Document EqYGomJV70JN7ynaGnkzY7EpV

V Aft % TO : Richard - Fesosrch Csntpr March 6, AnCCLOr. '..'IL.ELiri accusations E. Wheeler - EWHEZ B **. ' H. Bergen J. Springate V. Schtli: D. Olson R. Kelly J. Garrett ?. Hodges ?. Park TL Keller ~ *E. Tucker K3E.TG JSrn?; WSCHA EOLSO p:<izl JCARR PKODC PPA7UC JFQ JFQ Risebrcugh in a recent paoer "Mature", Vol. 220, Dee. 1J?, I960, hzt attacked chlorinated biphenyls in three ways: (1) a pollutant - widely spread by air-water? therefore an un controllable pollutant. (2) a toxic substance - with r.o permissible allowable levels causing extinction of peregrine falcon by induced hepatic enzymes which degrade steroids upsetting C2 metabolism lead ing to reproductive weakness, presumably through thinner egg shells. (3) e toxic substance endangering nan himself? implying that the peregrine falcon is a leading indicator of things to cots. As outlined in Science ,Vol. 153, Pg. Er.vircnr.antal EaTense Fund (EDJ) is attempting to write new legal precedents in conservation law by hearings and court action. In the Wisconsin case, water quality standards are at issue. "A substance shall be regarded as a. pollutant if its use results in public health problems or ir. scuts or* chromic (injury) to animal, plant or aquatic life". Wisconsin is one cf 7 states which now have federally approved Ler quality standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Water Quality Standards Branch, DDT would fit the definition of a pollutant upon a shewing that It is harmful tc aquatic life. These people In EDP are saying we must not put ctrers on sny living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim "enzyme __inducer" activity is the real threat of BET and PCS' s and are using 7 these arguments to prove that very small amounts of chlorinated ?? hydrocarbons are "harmful". f ' Monsanto is preparing to challenge certain aspects of this problem but v:c are not prepared to defend stainst all of the accusations. (a) Monsanto Is preparing itself to identify trace ppt quantities of chlorinated fcipher.yls in water tame let, in concentrated collected air samples, and i n animal tissues, be will knew whether we hz"e bien falrsly identified end accused or r.ct. We will eventually know where any pollution is taking plats and the extent of the pollution. PLAINTIFF'S EXHIBIT rlr--*******---- sPLAINTIFFIS [EXHIBIT; ' EXHIBIT "_____ 1 S22l 28 MON 0125 WATER PCB-00050347 . V.'hcaler -2- Karch 6, 3 69 (b) U*c are not prepared to defend ourselves against the accusa tions r.ade of enzyme and hormone activity, the Isolation of enzymes or metabolic product*, the indirect accusation of cancer, or the splitting of genes, when this accusation is made. Whether we can defend this route or not needs further discussion. (c) Through the Industrial Bio-Test program ve are to establish the long term allowable limits of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, patholo*!- ' cal examination, and tissue analysis for chlorinated biphenyls. V/c may be able to answer reproductive ability in acme animals. DF? has been under attack for sene years because of its chlorine content, its persistent ability to be identified, and the wildlife problems attributed to it. We will still be under the sane attack by the mechanisms listed in (b) even though we night establish safe operating limits for humans and certain animals. Where does this leave us? Under identification and control of exposure - ve will be able to identify and analyze residues as well or batter than anyona In the world. We will probably find residues other than DD? and ?C2* *. We will probably wind up sharing the blame In the ppm to ppb con centration level. Ve can take steps to minimize pollution fres our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. We can f<->r minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and"minimize losses fer large hydraulic users. But, we can't easily control hydraulic fluid losses in small plants. It will be ftill more difficult to control other end uses such r.s cut-ins oils, adhesives, plastics and IIIH paper. In thesz appli cations exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl ia shown to have gohe long tern enzyme or hormone activity in the pea range, the appli cations with consumer exposure would cause difficulty. /^ * Risebrough has taken known Aroclor samples and claims to have evidence of enryne and hormone change. Hers there is no question of identification. Either his position is attacked and discounter; or we will eventually have to withdraw product from end uses which . have er.nosure prcblcmc. Since P.isthroughpaper in "Nature" , Dae. 1S63 has Just been published, it it timely, perhaps lmperctiva, thit this paper and its implications be discussed with certain customers. This is a rough one because it cculd nssn less of busir.-ss or. crpty and false claims by ?.i set rough. V.'c i1 prepared discussions with Inc. Bio-Test, rionsant? biocher.i sts, the "medical end leg?.; departments must take place new. The MON 0126 5 J u uv_-, WATER PCB-00050348 2. Wheeler -3- Karch 6, 1955 position of DOT manufacturers should be determined as a guide,, We are being accused of the aaa* thing* attributed to DDT. I hae written this nemo to clarify acme of the issues. Hay I please have comments,, Tlianks, . as Att. W. R. Richard _. _MON 0127 5 0u / o WATER PCB-00050349