Document 85EG94LvYjKwkew2j7xbwoRga

Monsanto -- Dept, ol Medicines Environmental Health _g.J. I.evinskas, A2SA ( 4-210* August 29, 1980 "*" MSDS: PCB'S TO j.h. Craddock, G3WA SEP 3 1980 pA fd) D.R.^Brphaj# A3MB B26A >CS. Nelson, G3WA J.R.G. Ortiz, E2ND G. Roush, Jr., M.D., R.A. Stohr, B3NJ A2SA Suggested minor changes have been made on the draft which is being returned. The following additional changes should be incorporated. Emergency and First Aid Procedures Add as Note to Physician under: Skin - If hot PCB's are splashed on skin, thermal burns may be produced. Inhalation - If electrical equipment arcs over, PCB's or other .......chlorinated hydrocarbons in the dielectric fluids may decompose to produce hydrochloric acid which is a respiratory irritant. Add at End of this Section: There are literature reports that PCB's can impair reproductive function in monkeys. Another published report states they cause cancer in rats, but a recent report from the National Cancer Institute stated the PCB AROCLOK 1254 was not carcinogenic under the conditions of their bioassay. The consistent finding in animal studies with PCB's is that they produce liver injury following prolonged and repeated exposure by any route, if the exposure is of sufficient degree and dura tion. Liver injury is produced first, and by exposures that are greater than those causing reproductive effects and that' alleged to produce cancer in rodents. Therefore, exposure by all routes should be kept sufficiently low to prevent liver injury. Two other comments should be noted. 1. Under Inhalation in Physiological Effects Summary, it is stated that 42t chlorinated material does not produce iiver injury, but 54 chlorinated material does. That is based on 17 exposures, each of 7 hours duration, at 8.6 mg/m^. In m iom truv. 9/7*1 MONS 002359 J.H. Craddock, G3WA August 29, 1980 l'age -2- light of studies done since then which show that PCB's invariably attack the liver, it is very probable that longer exposures by inhalation to the 42% chlorinated material would produce liver injury. As a result, the statement on the draft MSDS could be misleading today, even though it was true when written and is still valid for relatively short-term exposures. Therefore, the following statement is proposed. ______ Inhalation: Animal experiments of varying duration and at different air concentrations show that for similar exposure conditions, 54% chlorinated material produces more liver injury than the 42% chlorinated material. the 2. Contaminated clothing is treated differently under Occupa tional Control Procedures (Skin Contact) and Spill, Leak t Disposal Information. The former says "launder before reuse". The latter (item 6) says "disposed of in the manner prescribed by EPA". Which procedure is to be followed? Laundering will result in a PCB discharge to some waterway. alw enclosure Levinskas MOWS 002360