Document G6ngxgqXobnmG0pnnRgbqd44v

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BROOME JAMES L. and BARBARA A. FURCH, et al., . _ Plaintiffs, . Vs GENERAL ELECTRIC COMPANY, et al. ___________________________Defendants. Index No. 1370/1982 RJI No. 86-1107-M INDEX OF PLAINTIFF'S EXHIBITS EXHIBIT NO. 375 ................................ 376 .......................... . . 377 ................................ 378 ................................ 379 ................................ 380 ................................ 381 ................................ 382 through 386 387 through 399 PAGE MARKED . . 54 . . 55 . . 78 . . 94 . . 94 . . 98 . . 98 . 105 . 147 VOLUME I DEPOSITION OF WILLIAM B. PAPAGEORGE, On behalf of Pi aintiffs April 27, 1 999 P.E. GATEWAY REPORTING ASSOCIATES, INC. 515 Olive Street, Suite 1506 St. Louis, MO 63101 (314) 621-2571 Gateway Reporting Associates, Inc. WATER PCB-SD0000070786 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BROOME JAMES L. and BARBARA A. FURCH, et al . , Plaintiffs, Vs. GENERAL ELECTRIC COMPANY, et al. Index No. 1370/1982 RJI No. 86-1107-M ___________________________Defendants. DEPOSITION OF WILLIAM B. PAPAGEORGE, P.E., produced, sworn and examined on behalf of the Plaintiffs, April 27, 1999, between the hours of eight o'clock in the forenoon and six o'clock in the afternoon of that day, at the offices of Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri, before FAITH A. OLLIGES, a Registered Professional Reporter and a ' Notary Public within and for the State of Missouri. APPEARANCES Plaintiffs were McDonough of the law Farnetti, 117 Hawley 13902-1740. represented by Mr. Kevin F. firm of Ball, McDonough, Artz Street, Binghamton, New York & Defendant Monsanto was represented by Mr. John C. Sabetta of the law firm of Seyfarth, Shaw, Fairweather & Geraldson, 1270 Avenue of the Americas, Suite 2500, New York, New York 10020-1801 and Mr. Timothy Peck of the law offices of Smith, Helms, Mulliss & Moore, L.L.P., 300 North Greene Street, Suite 1400, Greensboro, North Carolina 27420 . . Defendant General Electric was represented by Mr. Eric E. Grondahl of the law offices of Cummings Lockwood, CityPlace I, 185 Asylum Street, Hartford, Connecticut 06103-3495 and Ms. Effa G. Farnsworth, Easton Turnpike, Fairfield, Connecticut 06431. & 3135 Also present was Plaintiff James Furch. Gateway Reporting Associates, Inc. WATER PCB-SD0000070787 Gateway Reporting Associates, Inc. 3 1 IT IS HEREBY STIPULATED AND AGREED by and 2 between Counsel for the Plaintiffs and Counsel for the 3 Defendants that this deposition may be taken in 4 shorthand by FAITH A. OLLIGES, a Registered Professional 5 Reporter and Notary Public, and afterwards transcribed 6 into typewriting. 7 o-O-o 8 WILLIAM B. PAPAGEORGE, P.E., 9 of lawful age, being produced, sworn, and examined on 10 the part of the Plaintiffs, deposes and says: 11 DIRECT EXAMINATION 12 QUESTIONS BY MR. McDONOUGH: ' 13 Q. Mr. Papageorge, my name is Kevin McDonough, 14 and I represent the plaintiffs in this proceeding. I'm 15 going to ask you some questions. If you don't 16 understand my question, don't worry about just saying, 17 "I don't understand, rephrase it," and I will. You have 18 to give your answers orally. Are we agreed? 19 A. Yes. 20 MR. McDONOUGH: And we're going to do this 21 deposition under our standard stipulations? 22 MR. SABETTA: Yes. 23 MR. McDONOUGH: So all objections waived 24 except as to form. Do you want it signed? 25 MR. SABETTA: Yes. I'd like him to read it Gateway Reporting Associates, Inc. WATER PCB-SD0000070788 Gateway Reporting Associates, Inc. 4 1 and sign it. 2 MR. McDONOUGH: Waive filing of the 3 deposition. As I understand it, Monsanto is producing 4 Mr. Papageorge. 5 MR. SABETTA: Well, he's appearing as a 6 former employee, someone who has knowledge of events and 7 subjects relevant to the litigation. He retired I think 8 about ten or 12 years ago now, but he 1s agreed to appear 9 voluntarily. We requested that he appear, and he agreed 10 to do so. 11 MR. McDONOUGH: And it's my understanding I 12 can use his testimony just as an employee, someone 13 produced by Monsanto? 14 MR. SABETTA: I can't stipulate to that, 15 but I think you can probably use his testimony under 16 other provisions of the CPLR since he's going to be more 17 than a hundred miles from the courthouse and so forth, 18 and we haven't decided at this stage obviously whether 19 we would call him. Obviously, if we called him, you 20 could use his deposition for any and all purposes. But 21 he is a former employee, and he's not -- I had said to 22 you, I guess, informally one occasion that he was a 23 consultant to the company, and that's incorrect. He had 24 a relationship with one of the law firms that represents 25 Monsanto in some cases, but he's not had any consulting Gateway Reporting Associates, Inc. WATER PCB-SD0000070789 Gateway Reporting Associates, Inc. 5 1 agreement with Monsanto as such. So I don't regard him 2 as an agent of Monsanto. He's certainly not an employee 3 of Monsanto. But I don't think the use of his 4 deposition will be an issue because I think it will be 5 otherwise admissible since -- I think it's 3117 or 3217. 6 I've forgotten the number of the CPLR provision that 7 allows for use of depositions of persons with knowledge 8 who are not available or at a great distance from the 9 courthouse. ' 10 MR. McDONOUGH: I'm familiar with that, but 11 it is my understanding that Monsanto produced him. I 12 didn't subpoena him. Is that incorrect? 13 MR. SABETTA: Yeah. I mean, you requested 14 that he appear, and we made that request of him. We 15 don't have the power to order him to appear. We asked 16 that he do so, and he agreed to do so. 17 Q. Mr. Papageorge, will you state your full 18 name and address for the record, please? 19 A. William B. Papageorge, 321 Pebble Valley 20 Drive, St. Louis, Missouri, 63141-8039. 21 Q. Are you employed, Mr. Papageorge? 22 A. Self-employed. 23 Q. What are you self-employed as? 24 A. Technical consultant. 25 Q. Okay. Tell me what you're a technical Gateway Reporting Associates, Inc. WATER PCB-SD0000070790 Gateway Reporting Associates, Inc. 1 consultant in. What fields? 2 A. Its basis is chemistry, chemical 3 engineering, and it does involve matters such as the 4 environment and the introduction of chemicals into 5 society and the environment. 6 Q. Do you consult for the Monsanto Chemical 7 Company? 8 A. No. 9 Q. Do you consult for a firm? 10 A. I'm sorry? 11 Q. Do you consult for a firm? 12 A. Yes . 13 Q. What's the name of the firm? 14 A. Smith, Helms, Mulliss & Moore. 15 Q. Can you tell me - 16 A. And I have consulted for Syntex Company and 17 Chrysler Corporation. 18 Q. Can you tell me the nature of that firm? 19 What ' s its - - 20 A. Which firm? 21 . Q. The firm you consult for. 22 MR. SABETTA: Smith, Helms I think he's 23 referring to. 24 A. Oh, Smith, Helms? Oh, it varies, of 25 course, with the time. I have been involved in Gateway Reporting Associates, Inc. WATER PCB-SD0000070791 Gateway Reporting Associates, Inc 7 1 tutorials in which I try to introduce the subject of PCB 2 in the environment to attorneys. It involves such 3 things as the preparation of TV tapes, which are I 4 understand used as background information for 5 individuals unfamiliar with the subject. I share with 6 anyone asking the questions what my experience has been 7 regarding chemicals and the environment. Those are the 8 broad areas that come to mind at the moment. 9 Q. Is Smith, Helms a law firm? 10 A. Yes. 11 Q. Does it provide defense work for the 12 chemical industry? 13 MR. SABETTA: Objection to form.. You can 14 answer. 15 A. I'm only aware that they represent the 16 Monsanto Solutia team. I don't know who else they 17 provide law services for. 18 Q. What's the Monsanto Solutia team? 19 A. Up until 1997, that entity was identified 20 as Monsanto. At times it was Monsanto Company. 2 1 Sometimes it was Monsanto Chemical Company, and so on. 22 In 1997, I think that's correct, late '97, the chemical 23 portion of Monsanto was renamed Solutia, S-O-L-U-T-I-A, 24 and the Monsanto name was assigned to that activity 25 which involved the use of scientific technical knowledge Gateway Reporting Associates, Inc. WATER PCB-SD0000070792 Gateway Reporting Associates, Inc. 8 1 in agricultural activities. 2 Q. Do you know what happened to the plants 3 that made Aroclors in this reorganization that you've 4 told me about? 5 A. Yes. 6 MR. SABETTA: I have an objection to the 7 form. You can answer it. 8 A. They were assigned to the Solutia company. 9 Q. Is that a publicly stockheld company? 10 A. Yes. 11 Q. These tapes that you made and these 12 conferences that you participate in with Smith, Helms, 13 are they with respect to other law firms who provide 14 defense work? 15 A. Yes. On occasion there would be attorneys 16 involved from other law firms. 17 Q. Have you ever consulted with a plaintiff's 18 lawyer with respect to a plaintiff's case on PCB 19 exposure? 20 A. I don't recall any. 21 Q. This consulting arrangement that you have 22 with Smith, Helms, are you paid on an annual basis or a 23 per diem basis, or how does your remuneration take 24 place? 25 A. I'm paid on an annual basis. Gateway Reporting Associates, Inc. WATER PCB-SD0000070793 Gateway Reporting Associates, Inc. 9 1 Q. Do you mind telling me how much? 2 A. It's $8,500 a month. 3 Q. Are you also reimbursed expenses for your 4 work? 5 A. Only travel expense. 6 Q. Do you also receive a pension from Monsanto 7 or Monsanto Company or Monsanto Chemical? 8 A. I do. 9 Q. How old are you, Mr.Papageorge? 10 A. 76 . 11 Q. Could you give me your birth date? 12 A. September 7th, 1922. 13 Q. Could you give me your Social Security 14 number? 15 A. 500-18-0780. 16 Q. Did you receive any education beyond high 17 school? . 18 A. Yes. 19 Q. Would you tell me what it was? 20 A. Is this education limited to formal 21 institutions or -- 22 Q. Let's start with formal institutional 23 education. 24 A. I attended Washington University located in 25 St. Louis and received a Bachelor of Science degree in Gateway Reporting Associates, Inc. WATER PCB-SD0000070794 Gateway Reporting Associates, Inc. 10 1 Chemical Engineering in 1943 . I attended the same 2 institution in 1946 through 1947 and achieved -- was 3 awarded a Master of Science in Chemical Engineering. 4 That completes what I call the formal schooling. 5 Q. Could I ask a few more questions before I 6 go to the informal? 7 A. Certainly. 8 Q. Did you attend any other class work in an 9 educational institution after your Master's degree? 10 Let's limit that to credit earning courses. 11 A. Yes. 12 Q. Could you tellme about those, please? ' 13 A. I almost forgot those. I attended courses 14 held by the then Oklahoma A&M College, which were 15 intended to give me the appropriate credits for a Doctor 16 of Science in Chemical Engineering. 17 Q. How many credits were you able toachieve 18 in that program? 19 A. As I remember, I was able to achieve 12 20 hours. 21 . Q. How many did you need for the Ph.D.? 22 A. Oh, as I remember, I needed six more plus 23 an acceptable research project and thesis. 24 Q. Had you engaged in any research project as 25 part of that Ph.D. program? Gateway Reporting Associates, Inc. WATER PCB-SD0000070795 Gateway Reporting Associates, Inc. 11 1 A. I did not get started. 2 Q. Had you done any research project as part 3 of a Master's program? 4 A. Yes. 5 Q. What was your research in? 6 A. It was in electrochemistry, the use of 7 electrochemical techniques in the production of organic 8 chemicals. 9 Q. Did you write a paper? ' 10 A. Yes. 11 Q. What was its title? If you can't remember, 12 you can tell me that. 13 A. I'd be guessing because that's five decades 14 ago. I can' t remember the specific words. 15 Q. Have you written any other papers since 16 that paper? Let me withdraw the question. Have you 17 written any papers that were submitted for peer review 18 in the area of chemistry? 19 A. No. 20 Q. Have you written any papers that were 21 submitted for peer review in any area of science? 22 A. No. 23 Q. When you say electrochemistry with respect 24 to organic chemicals, can you tell me whether any of 25 that involved Aroclors or polychlorinated biphenyls or Gateway Reporting Associates, Inc. WATER PCB-SD0000070796 Gateway Reporting Associates, Inc. 12 1 monophenyls? 2 A. No. 3 Q. What did you do between 1943 and 1946? 4 A. I served in the military. 5 Q. What branch? 6 A. Army. 7 Q. What did theyhave you doing? 8 A. It varied with the progression of the war. 9 Q. Was any of it involved in chemistry or your 10 field that you had been trained in? ' 11 . A. There was a period in which I was assigned 12 the task of locating and properly destroying chemical 13 warfare materials in Japan. 14 Q. Do you recall generally what the chemical 15 warfare materials were? 16 A. Not totally or specifically. I do remember 17 mustard gas and phosgene and chlorine as best we could 18 .translate the Japanese hieroglyphics. 19 Q. Where were you born, Mr.Papageorge? 20 A. St. Louis. 21 Q. After you finished your Master's degree, 22 did you obtain a job? 23 A. Yes. 24 Q. Where did you go to work? 25 A. I went to work inBartlesville, Oklahoma. Gateway Reporting Associates, Inc. WATER PCB-SD0000070797 Gateway Reporting Associates, Inc. 13 1 Q. What was the name of the company? 2 A. Phillips Petroleum Company. 3 Q. Had you worked for any chemical companies 4 prior to this job for Phillips? - 5 A. No. 6 Q. All right. How long did you work for 7 Phillips? 8 A. Four years. 9 Q. What was the nature of your work? 10 A. There were twotypes ofassignments. 11 Initially I worked in the Research Department in 12 activities associated with oil well drilling and what 13 was called at that time secondary recovery. 14 Q. Did that pertain to recovery of oil? 15 A. Yes . 16 Q. Did you indicate there was another job 17 scope that you were involved with? 18 A. Yes. In the last two years, I was assigned 19 to refinery engineering. That's not the official 20 designation, but the activity involved engineering for 21 refining of crude oil. 22 Q. Did any of that work involve 23 polychlorinated biphenyls? 24 A. No . 25 Q. Did it involve any of the products that are Gateway Reporting Associates, Inc. WATER PCB-SD0000070798 Gateway Reporting Associates, Inc. 14 1 used to make Pyranol, P-Y-R-A-N-O-L? 2 A. No. 3 Q. Did you go to work someplace else in 1951? 4 A. Yes. 5 Q. Where was that? 6 A. Monsanto Company. 7 Q. Where physically did you work? 8 A. At the John F. Queeny plant located in St. 9 Louis. - 10 Q. What was your job title? 11 A. The initial job was Process Engineer, I 12 believe, as best I can remember. 13 Q. What were you involved with as a Process 14 Engineer? 15 A. I was assigned the engineering activities 16 associated with part of the process in making an organic 17 chemical. 18 Q. Was there particular organic chemicals that 19 you participated in the process of - 20 A. Yes. 21 . Q. -- making? What chemicals? 22 A. The product that was the object of all of 23 this activity was phthalic anhydride, P-H-T-H-A-L-I-C, 24 anhydride, A-N-H-Y-D-R-I-D-E. 25 Q. Any other chemicals during this process? Gateway Reporting Associates, Inc. WATER PCB-SD0000070799 Gateway Reporting Associates, Inc. 15 1 A. Well, there were, of course,chemicals 2 involved in starting the process, and then there are 3 waste chemicals, undesirable materials. 4 Q. Were polychlorinated diphenyls or biphenyls 5 used in that process? 6 A. I hesitate because my ears pick up 7 "phenols," which is a different chemical from phenyls. 8 Q. Okay. Phenyls. 9 A. Y-L? 10 Q. Y-L. 11 A. Y-L instead of O-L. You're referring to 12 the diphenyls? 13 Q. Yes. 14 A. No . 15 Q. What about the "nols"? 16 A. No. 17 Q. Where did you work next after this 1951 18 assignment? Let we withdraw that. How long did you 19 stay in that assignment? 20 A. A couple of years. 21 . . Q. That would take us to about 1953. What did 22 you start doing then? 23 A. I was assigned as an assistant supervisor 24 in a production unit out in the plant. 25 Q. What was the unit involved in producing? Gateway Reporting Associates, Inc. WATER PCB-SD0000070800 Gateway Reporting Associates, Inc. 16 1 A. This particular unit made products called 2 plasticizers. 3 Q. What are plasticizers? 4 A. These are materials that are added to 5 plastics to make the plastic flexible. 6 Q. Did that process include using PCBs? 7 A. No. 8 Q. Were you ever involved in manufacturing 9 plasticizers using PCBs? 10 A. No . 11 Q. Do you know of other manufacturers that 12 made plasticizers using PCBs? Do you know of other 13 manufacturers who made plasticizers that used PCBs? 14 A. I'd be guessing. I don't know 15 specifically. . 16 Q. How long did you work in that position 17 starting in 1953? 18 A. About a year. 19 Q. Then what position did youobtain? 20 A. I was given my own department to supervise 21 instead of being an assistant supervisor. 22 Q. Was that the same department? 23 A. No. 24 Q. What department were yousupervising? 25 A. I don't know that it had any formal name. Gateway Reporting Associates, Inc. WATER PCB-SD0000070801 Gateway Reporting Associates, Inc. 17 1 It had a number at the time. But, nevertheless, it was 2 a unit that produced chemicals that were starting 3 chemicals for the eventual manufacture of materials that 4 ended up in rubber blending, rubber additives. 5 Q. How long did you work at that job? ' 6 A. About one or two years. 7 Q. That would take us up to 1955 or 1956? 8 A. That's about right, yes. 9 Q. Were any PCBs involved in those rubber 10 additives? 11 A. No. 12 Q. What are PCBs? 13 A. They are chemicals that are described by 14 the chemists as consisting of the configuration of 15 benzene, which is a hexagon-shaped molecule, and the two 16 benzenes nose to nose form the biphenyl. Now, 17 associated with each of the corners of that six-cornered 18 formation, there is a hydrogen attached. To make 19 polychlorinated biphenyls, the hydrogen in one or more 2 0 of these positions is removed and a chlorine is 21 substituted. So the "polychloro" part of the name 22 refers to the fact that there are more than one chlorine 23 attached. 