Document B7x4djk8ZjBqkKBadq53xOLj

POSSIBLE CUSTOMER QUESTIONS ON PCBs PUBLICITY Question 1 / What article* have appeared on the PCB problem? Will you *end me copies ? /j Answer: In the U.S., newspaper article* have appeared in the San Francisco Chronicle on Feb. Ii4, 1969, the San Francisco Examiner on' Feb, 25, 1969, and the Hartford Time* on Aug. 3, 1969. Numerous articles were generated by the Wisconsin "DDT Hearings" in . May,' 1969. At the hearings, witnesses discussed the problem of PCBs as "interfering substances" in their search for DDT in the environment. PCBs, they eaid, produced peaks on a gas chromatograph similar to the peaks produced by DDT. In no case was PCB indicted at the Wisconsin hearings. ` /1 Copies of the articles will bo made available on request. Regional managers should contact E. V, John, Fhiblic Relations Managor Organic Chemicals Division, in St. Louis and eopio* will be for warded to the customer through tho regional manager's office. In addition to the newspaper afliclo* mentioned above, there have boon radio broadcasts. At tho lime of the San Francisco Chronicle and Examiner articles, radios in tho San Francisco area also carried the story. In August, the sports editor of iho Hartford Times syndicatad a radio broadcast on the subject of PCBs, and in Dee., 1969,/the Canadian Broadcasting 0. (radio) carried an interview they taped with a member of our me dical department. Ques1 tTMion"2 // / ' Were Monsnato's Aroclors specifically mentioned in these articles ? If so, which ^onet? ' MONS 034482 Answer 2 Momaiuo'i Aroclor* were mentioned in lomo of the article* but only in the San Francisco Chronicle *tory in Feb,, 1969, wti Aroclor 1262 specifically mentioned by number. In several of the articles, Monsanto was also identified as the sole U, S. producer of polychlorinated biphenyls, marketed under the tradename of Aroclor. ' Question 3 What did the articles on the PCB problem say? Answer Since the outset of the "PCB problom", when the first article appeared in the U.S. prsss in Feb., 1969, the whole question has beon elosely interwoven with the question of DDT as a possible environmental contaminant. The San Francisco Chronicle article carried a headline, "A Menacing New Pollutant.11 In rather sensational style, it identified PCB as a threat to birds and humane, highly toxic in a gaseous j state and related to known cancer-causers. PCB presence in the environment is rising swiftly, the article stated. The Examiner article called PCB a "plastic pollutant in the Bay and Mothers' Milk." This article called PCB an "alarming" new chemical pollutant that ia playing a role in tho declining peregrine falcon population, has Uten found in mothers' milk, and is the "latest addition to a growing list of chemical* in the ocean---- the newest symptom of man's chemical invasion of the ocoan. " These two articles quoted Dr. Robert Risebrough, a researcher at the Institute of Marine Resources in the University of California's^ Department of Nutritional Scientists, on the detrimental effects of PCBs, Later Dr, Risebrough said he had been misquoted in some newspaper stories. . The Hartford Timos story called PCB pollution a "new puzzle." Less sensational than the.San Francisco, articles, the Times gave an account of PCBs baing found in the environment and the studies under way to determine their biological effects. This article, says Dr. Risebrough, tend* to cloar PCB oi blame. ' *ONS 0344^3 I 1 3 Article* generated by the Wisconsin DDT hearings generally discussed PCB a* an interfering' ubatanco/di*covred in scientists' search for DDT in tho environment. Dr./RUabrough aaid at the hearing* that there wae no proof at the jnoment that PCB alone can cause thin eggshells, one of the phenomenon that he had discovered in studying the/dedining population of the peregrine falcon. '/ LEGISLATION Question 1 Are there any Fodoral/Stat<ylocal law* undor which tho use or discharge of Aroclors could bo prohibited? Answer; ' No existing Federal, State, or local laws prohibit the discharge of Aroclors, However, in'a number of states the basic water pollution control legislation is so broad that state agencies can prohibit chemicals, deemed necessary, from being discharged. Question Z ' / /. Is the DDT and the PCB problem related? ./ An*we r; / . Wo arc not a manufacturer of DDT or other chlorinated hydioesrbon pesticide and, theroforo, havo no Knowledge of tho soriousness of the charges against DDT other than what has been so widely publicised on TV, in the press and in technical journals. To the extent that both DDT and PCB are chlorinated hydrocarbons, then there is a similarity. They are sufficiently different in their chemical structures however, that it would be entirely wrong to assume that both behave /in the same way in the environment. There is another and more / obvious difference, DDT and other chlorinated hydrocarbon pesticides were specifically designed for a job that obviously leads to their being scattered in wide spread fashion across the countryside. Rain, birds, wind, insects further scatter these pesticide* in *n uncontrollable manner. PCBs are not used In this fashion and / 03^8<* 4 Monsanto ha* never sought to promote this. This, we believe, is an important distinction that should not be overlooked if DOT and PCB are linked as a common pollutant of the environment. To our knowledge PCBs