated with the 2 , 4-D Registration Standards. 747 pages. D- 9702A 09/01/88 EPA 9/88. Pesticide Fact Sheet. 12 pages. (Available from NTIS: PB87-192712). D - 9893A 09/01/88 EPA Report. 9/88. Guidance for the Reregistration of Pesticide Products Containing 4- (2,4 - Dichlorophenoxy) Butyric Acid (2,4-DB) as the Active Ingredient. 105 pages. (Available from NTIS: PB89 114078). - 9901A 09/01/88 EPA Science Chapters associated with the 9/88 Registration Standard, "Guidance for the Reregistration of Pesticide Products Containing 2,4-DB as the Active Ingredient." 341 pages. D-10885A 10/03/88 EPA Report. 10/3/88. Pesticide Fact Sheet No. 179. (Available from NTIS: PB89-114078). 6 pages. D - 9874A 09/01/88 EPA Report. 9/88. Guidance for the Reregistration of Pesticide Products Containing 2- (2,4 Dichlorophenoxy) Propionic Acid (2,4-DP) as the Active Ingredient. 97 pages. (Available from NTIS PB89-114086). r 2,4-D Registration Standard Public Docket Cumulative Chemical Index 10/27/92 PAGE 2 D- 9902A 09/01/88 EPA Science Chapters associated with the 9/88 2,4-DP Registration Standard. 187 pages. D-10711A 09/01/88 EPA Report. 9/88. Pesticide Fact Sheet No. 180. (Available from NTIS: PB89-114169). 6 pages. *** e n d *** / ,4-DP Registration Standard Public Docket CTimulative Chemical Index 10/27/92 PAGE 1 L 9874A 09/01/88 EPA Report. 9/88. Guidance for the Reregistration of Pesticide Products Containing 2- (2,4 Dichlorophenoxy) Propionic Acid (2,4-DP) as the Active Ingredient. 97 pages. (Available from NTIS PB89-114086). D- 9902A 09/01/88 EPA Science Chapters associated with the 9/88 2,4-DP Registration Standard. 187 pages. D-10711A 09/01/88 EPA Report. 9/88. Pesticide Fact Sheet No. 180. (Available from NTIS: PB89-114169). 6 pages. *** END *** / 2.01 7?- ' D-11965 / Z j ' i r lo \ 8 June 1990 RECEIVED E. R. ZUMWALT, JR. A D M IR A L , U. S. N A V Y (RET .) WHTr D I T O or p e t o Pwcwr Douglas D. Campt, Director Office of Pesticide Programs United States Environmental Protection Agency Received Washington, D.C. 20460 Dear Mr. Campt: *-* teoij Many thanks for your letter of March 23, 1990.DlRECrof! OF KSJIQQe I attach copies of two documents which aver that Dow Chemical Com pany has never informed EPA or any other government agency of sig nificant concentrations of potentially carcinogenic materials pre sent in 2,4-D including other dioxins than 2,4,5-T and closely re lated furans and xanthones. If this is the case, should not EPA investigate and consider an emergency suspension of the use of 2,4-D? Si ncerely, / // E. R./Zumwalt, Jr. 1500 Wilson Boulevard Ariinaton, Virginia 22209 703/841-8960 Attachments JUN 20 1990 Zio a o i 7 3 MEDICAL TOXICOLOGY PARTNERSHIP A partnership consisting o f Profess,ona! Corporations Daniel T. Teitelbaum, M.D., P.C Daniel A. Goldstein, M.D., P.C. 155 M adison Street Denver, Colorado 80206 Phone (303) 355-2625 FAX (303) 355-3361 APR 2 3 April 18, 1990 E. R. Zumwalt, Jr. Admiral, U. S. Navy (Ret.) 1500 Wilson Boulevard Arlington, Virginia 22209 Dear Admiral Zumwalt; Thank you very much for your letter of 21 February, 1990. Please forgive me for the delay in my response. I wanted to wait until I received some confirmation in writing of the Supreme Court's decision not to review the appellate court ruling in Peteet v. Dow. It is somewhat difficult for me to respond to your letter directly. The issues which were presented to me as a medical toxicologist in connection with Mr. Greenhill's illness were somewhat different than those which were originally presented during the Agent Orange cases. Thus, Mr. Greenhill's exposure was substantially more clearly characterized than was the exposure of most individuals to Agent Orange. His illness was one which fit more clearly into