24 Q. And did Monsanto Chemical Company make 25 those PCBs? Gateway Reporting Associates, Inc. WATER PCB-SD0000070802 Gateway Reporting Associates, Inc. 18 1 A. Yes. 2 Q. Do you know of any othercompany in the 3 United States that made PCBs besides Monsanto? 4 MR. SABETTA: At any time? 5 Q. At any time. 6 A. Well, I understood thatthere were at least 7 two companies mentioned in my study of the PCB 8 situation. 9 Q. Could you give me their names? ' 10 A. Oh, the names? Dow Chemical Company 11 aggressively tried to enter the market, and then later 12 there was a company down in Texas. I'm having 13 difficulty remembering its name. Its name started with 14 a C. That was I'm going to use the word rumored to be 15 selling -- making and selling PCBs to Monsanto's 16 ex-customers who were no longer supplied by Monsanto. 17 Q. What time period was that that they were 18 rumored to be selling? 19 A. Between '70 and '75, 1970 and 1975. 20 Q. What ex-customers of Monsanto would this be 21 that, they were rumored to be selling to? Was it 22 particular fields? 23 A. I can mention the fields. I cannot give 24 you specific names. 25 Q. That's okay. What fields? Gateway Reporting Associates, Inc. WATER PCB-SD0000070803 Gateway Reporting Associates, Inc. 19 1 A. The initial sales were made to those who 2 used PCBs as plasticizers. Later I understood that they 3 were sold to customers who had a need for heat transfer 4 fluids and for hydraulic fluids. 5 Q. Would you know any of the names of those 6 heat transfer fluid customers? 7 A. I never could getthat. 8 Q. Were you trying to get that information at 9 some point? . ' 10 A. Yes. 11 Q. For what purpose? 12 A. Oh, my purpose at the time was to avoid an 13 incident occurring with this material manufactured and 14 distributed and sold by another entity creating a 15 problem that the blame would be placed on Monsanto. 16 That was my purpose, and I tried to get the EPA to help 17 me i n that then. They never came back with an answer, 18 so I don 1 t know what they knew. 19 Q. Did you provide information to the EPA at 20 that time? 21 . A. Yes . I told them what I had understood. 22 Q. Did you give them written information at 23 that time? 24 A. No . 25 Q. What 1 s the EPA? Gateway Reporting Associates, Inc. WATER PCB-SD0000070804 Gateway Reporting Associates, Inc. 20 1 A. I'm sorry? 2 Q. What is the EPA that you're referring to? 3 A. It's a federal agency, the Environmental 4 Protection Agency. 5 Q. Who did you deal with there on this 6 particular matter? 7 A. I don't remember the specific person. 8 There were so many. I just don't remember. 9 Q. You said that Dow Chemical was aggressively 10 trying to enter the market. Do you know about what time 11 that was? 12 A. I can only give you a broad period. This 13 was before the environmental issues on PCBs came up. 14 Q. When would that be approximately? 15 A. Oh, approximately the 1950's. 16 Q. Could we do any better as to whether it was 17 the early '50's or mid '50's or late '50's? 18 A. I can't help you on that. I just don't 19 remember any. 20 Q. Do you have any factual knowledge that Dow 21 did try to enter the market at that time? 22 MR. SABETTA: Objection to the form. 23 Q. I'll withdraw it. Where did you get this 24 information that you're telling me about as to Dow 25 aggressively trying to enter the market at that time? Gateway Reporting Associates, Inc. WATER PCB-SD0000070805 Gateway Reporting Associates, Inc. 21 1 A. I got it from representatives of Monsanto's 2 marketing team who picked this up as they made calls on 3 the customers. 4 Q. Was any of that information conveyed to you 5 in writing? 6 A. No. 7 Q. When was that information conveyed to you? 8 A. 1970, '71. 9 Q. Is this the same Dow Chemical that made 10 Agent Orange? 11 A. That's the only Dow Chemical I know of, so 12 it must be. 13 Q. Did Monsanto also make Agent Orange? 14 A. Yes. 15 Q. Didn't Monsanto have the patent for PCBs? 16 MR. SABETTA: Objection to the form. 17 A. No . 18 Q. Did Monsanto ever have the patent on PCBs? 19 MR. SABETTA: Objection to form. 20 A. Monsanto had a patent that I recall on the 21 new approach to how to manufacture the material. 22 Q. Do you know when it obtained that patent? 23 A. ' I just don't remember the date. 24 Q. Do you remember that Monsanto purchased the 25 patent rights from Swann Chemical? Gateway Reporting Associates, Inc. WATER PCB-SD0000070806 Gateway Reporting Associates, Inc. 22 1 MR. SABETTA: Objection to form. 2 A. I'm not aware of that at all. I'm not 3 aware of any patents being in existence when the 4 purchase was made. 5 Q. Were you aware of why Monsanto purchased 6 Swann? . 7 MR. SABETTA: Objection to form. 8 A. Well, since I wasn't there, sir, I really 9 would be speculating. I don't know. ` 10 Q. Well, have you seen any records that would 11 give you information as to the purpose of purchasing 12 Swann Chemical? 13 A. I've never seen such a record. 14 Q. Now, I think we got up to 1955 or 1956 with 15 respect to your work for Monsanto. Can you tell me what 16 you did at that time? 17 A. Following that period? Immediately? 18 Q. Following that period, yes. 19 A. I was assigned to the plant's maintenance 20 department as a Supervisor of Small Project 21 Construction. 22 Q. Did that involve your chemistry education? 23 A . No, it didn't. 24 Q. How long did you work in that capacity? 25 A. Again, about a year or two. Gateway Reporting Associates, Inc. WATER PCB-SD0000070807 Gateway Reporting Associates, Inc. 23 1 Q. Which would take us up to 1957 or 1958? 2 A. That's close, yes. 3 Q. Had you had any involvement in PCBs up to 4 that time period? 5 A. During that time period or up to it? 6 Q. Up to that time period, 1957, 1958. 7 A. Well, during the period some of the 8 projects that my team or crew was involved with involved 9 the use of PCBs in the equipment that was installed. 10 Q. What was your team's involvement in the use 11 of PCBs in the equipment? , 12 A. Of course, it varied. I could give you an 13 example. When they installed a hydraulic -- I'm sorry. 14 When they installed an air compressor, and the project 15 called for a fire-resistant fluid in that compressor, 16 they would, of course, install the compressor, and they 17 would fill it with a PCB-type fluid. . 18 Q. Who is the "they" who would fill it? Some 19 employee of Monsanto? 20 A. Yes. It depended on the activity and who 21 that activity was assigned to in terms of the various 22 classifications. 23 Q. Was that your first encountering of PCBs in 24 that time period? Knowledge of PCBs is what I'm 25 referring to. Gateway Reporting Associates, Inc WATER PCB-SD0000070808 Gateway Reporting Associates, Inc. 24 1 A. Yes. 2 Q. Now, you said thatMonsanto had apatent on 3 new approaches to manufacturing PCBs . What was the 4 nature of that process? Can you tell me generally? 5 A. The whole process or the new approach? 6 Q. The new approach. 1 A. The newapproach really related to the use 8 of a process that would be called continuous where the 9 biphenyl would be exposed to chlorine as it went from 10 tank to tank, and it would pick up the chlorine as it 11 progressed through the system, as distinguished from the 12 older approach where a tank would be full of biphenyl 13 and chlorine would bubble through it to get that 14 chlorine to attach itself to the biphenyl group. 15 Q. Do you know when that new approach was 16 patented by Monsanto? 17 A. You asked me this before. I can't place 18 it . 19 Q. I'm sorry. I didn't remember that I did. 20 A. I just can't place the date. 21 . Q. Do you know whether the new approach was a 22 closed system? 23 MR. SABETTA: Objection to form. 24 A. Well, I have difficulty with the definition 25 of closed because they are all intended to be closed. I Gateway Reporting Associates, Inc. WATER PCB-SD0000070809 Gateway Reporting Associates, Inc. 25 1 have trouble making the distinction. 2 Q. Do you know whether the old system was 3 considered a closed system? 4 MR. SABETTA: Same objection. 5 A. The only time the old approach was open is 6 when the operator would remove the cover on an opening 7 into which he would introduce lime to neutralize any 8 acid that was in the completed batch. 9 Q. Do you know what the temperature of the 10 contents of that tank was? 11 A. Over 300 degrees Fahrenheit. 12 Q. Do you know what time period that process 13 was employed by Monsanto? 14 MR. SABETTA: Do you mean how many years or 15 months? 16 MR. McDONOUGH: Yes. Or dates. 17 MR. SABETTA: The old system you're talking 18 about ? 19 MR. McDONOUGH: Yes. The system where the 20 operator would remove the cover of a tank and put in 21 1 ime . 22 A. From the time they purchased the process 23 from Swann until they shut down the units in 1977. 24 Q. They still used that process until 1977, 25 Monsanto? Gateway Reporting Associates, Inc. WATER PCB-SD0000070810 Gateway Reporting Associates, Inc. 26 1 A. Yes. 2 Q. Was that in a particular plantthat that 3 process was being used? 4 A. All plants. 5 Q. I may havemisunderstood you,but I 6 understood there was a new approach that was patented 7 about continuing the biphenyl from tank to tank with 8 exposure to chlorine which didn't involve opening the 9 tanks. Did I misunderstood you in that regard? 10 A. No. No. 11 Q. Was that process used also by Monsanto - 12 A. Yes . 13 Q. -- to make PCBs? 14 MR. SABETTA: Let him finish the question. 15 MR. McDONOUGH: Did you get an answer? 16 THE REPORTER: Yes. 17 Q. What time period was that process used 18 through? I understand you don't remember when it 19 started. 20 A. Again, I don't have a date. 21 Q. Okay. 22 A. I just don't remember the date. 23 Q. You don't know if that process continued 24 through 1977 when you discontinued manufacture of PCBs? 25 A. Oh, I know that, but I don't know when it's Gateway Reporting Associates, Inc. WATER PCB-SD0000070811 Gateway Reporting Associates, Inc. 27 1 introduced. 2 Q. That's what I'm trying to ascertain now. I 3 understand you don't know when it was introduced, but 4 was it still employed up through the time that Monsanto 5 discontinued manufacturing PCBs? 6 A. Yes. 7 Q. Was thatemployed inparticular plants? 8 A. I know that the Anniston, Alabama plant and 9 the plant referred to as the W. G. Krummrich plant 10 located in Sauget, Illinois, S-A-U-G-E-T, had units of 11 that type. 12 Q. Did both of those plants have units of both 13 types? 14 A. Yes. 15 Q. Where did you get this information as to 16 these processes that you've described for me? 17 A. Of course, I read the process manual that 18 describes the units and what the operator should be 19 doing under what conditions, but in addition to that, I 20 personally walked the department. I saw all the 21 activities. I was aware of what each vessel was doing. 22 Q. I believe we have you up through about 1958 23 in terms of your employment with Monsanto. Can you tell 24 me what you did after you stopped being a Supervisor of 25 Small Projects Construction? Gateway Reporting Associates, Inc. WATER PCB-SD0000070812 Gateway Reporting Associates, Inc. 28 1 A. I was appointed as Superintendent of 2 Maintenance. 3 Q. How long were you Superintendent of 4 Maintenance? 5 A. A couple, three years. 6 Q. Were you on the fast track? 7 A. I1m sorry? 8 Q. I withdraw it. As the Supervisor of Small 9 Products Construction, did you receive any materials 10 from Monsanto as to how the PCBs were to be handled or 11 not handled, as the case may be? 12 A. Certainly. 13 Q. And what kind of instruction was that? Was 14 it in writing? 15 A. It was in writing, yes, and it was also16 shared with the employees at scheduled safety meetings. 17 Q. What was the writing called? 18 A. Well, it changed through the years. It had 19 the words "s afe handling" or "toxicity information" or 20 that kind of terminology. 21 Q. Was it contained in a particular booklet, 22 employee saf ety manual perhaps, something of that sort? 23 A. ' Yes . 24 Q. Would you tell me what that booklet was 25 called back in the time that you were Supervisor of Gateway Reporting Associates, Inc. WATER PCB-SD0000070813 Gateway Reporting Associates, Inc. 29 1 Small Project Construction? 2 A. I don't know that we had a -- that we just 3 had a specific name for it. It was a three-ring 4 notebook with sheets for all the chemicals that a 5 particular group might be exposed to. They were 6 encouraged to read this. 7 Q. Did people refer to it as, oh, "that damn 8 thing" or did they use a name with respect to it? 9 A. No. They -- Each one would use words like 10 "the safety manual" or "the safety booklet" or "the 11 chemical information". 12 Q. When you became Supervisor of Maintenance, 13 can you tell me - 14 MR. SABETTA: He said superintendent. Did 15 you say superintendent, Mr. Papageorge? What was the 16 correct - 17 THE WITNESS: Well, I was both. I was a 18 supervisor. 19 MR. SABETTA: And then thereafter you 20 became superintendent? 21 THE WITNESS: Superintendent. 22 MR. SABETTA: That's what I thought we were 23 discussing. 24 Q. When you became Superintendent of 25 Maintenance, what generally were your duties? Gateway Reporting Associates, Inc. WATER PCB-SD0000070814 Gateway Reporting Associates, Inc. 30 1 A. Well, I was responsible for the activities 2 of six or seven supervisors, each with a team of the 3 various craftsmen, welders, pipefitters, millwrights, 4 carpenters, and so on. 5 Q. Did that entail a particular plant ? 6 A. Yes . 7 Q. What plant? 8 A. The John F. Queeny plant in St Louis. 9 Q- Could you spell that last name for me? 10 A. Queeny, Q-U-E-E-N-Y. 11 Q. How long did you function in that capacity? 12 A. I thought we answered that. A couple, ` 13 three years. 14 Q. Oh, you did. I'm sorry. What did you do 15 in a couple, three years? What was your next job? 16 A. Oh, my next job, I was assigned to the 17 Plant Engineering Department as a superintendent. 18 Q. Were there job descriptions associated with 19 these particular jobs that you did? Written job 20 descriptions I'm referring to. 21 , A. I don't remember any formal job 22 description, no. 23 Q. In the Plant Engineering Department, as the 24 superintendent, what did you do? 25 A. I supervised the activities of engineers Gateway Reporting Associates, Inc. WATER PCB-SD0000070815 Gateway Reporting Associates, Inc. 31 1 and technicians, and the number would vary depending on 2 the workload. 3 Q. Was there a particular area of work that 4 you were assigned to as opposed to just supervising 5 engineers and technicians? 6 A. I was supervising theindividuals I 7 mentioned in their activities relating to assigned 8 production units scattered throughout the plant. 9 Q. Did any of those production units involve 10 PCBs ? 11 - A. Yes. 12 Q. How long a period of time did you function 13 as a superintendent in Plant Engineering? 14 A. A couple years. 15 Q. That would take us up to 1963 about? 16 A. Yes. 17 Q. And what did you do in 1963? 18 A. I was appointed a generalsuperintendent of 19 a multi-department unit that included warehousing, 20 shipping, receiving, the utilities department, a 21 blending station, a chemical product blending station, 22 the waste disposal unit. In other words, all of the 23 activities that support the manufacturing departments 24 other than maintenance. . 25 Q. You mentioned blending station. Did Gateway Reporting Associates, Inc. WATER PCB-SD0000070816 Gateway Reporting Associates, Inc. 32 1 Monsanto blend Pyranol at that time? 2 A. Yes. 3 Q. How long had they been blending Pyranol to 4 your knowledge? 5 MR. SABETTA: At that location or at any 6 location? 7 Q. We'll start with that location. 8 A. That location, starting in '63. 9 Q. How long had they been blending Pyranol at 10 other locations? 11 A. I was led to believe that that service 12 started to be provided just before World War II. 13 Q. Do you know why it was started to be 14 provided? 15 A. No, I don't. 16 Q. So that would make it just before World War 17 II? 1940, 1941? 18 A. That's close as best I can recall, yes. 19 Q. What plant was involved in that blending 20 prior to 1963 or plants? 21 . A. Anniston, Alabama. 22 Q. Was that the only plant involved in 23 blending up through 1963, blending Pyranol? 24 A. Pyranol, yes. 25 Q. Do you know the plant that started blending Gateway Reporting Associates, Inc. WATER PCB-SD0000070817 Gateway Reporting Associates, Inc. 33 1 in 1963 was the John F. Queeny plant? 2 A. Yes. 3 Q. Do you know what the particular reason was 4 that that plant started blending Pyranol in 1963? . 5 A. Oh, the basic reason was that there was a 6 need for a facility that could blend many products. 7 Whenever there was available time, in other words, there 8 were idle tanks and pumps and so on, the schedule would 9 be arranged such that some Pyranols were sent- through 10 the system, or if the Pyranol in the inventory reached a 11 certain level, they'd stop that and make some other 12 product through that blending system. ' 13 Q. John F. Queeny started blending because of 14 the demand for Pyranol? 15 A. No. 16 Q. What was the reason? 17 A. The reason for what? 18 Q. That John F. Queeny started blending in 19 1963. 20 A. The increase in demand for many products 21 that. Monsanto was selling, and somebody decided to put 22 that unit at the Queeny plant. 23 Q. Was that a new unit that was constructed 24 for that particular process blending? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070818 Gateway Reporting Associates, Inc. 34 1 Q. Do you know how much that cost? 2 A. I don't remember. 3 Q. Do you know if the unit was cleaned after 4 Pyranol was blended and before another chemical was 5 blended? 6 A. Always. 7 Q. How was it cleaned? 8 A. Oh, I can't sit here and tell you the 9 specifics. It had to be cleaned to the point where a 10 sample of the wash water at the end would pass a 11 specific criteria, specific tests. 12 Q. You're testifying that in 1963 Monsanto was 13 testing the- wash water at the end of cleaning the 14 blending tank? 15 A. Yes. 16 Q. So that it passed a sufficient certain 17 criteria? 18 A. Yes. 19 Q. What criteria was that? 20 A. Oh, I don't know the specifics. They 21 looked for chlorine, for example, but that's not the 22 only thing they looked for. I don't remember all the 23 others. 