have never been identified'in the absence of DlT or other chlorinated hydrocarbon pesticides. Question 3 Could it be PCB that's causing the environmental problems and not DDT? Answer*. We bolievo that prosont-day GLC *ftd mass spectrometric techniques are sufficiently accurate to be able to differentiate between DOT, related pesticides, their motabolites and PCB. Question 4 What authority do State and local governments have in banning/ controlling the use of PCBs, Answer: They do have authority to ban or control use of any substances they consider harmful. -: ' EFFLUENT AND ITS CONTROL Question 1 How do 1 dispose of Arodor 1254/1260, etc. effluent from my plant? . ' Answer: / / We would suggest collecting all process effluent, equipment washings, tank or drum washings and then regularly taking to the nearest . toxic materials dump. You may also be able to use a sanitary land fill if permits are issued for this in your locality. We don't / recommend feeding this material to local sewage treatment plants or taking out to sea in drums for dumping. These method* do not ' \/ I / HONS 034485 / / / 5/ solve the problem of contamination. We are working on the disposal of these materials by incineration and hiodegradatioi] Our work in these areas has-not yet reached the stage where/ we can offor practical suggestions, lt'is ol interest to note/ however, that research is underway fo find catalysts to make DDT self-destructive. The possibility exists that we could) find catalysts that would destroy PCBs in settling tanks con structed to catch all your effluents. i ' Question 2 Can 1 test my effluent to see if my.effluent has- no A/eclor 1254, . tc.? , . // : Answer: / ' Yes. Analytical oquipment is available that can do this if tho proper technique is used. The basis of Ae method is GDC or gas liquid chromatography. Are you or anyone in your company familiar with this ? Do you' have GL.C equipment? If you do, we can send you a description of a method that could.identify PCB. If not,/there may be a good analytical testing laboratory in the vicinity where you could send samples and rely on the resets if you want to test your effluent.. / Question 3 What is a "safe" PCB levol for effluent leaving my plant? Answer: / / As our letter points out, parts por million (ppm) and parts per billion (ppb) have boon mentionod in the published articles. There is still a lot of doubrps to how absoluts any quotsd values are. To bring this7into the reelms of reality, this definition of ppm and ppb'may help clarify things. /' To give you e practical example, the escape of one-two gallons per day could lead b/samples in a stream beside the plant showing 10-30 ppb on analysis. / / HONS 034486 /6 Question 4 / You munt have quite a control problem at your plants--! would think Monitnto'i Aroclor plant* are/the major polluters--how are you handling control?/ Answer: / The Aroclor product* wo make to sell at a profit, *o economic* dictate maximum housekeeping, minimum lo*e. The Aroclor process i* a "dry process'' or closed system. Quostion 5 \ How doe* Monsanto think Aroclor* can get into tho environment and cause so much pollution? Answer: / Disposal, leakage from/systems using it, spills, etc.'' Question 6 / -- - /' If 1 analyse my effluent stream and find ppb there, how do 1 know it didn't come from air-borne contamination or was present in the process water that I pump from the XYZ river into my plant? / Answer: Analyse water unto ring your plant and compare. Thero is a mo thod, avails bio for sampling air. Qua stion 7 / You seem to think from the tone of your letter that the source of pollution is from effluent disposal into streams. In my .process, Aroclor 1254, 1260, etc. vapors escape. What pre/ cautions can 1 take to prevent (a) employee problems and / > (b) escape of vapors into the atmosphere? j' / / HONS 034467 7 Answer (7>: "' ' Article* on PCB interference with pesticides analysis have mentioned the poibility of loss to the atmosphere from vaporization when Aroclor* are heated, We find thia hard to believe and it warrant* considerable investigation, / f TOXICITY Question 1 If PCB is a danger to fish and birds, how about humans ? '/ Answer; ' The amounts being found in the environment are not considered a danger to humans or fish. The whole question on chlorinated pesticides relates to birds. Question 2 J, /Are Aroclor 1254/1260, Why? etc. more toxic than other Arodors? / Answer: There is a difference in toxicity depending on degree of chlorination. This is not to say that higher chlorination is more toxic than lower chlorination. The alleged PCB problem is not really related to dagrea of toxicity. Question 1* DIFFERENCES BETWEEN AROCLORS "* : ` / / In your letter, you state that Aroclor 5060,^5442 and 5460 are not PCBs. What are they? >' . Answer: They are chlorinated torphenyls. HONS 034466 / 8 Question 2 Whit'i the difference between a chlorinated biphenyl and a terphenyl? ; Answer; A torphenyl hae throe borne no* linked togsthar and biphenyl only two. They are. therefore, similar but different, just as naphthalene is different from benaene. Question 3* / / Why should PCB be sn environmental' contaminant and chlorinated terphenyls not? Answer: 1i 1 don't think there`is any positive answer on this and I can't give you any theories. However, I would emphasize/that not all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1242 haven't been identified in marine, aquatic and wildlife environments. Chlorinated terphenyls - at least/those made by Monsanto-- have not been identified in the environment either. Question 4 . / Since you sell other PCBs beside Aroclor 1254 and 1260, . why are they not found in the environment?