the category of those illnesses for which a reasonable probability of association with herbicides had been developed over a long period of years. What I do think was important in connection with the Greenhill case and which may bear on the Agent Orange issue, is the fact that,in review of Dow's 2, 4-D documentation I found that there are significant concentrations of potentially carcinogenic materials present in 2, 4-D which have never been made known to the EPA, FDA, or to any other agency. Thus, in addition to the problem of the TCDD which, more likely than not, was present in the 2, 4, 5-T component of Agent Orange, the finding of other dioxins and closely related furans and xanthones in the 2, 4-D formulation was of compelling interest to me. Issues which were not addressed in the Agent Orange cases, that is what the companies knew about chloracne and its association with the chlorphenoxy herbicides and when they knew this was very relevant to Mr. Greenhill's case. I am sorry that I cannot address the issue of the Agent Orange cases and any illnesses which may be traceable to exposure to Agent Orange more directly. My association in the Agent Orange cases was April 19, 1990 Page 2 as a "non-causation" expert. In that litigation, I had occasion to review a large number of documents on the subject of knowledge, scientific information, and timing. I am convinced that the manufacturers of the chlorphenoxy herbicides have known for many years about the adverse effects of these materials on humans who were exposed to them. That knowledge was useful to me in formulating my opinions in connection with Mr. Greenhill's case. Whether it would be useful in other cases, remains to be seen. I trust this information will be useful to you. /mw CLOl'l ar: xrox ~eiecooisr 7017; 5-17-90 ; 7:56 ; 2019328965* 7035276037!# 2 SCOTT SALOWIN SCOTT AUDWIN. - R . M A M T . . O l U GILLAM J A C K SKOVUN BALDWIN BALDW IN & BALDW IN US NORTH WCLLINOTON WARs h a l l , t b x a s T C L C S M t M C (tlAI M ' A l S l April 10, 1990 g . QKAWLN | J 4 9 VIASMALL, T I K A t 7S S 7 | Mr. Bill Lew iB New Jersey Agent orange commission P. 0. Box 1717 Trenton, New Jersey 08607 HE: Greenhill vs. Dow Chemical Co Dear Mr. Levis: Pursuant to your telephone conversation vith my secretary, please find enclosed a copy of the internal Dow document (the Krumel report} which you requested. Since this document is under a protective order, portions of it have been expunged. If we can be of any further assistance, please do not hesitate to contact us. Kindest regards SBjr/ss Enclosure O I 7 (d a t w i o ' - ACrtUA e i e c o p i e r i u i f . o - r '- a u .> ic-gsii > R ! D REPORT uiaomoj- T fU03Z 70U0 f># 3 CRI HUMBER D O W C H E M I C A L U .S .A . V RESTRICTED: f*r ui* viihM Th* 0* Cfcil CM"r ut* -ui : 0 RGA.MIC CHEMICALS RSSSAflCH a* nr.7ii8l-ii11* 1 kOilclt*ou^hej^We7u^1M^ '>&le-r b 0 M fl 0 0 A. ST '-T Y 0 ? ?H5 FORMATIAN AND Rg.VPV" n r TygrruTtr-gg t\ " u ? _______________P30CSSS FOR 2 , 4 - 0 _________________________________________________________ urmi* -it ST Ra c e : in u t : RI.CRT AUrfMaBH. fir! ..EffrlWilMlf ti i -R'^ r ' J u a Bl a - j < u p u . k ? s-- !, i **'**wn % b * D E S C R IT T IV I SUMMARY WITH CSn CLUSIOHSi </r TTib nel INTERIM __nMpwt 1,1 riMii end moJnlyi ir NE'V r i vis-* ( U lw ia a hi* * m * data ka, t a i ta a a 'lla r ra iata M p a r ti, garant t a i p a klla a tia n t) Shortly after th startup of th 2,4-Dwprocs-in-W8building, a new and unexpected class of nonacidic'impurities were isolated in which two of the major components-were'tetrachloroxanthone and*p octachiorcspirobixaathane. These irap\iritie1'*T75rmning"proBiama3 in the subsequent formulation of 2,4-d as amine salts. q a project was started