Document 9wMwwdzXqOw0zwj8EmyoLnbV

'Monsanto LAW DEPARTMENT I !>;975- ..H. to May 14, 1979 TSCA Section 8(e)Evaluation-- 2,*JChlorophenol t; C. F. Callis W. R . Corey T. L. Gossage E. L. Head W. Kilbourne G . Roush Memorandum to P ile C O ^ N F I I K J 'E ^ f r l A t 0" SUBJECT TO PROTECTIVE ORDER. On May 11, 1979, the above-named persons and the undersigned met to consider whether an immediate notification to the Administrator of the EPA, pursuant to Section 8(e) of the Toxic Substances Control Act, is required with respect to chlorophenol. The April 20, 1979 issue of the Federal Register, at M FR 23582, indicated that copies of a report, "Bioassay of 2, ,6-Trichlorophenol for Possible Carcinogenicity (T.R. 155)M were available at the National Institute of -Health. The notice stated that the study concluded that ", . . under-the conditions of this bioassay, 2,4,6-trichlorophenol was carcinogenic in male F 3^ rats, inducing lymphomas or leukemias. The test chemical was also carcinogenic in both sexes of B6C3F1 mice, inducing hepatocellular carcinomas or adenomas." It was pointed out that Monsanto's technical (93%) 2,^-dichlorophenol, at the present time, contains l-^iS 2,k ,6-trichlorophenol. This product is sold to five customers. To the best of Monsanto's knowledge, this product has been manufactured and used in the United States for at least *J0 years, with no known adverse effects on health or the environment. A project is underway to improve the purity of the product to 97% 2, ^-dichlorophe^ieJ^f This, wi tnhje contained c2,,hU ,o6-ttrriicchmloorrooppnheennoil to lessyyttnaSn 100 p p m ^ ^ K l i ^ $5,000,000 project is expected to be completed in October- 1979 Since the product has been used for a number of years with no known harm to health or the environment, it was felt that the FederaT Register notice did not contain sufficient information to indicate a substantial risk of injury to health or the environment, or to warrant other precipitous action. Dr. Roush was requested to obtain a copy of the report and report to the group after having reviewed it, It was mentioned that the product (93% 2,4-dichlorophenol) may contain monochlorodioxin, dichloroaioxin, trichlorcaioxin and tetrachlorodibenzodioxin in trace amounts. After a process change (elimination of caustic) completed in April 1979, the product contains no detectable dioxin (at a detection level of 10-20 ctb). In view of the relatively long experience in manufacturing ar.d using this product with no known- adverse effects, it is not felt that this information indicates a substantial risk of injury to health or the environment. 2- - A waste material generated when the product is produced, described' as chlorophenol still bottoms, contains all eight chlorodibenzodioxins in concentrations varying from 0.1 to 1,000 ppm. Disposal of this material has been accomplished in the past by 200-fold dilution with non-dioxin containing residues, and shipment to Baton Rouge, Louisiana or Deer Park, Texas for destruction by high temperature incineration. This method of disposal is being evalu ated to determine its continued viability. In summary, it was concluded that, since none of the information evaluated reasonably supports the conclusion that 2, iJ-dichlorophenol presents a substantial risk of injury to health or the environment, no notification to the EPA is necessary.s-Dr-:-- Pouch will-- report* to the- gy-QUp--3rftH?r-jror has reviewed the NIH rqpert on t-hc 2, 6~-tri ~ chlnrophpnnl . C U/vkf tfci A & V M J L o 4 oMM- f f P Apt JkAAtfcj*. 2)ji. W *0!HJLA'L- u HJL . Phocion S. Par^ - A Or. a u . / OY jJ a d d j b u M ^ V