24 Q. Do you know if they looked for PCBs? 25 A. In 1963, there was no technology that Gateway Reporting Associates, Inc. WATER PCB-SD0000070819 Gateway Reporting Associates, Inc. 35 1 related to the analysis of PCBs other than chlorine 2 determination. 3 Q. No other process had been developed up to 4 that point to do that analysis? 5 A. Correct. 6 Q. Do you know whether they tested for tri or 7 tetrachlorobenzene in this water wash? 8 A. That would be picked up with the chlorine 9 analysis. ' 10 Q. What is the chlorine analysis? How does 11 that get analyzed? 12 A. Well, you take your sample and -- I'm not 13 going to claim that this is the perfect way to do it, 14 but - - 15 Q. I just wondered what equipment was used to 16 do this chlorine analysis that you told me about. 17 A. It's the old wet chemistry. You take 18 silver and add it to the water that you're testing, and 19 the silver combines with the chlorine and comes out as a 20 white sediment, and that sediment is weighed, and the 21 calculation is made from silver chloride the chlorine, 22 and that chlorine is associated with the volume of 23 water, and it's reported as parts per million of 24 chlorine or grams per liter or some such designation. 25 Q. And what was the purpose of that testing? Gateway Reporting Associates, Inc. WATER PCB-SD0000070820 Gateway Reporting Associates, Inc 36 1 A. That's to show that the tank was within 2 previously designated limits regarding the presence of 3 not only chlorine, but all the other chemicals that are 4 put through the system. 5 Q. Would those tests have to be -- have to 6 result in a certain fashion before the water was flushed 7 into the public system? 8 A. No. . 9 Q. Was that water flushed into the public 10 water system? 11 A. Yes. 12 Q. Do you know whether that same form of 13 testing was made at the Anniston, Alabama plant? 14 MR. SABETTA: Objection to form. 15 A. It was not. 16 Q. Is there a river near the Anniston, Alabama 17 plant ? 18 A. I need help with the word "near". 19 Q. Within a mile? 20 A. Within a mile? No. It's a little further 21 away, than that. 22 Q. How about within five miles? 23 A. Oh, I've never measured it. 24 Q. Is there a river in the vicinity of the 25 Anniston, Alabama plant? Gateway Reporting Associates, Inc. WATER PCB-SD0000070821 Gateway Reporting Associates, Inc. 37 1 A. Yes . 2 Q. What 1s the name of that river? 3 A. Coosa River, C-0-0- S-A. 4 Q. Now, you mentioned that you were a general 5 superintendent involved with waste disposal also, and 6 this is in the 1963 time period? 7 A. Yes. 8 Q. How long were you a general superintendent 9 involved in that? 10 A. About two years, '63 and most of '64. 11 Q. So that would take us up to 1965 when you 12 became employed in some other capacity? ' 13 A. Yes. 14 Q. What was the nature of the waste disposal 15 done in this time period, '63 through '65, with respect 16 to PCBs and Pyranol waste? 17 A. It varied with the materialbeing disposed. 18 If it was just sawdust with PCBs on it, it would go to a 19 Monsanto landfill. If it was rags, of course, it would 20 be handled the same way. If it was a presence in water, 21 it would go to the municipal treatment system, the St. 22 Louis municipal treatment system. I don't know of any 23 other form' that it would take. There was to my 24 knowledge no incident of just liquid PCBs in a pail or a 25 bucket to be disposed of. That was sent back to be Gateway Reporting Associates, Inc. WATER PCB-SD0000070822 Gateway Reporting Associates, Inc. 38 1 reworked. 2 Q. Did you go out on the floor to see if they 3 disposed of buckets of PCBs? 4 A. Did I go around and see it? 5 Q. Yes. 6 A. When I took my routine fairly frequent 7 walks through the operations, yes, I would have that in 8 mind, along with hundreds of other chemicals. 9 Q. You didn't notice any buckets of PCBs being 10 dumped? Is that what you're saying? 11 A. I never saw that, no. 12 Q. What about incineration duringthis time 13 period, 1963 through 1965? Was any incineration 14 employed in disposing of PCBs or Pyranol? 15 A. The technology was notavailable. There 16 was no incineration. 17 Q. When did -- Withdraw that. Did Monsanto 18 ever begin the development of technology for 19 incineration to dispose of PCBs and Pyranols or other 20 chemicals? 21 A. Yes . 22 MR. SABETTA: Obj ection 23 Q. ' Yes? 24 A. Yes . 25 Q. When did they do that? Gateway Reporting Associates, Inc. WATER PCB-SD0000070823 Gateway Reporting Associates, Inc. 39 1 A. Started in -- It's difficult to pinpoint 2 the exact timing. The Monsanto Engineering Department 3 was assigned the task in late '69, and, of course, that 4 work continued through early 1970. 5 Q. So, as I understand it, you know of no work 6 done by Monsanto or its engineers or employees with 7 respect to trying to develop a technology of 8 incineration of PCBs up until this late 1969 time 9 period? 10 A. That is true. 11 Q. Did Monsanto employ any outside contractors 12 with respect to incineration of PCBs up till this 1969 13 time period? 14 MR. SABETTA: Objection to the form. 15 A. I don't recall the exact date on which an 16 incinerator manufacturer was contacted. It would have 17 to be within that period of time, late '69 or early 18 1970 . 19 Q. I think we've got your employment history 20 up to 1965. With this general superintendent job 21 assignment, what was your next assignment? 22 A. I lost a year in there somewhere. I was 23 assigned to the -- 24 Q. I've done that myself. 25 A. -- W. G. Krummrich plant as a General Gateway Reporting Associates, Inc WATER PCB-SD0000070824 Gateway Reporting Associates, Inc. 40 1 Superintendent of Manufacturing at that plant. 2 Q. Did that plant manufacture PCBs? 3 A. Yes. 4 Q. And I think you already told us that that 5 plant -- Withdraw that. Did that plant blend Pyranol? 6 A. What period of time? 7 Q. Well, I think you told us about 1965 you 8 became the General Superintendent of Manufacturing. How 9 long did you occupy that position? 10 A. About a year. 11 Q. During that time period, '65 through '66, 12 did it blend Pyranol at the Krummrich plant? ' 13 A. No. 14 Q. Prior to that time period, had it blended 15 Pyranol at the Krummrich plant? 16 A. Not to my knowledge. 17 Q. What about subsequent to that time_ period? 18 A. Yes. Eventually. 19 Q. Do you know when about? 20 A. About 1975. 21 Q. Did you have anything to do with the plant 22 at that time, 1975, when it was blending Pyranol? 23 A. No . 24 Q. Do you know what particular blend of 25 Pyranol it made? Gateway Reporting Associates, Inc. WATER PCB-SD0000070825 Gateway Reporting Associates, Inc. 41 1 A. No. 2 Q. Do you know what blends of Pyranol the 3 Anniston, Alabama plant made in 1970? 4 A. Did you say were there blends? 5 MR. SABETTA: Do you know what kind of 6 blends? 7 A. No. There were so many, I just don't 8 remember the numbers. 9 Q. What did you do after 1966 for Monsanto? 10 A. My dates are a little advanced. 11 Q. Okay. 12 A. In1965 I was assigned to the Anniston, 13 Alabama plant as the Plant Manager. 14 Q. At that time, was the Anniston plant 15 blending Pyranol? 16 A. Yes. 17 Q. Was it making PCBs? 18 A. Yes. 19 Q. Was it making otherchemicals? 20 A. Yes. 21 . Q. About how many other chemicals? 22 A. Gosh! 15, 20. 23 Q. What is Pyranol? 24 A. Pyranol is a mixture of chemicals that is 25 used as a cooling medium in electrical equipment. Gateway Reporting Associates, Inc. WATER PCB-SD0000070826 Gateway Reporting Associates, Inc. 42 1 Q. Do you know whether General Electric 2 company patented that process? 3 MR. SABETTA: Objection to the form. 4 MR. GRONDAHL: Join in the objection. 5 A. I'm not aware of any - - I don't know. 6 Q. Do you know whether General Electric 7 company patented dielectric fluid using Aroclors? 8 MR. SABETTA: Objection to form. 9 MR. GRONDAHL: Objection to form. 10 A. I recall a patent referring to dielectric 11 fluids with PCBs issued to General Electric. I don't 12 recall at this moment the specifics of the patent. ' 13 Q. Do you know whether Pyranol was a trademark 14 of General Electric Company? 15 A. That's my understanding. 16 Q. Is Aroclors a trademark of Monsanto? 17 A. Yes . 18 Q. How long were you Plant Manager at 19 Anniston? 20 A. Until the end of 1969. 21 Q. What did you do in 1969 or early '70 for 22 that matter? 23 A. ' I was assigned a new job called Manager, 24 Environmental Control, located in Monsanto's 25 headquarters in St. Louis. Gateway Reporting Associates, Inc. WATER PCB-SD0000070827 Gateway Reporting Associates, Inc. 43 1 Q. Was there a job description written for 2 that job? 3 A. I never saw one. 4 Q. Who assigned you to that job? 5 A. The word "assigned" kind of puzzles me. I 6 never perceived it as being assigned by these 7 individuals, but I was acceptable to the two business 8 directors whose business groups were involved with PCB 9 products. 10 Q. Who were those two business directors? 11 A. James Springgateand Howard Bergen. 12 Q. What do you mean "groups assigned to PCB 13 products"? 14 A. These are I'm going to call them teams of 15 people, including researchers, marketing people, 16 production people involved with an assigned set of 17 products. Product A, product B, product C is yours, and 18 D, E, F is this fellow's. And they then are to 19 supervise the activities of these individual fellows to 20 get the best results for that set of products. 21 Q. What set of products did Mr. Springgate 22 have at that time? 23 A. ' His group was called in Monsanto as the 24 plasticizers group. 25 Q. Did that group go out of business in 1972? Gateway Reporting Associates, Inc. WATER PCB-SD0000070828 Gateway Reporting Associates, Inc. 44 1 A. No. Not that I'm aware of. 2 Q. Did that group have any otherproducts than 3 plasticizers? 4 A. No. 5 Q. What products did Mr. Bergen's group have? 6 A. Industrial fluids. 7 Q. Could you explain that a little bit more as 8 to what fluids? 9 A. Explain what I mean by industrial fluids 10 you mean? . 11 Q. Yes. What products are entailed in 12 industrial fluids? '. 13 A. Products? Several types. There's the 14 fluids that are used in hydraulic systems to move 15 equipment or move conveyor belts or run air compressors. 16 Then there's the type that's used as a medium for 17 transferring heat from one source to a use point. And 18 then there's, of course, the use in the electrical 19 equipment. There's the use in aircraft to raise and 20 lower the wheels and the flaps and so on, aircraft 21 hydraulic fluid. I'm sure I didn't cover all of them, 22 but that's an example of the type of fluids that they 23 were involved with. 24 Q. Who did Mr. Springgate report to in terms 25 of his superiors? This is back at the time period that Gateway Reporting Associates, Inc. WATER PCB-SD0000070829 Gateway Reporting Associates, Inc. 45 1 you're at. 2 A. As best I remember -- As best I remember, 3 it was John Mason, Assistant General Manager. 4 Q. General Manager of what? Assistant General 5 Manager of what? 6 A. At that time, it was called the Organic 7 Chemicals Division of Monsanto. 8 Q. Do you know who Mr. Mason reported to? 9 A. At that time, it was Howard Mink'ler, 10 M-I-N-K-L-E-R. 11 Q. What was his title? 12 A. He was the General Manager. 13 Q. Of the company? 14 A. No. Of that division, Organic Chemicals 15 Division. 16 Q. Who did Mr.. Bergen report to at that time? 17 A. Mr . Bergen reported to John Mason. 18 Q. Who did Mr. Minkler report to? 19 A. I ' m trying to remember. It was a vice 20 president of Monsanto. 21 Q. Was that vice president in charge of any 22 particular area of the company? 23 A. You mean physical area or assigned activity 24 area ? 25 Q. His job activity area. Gateway Reporting Associates, Inc. WATER PCB-SD0000070830 Gateway Reporting Associates, Inc. 46 1 A. He was assigned what I'm going to call the 2 chemicals type of activities. 3 Q. Did Monsanto do anything else at that time 4 except for chemicals activities? 5 A. Certainly. 6 Q. Going back to Plant Manager at Anniston, 7 who did you report to at that time? 8 A. When you say "at that time," you mean the 9 whole period or... ' 10 Q. Well, I think you said it was a four-year 11 period. 12 A. Yes. 13 Q. '65 through '69? 14 A. Yes. 15 Q. That period. 16 A. That period.Initially Ireported to 17 Robert Soden, S-O-D-E-N, and then I reported -- He got 18 promoted, and he was replaced with Raymond Stratmeyer, 19 S-T-R-A-T-M-E-Y-E-R. 20 Q. In terms of Pyranol, when you were working 21 as Plant Manager at the Anniston plant, was there a 22 particular place where that chemical was shipped when it 23 was sold to General Electric? 24 MR. SABETTA: Objection to form. 25 A. I'm confused with thequestion, because Gateway Reporting Associates, Inc. WATER PCB-SD0000070831 Gateway Reporting Associates, Inc. 47 1 when you say "particular place" -- 2 Q. Let me ask you some more questions. As I 3 understand it, for example, General Electric made 4 transformers in Rome, Georgia and Pittsfield, 5 Massachusetts and made other electrical equipment at 6 other various plants. I'm interested to know whether it 7 was any particular site that Anniston shipped the 8 Pyranol to in this 1965 through '69 time period. 9 MR. GRONDAHL: Object to the form. 10 MR. SABETTA: Objection to form. 11 MR. McDONOUGH: I would hope so. 12 Q. Can you answer it? ' 13 A. I think I can. As I understand it, you're 14 asking me to tell you the General Electric plants that 15 received these shipments? 16 Q. If youcan. 17 A. I can. 18 Q. Okay. 19 A. Rome, Georgia and Pittsfield, 20 Massachusetts. 21 Q. Okay. Was there a difference in the 22 quantities that went to those plants during those years? 23 ' MR. SABETTA: Objection. 24 Q. And I'm talking about generally now. Was 25 it shipped half to Pittsfield, half to Rome, and so Gateway Reporting Associates, Inc. WATER PCB-SD0000070832 Gateway Reporting Associates, Inc. 48 1 forth? 2 MR. SABETTA: Objection to form. 3 MR. McDONOUGH: You only have to say it 4 once, John. 5 A. I just don't recall specific numbers. The 6 activity varied. 7 Q. How are you doing? 8 MR. SABETTA: I could use a short break if 9 it's okay. 10 MR. McDONOUGH: Based on your last series 11 of objections, take a break. 12 MR. SABETTA: Okay. ' 13 (Whereupon, there was a brief recess.) 14 Q. What was your job or what were your job 15 duties as Manager of Environmental Control? 16 A. I was to serve as the individual that tried 17 to keep abreast of all new developments as they related 18 to PCBs and the environment, and it was a -- Really, 19 initially it was a case of letting the left hand know 20 what the right is doing regarding not only within 21 Monsanto, but with its customers, with the university 22 laboratories, with other producers of PCBs, citizen 23 groups, anybody that wanted to know something about 24 PCBs. I was to be aware of that and to try to provide 25 the answers as they developed, and it was up to me to Gateway Reporting Associates, Inc. WATER PCB-SD0000070833 Gateway Reporting Associates, Inc. 49 1 keep abreast of all new developments. 2 Q. Was this position a new position with 3 Monsanto? 4 A. Yes. 5 Q. Do you know who participated in its 6 creation? 7 A. There was a group in '69 of Monsanto 8 individuals who, as best as I can determine, were 9 appointed by Mr. Bergen, Mr. Springgate, and the 10 Corporate Medical Director to address this PCB 11 environmental issue and make recommendations to Monsanto 12 management regarding how to best understand the issue 13 and to respond to it. This group referred to itself as 14 the PCB Ad Hoc Committee. 15 Q. Did it ever get any other names than the 16 PCB Ad Hoc Committee? 17 A. No . 18 Q. Who was the Corporate Medical Director that 19 referred to? 20 A. Dr . Emmet Kelly. 21 Q. Do you know if Dr. Kelly is still alive? 22 A. He is not. 23 Q. ' Who else was involved in this group in 1969 24 or '70? 25 A. I'll try to remember them all. I'm sure Gateway Reporting Associates, Inc. WATER PCB-SD0000070834 Gateway Reporting Associates, Inc. 50 1 I'm going to miss somebody. There was Elmer Wheeler, 2 Bill Richard, Paul Hodges. I think Mel Ferrar, 3 F-E-R-R-A-R. He was a member. That's as far as my 4 memory will help me. 5 Q. Are any of these gentlemen still alive? 6 A. Mr. Ferrar is, and I understand Mr. Hodges 7 is. The others are not. 8 Q. Do you yourself have any medical 9 background? 10 A. No. 11 Q. Are you a toxicologist? 12 A. No. ' 13 Q. Do you have any toxicological background? 14 A. No. 15 Q. Are you an epidemiologist? 16 A. No. 17 Q. Do you have any epidemiological background? 18 A. No. 19 Q. Did you get any information in those 20 various areas when you took on your new assignment? 21 A. Yes. 22 Q. Who gave you information, or how did you 2 3 get information? 24 A. I would make it a point to talk with 25 individuals within and without Monsanto who I was told Gateway Reporting Associates, Inc. WATER PCB-SD0000070835 Gateway Reporting Associates, Inc. 51 1 had the expertise and were willing to share it with me. 2 Q. Were you given any training program? 3 MR. SABETTA: Objection to the form. 4 A. Not in those fields. 5 Q. What about training for the job of Manager 6 of Environmental Control? Did you get any training? 7 A. Well, I got what I call a tutorial, a 8 one-on-one kind of training. 9 Q. Who gave you this tutorial? ' 10 A. It depended, of course, on the subject. If 11 it was medically related, it was Dr. Kelly, or Elmer 12 Wheeler. That's only one example. ' 13 Q. Do you recall meetings with Dr. Kelly and 14 Mr. Wheeler immediately after you assumed your position? 15 A. Yes. 16 Q. Was there a regular series of meetings, or 17 was it informal? How did that go? 18 A. Oh, I don't know what you mean by regular 19 and informal. 20 Q. Well, withdrawn. How many meetings did you 21 have within a month with Dr. Kelly? 22 A. I never kept a record. I would suggest 23 that every working day and some weekends I met with one 24 or the other for periods of time. 25 Q. What was Mr. Wheeler's title? Gateway Reporting Associates, Inc. WATER PCB-SD0000070836 Gateway Reporting Associates, Inc. 52 1 A. At that time, he was the Assistant Medical 2 Director. 3 Q. Was he a medical doctor? 4 A. No. 5 Q. What was his training in? 6 A. Public health. 7 Q. Do you know what his degrees were? 8 A. Master of Public Health. 9 Q. Do you know whether Dr. Kelly had a 10 particular field of specialty? 