Document ExwaE7EmrmpvwYxq1gyZg4KMN

. 4H eiitcf TO : R. Richard - Feseerch Center March 6, 1953 AROCLOP. \HIVLI7Z ACCUSATIONS E. Wheeler - EWHEZ H. Bergen J. Sprlngcte V/. Schalk D. Olzon R. Kelly J. Oarrctt P. Hodges fc.?. Park Keller *Z. Tucker K3iPC JSrnl WSCHA dolso RXEIL JOARR PKODO PPARIC JFQ JFQ Risebrcugh in * recent paper "Nature", Vol. 220,. Bee.' 14, 1J5C, hcs. attacked chlorinated biphenyl* in three Kays: (1) a pollutant - widely spread by air-waterj therefore an un controllable pollutant. (2) a toxic substance - with no permissible allowable levels causing extinction of peregrins falcon by Induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. (J) a toxic substance endangering nan himself: Implying that the peregrine falcon is a leading Indicator of things to come. As outlined in Science,Vol. 163, Pg. 5^8, Environmental Defense Fund (ED?) is attempting to write new legal precedents in conservation law by hearings and court action. In the Wisconsin case, water quality atandards art at issue. "A substance shall be regarded as a pollutant if its use results in public health problem* or lr. acute or chromic (injury) to animal, plant or aquatic life". Wisconsin is one of 7 states which now `nave federally approved **ler qualify 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 to aquatic life. These people In ED? are saying we must not put stress 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 la the real threat of DDT and PCB's and are uslr.3 7 these argvmenti to prove that vary small amount* of chlorinated .V hydrocarbons are "harmful". Monsanto is preparing to challenge certain aspects of this problem but wo are not prepared to defend against all of the accusations. and the extant of the pollution. ** * age tt $ f>0 003331 PLAINTIFF'S EXHIBIT T 091772 ^ HARTOLDMON0043256 E. '/heeler -2- March 6, 3^9 (b) We are not prepared to defend ourselves against the accusa tions made of enzyme and hormone activity, the isolation of enzymes or metabolic products, 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 we are to establish the long term allowable Units of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. Vo may be able to answer reproductive ability in some animals. SET has been under attack for some 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 same attack by the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where doss this leave us? Under identification and control of exposure we will be able to identify and analyze residues ss well or better than anyone in the world, We will probably find residues other than DDT end FCB's. We win probably wind up sharing the blsme in the ppm to ppb con centration level. We can take steps to minimize pollution from our own ehlorinsted biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up dispossl end reclaim operations. We ce" wo^k fr minimum exposure in manufacture and dispossl of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulie users. But, we can't easily control hydraulic fluid losses in smill plsnts. It will be still moro difficult to control other end uses such r.s cuVeins oils, adhesives, plasties and :::R paper. In these appli cations exposure to consumers is greater end the disposal problem becomos complex. If chlorinated biphenyl la shown to have some long term enzyme or hormone setlvlty in the ppm range, tha appli cations with consumer exposure would eause difficulty. Xlsebrough has taken known Aroelor sample 1 and elalms to have evldcnee of enxyae and hormone change. Here there la no question of Identification. Either his position is attacked and discounted or wa will eventually have to withdraw produet from and usos whieh have exposure prtbleas. SInee Rleabrough'* paper in "Nature", Dec. 1953 has just been published, it it timely, perhaps imperative, that this paper and its implications be dlseuesed with eerPtin customers. This is e rough one because it eeuld neon lets of business on ezipty and false elalms by Hlsobrough. Well prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical er.d legal department* must take place now. The T 091773 f>0003392 5 0078" HARTOLDMON0043257 Z. Wheeler 3 March 6, 1955 position of DDT manufacturers should be determined as a guide. V/e are being accused of the sane things attributed to DDT, I ha"e written this nemo to clarify some of the Issues. Kay 1 pleats have cocments. Thanks, W. R, Richard as Att. 0003393 T 091774 5 ODVr HARTOLDMON0043258