to learn th source of these impurities ind^ri. methods for controlling then. Zt was found that the impurities ars formed mainly in the 2,4-0 reaction step by several difierant^Zi routes vT* A number of techniques were evaluated for removing the impurities were totally successful. None of the treatments pjd DISTRiSUTtOMi Jt 4 Iu4 a a e OiHitr*noN t . a -- * Ditfribvfd* list n r ^ \ <1 r i DOW 9i:77'jr SENT b y : XEROX Telecopier 70175 5-17-90 7:57 : cca 1 2019328965 70352760375# 4 r OC/78--.85' . introduction TABLE OF CONTENTS Pace 2 RESULTS AND DISCUSSION------------------- ---------- -- (a) The Mechanism o TCE Formation -- -------------- -- - (b) The Distribution of TON in the Process----- ----- - (c) ' Reduction of TCX by Chemical Means -- -- (d) Reduction of TCX by Physical M e a n s ---- ------- -- 9 lo 3$ 30 38 GENERAL CONCLUSIONS------------------ _--------- ---- --- SAFETY i E C O L O G Y ----------- ------------------ ---- ----- 50 SO EXPERIMENTAL------------------- ------ ---....------- --- 51 ACKNOWLEDGEMENTS 56 REFERENCES 57 v lO 1 7 & nri.to7.Moa w ^ t .a v i> \ 9i < v v y * v i vv - 2- 4UI9W 4VVW v v v fc i v v v OC/78-33 INTROIL'CTIOM A process for preparing high purity 2/4-D was started in May 1977 nt, 943 Building. The high purity mol tan acid is transferred hy pipe line from 948 Building to 489 Building where it is formulated into stars and water solubla amine salts. Starting in lata October 1977/ precipitates vara observed regularly in diluted amines formulations that were found to ba made up of a number of impurities associated with the process but that vara never detected during laboratory or pilot plant development work. Zn addition/ these impurities were not found in the old 489 Building 2/4-0 process. R. Mciaehlan^ analyzed the precipitates and found 1/3/5/8-tetrachloroxanthone (I: TCK) / 1/1'3 #31 6*6 '8 ;8 '-octachloro-9/9'-spirobinanthene (12: OCSX), and marginally soluble salts of 2/4-0. (ID v A screening program in the plant showed TCX et levels of 200-500 ppm in the crude reaction mas8 / the recycle solution/ and in the final product. Laveis of 1000-2000 ppm were found in the solvent and as much as lot in the still tars. iciachlan1 analysed a sample of ;unnari-d in table 1. still tars and his results are O i'i^ stNi UY; XEROX Telecopier 7017; 5-17-90 - 7:56 ! .op*.. . ' -3- 201 9328965- Table 1: An Analysis of One Tar Sample 7035276037!* 6 OC/78-35 r 4 1 Approximate Ferrantaee Comment DC?"*' 2.4-0 t c :: (i) Diehierophenyl- 9 diehlorovinyl ether Dichlerophenyltrichlorovinyl ether 601 25% 0.5% 0 .01 1 .S1 1 .1 % 1 .2% 0.81 Main Component Prom a heat exchanger leak (Dovtharm J) raw material Product Hxn product Plus: *t lesst eleven other minor components structurally similar to the above. See Ref. 1 for details. v % 9^01^0 Igyi!. 8 " a c u v a eiecspier ryil- 3 - 1 r-3U JS OC* 'U19420303' I U33L 10U01'# ' OC/78-85 A project was started to study the formation of TC2C and OCSX in soma detail to learn mora about their formation and fata in the process O because it is r.ot obvious how they are made. Several months aftar starcirc this study, another sionifleant impurity was found in the ^ produce and, to a leaser extent, in the tars. It was identified 3 as (Ills "8-S") 2,2* ,4,4 ,5' ,7,7' ,9-octachlarosairo-(beft2Giuro (3,2-b) i benoopyran-ll, 9' -xanthenej . CC r\ 1^1 V^ V 5bNi br:.XEROX Teiecopier 7017; 5-17-90 7:59 2.01 3328965' CCS 5 Tracer ta n t S ica R eactio n s ClCH2c : 2Ma + NaGH -------- HOCHjCOjNa * N a d G iveslie Acid fUaPZ'fOUO II# o oc/78-.ar H O W n i'iin ! ON* Ci + CljCHCCjNt "Bia 2,4-0* The reaction is performed in two stages by first reacting 2.2 malaa of DC? with 1.2 moles of caustic (added as SQ% NaOS) to fora a solution or NaOCP in DCP. . High