11 A. I do not. 12 Q. Do you know where Mr. Wheeler is now? ' 13 A. Deceased. 14 Q. Did you continue to have these meetings 15 with one or the other of them every day and sometimes 16 weekends in the second month after you started your job? 17 A. Not as frequently. 18 Q. Was there a general topic to these meetings 19 in the first month? 20 MR. SABETTA: Objection to the form. You 21 can answer it. 22 A. General topic was what effect, if any, the 23 PCBs that were being reported as being in the 24 environment could cause, some effect somewhere. 25 Q. Were these discussions of human health Gateway Reporting Associates, Inc. WATER PCB-SD0000070837 Gateway Reporting Associates, Inc. 53 1 effects? 2 A. Well, that was the basis, and we picked it 3 up from that after they brought me up to speed on human 4 health. 5 Q. Did they assign you readings? 6 A. Readings? 7 Q. Yes. 8 A. Oh, certainly. Yes. 9 Q. What did they tell you about the effects on 10 human health at that time when they brought you up to 11 speed? 12 A. I don't remember the specifics, but the' 13 general impression was one of after decades of the use 14 of these materials with the firm belief that they were 15 innocuous no information had developed to cause any 16 concern regarding illnesses, the toxic effects on 17 humans, as long as they did not overly expose 18 themselves. 19 Q. Whose firm belief was that? 20 MR. SABETTA: Objection to the form. 21 . Q. Withdrawn. You mentioned firm belief in 22 your answer. What firm belief or whose firm belief were 23 you referring to? 24 A. Well, I would suggest to you that anybody 25 who even knew what PCBs were had that belief. Gateway Reporting Associates, Inc. WATER PCB-SD0000070838 Gateway Reporting Associates, Inc. 54 1 Q. Can you tell me what you were referring to 2 when you referred to a firm belief in your last answer? 3 A. A firm belief was that PCBs, if used with 4 respect, have not and are not expected to cause serious 5 human health problems. 6 Q. Did Dr. Kelly tell you that? 7 A. Yes. 8 Q. Did Mr. Wheeler tell you that? 9 A. Yes . 10 Q. Did you read any Monsanto documents at that 11 time that said that? 12 A. I believe I did, yes. ' 13 Q. Do you recall what the titles of the 14 documents were? 15 A. No, I don't. 16 Q. Did it have a title that pertained to PCBs? 17 A. Certainly the documents I read involved 18 reference to PCBs. 19 Q. You don't recall what the titles were of 20 those documents? 21 , A. There were so many, sir, that -- Some had 22 product titles; some had use titles. 23 ' (Reporter marked Plaintiff's Exhibit No. 24 375 . ) 25 Q. I'm showing you Exhibit 375 for Gateway Reporting Associates, Inc. WATER PCB-SD0000070839 Gateway Reporting Associates, Inc. 55 1 identification, Mr. Papageorge. It reports to be 2 Monsanto's responses to interrogatories on this matter. 3 And I'd ask if you had seen that document before. 4 (Reporter marked Plaintiff's Exhibit No. 5 376 . ) 6 A. I have scanned the document, and I just do 7 not recall ever having seen this before. 8 Q. All right. If you'll look at question 36 9 for me, at page 29, that says, "Set forth the name and 10 present address of the person most familiar with the 11 following: (a) The manufacture of the product 12 Aroclors; (b) The design of said product; (c) The 13 safety aspects of said product; (d) Advertisement and 14 promotion of said product." And if you look at the 15 response, after the objection, it says that you are the 16 most familiar with the manufacture of the product. Do 17 you see that? 18 A. I see it. 19 Q. Do you agree with that? 20 MR. SABETTA: Objection to the form 21 Q. I'11 withdraw it. Are you the most 22 familiar with the manufacture of Pyranol? 23 MR. SABETTA: Same objection. 24 Q. In the Monsanto Company? 25 A. I don't picture myself as being the most Gateway Reporting Associates, Inc. WATER PCB-SD0000070840 Gateway Reporting Associates, Inc. 56 1 familiar, no, sir. 2 Q. Are you the most familiar with the 3 manufacture of Aroclor 1254 in the Monsanto Company? 4 A. Again, I can think of individuals who can 5 give you much more in the way of specifics regarding the 6 manufacturing process. 7 Q. What about the -- Withdraw that. Can you 8 give me the name of individuals who could give me that 9 information with respect to 1970? ' 10 A. I'm trying to recall the names of the 11 individuals at the manufacturing plants who supervised 12 the manufacturing process and were familiar with all 'the 13 details, temperatures, pressures, flows and so on. 14 1970. No specific name comes to mind. 15 Q. What about the chemical characteristics of 16 the product Aroclor 1254 as of 1970? Who would be the 17 most familiar? 18 A. Will you help me with the expression 19 "chemical characteristics"? 20 Q. I was hoping you would help me with that 21 expression. You mentioned things like flows and 22 temperatures and things of that sort in your answer. I 23 wanted to know who might be the most familiar in 1970 24 with the properties of Aroclor 1254 as to them being 25 inert, perhaps., or not oxidizing perhaps or not Gateway Reporting Associates, Inc. WATER PCB-SD0000070841 Gateway Reporting Associates, Inc. 57 1 hydrolyzing perhaps, or things like that. 2 MR. SABETTA: Objection to the form. 3 MR. GRONDAHL: Object to the form. 4 MR. SABETTA: I just observe that my 5 understanding of Mr. McDonough's question encompasses 6 several different areas, chemical characteristics, 7 process characteristics, and properties of the compound, 8 all of which to me are quite different. So I object to 9 the form of the question as it's been put. If you can 10 answer it, go ahead. 11 A. Well, I heard references to temperatures 12 and flow rates, and all of those are manufacturing 13 parameters that the supervisor and his foreman in that 14 department would know because that is their job. It is 15 not something that a person in my position would need to 16 know. 17 Q. But you don't know anybody in the company 18 that would know about properties of Aroclor 1254 as to 19 it being inert? 20 A. Now, the physical and chemical properties, 21 I would personally go to a research person. And, again, 22 I can't at the moment recall an individual because this 23 has been decades ago. 24 Q. Okay. Do you know that Aroclor 1254 is 25 generally considered to be inert? Gateway Reporting Associates, Inc. WATER PCB-SD0000070842 Gateway Reporting Associates, Inc. 58 1 MR. SABETTA: Objection to form. 2 A. I have difficulty with understanding the 3 word "inert". 4 Q. Well, did you ever have an understanding 5 that Monsanto's understanding was that this chemical was 6 going to be like pebbles on the beach? 7 A. Yes. Yes. Yes. 8 Q. In fact, you've used that phrase before; 9 haven't you? 10 A. I have. I inventedit. 11 Q. What did you mean by "pebbles on the beach" 12 when you invented that phrase? ' 13 A. I was referring to the fact of presence and 14 health effects, human health effects. 15 Q. You say when you were referring to the term 16 "pebbles on the beach", you were referring to presence 17 and human health effects? 18 A. Yes. 19 Q. In what fashion were you referring to it? 20 A. Well, the pebble is there on the beach. 21 It's present. And unless you stump your toe or 22 something, it's not going to affect you as a human 23 being. ' 24 Q. As an organic chemist with a Master's 25 degree, did you understand from the molecular structure Gateway Reporting Associates, Inc. WATER PCB-SD0000070843 Gateway Reporting Associates, Inc. 59 1 of this chemical that it was inert? 2 MR. GRONDAHL: Object to the form. 3 MR. SABETTA: Same objection. 4 A. I am not saying it's inert, uh-uh. 5 Q. What does inert mean? 6 A. To me, it means it's nonreactive and it 7 causes no effect. It's just present. 8 Q. Isn't that what Monsanto thought the 9 chemical was, A-1254, from 1931 up till 1966?10 MR. SABETTA: Objection to form. 11 A. Again, I have trouble fitting the word 12 "inert" because Monsanto did say, "Don't get it on your 13 skin. It's going to get chapped hands effect. Don't 14 breathe it. It will hurt your breathing." So it's not 15 inert in that definition of the word "inert". 16 Q. Do I understand it's not a pebble on the 17 beach? 18 MR. SABETTA: Objection to form. 19 A. I still think it is. It's there. Just 20 avoid the pebble and go around it. 21 Q. How big is this pebble? 22 MR. SABETTA: Objection to form. 23 ' MR. GRONDAHL: Objection. 24 A. I was just using that as a figure of 25 speech. Gateway Reporting Associates, Inc. WATER PCB-SD0000070844 Gateway Reporting Associates, Inc. 60 1 Q. Did Monsanto ever test these, pebbles by 2 heating them that you know of ? 3 MR . SABETTA: Objection to form. 4 MR . GRONDAHL: Obj ection. 5 A. I need more help with the word "testing by 6 heating". 7 Q. What is unclear with my phrase "testing by 8 heating"? 9 A. I can give you a scenario where you take 10 test animals, heat Aroclor till it becomes a vapor and 11 then you expose these test animals and see what happens. 12 Q. What about taking the Aroclor and applying 13 heat to it and determining what its combustion products 14 or pyrolysis products were? 15 MR. SABETTA: Objection to the form. 16 Q. Did Monsanto do that? 17 A. No. 18 Q. Do you know why not? 19 A. There was no information of any kind to 20 lead anybody in the world, not just Monsanto, to conduct 21 such a study. Why would you do it? There's no evidence 22 that there's a harm being observed. 23 Q. What about people in Monsanto who are most 24 familiar with adverse human health effects or biological 25 effects on animals of Aroclor 1254? Do you know anyone? Gateway Reporting Associates, Inc. WATER PCB-SD0000070845 Gateway Reporting Associates, Inc. 61 1 A. That would have been members of Monsanto's 2 Corporate Medical Department. 3 Q. What about now? Does it still have a 4 Corporate Medical Department? . 5 A. They have the department. 6 Q. Where is this Corporate -- Well, withdraw 1 it. Where was this Corporate Medical Department in 8 1969, 1970? Was it in the - 9 A. It was in St. Louis. 10 Q. Was it in the same building that you were 11 in at the time of your assignment? 12 A. No. ` 13 Q. Was it on the same campus? 14 A. Yes. 15 Q. Did Monsanto have a Research and 16 Development Department at that time in 1969/70? 17 A. Yes. 18 Q. Where was that located? 19 A. On the St. Louis campus. 20 Q. Who was the head of that department in 1965 21 through 1975? 22 A. As best as I recall, it was Monte Throdal, 23 who was the Vice President of Research. M-O-N-T-E 24 T-H-R-O-D-A-L. 25 Q. Is -he still alive? Gateway Reporting Associates, Inc. WATER PCB-SD0000070846 Gateway Reporting Associates, Inc. 62 1 A. Yes. 2 Q. Did that department have a library 3 associated with it? 4 A. Yes. 5 Q. How extensive a library? Have you ever 6 seen it? 1 A. I am not qualified to measure extent. It 8 was a -- It was an excellent library as far as I could 9 tell. 10 Q. What about a medical library? Did the 11 Corporate Medical Department have a medical library? 12 A. Yes. ' 13 Q. How extensive a library was that? 14 A. I have no idea of the number of volumes 15 they had or... 16 Q. With respect to Pyranol or Aroclor 1254, 17 did that medical library gather information on those 18 particular chemicals? 19 A. I'm aware that they gathered information on 20 Aroclor 1254 as a PCB. I am not aware of any library 21 information available for Pyranol per se. 22 Q. Did Pyranol in 1969, 1970, contain other 23 chemicals than Aroclor 1254? 24 A. Yes. 25 Q. Do you know what other chemicals it could Gateway Reporting Associates, Inc. WATER PCB-SD0000070847 Gateway Reporting Associates, Inc. 63 1 contain at that time period? 2 A. I know they contained a mixture of tri and 3 tetrachlorobenzene, and they also contained other 4 ingredients that I don't remember now, but they were 5 intended to, for example, scavenge any free chlorine 6 that might still be in there. Also, as best I recall, 7 there was an attempt to give it a color, a dye 8 ingredient, and I don't propose to tell you that I know 9 all the ingredients in the recipe. 10 Q. Do you know where tri/tetrachlorobenzene 11 came from? 12 A. Yes. ' 13 Q. Where? 14 A. Hooker Chemical Company. 15 Q. Do you know what the qualities or chemical 16 products of trichlorobenzene were that caused them to be 17 used in this blend? 18 A. I don't knowtoday, no, but there were 19 pretty stringent specifications. 20 Q. Did Monsanto buy that chemical from Hooker 21 Chemical when they blended the Pyranol at their plants? 22 A. Yes. 23 Q. ` Did you do anytesting on thatchemical 24 tri/tetrachlorobenzene? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070848 Gateway Reporting Associates, Inc. 64 1 Q. What tests did you do? 2 A. I don't remember the details, butsamples 3 were taken, and if they passed the criteria that were in 4 place at the time, the shipment would be accepted. If 5 not, it would be returned. 6 Q. Do you know whether the chemical was ever 7 heated by Monsanto and its pyrolysis products tested? 8 A. No. 9 Q. Do you know whether Monsanto ever 10 ascertained that dioxins pyrolized from 11 tri/tetrachlorobenzene? 12 MR. SABETTA: At any time? 13 MR. MCDONOUGH: At any time. ' 14 MR. SABETTA: Up to the present. 15 A. I'm not aware of any studies of that kind, 16 but I cannot speak for recent years. I don't know. 17 Q. When did you retire from Monsanto? 18 A. The end of 1986. 19 Q. Can you tell me, by "recentyears," can you 20 tell me what are recent to you? 21 A. The '80's and '90's. 22 Q. After Dr. Kelly retired, who became Medical 23 Director of Monsanto? . 24 A. Dr, George Roush, R-O-U-S-H. 25 Q. Do you know whefh that was about? Gateway Reporting Associates, Inc WATER PCB-SD0000070849 Gateway Reporting Associates, Inc. 65 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't recall the exact year. I'm going to suggest about 1974. Q. How long did Dr. Roush remain as Medical Director? A. Again, I don't know the exact date. I was retired by then, so it would have to be after 1986. That's as close as I can get to it. Q. Do you know if Dr. Roush is still alive? ' A. Yes. ' Q. Do you know where he lives? A. No, I don't. Q. Do you know if he lives in the St. Louis area? A. Q. Yes, he does. Do you know if he still practices medicine? A. He does not. Q. Do you know how old he is about? A. About 7 0. Q. Who became the Medical Director after Dr. Roush? A . I don't know. Q. I'm showing youExhibit 376 for identification, which purports.to be Responses and Objections of Monsanto to Plaintiffs' Notice to Produce and ask you to take a look a't that for me, if you would, Gateway Reporting Associates, Inc. WATER PCB-SD0000070850 Gateway Reporting Associates, Inc. 66 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 please. I'm going to ask you if you've ever seen the document before, and I'm particularly interested in the response at 19. Have you had a chance to look at that? A. I have scanned it. Q. Have you seen it before? A. I don't recall ever seeing this. Q. Could we take a look at 19, please? Now, in 19, I ask for any memos and correspondence to and from Monsanto Chemical Company from 1930 through 1975 regarding health and/or environmental effects and/or toxicity of chlorinated diphenyls, chlorinated biphenyls, Inerteen, Aroclors and Pyranols including, without limiting the foregoing." The response after' some objections is Monsanto states that documents responsive to this request will total in excess of 30 bankers boxes of documents, and then there's an offer to make them available to the plaintiff. Do you see that? A. Yes. Q. When you started your job in 1970, was there in excess of 30 bankers boxes of documents in the libraries that you were looking at? MR. SABETTA: Object to the form of the question. A. No. . I did not personally see 30 boxes of information. T- Gateway Reporting Associates, Inc. WATER PCB-SD0000070851 Gateway Reporting Associates, Inc. 67 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. How much information did you see in this tutorial program that you've told me about? A. As best I recall, there was two three-ring notebooks about three inches in contents. Q. Did those two three-ring notebooks have a title? A. No. Q. Do you know who prepared them? A. Yes. - Q. Who? A. Elmer Wheeler. Q. Do they still exist? A. I don't know. Q. Did they have any summaries associated with them? A. There were summary paragraphs on some of the pages, yes. Q. Could you describe for me what you mean by summary paragraphs on some of the pages? A. I recall paragraphs that would refer to an article or a study by author and date and summarize what was concluded from the study. Q. And that would be.in the beginning of the book, the three-ring binder? A. That would be shattered throughout the Gateway Reporting Associates, Inc. WATER PCB-SD0000070852 Gateway Reporting Associates, Inc. 68 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 book. As I remember, they were in the book chronologically depending on when the article first appeared. Q. Do you recall what the first article was? A.., Something in the 1930's, but I don't remember the specific article. Q. How about Drinker? A. Drinker was one of them, but I don't know if that was the first article. It was one of the earlier articles, yes. Q. How long did you work in that position? A. Which position, sir? / Q. The last position you gave me was Manager of Environmental Control. A. About 1973 my title was changed to I believe it was Manager, Environmental Protection. Q. Did your duties change? A. In a way. They did not change with regard to PCBs. Q. Okay. In what way did they change? A. I was given additional products of Monsanto to monitor and advise on and become familiar with. Q. Did Monsanto have anybody with that title, Manager of Environmental Protection, before you? A. Not to my knowl-edge. Gateway Reporting Associates, Inc. WATER PCB-SD0000070853 Gateway Reporting Associates, Inc. 