/ Answer; - One reason could be that they biodegrade and hence never build up to a level where they can be labelled persistent contaminants. Therefore, although you would find if in an effluent stream if you analysed it juat after you poured PCB into it, ita absence when a river, for example, is analysed downstream at a later date would indicate degradation^ bacterial organisms. We are actively working on this aspect of biodegradability in our laboratories at this time. Results of this type of work won't come to hand quickly but our preliminary work HON S 034489 I In your letter, you make no' mention of Aroclor 1262 end < 1268. Whet is thsir status? i /, Answer: ----------- , . /, It could bo that their semi-solid/solid water insoluble nature /' means they are far, far less likely to become "mobile'' / contaminants. It could be that their structural differences / from Aroclor 12$4 and 1260 are responsible for the apparent / lack of a problem. In any event, they have not been identified by scientists in the environment and--believe me-- a lot of 7 i scientists seem to be looking for PCBs. -" Question 6* Both Aroclor $460 and 1260 contain 60% chlorine. Why is one ' a problem (1260) and apparently not the other ($460)? ^ . Answer; j ' A terphenyl has three benaenes linked together and biphenyl only two. They are, therefore, similar but different. Just as naphthalene is different from benaene. .1 would emphasise that not all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1342 haven't been identified in marine, aquatic and wildlife environments. Chlorinated te rphenyls--at least those made by Monsanto- - have not been identified in the environment,either. ./ . ' ' r/ ' Question 7* / i Does this PCB problem mean that you have discontinued efforts to get Aroclor $460 approved by FDA? Answer; No. / / f ' ,L- / i /1 / HONS 034490 l Question Is the reason for not rosubmitting your petition to the FDA for approval of Aroelor 5460 duo to thia PCB publicity? Answer; ' No. Question 9 1 . ' What's the problem then? Anawo r: We aro bringing a new solid Aroelor plant on*stream in the next two>threo months. Wo want to make sure it produces/ the same quality Aroelor 5460 wo used in our foeding studios for the FDA. Once we're sure that's O. K. -- and.we/ feel it will be then we'll get the petition moving again but FDA clearances do take time. j Question 10 ` [ Does this PCB publicity mean that FDA approval of Aroelor 5460 is not going to be^btained? Answer; We have no reason to think the two things are related. Aroelor 5460 is not chemically a PCB. The delay resulted from the need to set up certain analytical methods to satisfy A. This involved analytical instrumentation and is bei completed now, It is my understanding we plan to resubmit o^ petition although 1 personally don't know the exact data. / /./ CONTAINERS Question 1 Joe Doe buys all my use.d Aroelor drums without me Having to wash them. 1 get $3. 00 a piece/ 1 can't afford to wash them out. Even if 1 did. what wojuld 1 do with' the wsshings ? HONS 034491 1I j *r This will depend entirely on ths fiasl us* to which your product is used- -its ultimsu disposition. .. " . Question l* . . ? - * 1 - </ / / > ' t / My product X contnias Arodor 1254/1160. What should l toll / my customers? . /. / Answer; Tell your cu*tomer--We went to sdvise you of s possible environ ments! problem. Without knowing whet your customer does with product X. this is herd to answer. (We would sey that it would not seem wise to use Arodor 1254 or 1260 lor keeping dust down on the roads, lor use in dental sealing compound* or as carriers lor pesticides. )* Question 3 Only if you suspect or sre to! what' the application is. / Does Monsanto intend to continue manufacture of Aroclor 1254/ 1260, etc. 7 . / / / MOHS 034492 {' ! i ' Answor (3): . I hav* been given no indication otherwise!. / 12 Question 4* ' Should 1 look for replacement for Aroelor 1254/1260, etc, ? Answeri 1 think only you can decide this. How oasy would this be for you? Do you have any other replacement product in mind? Question 5* ( .` i Does Monsanto have replacement products for Aroelor 1254 and 1260? j '> ` Answer: */ / i. As you know, we have over eighty plasticisers in our n*e and there's quite a bit of product interplay so it is possible that there is another product in our line that might replace them. What resin do you use? Perhaps we could look at these re sia/plasticiaer Selector Charts in the baekof the Blue Book. I've got it with me. `. , I Question 6* r Is Monsanto working on replacement* for Aroelor 1254 and 1260? Answor; These research fellows are always busy on things like that. To some people Aroelor 1254 and 1260 have drawbacks.-* quits apart from present publicity on PCB. Aroelor 1254 is fairly volatile. Aroelor 1260 is very viscous and difficult to handle. For polysulfid* sealants, for example, the technic people in St. Louis have just sent us data on products that wiU behave better than Aroelor 1254 in polysulfids sealants. . Maybe there's something here for you to look at. Let's go over it. i t / / HONS 034493 i i /