purity 2, 4-dichloropher.ol (2,4-DCP) made by the chlorination 0: phenol with sulfuryl chloride in the presence of reCl^/Diphenyl sulfide catalyst is used with chloroaeetie acid (MCAA) made by the oxidation of vinylidir.e chloride to sake 2,4-D as shown above. The typical raw materials analyses for each is shown in Table 2. Table 2 1 Tvolcal Raw Material Analyses for the 2,4-D Process v DC? MCXA. 2.4-DC? 2,6-DC? Other Chloroehenols 98.St ^ 0.8* *0 ,S* MCAA Dichloroacatie acid Chloromaleie acid h 20 99.0* 0 .2* ^0.05* <1 .0* 2.01`SQ' tini o r - A t .w x e i e c o p i e r /u t / i 5- 1 7 - 9 0 ; 7 : 5 s cca -6- 201 9320965** 70352760371# 9 OC/78-3; T a -j 0 A rapid initial screening o the toxicity.of purified TCX and tars gave the following results. Tar (contains 3-55 TCX + OCSX) Purified ?c:: Oral L3S0 fsinale dose) >5g/Kg >4g/Kg Skin/Eve slight transient initiation. Chlcracr.e response after 10 applications of neat tars. v not irritating. Chlcr* acne response after 10 applications of 11 solution in CHCI3. 22&> ociMI DT' AttiuA . e!ecopier v17; 5-11-90 uu ; OC.*' 201932895-* 7 '4>Z 7 U d f i * 1 U OC/78-Q3 I fKOCtSS I SENT b y : XEROX iecopier 7017; 5-17-90 : 0:00 i 'aca - 8- 2019328965- 7035276037;#11 OC/78-83 f * VUftZ' ^ O g These results art encouraging from 4 plant hygiene standpoint, but mcra data is necessary regarding long tara eiiacts. When the im purities ware first discovered in the plane, the still was used very occasionally The still was originally added to the process as a way of purging contaminants out of the stream to maintain high quality recycle solvent. At this point* tar impurities made up 0-75* of the precipitates formed in diluted amines formulations. M About February 1978* the capacity of the still was inertased and the average levels of TCX levels dropped to *50 ppm in the crude reaction mass and product and to 200-500 ppm in the recy- cied From the period of March-May 1978* the ability to produce quality 2*4-0 continued to improve and the amount of tar im purities found in the dilution test precipitates dropped . The balance were sparingly soluble metal salts of 2*4-0 and seme new impurities called Complex 1 and Complex 2* two of which are shewn below (IV k V). * In July 1973, the still capacity was increased and eriorzs gained at understanding the parameters affecting formulation quality by 5. Siegel (CCS) , S. Schell (Production 489), ani J. King (Formulation - 9001 31dg) and their co-worhers have greatly inoroved ScNi BY: XEROX 7e:ecopier 7017! 5-17-90 8=01 2019328965- 7035276037: *il 2 OCX -9- OC/78-3 i \ tha consistency with which 943 Bid?. 2,4-D cat* ba formulated. Based user. partition coefficients *nd dAta on tha rata o foraation of TCX tc ba d i a e - s l a t e r in this revere, K. E. First4 (Freeses Engineer . generated a computer program which predicted that by distilling of recycle the steady state level of TCX in tha product would be ^10 pta and in the recycled pare the TCX level would ba ^40 F==. . The purpose of this report is to present data on the foraation and fate of tha impurities in the 2,4-0 process. In addition, tha results of experiments ained at reducing or eliminating the impurities by chemical and physical methods will be presented. RESULTS AND OISCUSSICX This study was divided into tha following sections and the results of each are discussed separately. (A) The mechanism of TCX foraation. (B) The distribution of TCX in the process. (C) Reduction of TCX by chemieal means. (0) Reduction of TCX by physical means. Although there art many impurities formed in this process, it was decided to focus the research on TCX for several reasons: (1) The rata and mode of formation of TCX was the most predicable of the major multi eye lie impurities; (2) it was a major impurity; (3) a pure sample was readily obtained (by 0. Humbert, Anel. Lab) ; (4) the analysis is not complicated; and; (S) structurally, it is the simplest of the multieyelic impurities. a Pot# y M oq SENT by; XEROX Telecopier 7017; 5-17-90 : 8: 01 : cca 10 201 9320965-* 7035276037: 1 3 OC/73-8S `(A) The Mechanism of TCX Formation A brief search of the literature including Chemical Abstract* shewed that the xnr.thcr.e ring system is farmed from e number of reactions. 