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. How long did you perform that title? A. I'm not certain of my dates here. '73 may be too late. But, nevertheless, a couple of years for the environmental protection title. Q. Do you know whether the duties of that title were ever put in writing? A. I never saw it in writing. Q. What was your next title? A. Manager of Product Acceptability. Q. Did your duties change with the assumption of that new title? A. They changed only in the types of products I was held responsible for, but I still, as best I recall -- Yes, I still kept the PCB activity. Q. Were your other products that apparently you got involved with products involving issues of environmental concern or concern on biological effect? A. Not necessarily. Q. How did it happen that you got involved in them? MR. SABETTA: Objection to form. You can answer it. A. As I recall, Monsanto had reorganized into separate operating units, and each of those units had a Manager of Product Acceptable.ity, so the products Gateway Reporting Associates, Inc. WATER PCB-SD0000070854 Gateway Reporting Associates, Inc. 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 assigned to those units were also assigned to this Manager of Product Acceptability within the major unit. Q. What unit were you assigned to at that time? A. As best I recall, it was Monsanto Industrial Chemicals Company. Q. How long did you function in that job title? A. Until the next reorganization. ' Q. Which was about when? A. A couple, three years later. Q. Would that be about 1977? A. '76, '77, somewhere in there. Q. What was your title? A. I had the same title of Manager, Product Acceptability, for the Monsanto Intermediate Chemicals Company. Q. Did that job title include PCBs? A. Yes. The PCBs, of course, were assigned to a different company, but the environmental issue was still me, was assigned to me. Q. What different company was PCBs assigned to? ' . A. I'm a little confused at this moment recalling the Industrial Chemicals Unit and the Gateway Reporting Associates, Inc. WATER PCB-SD0000070855 Gateway Reporting Associates, Inc. 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Intermediate Chemicals Company and the timing. Q. Now, I believe you mentioned -- Withdraw that. Had Monsanto discontinued production of PCBs at that time when you took that assignment? A. I think we're still talking about an era before 1977; aren't we? Q. I thought you took this new position in 1977. Perhaps not. Maybe I misunderstood. Let me withdraw it and make it less difficult. At some point did Monsanto discontinue manufacturing andselling PCBs? A. Yes. Q. Do you know about when that was? A. The summer of 1977. Q. Did you continue to work with respect to environmental issues on PCBs after Monsanto discontinued their manufacture and sale? A. No. I had been -- It had been reassigned earlier than that. Q. Meaning you had been reassigned earlier than that? A. Q. Yes. Okay. What were you assigned toearlier than the discontinuance of the.PCB manufacture? A. I was given, and I don't remember all of them, a whole series of products which were the Gateway Reporting Associates, Inc. WATER PCB-SD0000070856 Gateway Reporting Associates, Inc. 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 responsibility of the operating unit, which at this moment I can't recall whether it was Industrial Chemicals or Intermediate Chemicals. But in February of '76, the PCB issue role was transferred to another individual. Q. Who was that? A. J. C. Webber. Q. Is Mr. Webber still alive? A. I think, yes. Q. Does he still 1 ive in the St. Louis area? A. As far as I know. Q. know? Does he still work for the company? Do you A. No. Q. Do you know how long Mr. Webber continued in that position? A. Not specifically. I would suggest that he monitored the activities for a couple, three years. Q. Do you know what happened after a couple, three years with respect to that activity? . A. I think Mr. Webber sort of broadly covered it, but the activity had diminished to the point where nothing really was going on. . ' Q. Now, as I understand it, you seem to have stopped your involvement with PCBs in about 1976 or Gateway Reporting Associates, Inc. WATER PCB-SD0000070857 Gateway Reporting Associates, Inc 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 thereabouts? A. Yes. Q. And you continued to work for the company until 1986? A. Yes . Q. Can you tell me what you did between 1976 and 1986? Just generally. Did you have different titles? What generally were your duties? A. Yes. I was made a Director of Environmental Operations for one of those operating units we discussed earlier, which involved all activities within those operating units that would or could relate to the environment. All the chemicals, all the products, the shipping, trash disposal, the whole bit . Q. Did any of that work entail PCBs? A. PCBs as a presence in the plants, yes, but not with respect to government or customers. Q. Did you meet with any government authorities during this 1976 through 1986 time period with, respect to PCBs? A. I met in November of '76 as a committee member of the National Institute of Occupational Safety and Health, N.I.O.S.H., N-I-O-S-H. This committee was Gateway Reporting Associates, Inc. WATER PCB-SD0000070858 Gateway Reporting Associates, Inc. 74 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I'll ask you to describe it later if I think it's really relevant. I'm more interested in getting a framework right now, if I can. I understand that I was asking about a roughly ten-year period, '76 through '86 in terms of meeting with government agencies or authorities, and you've told me about N.I.O.S.H. in November of 1976. Any others? . MR. SABETTA: This relates to PCBs or in general? Q. A. ' Yes. Which relates to PCBs, yes. - I don't recall any other activity of that type . Q. Now, did you have any other job titles with Monsanto before you retired? A. The job titles did not change. Q. In terms of your work in the last ten years, did you deal with any incineration or disposals of PCBs? A. Q. Not directly. Had Monsanto set up a division or part of its operation that incinerated PCBs? A. There was an incinerator installed by Monsanto and operating in the early part of that period, up through ' 77 . Q. Okay. Do you Icnow how long a period that Gateway Reporting Associates, Inc. WATER PCB-SD0000070859 Gateway Reporting Associates, Inc. 75 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 incinerator was operating? A. Yes. From about 1970, about the middle of 1970 to the middle of 1977. Q. You know why it stopped operating in 1977? A. Well, the production of PCBs was terminated, and the amount of material being returned had reduced to the point where it was perceived not to be needed any longer because there were commercial units available. Q. Were there commercial incineration units available in 1977? A. Yes . Q. Wasn't there a permitting process necessary for those commercial incineration units? A. I'm not familiar with the details of their operations. Q. Do you know who was in charge of the disposal of PCBs for Monsanto's corporate operations? MR. SABETTA: Objection to form. Q. I'll withdraw it. Was anyone in charge of disposals of PCBs by incineration at Monsanto? A. The Monsanto employee who was responsible for an activity that resulted in PCBs that were no longer usable and must be discarded was expected to dispose of those PCBs in a responsible manner. If this Gateway Reporting Associates, Inc. WATER PCB-SD0000070860 Gateway Reporting Associates, Inc. 76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 involved sending it to Monsanto's incinerator, all right. If it involved going to a nearby approved commercial incinerator, that's all right, too. Or if it involved perhaps even sending it to Monsanto to refine, to run it through the system and clean it up and make it useful again, that was acceptable. So it was a decision, a judgment call really on the part of the individual held responsible for that so-called waste material. ' Q. Are you telling me no one was in charge of supervision of the disposal or incineration of waste material? A. There were hundreds responsible. I don't know how to describe it . Q. Who was at the top? A. The president of Monsanto. Q. Was there any job title associated with disposal or destruction of PCBs in the Monsanto system? A. No. Q. Okay. If you take a look at Exhibit 375 for me, page six, there's a question as to products sold to General Electric and response by Monsanto for the 1970-1977 time period. Would you take a look at that question and answer, please? MR. SABETTA: The question starts on page Gateway Reporting Associates, Inc. WATER PCB-SD0000070861 Gateway Reporting Associates, Inc. 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 five and continues on page six. Q. Do you know whether there was a particular blend of Pyranols sold to Rome, Georgia, during the 1970 through '71 time period? A. No, I do not. Q. I'm showing you Exhibit 331. It's been marked earlier with another witness. It purports to be a General Electric document on their letterhead dated October 15th, 1995. I'm sorry. 1975. Subject Pyranol formulations, MTPD, Rome, Georgia. It purports to set forth a schedule as to products and years that the products were used. Would you take a look at that, please? MR. GRONDAHL: What's the number on it? MR. SABETTA: 331 is the exhibit number. Q. Now, with respect to 1970, it has an Aroclor 65 percent 1254, 23 percent trichlorobenzene, and 12 percent tetrachlorobenzene. Do you see that? A. I do. Q. Do you knowwhat productdesignation that was ?. A. I do not. Q. Now, it alsoreferences in year 1993 a product called A13B3B with a footnote saying that that was also used from September' '69 through October 1970. Gateway Reporting Associates, Inc. WATER PCB-SD0000070862 Gateway Reporting Associates, Inc. 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Do you see that? A. Ido. Q. Now, that product is apparently a 45 percent Aroclor 1260 blend with other products; is that correct? A. Q. A. Q. That's what this says, yes. Are you familiar with these blends? No. Today, no. Is that an area outside your field of expertise? A. Yes . (Reporter marked Plaintiff's Exhibit No.' 377 . ) Q. I'm showing you an exhibit I've marked 377 for identification. It purports to be a memo of data transmitted from General Electric Medium Transformer Department, Rome, Georgia, with a box checked for installation and a date of March 22nd, 1971 on it. Would you take a look at that for me, please? I'm interested in the designation of Pyranol set forth on the inside of that particular exhibit. I'll see if I can help you 'find it. (Indicating.) What is that designation of Pyranol shown on that exhibit? A. What is it? Q. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070863 Gateway Reporting Associates, Inc. 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A13B3B. Q. Do you know what the contents of that particular Pyranol is? A. No, I don't have the recipe in front of me. Q. Do you know whether that designation of Pyranol was being blended by Monsanto in that time period shown in that exhibit, March of 1971? A. I would say, yes, they did it. Q. Would there be a particular plant involved in that? A. Q. Anniston, Alabama. Now, did it come to your attention that at some point there was a change in the formulation so that tetrachlorobenzene was deleted from the formula provided by General Electric? ' MR. GRONDAHL: Object to the form. A. Well, on occasion, I would get information that would indicate changes in these formulations. I don't remember the exact change and the timing of that change. . Q. In terms of the formulations, did Monsanto design those formulations, or did someone else? A. Monsanto did not design. Q. Who designed them? A. That I don't krr-bw. All I know is General Gateway Reporting Associates, Inc. WATER PCB-SD0000070864 Gateway Reporting Associates, Inc. 80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Electric sent it to us and said, "This is what we want." Q. Did you receive correspondence and communications from General Electric setting forth the quantities of chemicals to be contained in that blend to by Monsanto? A. Oh, yeess. It's a form that they send us. Q. It came from General Electric? A. Yes . Q. Is that A. Yes . Q. I asked if you had any recollection of the blend from General Electric changing to eliminate tetrachlorobenzene. A. I don't remember that specifically, no. Q. I want to show you Exhibit 373 that's been previously marked for identification. It's entitled "Transformer Pyranol Blends, Pittsfield," and I'd ask you if you would take a look at that for me, please. If you look at the page marked four, it's the second page of the document, it has a heading April '72, "Change from. Hexachlor No. 1260 to Pentachlor No. 1254 biphenyl. Change initiated by Monsanto for ecological reasons." Do you see A. that? I do. . Q. Do you know anything about that topic? Gateway Reporting Associates, Inc. WATER PCB-SD0000070865 Gateway Reporting Associates, Inc. 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Can you tell us what you know about that? A. Monsanto's information at that point in time was that the higher chlorinated PCBs were those that were being found in the environment. People within Monsanto discussed with individuals at General Electric the possibility of discontinuing the use of Aroclor 1260, which was not a high volume Aroclor, for transformer use, and revise their formulations to introduce the use of Aroclor 1254. I personally was involved in discussions with General Electric representatives in this area, and the impression was definitely one of, "It's okay with us." So in April of '72, it was finally implemented, and Aroclor 1260 was no longer manufactured. Q. When you say "Okay with us," you're referring to General Electric? A. With the individuals in General Electric that I wa s talking to. Q. . A. Who was that? Ed Raab. Q. Anyone else that you recall? A. No. Ed Raab was my principal contact and he was it as far as I was concerned. Q. Do you remember' what Mr. Raab's title was ? Gateway Reporting Associates, Inc. WATER PCB-SD0000070866 Gateway Reporting Associates, Inc. 82 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I never did know it. Q. It's R-A-A-B? A. Yes. Q. Did you know whether findings had been made as to the presence of Aroclor 1254 in the environment at that time? A. , Oh, sure. Yes. Q. Weren't most ofthe findings indicative that primarily it was 1254 in the environment' rather than 1260? MR. SABETTA: Objection to form. MR . GRONDAHL : Object to form. A. The indications, yes, that' s correct Q. Do you have any recollections of discussions with Westinghouse and Westinghouse going to 1242 as opposed to 1254? MR. SABETTA: Objection to form. A. I recall discussions with Westinghouse representatives, and, as I recall, they always had an interest in 1242 because they, for reasons unknown to me, were avoiding the use of chlorobenzenes. Q. Could you spell that word for me, please? A. Chlorobenzenes. C-H-L-O-R-O-B-E-N-Z-E-N-E. Q. You don't know why they were avoiding the use of chlorobenzenes? ^ Gateway Reporting Associates, Inc. WATER PCB-SD0000070867 Gateway Reporting Associates, Inc. 83 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I was never told. But with using 1242, they didn't need the diluent in chlorobenzenes. Q. Were there also changes made in terms of the Aroclors that were marketed wherein 1016 was used? MR. SABETTA: Objection to form. MR. GRONDAHL: Objection. A. Oh, yes. Those were -- We're now talking about another PCB used for a different electric purpose. Q. When was that? Let me withdraw that. What electric purpose are you referring to? A. The use in capacitors. Q. Had PCBs been used in capacitors in the' past? A. Q. Yes. And what PCBs were used in capacitors in the past going up through 1972? 1221 . A. Aroclor 1242, Aroclor 1232, and Aroclor Q. At some time was there an Aroclor designed for use in capacitors sold by Monsanto? A. Yes. Q. What Aroclor was that? A. It was called Aroclor 1016. Q. Now, as I understand it, Aroclor 1254 connotes a 54 percent chlorine content? Gateway Reporting Associates, Inc. WATER PCB-SD0000070868 Gateway Reporting Associates, Inc. 84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And Aroclor 1242 connotes a 42 percent chlorine content? A. Yes. Q. What does 1016 connote? A. It has no relationship to the amount of chlorine present in the product. Q. How much chlorine is present in the product, 1016? ' A. About 41 percent, 42 percent. Q. Had there been studies done up to that point as to that Aroclor being more biodegradable than 1242? A. Yes. Q. Whatstudies had been done? A. Well, Monsanto had its own studies, which indicated that the 1016 would be destroyed or consumed in an activated bacteria sludge just like you find in waste treatment plants throughout the country. Q. Did Monsanto do studies on 1254 as well about the same time? A. Yes. Q. What did they find out with respect to biodegradability of 1254? A. They found that"' the higher chlorinated PCBs Gateway Reporting Associates, Inc. WATER PCB-SD0000070869 Gateway Reporting Associates, Inc. 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 would resist degradation. They were still there after a long period of time. Q. About when were these studies conducted on 1016 and 1254? . A. Oh, they were ongoing. They were started in 1971 and ongoing in 1972. Q. Were you aware of Monsanto having started the studies of biodegradability of 1254 back in the 1930's? A. That's the first I heard of that. Q. Have you heard anything as to burying 1254 in Florida and digging it up 30 years later and finding it not biodegraded? A. Yes. I was involved in that. Q. What was your involvement? A. Well, I was following that activity closely with one of our research people Q. About when was the 1254 excavated? A. Late 1970. Q. All right. And what was the purpose of doing the excavation? Do you know? A. Q. ' To see if they were still detectable. How did it come about that 1254 was buried in the first place? Do you know? A. There was an experiment conducted in which Gateway Reporting Associates, Inc. WATER PCB-SD0000070870 Gateway Reporting Associates, Inc. 