Document B5GwM2eqOJkJ3orY8yKBmoZGj
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April 13* 1970
Dr. Harry VJ. Ha ye 3
Director
Pesticide Regulations Division.
Agricultural 'Research Service
U. 3. Department of Agriculture
Washington, D, C,
.
Dear Dr. Hayes:
Perhaps you are familiar v.'ifch the current widespread interest in polychlorinated biphenyls and theix* re ported nresGnce an the ecosystem. There arc a number' of -publications that ihcic.uto one possible courcr be the use oi` those materials in pesticide formulatione.
In the early IgyO'o there v/ere several publications (see enclosed copies of two) v/hich. indicated that "chlorinated polyphenyls" improve the residual effect of lindane and possibly ciilordano. To our knowledge there was never any recontnendation by anyone for their use on food or other crops. The principal application was to stray metal or paintod surfaces to increase the effectiveness of tho active pesticide against flies, ants, roaches, silvorfish, etc.
For a number of years our technical bulletins con . - tained references to reports by U. S. Department of
. Agriculture scientists that this type of application improvedthe residual characteristics of insecticides. To our knowledge this usage of the chlorinated bi-
----- -- phenyls never' developsa to a significant degree.
Perhaps you are aware that Monsanto is the sole pro ducer of polychlorinated liphonyls in the United States, bur products are trademarked /-..coolers. The polychlorinated biphenyls are represented by our Aroclor 1200 series, e.g. Aroclor 12pd is biphenyl chlorinated to the extent of
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Dr. Harry 17. Hayes April 13, 1970 Payq Iwo
It la possible that some pesticide formulators are purchasing from cur distributors our chlorinated biphenyls Tor inclusion in.their formulations, In vievr of the concern oyer the presence in the envir onment of persistent chlorinated hydrocarbons, v;e believe that the chlorinated biphenyls should no longer be used in such formulations.
We ask,, therefore; as your department considers the re-registration of pesticide formulations, that critical attention be given to the presence of these materials.
We will be happy to discuss this further with you either by letter or personally.
Very truly yours.
REX;ju Enclosures
R. Emmet Kelly, M. I>. He d i cn 1 .Dire c t or
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