3 A common synthetic reaction is shewn below in which the -X is included 0 OH 0 to shew the orientation of reaction. Xanthone is formed along with other products frea the pyrolysis of o-chlorofcanzoie acid, salicylic acid, aspirin, o-phenoxybenzoic acid, and salts of the carboxylic acids.. Most of these cyclisations take place in the presence of acidic catalysts such as P^Oj, AlClj, Acetic anhydride, or sulfuric acid, xenthane is prepared in seasonable yield6 by the pyrolysis of phenol salicylate with or without a catalyst. The ease of formation of ring systems that are structurally similar to xanther.es is most clearly shown by the formation of fluorescein and flucrascein dyes, fluorescein7 is made by reaction of phthalic anhydride and resorcinol as shown on the following page. v 3-01^7 \ DOV/ 2C7745 S.ENT BY: XEROX ~e!ecopier 7017; 5-17-90 ; 8:02 O C a - 11- 2019328965- 7035276037 :#H OC/78-3 if OB g Phenoishthalein it also made by this process using pheno 1 instead of resorcinol. t ao ig g ' ~~n btNl By: XEROX !ecopier 7017; 5-17-90 i 0:02 ; . cr. -12- 2019328965 7035276037 !#1 5 OC/7S-85 M LLM . Moa V Th ese background dace give ama important clues as to reaction mechanisms as will be whown later in the raport. % n o w n c* -a--* stNi ot; xtnvx, i'eiecopier ''Ui-'i 5-17-90 ; 8`-02 5 CCS, 13- 2019328965 7035276037:#16 t OC/73-35' I- criar to understand the pathway of TCX formation, a srias of ampoule tests were' performed ts determine which chemical* and/or combinations give rise to TCIC. Table 3 summarizes tha results of study. A saries of ampoules ( 25 ail capacity} wara charged with 3-5 epos of mixtures in molar ratios as shown inTable 3 and wara ? heated in an oil bath o 72 hours at 150*C. The sources of the chemisais ware as follcwsi 2,4-Dj High Purity Rhone-Progil Acid DC? Doubly di stilled 948 Bldg material Parc NaOK ' : /lGlyoxal t Giyoxylic acid i Tetrachlorc ethane * l> Reagent aatarials (50:50 1,1,2 ,2 - i 1,1,1,2-isomers) v % ^ O l^ o u k i oT - AcnijA , e i e c o p i e r fu i f 3 - i f - su < o* uo P C S "50- zuimoaea-* uasr/eua'f ri OC/78-S5 GZ2TERAL CONCLUSIONS TCX and other non-acidic inpurities ere formed chiefly in the reaction etep of tha 2,4-0 by several routes. A number of attempts to chemically and physically remove these species have sat with limited success. *` SAFETY 6 ECOLOGY 2 ,4-Diehlorophanol, 501 NaOH, and chloroacetic acid are highly tdxic ar.d corrosive raw materials* Whan handling, tha protective clothing included lab coat, rubber gloves and goggles, and whan possible, all operations were performed in a fume hood. A number of operations were carried out at elevated pressure which required the use of a face shield and secondary shielding in tha hood. All waste samples and solutions wara sene to the burner for disp*osal. & ^-(7^1 3bN'< BY- XEROX ~eiecopier 1017; 5-17-90 S: 03 201 9328955' OCX 51 7035275037 :18 . OC/78-35 Tha ?rgsaraslcn and Workua of 2,4-3 O The :11cwin? is a general dascrlpticn of the procedure used to ^ prepars ana isolate 2,4-D when simulating 948 Bldg. A 1 liter in round totton flask equipped with a bottom drain, two dropping funnels, a mechanical stirrer, a thermometer, and a distillation head was charged with 17 9g (1.1 moles) of 2,4-DC? and 48 g (0.6 moles ) of 50% NaCH. The flask was heated with a heating mantel attached to an I2X Thamewatch controller. The reactor contents were heated while seirring and a DC?