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PCBs were used along with other chemicals to treat wood for use as fence posts. In other words, to permeate the post with the chemicals. And these posts were inserted into the ground down in Florida, and the Monsanto individual who was involved remembered that study, and it occurred to him that perhaps we could go and take samples and see if the PCBs were still detectable. That's how that came about. Q. What was the purpose of burying the fence posts to begin with in terms of doing a study? A. To see how long the fence posts would last with that particular material below ground. Q. Going to the last entry on that exhibit in front of you, 373, it says, "November of '73 changed from tri/tetrachlorobenzene to trichlorobenzene; change initiated by Hooker Chemical Co. because, ban on Hexachlorophene put a stop to production of TTCB." Close quote. Do you see that? A . I do. Q. Do you know anything about that change initiated by Hooker? A. I was aware of the change, and I related it to the almost unavailability of the tri/tetra mixture. Q. This says ban on Hexachlorophene; does it not? '' Gateway Reporting Associates, Inc. WATER PCB-SD0000070871 Gateway Reporting Associates, Inc. 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Were you familiar with a ban on Hexachlorophene at about that time? A. I'm aware of it, yes. Q. What can you tell me about that? A. There was a problem associated with Hexachlorophene. The government got involved and banned it . Q. What was the problem? Do you recall? A. I haven't thought about this for 50 years. Q. Was it dioxin? A. I don't know. I don't know that the word "dioxin" existed then as popular as it was later. Q. What do you know about the existence of the word "dioxin"? MR. SABETTA: Objection, form. Q. Or is it just the popularity of it that you're referring to? ' MR. SABETTA: Objection to the form. Q. Withdrawn. Are you telling me that you don't know if the word "dioxin" was known in November 1973? A. The word was known. The studies were limited. When I first heard about it, it was referred to as Agent X. T` Gateway Reporting Associates, Inc. WATER PCB-SD0000070872 Gateway Reporting Associates, Inc. 88 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Who referred to it as Agent X? A. The medical and toxicology community. There's no one person. Q. When did you first hear about it? A. It was during my tutorial with Mr. Wheeler. Q. And what did he tell you? A. He told me there's some stuff out there that is affecting chickens, and he even showed me a photograph of a chicken walking down a corridor with a drooped wing and with a bloated chest. Q. Did he tell you about any studies out there as to dioxins affecting workmen? A. No. There were none to report. Q. A. Q. A. Q. Virginia?. Excuse me? There were none that he could report on. Is that what he told you? Yes . Did Monsanto have a ;plant at Nitro, West A. Yes . Q. Was there an explosion at that plant in 1949? A. Q. Yes. . And were there complaints by the workmen that they had become ill? Gateway Reporting Associates, Inc. WATER PCB-SD0000070873 Gateway Reporting Associates, Inc. 89 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Were there studies done by dermatologists relating to the illness through exposure to dioxin? A. Yes. - Q. Were those studies done in the 150 ' s? A. Well, your use of the word "studies" differs from mine. A study is a planned program with the protocols and dosages and times of exposure. This was just an evaluation and an attempt by individuals to try to find the source of the problem. So when you said study, that meant something different to me. Q. And these evaluations and attempts by ' individuals to try to find the source of the problem, were those attempts by Monsanto individuals or by others ? A. I know the Monsanto individuals were involved. I don't know about others. Q. Did you say were not or were? A. Monsanto individuals were involved, but I don't know if others were also involved. . Q. What Monsanto individuals were involved? A. Oh, gosh. I never knew the people. I don't know. Q. How about Dr. Kelly? Did you know Dr. Kelly? Gateway Reporting Associates, Inc. WATER PCB-SD0000070874 Gateway Reporting Associates, Inc. 90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. But I don't know if he was personally involved. The plant physician may have done it. I don't know. Q. How about Mr. Wheeler? Did you know Mr. Wheeler? A. Yes. Q. Do you know if he was personally involved? A. I don 1t know. Q. Did you ever see any documents passing to Mr. Wheeler and Dr. Kelly with respect to this Nitro, West Virginia exposure and the question of dioxin? A. I have not. Q. They didn't tell you about that in your tutorial when you took over? . A. They told me about the incident, but they didn't show me a document. Q. Did Monsanto manufacture Hexachlorophene? A. Not to my knowledge. Q. Do you know what Monsanto manufactured at Nitro, West Virginia? MR. SABETTA: Objection to form. I think you have to give him a date or some period of time. Q. 1949. . A . I don't know. Q. Do you knowwha:t they manufactured in 195 0 Gateway Reporting Associates, Inc. WATER PCB-SD0000070875 Gateway Reporting Associates, Inc. 91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 at Nitro, West Virginia? A . I don't know. Q. Do you know what the purpose of the tri/tetrachlorobenzene was in the Pyranol? A. . I can share with you my understanding. Q. Is this an understanding told to you or something that you researched on your own? Let me withdraw that. What was the basis of your understanding before I ask whether I want to hear it? A. It has to do with the physical and chemical properties of the chemicals involved. Q. Wasn't this an area that you weren't familiar with earlier? Did I understand you? A. I'm confused. MR. SABETTA: Just a second. The last question that Mr. McDonough put to you was different than the one you answered, I believe. He asked you what the source of your knowledge was about the reasons for using tri or tetrachlorobenzene in Pyranol. What were the sources of your information about that? That's what I think he asked you. Q. I'll ask a new question because I'm lost. What was your understanding as.to the purpose of the tri/tetrachlorobenzene in the Pyranol? A. For reasons unkhown to me, General Electric Gateway Reporting Associates, Inc. WATER PCB-SD0000070876 Gateway Reporting Associates, Inc. 92 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 preferred the use of Aroclor 1254 and 1260 in their transformer fluids. Those PCBs are rather viscous. To become more fluid, they had to blend this chlorinated benzene mixture at the same time they wanted to retain the fire resistance of the total mixture, and then there was a cost consideration involved where the material from Hooker was pound to pound cheaper than the PCB, so it was an economic as well as a fire resistant, as well as a fluidity question to be answered. - Q. What is the source of your information in that regard? A. I can't pinpoint any particular person. To me, it was just sort of general knowledge. Q. Well, you mentioned economics as being one of the factors and viscosity being another factor. If the material PCBs was too viscous to be used in the transformer, how did economics have to do with that? MR. SABETTA: Objection to the form. I don't understand the question. If you do, you can answer it . . A. Well, the competition was willing to use a different PCB that did not require dilution with a more fluid material. Q. And that competition would be Westinghouse? A. That's one of them. Gateway Reporting Associates, Inc. WATER PCB-SD0000070877 Gateway Reporting Associates, Inc. 93 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Was there other competition besides Westinghouse that used Aroclor other than 1254 or 1260 at that time? A. Yes. Q. Can you tell me who that was? A. I'm certain I'm not going to remember all, but I recall an Allis-Chalmers activity. At the moment I can't recall anymore. . Q. Do you know of any other transformer manufacturers at about that time that were using 1254 other than General Electric? A. There were others, but I'm at a loss to try and recall the names of these entities. I just can't remember them. Q. Had Monsanto required an indemnity agreement by the transformer manufacturers at that point in time, 1973, before they would sell them - A. Yes. Q. -- 1254 or anyAroclor? A. Yes. Q. Do you know about when that was that they started? I'm sorry. Do you know at about what time that was that Monsanto started.requiring the indemnity agreement ? A. Yes. '' Gateway Reporting Associates, Inc. WATER PCB-SD0000070878 Gateway Reporting Associates, Inc. 94 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. When? A. Early1972. Q. Did youparticipate in discussions with respect to that indemnity agreement? A. No. Q. Do you know who did for Monsanto? A. Yes. Q. Who? A. Mr. Bergen and Mr. Mason, his boss. Those two I know for sure. I don't know any others. Q. How about the lawyers? In-house. A. Oh, yeah. The lawyers were involved. Q. Like pebbles on the beach? MR. McDONOUGH: This might be a good time to break. If he's not tired, I am. MR . SABETTA: All right. MR . McDONOUGH : An hour. MR . SABETTA: All right. It's ten till 1:00. Try to get back at ten to 2:00. (Luncheon recess.) (Reporter marked Plaintiff's Exhibit No. 378 and 379.) Q. Mr. Papageorge, I'm showing you Exhibit 378 for identification. It purports to be a document from United States Patent Office 'on dielectric composition by Gateway Reporting Associates, Inc. WATER PCB-SD0000070879 Gateway Reporting Associates, Inc. 95 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a Frank M. Clark, Pittsfield, Massachusetts, and ask if you've ever seen that document before. A. This document does look familiar. I've seen it before. . Q. Is that the General Electric patent on dielectric fluids containing PCBs? MR. SABETTA: Objection to form. MR. GRONDAHL: Object to form. A. PCBs and other chlorinated materials. Q. Yes. As I understand it, that's the General Electric patent on dielectric fluids containing PCBs and other chlorinated materials? ' A. Correct. MR. GRONDAHL: Object to the form. Q. Do you know whether General Electric patented dielectric fluids before Monsanto purchased Swann Chemical? A. That's my understanding. Q. Is it your understanding that Monsanto purchased Swann Chemical for purposes of providing PCBs for General Electric's dielectric fluid? A. That is not my understanding. Q. ` Do you have any understanding in that regard to why Swann Chemical was purchased? A. I do not. Gateway Reporting Associates, Inc. WATER PCB-SD0000070880 Gateway Reporting Associates, Inc. 96 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I'm showing you Exhibit 379 for identification, a document entitled "The Proper Handling of Aroclors and Their Mixtures in the Electrical Industry" with a Monsanto Chemical Company address and a P. G. Benignus, P. G. B-E-N-I-G-N-U-S, revised January 1980 date on the cover, and ask you if you've ever seen that document before. I'm only going to ask you about one entry, so I don't think you have to look at the whole thing. , MR. SABETTA: ' I think you said the date was 1980. It's 1960. January 1960. MR. McDONOUGH: I'm sorry. Thank you. I lose decades, much less years. A. This looks familiar. Q. Who is Mr. Benignus? Do youknow? A. Yes. He's a Monsanto employee who at the time of this report was involved with Monsanto's marketing group located at the home office to supply information to the field marketing people about electrical use of Monsanto products. Q. Is Mr. Benignus still alive? Do you know? A. The last I heard, hewas. Q. Do you know if he.still lives in the St. Louis area? A. That's my understanding. Gateway Reporting Associates, Inc. WATER PCB-SD0000070881 Gateway Reporting Associates, Inc. 97 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you know if he still works for the company? A. No. He's been retired. Q. Do you know about how old he would be? A. Well, he retired at 65 in 1974, so. . . Q. Later on when we get time we'll work that out. That marketing group, did it have a particular name other than marketing group? A. This is the marketing groupwithin the functional fluids group. Q. Who was the head of functional fluids in the 1970 time period? A. Howard Bergen. Q. Who was the head of it in 1960? A. 1960. I can see the individual's face, but his name escapes me. I can't recall his last name. His first name is Constantine something. Q. Referring to the page marked page one of Exhibit 379 at the bottom of the page, above the footnote it says, quote, "The electrical industry's use of these fluids has been largely in accordance with the General Electric's Company's patents and developments." Do you see that? . A. Yes. Q. Was it your understanding that that's Gateway Reporting Associates, Inc. WATER PCB-SD0000070882 Gateway Reporting Associates, Inc. 98 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 accurate? MR. GRONDAHL: Object to the form. A. Yes . Q. That's all I have on that document. (Reporter marked Plaintiff's Exhibits 380 and 381.) Q. I'm showing you Exhibit 380 for identification. It purports to be a document entitled "The Journal of Industrial Hygiene and Toxicology" with an article "The Problem of Possible Systemic Effects From Certain Chlorinated Hydrocarbons," dated September 1937, with the first listed author Cecil, C-E-C-I-L, K. Drinker, D-R-I-N-K-E-R. Have you ever seen that article before? A. It looks similar to something I saw in early 1970. Q. I'm showing you Exhibit 381 for identification. It purports to be entitled "Report to the Monsanto Chemical Company," Cecil K. Drinker, M.D., September 15th, 1938, and ask if you've ever seen that document before? A. This document which I have scanned appears to be one I had seen before. . Q. When you said with reference to Exhibit 380, the earlier report, tha't you had seen a document Gateway Reporting Associates, Inc. WATER PCB-SD0000070883 Gateway Reporting Associates, Inc. 99 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 similar, were you referring to 381 as the similar document ? A. No. In my recollection, they are two distinct and separate documents. Q. Do you know whether these documents were contained in these three-ring binders that you reviewed when you took your position in 1970 and did your tutorial with Dr. Kelly and Mr. Wheeler? A. As best as I recall, yes. ' Q. Do you know if they were abstracted by Monsanto in that three-ring binder? A. I don't recall abstraction of these Drinker articles, no. Q. Did you read those articles or look through them in 1970? A. Yes. Q. Where did they come from? Do you know? A. I just automatically assumed they came out of the medical library. Q. Do you know whether the medical library had those articles in it at about the time they were published or written? A. I'm sure of that,.yes. Q. Do you know generally that Dr.Drinker voiced some concerns with vapors of Aroclors or Gateway Reporting Associates, Inc. WATER PCB-SD0000070884 Gateway Reporting Associates, Inc. 100 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 biphenyls? A. Yes. Q. What concerns did he reference? A. I forget exactly, but it's a typical . concern of almost all chemicals when the vapors exceed high levels, which is different for each chemical, and the time of exposure to that high level, you will see some effects on the human being. Q. And did Dr. Drinker find back in 1937 that there were effects on animals with respect to exposures to biphenyl vapors? MR. SABETTA: Objection to the form. ' A. Biphenyl -- I don't remember the unchlorinated material. Q. Well, maybe I misspoke. Did he find effects on animals as a result of exposure to vapors of polychlorinated biphenyls? A. Yes. Q. Do you know whether or not Monsanto did anything in terms of its process of production or marketing with respect to chlorinated biphenyls as a result of Drinker's studies? A. That certainly appeared in their product bulletins and pamphlets, and it appeared on the product label with the reference to -avoid inhalation. Gateway Reporting Associates, Inc. WATER PCB-SD0000070885 Gateway Reporting Associates, Inc. 101 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. When did it appear on product pamphlets or bulletins? A. I don't have an exact date. I would suggest it appeared before World War II. Q. When did it -- I'm sorry. A. Early '40's, somewhere in there. Q. When did it appear on labels or information given to customers? A. I don't remember the -- Well, the bulletins were given to customers. I don't personally recall the dates in which it appeared on product labels. Q. Do you know whether that occurred in the early '70's as opposed to before the war? A. Oh, I would -- No. It was certainly in place in the '50's and so on. My best recollection is that it was there before World War II. Q. And do you recall generally what the instruction or direction or warning was? MR. SABETTA: Objection to form. Q. Withdrawn. Do you recall generally what the instruction was? A. Generally, it was avoid prolonged inhalation or some such words.. Q. Do you know what prolonged inhalation meant? Y Gateway Reporting Associates, Inc. WATER PCB-SD0000070886 Gateway Reporting Associates, Inc. 102 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't have any time to quote in terms of describing a period. It was understood by all of those involved that it had to do with the appearance of symptoms. Q. Does that mean you were to avoid exposure to inhalation after you had symptoms? MR. SABETTA: Objection to the form. MR. GRONDAHL: Object to the form. A. No . The intent was to avoid exposure vapors, and if you expected to be in that environment a while put on your respirator, and if you notice that your throat was sore and you were coughing, go get that respirator or stay out of the area. Q. Do you know whether Monsanto provided respirators for its own employees that manufactured Aroclors? A. Yes. Yes. Q. When did they start doing that? A. In the 130 ' s. Q. Did they stop doing that after the war? A. No. Q. Did they provide special equipment to their own employees prior to the war? MR. SABETTA: Objection to the form. Q. Withdrawn. Did5' they provide clothing to Gateway Reporting Associates, Inc. WATER PCB-SD0000070887 Gateway Reporting Associates, Inc. 103 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 their employees before the war, employees who dealt with PCBs ? A. I