Document 6ReJqyNZJxJq1aN4e4YMQbGD4

() ^* *) * **r3 *1 < t i' fiz.3o.,U' aub caiiS.'rs aw KiiiiLiG a/ ciiioruiariD sir hi. LW i'H ShVIRONH ii,T Al' I:.'MJ3fRI;J. BICfISr a30.`Ui'0:C3J, CHICAGO, MARCH 21, 1969 Robert L. He ten 1 f f'rom the background data presented it appears that something of the order of SO million pounds of polychlor biphonyIs (PCB) are produced annually. These products contain from 3 to 9 chlorine atone p-r molecule and boccoto increasingly inert and stable to environmental oxidation with higher degree of chlorination. However, about hall' the production is in the 3-chlorine a ton variety (Aroclor-.-12h2). At first thought it seams unlikely because of the major uses of PCB in capacitors, transformer oils, heat transfer fluids in closed system*, that these materials could be the source of the substantial degree of envlronmantal contamination reported. However, about 1,0 million pounds annually is stated to be used as plasticisers, hydraulic fluid, adhesives, and in carbon paper, from this amount a very substantial percentage must escape into the environment as vasts. Because of the apparent high stability of PCB, amounts entering the environment would 'be degraded very slowly and it seems possible that at least lOmillion pounds annually may bocome environmental contaminants. Since the PCB's were introduced commercially in 1?2? there have bean 1*0 years of production. If this has avsragod 50 million pounds per year, then about 2 x 20? pounds hare' been a made and perhaps 2 z ID pounds have entered the environment* Because of " the apparent stability of these compounds mos* of this amount aiy still ba circulating in the global ecosystem and this is suggested by the levels reported by Holmes _et al. (1967) and Riesbrough _et al. (1963) in animal tissues which are quite comparable to those fouid for EOT. Both PCB TOWOLDMON0046181 u and MI are extremely stable and water insoluble and have been produced in roughly the same total amounts over the past 30 years. l'hus it ssesis quite reasonable to conclude that tho environmental contamination described for PCS is due to waste amounts of these coraooundo iTiis, coupled with the thorough evidence from mass spectonetry strongly sugg-e-j that there is an important environmental quality problem involved in wastes of PCB. nxoerimnntal Work Planned jtt Industrial- Biptssjt. -- ihis laboratory is highly experienced and seems quite comoetent to provide standard data required by FDA for evaluating the safety (or ' hazard) of agricultural or industrial chemicals. Xhe long term feeding studies on rats and dogs will doubtless serve to indicate the chronic toxicity hazards of chronic ingestion of the Fun at ppm levels and this will almost certainly result in severe liver damage at some reasonable level. Xhe chicken reproduction investigations at 0,,Q1, 1, 10, and IDO ppm should be considerably more meaningful particularly in regard to studies of egg batchabilLty, shall thickness, etc.- - While the fish toxicity investigations will be interesting, I cannot see that they are particularly relevant or necessary at this tine and I would think this data could bs obtained iron Kish and Wildlife investigations, ate,, and will undoubtedly be forthcoming, unsolicited. i Conclusions and Suggestions..-- - It seema to the writer that the evidence regarding PCB effects on environmental quality is sufficiently substantial, widespread, and alarming to require immediate corrective action on the part of Monsanto. The defensive measures presently indervay will do little if anything to ^ A. . N EV 047131 . ------- ------------------------------------------------------------------------------------- 740438 TOWOLDMONOQ46182 refute the evidence already presented. I would surest the following; 1,. A substantial analytical program to monitor air and water effluents from Kansanto plants producing ?CH and also thosa of major customers. 2, Prompt correction of effluent conditions where PCS can ba demonstrated.. . _ 3. Sorioua consideration of curtailing sales of PCB fer usee such is plasticisers, adhesives, and carbon paper where waste is certain to ent-r environment. . It. Review of disposal and recovery methods for FC3 in capacitors, transformers, heat transfer fluids, and hydraulic fluids, fmphasize to customers importance of preventing environmental contamination. 5. Thorough investigation of environmental fates of various PCS's including photochemical oxidations, chlorination in water systems, etc. ' 6. Biochemical and electron microscopic study of levels of PCB ingestion which causa proliferation of endoplasmic reticulum and induction of multifunction oxidases in chickens and rats (perhaps these are partially Included in present Industrial Biotsst experiments). ' 7. Begin investigations of possible biodegradable substitutes for PCB* s as plasticisers, adhesikes, fire resistant hydraulic fluids, etc., anticipating lots of these markets as a necosaary corollaiy of environmental problems.. Are, far example, chlorinated diphenyl oxides or diphenyl sulfides suitable for theae uses. They should be considerably more biodegradable. NEV 0271B% 740439