-watar azetrcpe was distilled out. The distillation was continued until enough water was removed so that a temperature of 130*C could be achieved. Normally 3-10 ml of H^o and 2*3 ml of DC? were removed. The DC? was returned to the pot. Then 47.3g (0.5 moles) of melted MCAA and 40.Og (0.5 moles) of SOI eaustie were con-added from the two dropping funnels during 50-60 minutes at 130*C. The rates of addition were carefully controlled so that neither added reactant was signi ficantly in excess of the other. Hater and DC? continuously distilled out during ths con-add and the DC? was returned to the reactor. After tha addition was complete, the reaction was heated an additional 60 minutes. About 43-47 gms of HjO was racovered in the con-add tec. At tha end of the jpest reaction samples of the viscous crude reaction melt vara token into ampoules,`if desired. v The work up procedure for isolating the 2,4-D is as follows (The amounts used assumes no samples were taken aft&r reaction) . The reaction muss was diluted with about 500 ml of water, heated to boiling to ensure complete dissolution and the pH was adjusted to 5 . 2 0 . 2 with about 12 ml of cone HCl. The solution was than extracted with six 150 ml portions of perc at a temperature of >90*C to removg the DC?. Occasionally 50-100 ml of additional HjO was necessary to keep .all - the solids dissolved. Th a *** 4 at , OOVV2UV78G SENT 0Y`. XEROX ~eiecopier 7017; 5-17-90 ; 8=04 o ca 52- 2019328965-* 7035276037:#19 OC/78-35 te beili..? and any traces of pere vera dittili* off. The pH of tha in to a beafcaz. Tha risultine brine was discarded. The 2,4-9 was rsslurried in 25a ml of hot distilled HjO In the pot and washed in this manner two tines. The final ps of the aqueous layer was 2.7-?.?. Tha 2,4-0 was recoverad and dried overnight at, ambient temperatures. The analyses of product and intermediate streams vers performed by personnel in the 948 Bid? quality control laboratory* Tha analyses . for ic:c. OCSX, and "8-5" were performed as described earlier8 "be Carbon Clean u p of Molten 2,4-0 v . glass pressure apparatus was assembled in which molten 2,4-D was umsed onto a carbon column (downflow) . Tha apparatus is shown chematically in Figure 10. The flaw of 2,4-0 was controlled by or.troll in? the pressure drop across a capillary tube. To handle 2 - 0 1^3 at: dt: AtKUX reiecopier 7017! 5-17-90 : 8:Q4 ; .. CC*.- " S-i- 2019329965' /U95Z76UJ I'#iU cc,:s- Figure 10: \ Schematic Drawing of the apparatus used to traa Molten 2,4-0 with activated carbon r tfOVV' 2U 7788 c /* t* ' Iv. SENT by: XEROX Telecopier toit: 5-17-90 : tj:u5 S3 2019320965- 7035275037921 OC/73- 5 molten 2,4-D reliably and effectively, required at least 10 psig/ a10C-10S*C to avoid lashing and freezing problems. The 2,4-3 and a slight excess of water were placed ia the feed tank and heated to 110*C. When the entire contents were melted the valve on the bottom of the column was closed, the column was filled with sol tan acid to 1 " above the top of the carbon, and the system stood for 60 min. The pressure drop across the capillary was adjusted to 7 psi (vlo ml/min flow) and the valve on the bottom of the column was adjusted so as to maintain the liquid level above the carbon bed. The results are shown in Table 10. V Slc? ^ 5 r sc-, dt- atttux eiecopier vul /: P-iv-au i 0-U3 t >0Ca t " ' -So zuisozosos-' I Utf W4 I V VW r >v r t * OC/73-35 ACKNC^SDGSMSNTS The authors wish to thank 0. Hurharr, R. Maciachian, T. Evans, G. Jevei-, p. Schlceraann, and their colleagues for their analytical support. The .assistance of K. rirst and his process modeling efforts are also acknowledged. C o * M IL S V btNi y: XEROX Telecopier 7017i 5-17-30 ; 8: 05 ; cca 201 3328965' 7035276037!