don't know when the issue of clothing began. Q. Did you say anything -- Withdraw it. Do you know whether Monsanto said anything in its labels or bulletins about wearing respiratory protection? A. I recall reading some of the product literature that included words to that effect'. Q. Do you know what the time period of that product literature was? A. It ranged from the '30's all the way to the '70's. Q. And my question was do you know when it was that this product literature referenced respiratory protection? A. No, I don't remember that. Q. Do you know whether it was in the '70's as opposed to the '30's? A. It was long before the '70's. That was standard information by the '70's. Q. Do you know what this literature is called other than labels and bulletins? A. Well, other words were used, such as product literature, product pamphlets. Gateway Reporting Associates, Inc. WATER PCB-SD0000070888 Gateway Reporting Associates, Inc. 104 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Was there anybody in the Monsanto structure that was in charge of this labeling or supplying of bulletins to customers? MR. SABETTA: Objection to the form. I think you have to give him a time. You're talking about a 40-year period here. Q. Let's take the time period 1960 to 1970. A. The marketing representative located in St. Louis assigned to a specific use would periodically have the available literature reviewed, and he would have the appropriate individuals in Monsanto comment, revise as necessary the different portions. For example, the medical people would be involved, the research people, the engineering people, and so on. And once he got all the comments in, he would arrange with the group in Monsanto that was responsible for assisting in the publication to put together the pamphlet with the necessary photographic information, pictures and logos and the like, and have it printed, so many copies. So it kind of changed hands as it progressed through the system. Q. I was asking who that individual might be in 1960 through 1970. Do you know? A. For dielectric fluids? Q. For the labels land the bulletins that would Gateway Reporting Associates, Inc. WATER PCB-SD0000070889 Gateway Reporting Associates, Inc. 105 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have been discussing about the dielectric fluids for PCBs . A. Mr. Benignus was the initiator of any activity of this type. Q. Do you know how long Mr. Benignus was that individual? A. Oh, he was -- Again, the exact dates are difficult to recall, but it's from the 1501s through 1974. Q. ' Did Mr. Benignus retire in 1974? A. Yes. (Reporter marked Plaintiff's Exhibits 382 through 386.) Q. I put a book in front of you, Mr. Papageorge, and I'd ask you to open it to the tab two, if you would. Have you got tab two in front of you? A. 382, yes, sir. Q. Thank you. That purports to be a letter of February 6th, 1950 from Louis Spolyar, S-P-O-L-Y-A-R, M.D., Director, Division of Industrial Hygiene, Indiana State Board of Health, to Toxicology Department, Monsanto. Have you seen that before? A. I don't recall it. Q. Now, in the firfet paragraph, Dr. Spolyar Gateway Reporting Associates, Inc. WATER PCB-SD0000070890 Gateway Reporting Associates, Inc. 106 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 says, "One of our Indiana industries is using your Aroclor 1248 (tetrachlorodiphenyl) as a heat transfer media (up to 400 degrees F)," meaning Fahrenheit, in the extrusion of Tenite, T-E-N-I-T-E, 2 plastic. Considerable vapor of Aroclor is present in the workroom due to leaks in the 'closed' system. Several workers have reportedly become ill due to the inhalation of these vapors ." Were you familiar with that situation? A. Am I familiar with that situation? Q. Yes . A. No. This is the first I've seen of this. Q. Was that covered in your tutorial by Dr. Kelly or Mr. Wheeler? ' A. Q. I don't recall it being so, no. Do you know if Monsanto had a Toxicology Department ? MR.. SABETTA: At what time? Q. Let's start February 6th, 1950. A. Not a department as such, but the function was carried out by the Medical Department. . Q. So would it be your understanding that if a letter was directed to the Toxicology Department, would it have been delivered to the Medical Department? A. Yes. Q. Do you know if -there was ever a response to Gateway Reporting Associates, Inc WATER PCB-SD0000070891 Gateway Reporting Associates, Inc. 107 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this particular document? A. I do not. Q. On the second paragraph, Dr. Spolyar says, "This plant called us as to any knowledge relative to the toxicity of this product. We did not have any data that could be transmitted to them. The so-called illness was vague in that we could not learn from the plant what the exact complaints were." Do you know whether any data or information had been transmitted by Monsanto to anyone to that date, 1950, as to toxicity of Aroclor or PCB oil? A. Oh, yes. Q. And who had it beentransmitted to? A. Oh, gosh! I don'tknow. Many, many people. Customers and state authorities and so on would get those. Q. Apparently Dr. Spolyar hadn't gotten any as the Director of the Division of Industrial Hygiene at the Indiana State Board of Health? A. - Q. Apparently not. How do you know that Monsanto sent information to state agencies or federal government up through 1950? , A. That was the practice of the Medical Department to do so, and I don't see why they would fail Gateway Reporting Associates, Inc. WATER PCB-SD0000070892 Gateway Reporting Associates, Inc. 108 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to do so. Q. Who told you it was the practice of the Medical Department? A. Mr. Wheeler, Dr. Kelly. Q. And what was this practice that they told you about up through 1950? A. Whenever they had new data or they had a new customer or a new inquiry, they would share what they knew about the product that they might be interested in. Q. Would the sharing of that information go to the ultimate recipient of the product? MR. SABETTA: Objection to form. A. It went to arepresentative asperceived by Monsanto of that entity that received the product. Q. Well, if we look at Aroclor 1254, that was sold for use in transformers, among other things; is that correct? 1254 was sold for use in transformers among other things? A. Yes. Q. Now, as I understand youranswer, youwould provide information to the purchaser of the 1254; is that correct? . A. Yes. Q. And what would 'the purchaser of the 1254 do Gateway Reporting Associates, Inc. WATER PCB-SD0000070893 Gateway Reporting Associates, Inc. 109 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 with the chemical with respect to its transformers? MR. SABETTA: Objection to form. Do you understand the question? A. Not quite. What would the purchaser do? Q. I was trying to make it easier. Did you understand that General Electric and Westinghouse sold transformers to others? A. Yes. Q. And did you understand that these transformers contained Aroclors in them? A. Yes. Q. Did Monsanto do anything to notify whoever the transformers were sold to of problems associated with vapors? A. Monsanto would never know who that customer was . Q. Would the answer be no? A. That's correct. Q. Did Monsanto ever ask who those customers were ? MR. SABETTA: Objection to form. A. I don't know that. Q. Turn to the next tab. We've marked it as Exhibit 383. Have you got that in front of you? A. I do. Gateway Reporting Associates, Inc. WATER PCB-SD0000070894 Gateway Reporting Associates, Inc. 110 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. 383 purports to be a letter from Dr. Kelly to Dr. Newman in Newport, England, February 12th, 1954. Have you ever seen that letter, before? A. I remember this letter, yes. Q. When did you see that? A. During my tutorial in 1970. Q. Now, the first paragraph of that letter - Let me withdraw that. Was that in this three-ring notebook or two three-ring notebooks that you looked at? A. Yes. Q. The first sentence says, "We do not know what the maximum allowable concentration of Aroclor is. One milligram per cubic meter has been set up. We have run animals for about 60 days at seven times this and found some liver damage. We are now running this at a lower level." Do you see that? A. I do. Q. Do you knowwho set up this onemilligram per cubic meter as referred to in the document? A. I don't know the individual. Q. Well, do you know whether it was Monsanto or another agency or company? A. Monsanto. . Q. Now, thisrefers apparently tosome animal testing done by Monsanto; is1' that correct? Gateway Reporting Associates, Inc. WATER PCB-SD0000070895 Gateway Reporting Associates, Inc. Ill 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It is done for Monsanto. Q. Had Monsanto done or had done animal testing up to that point? A. Yes. Q. How do you know that? A. I recall seeing reports reporting the results of some studies done back in the '30's and '40's as best I remember. Q. Do you know who did those studies in terms of an outside agency? A. I don't remember the laboratory that did the work. Q. How many studies are you familiar with in the '30's and 140 1 s? A. It seems they had performed for them studies referred to as acute toxicity studies on test animals for Aroclor 1242, 1248, 1254 and 1260. That's all my memory will help me with. Q. Does that mean one study or four studies with respect to each chemical? A. Four different studies. Q. Your memory hasn't come back yet on the agency or laboratory that might have done the testing? A. I should know. It evades me. I can't remember it. ^ Gateway Reporting Associates, Inc. WATER PCB-SD0000070896 Gateway Reporting Associates, Inc. 112 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Now, Dr. Kelly references "some liver damage". Do you know what liver damage was reported in these studies? A. As best I remember, it was described to me as liver enlargement. Q. Do you know whether there were any pathological tests performed on liver sections? A. I do not . Q. Who described it to you as liver enlargement ? A. Elmer Wheeler. Q. Now, do you know what lower level they were going to now run the studies at? A. I believe it was a half a milligram per cubic meter. Q. Do you have a recollection of a half a milligram per cubic meter? A. Yes. Q. Okay. And do you recall what the results of that study was? A. They found no damage of any kind. Q. And who is "they"? A. This laboratory, I'm trying to recall. Q. Was it the same laboratory? A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070897 Gateway Reporting Associates, Inc. 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And the best date you can fix for this is the ' 3 0 1 s or '4 0 ' s ? MR. SABETTA: I think we're talking - A. This is the 1 50 1 s. MR. SABETTA: -- testing in the '50's. Q. The best date you can fix is the '50's? A. Yes. Q. Who's Dr. Newman? Do you know? Or who was Dr. Newman? ' A. Dr. Newman was the physician, head of the Medical Department of Monsanto's European office located in England. Q. Did that Monsanto installation also produce PCBs ? A. Q. Yes. Did it produce Pyranol? A. No. Q. If you look at the last paragraph, in the last sentence, it says, "As soon as I get a report on the work at Kettering," K-E-T-T-E-R-I-N-G, "I will let you know." Do you see that? A. Yes. Q. Do you know what the reference to Kettering is? A. Yes. That is attesting laboratory. Gateway Reporting Associates, Inc. WATER PCB-SD0000070898 Gateway Reporting Associates, Inc. 114 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Is that the testing laboratory that you believe these tests were done on 1242, 1248, 1254 and 1260? A. That's what this last sentence tells me, yes . Q. Your answer is based on how you read this; is that correct? A. Yes. Q. Where is Kettering? ' A. Ohio. Cincinnati,Ohio. Q. Do you know the name of any particular tester that was involved in these chemicals? A. No, Idon't. Q. Do you know whether Kettering was also doing testing with reference to the 1949 Nitro, West Virginia explosion? A. No, I don't know much about that explosion. Q. Do you know whether there was a different individual in Monsanto in the 1960's and 1970's that dealt with dioxins as opposed to PCBs? . MR. SABETTA: Objection to the form. Q. I'll withdraw it. Do you know if there was an individual in Monsanto in the 1960's and 1970's that dealt with dioxin? MR. SABETTA: Rame objection. Gateway Reporting Associates, Inc. WATER PCB-SD0000070899 Gateway Reporting Associates, Inc. 115 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Well, when you say "dealt with," I have some difficulties distinguishing between obtaining a medical knowledge or developing analytical procedures. There were two sets -- two groups of people that addressed each of those. Q. Would it be a fair statement that your job involved dealing with PCBs? A. Yes. Q. Was there anybody in Monsantoin' the '60's or 1701s that you know of that dealt with dioxins in the same fashion that you dealt with PCBs? A. No. ' Q. Was there anybody in the '60's or '70's that dealt with dibenzofurans in the same fashion as you dealt with PCBs? A. No . Q. You mentioned medical problems and analytical problems. Is that what you said? A. Those are two that come to mind, yes. Q. And do I understand that it was somebody that dealt with medical problems associated with dioxins at Monsanto in the '60's and '70's? A. Yes . Q. Who would that be? A. Elmer Wheeler, Jack Garrett, Fred Johansen Gateway Reporting Associates, Inc. WATER PCB-SD0000070900 Gateway Reporting Associates, Inc.. 116 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 George Levinskas. In other words, the medical team all played a part in this. Q. Do you know whether Jack Garrett is still alive? A. Q. . I understand he is. Do you know whether he's located in the St. Louis area? A. That's my understanding. Q. Do you know whether Frank Johansen is still alive? A. Q. A. Q. Yes. Do you know where he's located? No, I don't. Do you know whether George Leviticus (sic.) is still - A. Lavinskas, L-A-V-I-N-S-K-A-S. Q. Do you know whether George Lavinskas is still alive? A. Yes. Q. Is he in the St.Louis area? A. Yes. Q. Do any of them still work for Monsanto? A. I don'tknow about Mr. Johansen. Mr. Garrett and Mr. Levinskas are retired from Monsanto. Q. Do you know wha-t training each of these Gateway Reporting Associates, Inc. WATER PCB-SD0000070901 Gateway Reporting Associates, Inc. 117 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 individuals had, Mr. Levitikas or Lavinkus? A. Levinskas ? Q. Yes . A. He has a doctorate in toxicology. Q. Do you know whether he was working for Monsanto in the '60's? A. No, he was not. Q. Do you know about when he started working for Monsanto? A. ' Q. About 1971, '72. Did he replace another toxicologist? A. That's rather hard to define because the individual who was following PCB studies died at the same time that the department was expanded, hiring people. So when Mr. Levinskas showed up, you couldn't tell whether he was replacing someone or just part of the growth of the department. Q. You said the individual following PCB studies died Who are you referring to? A. I cannot remember his name. I just can't remember it. Q. It was my understanding that you gave me these gentlemen's names of people who were working in dioxins. Was I incorrect in my understanding? MR. SABETTA: Objection to the form. Gateway Reporting Associates, Inc WATER PCB-SD0000070902 Gateway Reporting Associates, Inc. 118 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I at this moment am wrestling with the concept what does working in dioxin really mean. Is it keeping tuned in? Is it talking to the toxicology community, and so on? Q. Did the same people that worked in following PCBs work in following dioxins? A. Pretty much so. Q. And what was Mr. Johansen's training in? A. A doctorate of toxicology. ' Q. Mr. Garrett, do you know what his training was in? A. Mr. Garrett had, as best I recall, a . Master's degree in chemistry, working in the field of industrial hygiene. Q. Do you know whether these same gentlemen were involved in following dibenzofurans? A. Yeah. They were keeping tuned in. Q. Was there anyone else in the company in the '60's and '70's that was following dioxins or following dibenzofurans than these gentlemen you've given me the names of? A. MR. SABETTA: Objection to form. Well, there were several of us following those two chemical groups, but each from a different perspective. I was following personally from an overall Gateway Reporting Associates, Inc. WATER PCB-SD0000070903 Gateway Reporting Associates, Inc. 119 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 viewpoint in terms of where were they, what do they do, how do you know you have them? That kind of attitude or that approach. There were others who were interested enough to kind of keep tuned in and talk to the customers, see if any of our customers were doing any studies. Q. Who were these people keeping tuned in by talking to customers? A. They were primarily marketing people who made calls at the customers' locations. Q. Do you know any names? A. Oh, I just can't remember all of them. Q. Was GE one of these customers that they were making calls on? A. Oh, certainly, yeah. Q. What was the answer from GE? MR. SABETTA: Objection to form. MR. GRONDAHL: Objection. Q. I think you told me thatthese marketing representatives were calling on customers to see whether the customers were doing anything - A. Yes. Q. -- with respect todioxins or dibenzofurans. Is that what you told me? A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070904 Gateway Reporting Associates, Inc. 120 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did you get a response from General Electric? MR. GRONDAHL: Object to the form. MR. SABETTA: Objection to form. A. I did not hear, not only from General Electric, anybody regarding studies being made and the results of those studies. Q. Did Monsanto do any studies with respect to dioxins and dibenzofurans? ' MR. SABETTA: Objection to form. A. Well, they did a lot of work on the analytical procedure. Q. Other than doing a lot of analytical work -- Other than doing a lot of work on the analytical procedure, did Monsanto