#23 R s i n c e s 1. ?.. Mciachian, 0. Kumbert, G. Kalles, Ai 73001C1, to he iaauad. .2. ?. Kaliar, at. si., HET I-2372-(l8) February 9, 1973. 3. 0 . Humbert ae. al., unpublished results. 4. Unpublished results to ate. 3. Sail*tain I, 17 354. 6 . Organic Synthesis Coll, Vol 1, Pg. 552. 7. Seilstein 19 (3) 222, Merck Index 9, 4040. 8 . Morrison i Boyd Organic Chemistry, Allan and Bacon, Boston (1953) Pg. 684. 5. . (a) S. M a d e an, AL-75-20021. (b) V. Stevens, Communication, Inorganic Cham. TSfiO. 10. D. Humbert, unpublished results. 11. K. t. Krmel, 1R 78-74, 8-13-78. 12. H. F. Bnst, OC 0730013-2, 2-26-73. 13. I. R. Dhingra OCR lab Book OC 327-5, p, 22-67, 1972. 14. O. L. Fern, PE 73-10, 4-16-73. 15. F. G. Aerstin, private discussion. 16. X. L. Kzuael, OC 78-17 LR, 39-78. 17. s. Siegel, Results to be published. 13. Absorption Handbook: Issued by Activated Carbon Div., CilgcnCorp., Pittsburg, ?A. v LABCRACCRV NOTEBOOK REFERENCES: R. F. Arnold OC 417, Pg. 109-150, OC 640 Pg. 1-73. je. L. Krmel OC 559, Pg. 95-131. * SENT b y : XEROX Te*copier 7017i 5-17-90 ! 806 201932896 5- \ o DISTRIBUTION O JO c: ^2 :::o M^ A. . Yca.ic A* J. Vocal P. w. owan S. Sia?el w. McGaa *S. 0. McGra^c *S. W. Tohay 948 Building R. Youn? E. Hoy w. rocharyill "A. luack 834 Buildir.o *D. S. Morehouse *a. T. Busselli 0 . Woodward V. Kabarstroh s. Parsay J. Maddox 5 **i Buildinc *S. V. Lucma *w. Westovar 0 . Hunaert *3. MacLachian G. Javatt *C. Mandoza a. Darsnah, 439 2020 Building *X. E. Pruitt 1303 Building L L Smith 3. J. Gorxinski 0. xcciba *3 . Sehvatt 9001 Building *R. 0. Moss J. Xing *X. Saymour *C. S, Williams Bahia, irssil T. L. XeaAsdy r. G. Aerstia *P. Sehloaaana R. Manfrom * 56$ Building *R. R. Bumb *M. J. Mints 633 Building *J. Slaiveiss X. E. First ^ M ^ J S a z A. 9008 , 7035275037#24 1 D-11966 / ^ q - > P&p'jZ' f. * ft E.R. Zumwalt, Jr. Admiral, U.S. Navy (Ret.) 1500 Wilson Boulevard Arlington, Virginia 22209 Dear Admiral Zumwalt: Thank you for your inquiry about Agency consideration of the carcinogenicity of 2,4-D. The documents that you transmitted with your letter, which refer to the contamination of that herbicide with potentially harmful dioxins, furans, and xanthones, are being reviewed by Agency personnel. The copy of the "Krumel Report" which documents the presence of xanthones in 2,4-D and Dow Chemical Company's efforts to remove these impurities, while incomplete, is especially interesting, and the Agency will pursue efforts to obtain the unexpurgated report. I would like to provide some background by way of explaining the Agency's responsibilities in evaluating the need for cancellation or suspension of pesticide registrations. As I mentioned in my letter of March 23, 1990, the Agency plans to make a decision on whether to initiate a Special Review of 2,4-D after it receives two important epidemiologic studies that will add to our understanding of the effects of 2,4-D use. The \ Special Review process is an intensive assessment of the risks and benefits related to the use of a particular pesticide, ancris triggered by indications of an unreasonable adverse effect (i.e., evidence of carcinogenicity) arising from that use. A Special Review culminates with a determination on whether a change in the registration of the pesticide is necessary to mitigate any unreasonable risks. Possible changes to the registration include requiring that applicators of the pesticide wear protective clothing, placing restrictions on who may use the pesticide, or cancelling the registration altogether. In the case of 2,4-D, the Agency has decided that an outside panel of experts should be convened to evaluate the body of evidence relating to carcinogenicity of 2,4-D. This approach is necessary because of the complexity of the issue, the lack of direct causal evidence, and the contradictory and nonspecific nature of previously reported human studies of 2,4-D exposure and cancer incidence. The panel's consensus on the cancer-causing ability of 2,4-D will be used by the Agency to determine whether a Special Review should be initiated. 52.0(99 i -2- The Agency believes that the two new epidemiologic studies may yield information which is more specific for the association between 2,4-D and cancer than earlier epidemiologic studies. When the Agency published its decision to convene an external panel of experts to advise the Agency on 2,4-D's cancer-causingpotential, the two studies, one from Nebraska and one from Minnesota and Iowa, were expected to be available in December 1989 and March 1990 respectively. The release of both publications was subsequently delayed, causing a setback in the Agency's schedule for the weight-of-evidence review. We have recently learned that the Nebraska study will be published in the journal Epidemiology in September 1990 and may be released to the Agency prior to that time. The Minnesota/Iowa study will be submitted for publication in September 1990. Depending on the policies of the journal to which the report is submitted, the Agency may be able to receive an advance copy'after editorial changes are made. The advisory panel could be convened after that time. Once the studies are available to the Agency, they can be distributed to the panel experts along with all the other information to be included in the review. Such materials include earlier epidemiologic studies, reports on animal testing, information on applicator exposure, and literature on the contamination and mixture of 2,4-D with potential cancer-causing agents. Evidence of early and present-day contamination of 2,4-D products is considered to be essential to the evaluation. The Agency will include whatever data it has received from required studies, along with published articles, and the Krumel Report if it is deemed applicable. The panel will advise the Agency on its conclusions about the carcinogenicity of 2,4-D. The Agency will use that determination to decide whether or not a Special Review should be initiated. If a Special Review is initiated, the Agency would make an in-depth evaluation of the risks associated with use of 2.4- D and the benefits afforded society by its use. If risks are determined to outweigh benefits, the Agency will take steps to modify or cancel the registrations of 2,4-D products. Under the Federal Insecticide, Fungicide, and Rodenticide Act, the Agency can effect the emergency suspension of a pesticide registration if it determines that such an action is necessary to prevent an imminent hazard during the time it would take to determine that the pesticide registration should be cancelled. The Agency has determined that the continued use of 2.4- D during the time that it will take to decide whether a Special Review is necessary, and the time that would elapse between initiation of a Special Review and a regulatory decision, does not pose an imminent hazard. Therefore, the Agency does not believe an emergency suspension of 2,4-D products is appropriate based upon available information.  -3I hope that this information is useful to you. I appreciate your interest in the Agency's regulation of 2,4-D, and encourage you to contact me again if you have further questions or additional information. Sincerely yours, : A / y'-""*" -- -- A* Douglas D. Campt, Director O f f e of Pesticide Programs H7508C:SRB:J.Bloom:WF3-1N4:308-8019:08/10/90