do any studies on dioxins? A. No . Q. Other than doing a lot of analytical work, did Monsanto do any studies on dibenzofurans? A. No . Q. What do you mean by analytical work? . A. It involves the development of a procedure of taking a sample of material and running through a series of steps through instruments that will report or display a certain reaction, a graph or a bar or a color or what-have-you, which the 'tehemist will then interpret Gateway Reporting Associates, Inc. WATER PCB-SD0000070905 Gateway Reporting Associates, Inc. 121 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in terms of what is the material and how much is present. Q. Where was this work done? A. For Monsanto, most of it was done in the St. Louis main offices of the Analytical Research Laboratory. Q. Do you knowwhether that research laboratory has its own library? A. It does not. ' Q. Do you know whatlibrary they would rely on if they needed to find some information? A. Yes. Q. What library? A. The Monsanto Research Department's library. Q. Do I understand it that Monsanto was attempting to find out whether there were dioxins present in its products? A. Yes. There was an effort to answer that question, yes. Q. And do you know when that started? A. I would suggest about '71. Late '71, early ' 72 . Q. Do you know whether it started in the '60's? MR. SABETTA: Objection to form. Gateway Reporting Associates, Inc. WATER PCB-SD0000070906 Gateway Reporting Associates, Inc. 122 1 2 3 4 5 6 7 8 9 10 H 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A . It did not. Q. How did you find out it started in late '71 or early '72? <t A. I was in close contact with the head of that group, and I would contact him to see what progress, if any, had been made and where they stood and when they expected results, that kind of conversation would take place. Q. Who was the head of the group? ' A. Dr. Robert Keller. Q. Do you know what product Dr. Keller's group was testing? A. They were checking chlorinated hydrocarbons of all kinds. Q. Including polychlorinated diphenyls and biphenyls? A. Yes. Q. Were the results of that effort ever published? A. You mean for peer reviewed articles and so on? Q. No. I mean in the literature, newspapers, magazines, journals, peer review, not peer reviewed. A. None of that. Q. Do you know wha't the results were? Gateway Reporting Associates, Inc. WATER PCB-SD0000070907 Gateway Reporting Associates, Inc. 123 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. SABETTA: Objection to form. A. In general, the results were that we didn't find it. We can't find it. It's not there. Q. At some time -- Withdraw that. You can't find it in what? A. In the whole list of products that they were looking at. Q. Did you ever test Pyranol to see if you could find it? ' A. Not as a mixture, no. Q. Isn't it true that if you had tested the tri/tetrachlorobenzene you would have found dioxin? MR. SABETTA: Objection to form. MR. GRONDAHL: Object to the form. A. Oh, I don't know that that's true, no way. There's nothing that I am aware of that would lead me to that conclusion. Q. Do you know we're here about this fire on February 5th, 1981 in the Binghamton State Office Building? A. Q. Yes, sir. Do you know that dioxins were found after the fire? A. Q. . After the fire, yes. Where do you think they came from? Gateway Reporting Associates, Inc. WATER PCB-SD0000070908 Gateway Reporting Associates, Inc. 124 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. SABETTA: Objection to the form. MR. GRONDAHL: Object to the form. A. I don't have enough information to make a wise conclusion. Q. Do you know that dibenzofurans were found after the fire? A. That's what I heard. Q. Where did they come from? A. I don't know that one either. ' Q. Did Monsanto test for dibenzofurans in its products? MR. SABETTA: Objection to form. A. Which products? Q. You don't know whether it tested or not for dibenzofurans in its products? A. Which products? MR. SABETTA: Just a second. Let me get in my objection. Okay. There's no race to complete this exercise. Objection to form. Q. I have to tell you which product before you can answer that question. MR. SABETTA: Objection to form. Q. Is that true, Mr.Papageorge? A. Well, from whatlittle I know of the scenario at Binghamton, thebe were many other things Gateway Reporting Associates, Inc. WATER PCB-SD0000070909 Gateway Reporting Associates, Inc. 125 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other than transformer fluid. Q. We're talking about Monsanto testing its products for dibenzofurans, that's what we're talking about, and I want to know whether Monsanto ever tested its products for dibenzofurans. MR. SABETTA: Do you know whether Monsanto tested any of its products at any time for the presence of dibenzofurans? That's what I understand the scope of Mr. McDonough's question to be. ' A. Any product, yes. Q. And did it test PCBs? A. Yes. Q. And when did it first test PCBs for dibenzofurans? A. 1970 ' s . Q. Is that part of the same test group that was testing for dioxin, or is it a different group? A. Same analytical group. Q. And did it test Aroclor 1254? A. Yes. . Q. And did it get any results? A. By that, you mean did it get positive results? Q. No. What were the test results? MR. SABETTA: Objection to form. As I Gateway Reporting Associates, Inc. WATER PCB-SD0000070910 Gateway Reporting Associates, Inc. 126 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 understand, the tests went on over a period of time. I don't think you can ask him about test results without specifying some time period, because there's no reason to believe that the test results were the same throughout the period. MR. McDONOUGH: Counsel, the witness said they did testing in the 1970's. MR. SABETTA: Right. MR. McDONOUGH: I can't help that. I asked him what the test results -- Are you saying he can't answer that? MR. SABETTA: I think you have to zero in on a specific time or series of tests because I know from my own studies that the test results varied. MR. McDONOUGH: I think the witness can tell me that if he's having trouble with the question. MR. SABETTA: Well, I object to the form of the question. Can you read me the question? Q. I'll ask another question. Let's not waste anymore time. Did you testify that Monsanto tested Aroclor 1254 to determine whether it contained dibenzofurans in the 1970's? A. Yes. Q. When in the 1970's did Monsanto do that? A. It started, gosh, very early in the year. Gateway Reporting Associates, Inc. WATER PCB-SD0000070911 Gateway Reporting Associates, Inc. 127 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And do you recall whether Monsanto ever got test results that their Aroclor 1254 contained dibenzofurans ? A. Eventually, yes. Q. And when was that? A. 1976. Q. Did any of those tests in the 1970's include applying heat to Aroclor 1254? A. Not knowing the analytical procedure, I don't know if heat is part of the process, so I can't answer that. . Q. Do you know anything as to the analytical procedure that was employed by Monsanto to test for dibenzofurans? A. Did I know what? Did I know anything else? Q. Anything about it. A. Not in the technical sense, no. Q. Did you tell me you didn't know whether they tested the Aroclor 1254 by applying heat or not? A. Why not? Q. Why not? A. I don't understand. Q. Do you know whether Monsanto tested Aroclor 1254 by applying heat? MR. SABETTA: f' think he's already answered Gateway Reporting Associates, Inc. WATER PCB-SD0000070912 Gateway Reporting Associates, Inc. 128 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that. I object to the form of the question. Q. Can you answer it? A. I do not know. Q. Did Monsanto have any other laboratory facilities in the 1960's or '70's other than this laboratory run by Dr. Keller that you've told me about doing analytical work on Monsanto's products? A. Yes. Q. Where were those laboratories? Well, let me withdraw that question. Did they have any other laboratories testing to determine whether Monsanto's products produced dioxins or dibenzofurans other than Dr. Keller's laboratory? A. Not to my knowledge. Q. If you'll look at tab four for me, it's marked as Exhibit 384. That purports to be some pages out of a document entitled "Process for the Production of Aroclors, Pyranols, Etc., at the Anniston and at the Wm. J. Krummrich Plant, April 1955, E. Mather." Have you got that in front of you? A. Yes. Q. Have you seen that document before or the entire document from which that is taken? A. I believe I recognize this article, although it doesn't appear to be a complete document. Gateway Reporting Associates, Inc. WATER PCB-SD0000070913 Gateway Reporting Associates, Inc. 129 1 Q. Did you know an E. Mather? 2 A. Yes. Uh-huh. 3 Q. Was he a predecessor of yours at the 4 Anniston plant? 5 A. I don't associate him with the Anniston 6 plant, but -- 7 Q. Do you know what his job title and function 8 was about that time? 9 A. He was a research individual. ' 10 Q. If you look at the page -- first page in 11 from the cover, it's marked Roman numeral XI-1, Hazards, 12 referencing the second paragraph, it says, "There was 13 some trouble of this kind among the production workers 14 at Anniston in the early days of the development of the 15 Aroclors." 16 A. I see that. 17 Q. Do you know what that's with reference to? 18 A. They are referring to a situation in which 19 a highly chlorinated biphenyl was produced and some of 20 the workers got some sort of skin problem. It was 21 described to me as chloracne. 22 Q. Who described it to you that way? 23 A. Elmer Wheeler. And it was attributed to 24 the use of impure benzene in the manufacture of the 25 PCBs . " Gateway Reporting Associates, Inc. WATER PCB-SD0000070914 Gateway Reporting Associates, Inc. 130 1 Q. Do you know of any study or attempt to 2 study whether the benzene used at Anniston at that time 3 was impure? 4 A. I'm not aware of any such studies. 5 Q. Do you know whether this outbreak of 6 chloracne was associated with vapors from the Aroclors? 7 A. It's my understanding that it resulted from 8 the dust of this particular PCB. This is a solid PCB 9 ground into a flour-like dust that settled all over the 10 equipment and on the workers and so on. 11 Q. The first paragraph says, "There are many 12 literature references to harmful effects of the type of 13 'chloracne' resulting from exposure to chlorinated 14 diphenyls, especially in cases where people working with 15 small electrical components have been exposed to the 16 fumes of hot, highly chlorinated Aroclors. Chloracne is 17 sometimes accompanied by gastric troubles, and there are 18 literature references to liver troubles." Do you see 19 that ? 20 A. Yes. 21 Q. Isn't that the trouble that wasexperie 22 at Anniston in the early days? 23 A. Yes. 24 Q. And wasn't that trouble with reference to 25 being exposed to vapors? '' Gateway Reporting Associates, Inc. WATER PCB-SD0000070915 Gateway Reporting Associates, Inc. 131 1 MR. SABETTA: Objection to form. 2 A. Well, certainly there are two types of 3 exposures here. The paragraph you just read does refer 4 to fumes, but the second paragraph follows an incident 5 where it's my understanding they were -- You'll see the 6 word "highly chlorinated Aroclors". That refers to the 7 Aroclor 1270 that was made at that time. 8 Q. How do you know it refers to 1270? 9 A. That's what I was informed was the product. 10 Q. Isn't 1254 considered highly chlorinated? 11 MR. SABETTA: Objection to form. 12 ' MR. GRONDAHL: Objection to form. 13 A. It all depends what you're comparing it to. 14 Q. Well, as you subsequently worked in PCBs in 15 the 1970's and thereafter, didn't everyone consider 1254 16 highly chlorinated - 17 MR. SABETTA: Objection to form. 18 MR. GRONDAHL: Object to form. 19 Q. --as compared to the other Aroclors? 20 A. That's what I meant when I said it depends 21 on what you compare it to. In the '70's, 1260 and 1254, 22 when compared to 1242, 1232, and so on, they were 23 perceived to be the highly chlorinated. But back in 24 this period of time that we're reviewing here, when they 25 made 1272 and 1270, those we're understood to be highly Gateway Reporting Associates, Inc. WATER PCB-SD0000070916 Gateway Reporting Associates, Inc. 132 1 chlorinated as compared to a 54 or even a 60. 2 Q. If you look at page Roman numeral XI-3, 3 it's an article "On the Toxicity of the Aroclors". Now, 4 that article refers to another recently-published 5 article that has recommended the substitution of one of 6 the Aroclors as the melting-point bath liquid in 7 preference to the customary sulphuric acid. As stated 8 in that article, Aroclors are a group of chlorinated 9 diphenyls produced by the Monsanto Chemical Company. 10 Then it says, "There is need, therefore, to give 11 warning." . 12 A. Okay. 13 Q. Do you know what that references? 14 MR. SABETTA: Object to form. 15 A. Not yet. I have to read more of the 16 article . 17 MR. SABETTA: Is there a question pending? 18 MR. MCDONOUGH: Yes. 19 MR. SABETTA: Please read it. 20 (Whereupon, the reporter read "Do you know 21 what that references?") 22 MR. SABETTA: Do you understand the 23 question? Objection to the form. Do you understand the 24 question? 25 Q. I withdraw it. If you'll look at the last Gateway Reporting Associates, Inc. WATER PCB-SD0000070917 Gateway Reporting Associates, Inc. 133 1 page of the exhibit, which is page Roman numeral XIV-1, 2 "History of the Process in Monsanto," I'd ask you to 3 read it to yourself, and then I just want to know 4 whether you believe it's an accurate history. 5 A. I have read it. 6 Q. Is it accurate? 7 A. I'm sorry? 8 Q. Is it accurate? 9 A. As far as I know, yes. ' 10 Q. Referring back to page XI-4, a little bit 11 down the page, it's entitled "Health and Safety". It's 12 Bates number 3784. It states under "Health and Safety," 13 "At Anniston, no special protective clothing is provided 14 for the diphenyl and Aroclors operators. A daily change 15 of clothing was provided in the past but this practice 16 ceased before the war. Gauntlet leather gloves and face 17 shields are, of course, available as required by the 18 plant." Do you see that? 19 A. Yes. 20 Q. Did you testify when you were at Anniston 21 they had special protective clothing? 22 A. Yes. 23 Q. Do you know when they started getting them 24 after the war? 25 A. It was after the war. When I arrived in Gateway Reporting Associates, Inc. WATER PCB-SD0000070918 Gateway Reporting Associates, Inc. 134 1 '65, it was a well-established practice. 2 Q. Do you know who established the practice? 3 A. I do not. 4 Q. Do you know why it was established? 5 A. I have an understanding. 6 Q. What's your understanding? 7 A. It was a matter that was raised during 8 union contract negotiations. 9 Q. This article apparently refers to the 10 employees at Anniston having to shower on their own time 11 whereas at Krummrich they tried to shower on company 12 time . 13 A. That was part of the discussion. 14 Q. So it your understanding that the special 15 clothing was a product of negotiations with the union? 16 MR. SABETTA: Objection to form. 17 A. Yes. 18 Q. What about showers on company time? Was 19 that a practice when you were at Anniston? 20 A. Yes. 21 Q. Do you know how that practice came about? 22 A. That was part of the union negotiations 23 between World War II and 1965. 24 Q. Do you know whether at Anniston the 25 Aroclors building was ever designated as a toxic Gateway Reporting Associates, Inc. WATER PCB-SD0000070919 Gateway Reporting Associates, Inc. 135 1 department ? 2 A. Not to my knowledge. _ 3 Q. If you go down about two-thirds of the way 4 down this page, it says, "At St. Louis, Plant B, the 5 Aroclors building is rated a toxic department." And it 6 goes on to talk about operators being provided with a 7 complete set of clothing and that sort of thing. Do you 8 see that? 9 A. Yes. ' 10 Q. What does a designation as a toxic 11 department mean? 12 A. It means that the employees of that 13 department so designated get this shower time, clothing 14 change, shoe change, all of these benefits, because not 15 all operations were designated as such. 16 Q. Do you know if Anniston was designated as a 17 toxic department at some time? 18 MR. SABETTA: Objection to form. 19 A. The term "toxic department" at Anniston was 20 not used for operations like PCB. 21 MR. McDONOUGH: Could I have that answer 22 back, please? 23 (Whereupon, the reporter read back as 24 requested.) 25 Q. If you look at 'the last paragraph on that Gateway Reporting Associates, Inc. WATER PCB-SD0000070920 Gateway Reporting Associates, Inc. 136 1 page, it says, "Employees in toxic departments are given 2 an annual medical examination and a lung x-ray every 3 three years." Do you see that? 4 A. I do. 5 Q. Do you know whether the Anniston employees 6 got an annual medical exam and a lung x-ray every three 7 years ? 8 A. They did when I was there. 9 Q. Was there any classification of Anniston 10 that caused that medical examination and lung x-ray to 11 be given? . 12 A. Not to my knowledge. 13 Q. Well, here it says if you're a toxic 14 department you get the medical examination and the lung 15 x-ray. Doesn't that seem to say that? 16 MR. SABETTA: Objection to form. 17 A. Well, yes. But you have to keep in mind 18 that this is dated 1947 describing -- 19 Q. '55? 20 A. -- conditions observed before '47. 21 Q. '55, I believe is why I quibble. 22 A. Well, I'm looking at page XI-3. 23 Q. Uh-huh. Is that contained in a document 24 called 384 with a title "Process for the Production of 25 Aroclors, Pyranols, etc." with a date of 1955? Gateway Reporting Associates, Inc. WATER PCB-SD0000070921 Gateway Reporting Associates, Inc. 137 1 A. I don't see that. 2 MR. SABETTA: He's referring to the first 3 page, the cover page, I believe, of this entire 4 document, which is an incomplete version I guess of a 5 document that we produced in the litigation. The first 6 page is numbered 3397, and the second page jumps to 7 3781, so it's obviously an extract of some sort. Do you 8 see the date on the first page? 9 A. I see that, but I also see the other dates 10 to which the material showing up underneath is -- I 11 associate those other dates with the material below it. 12 Q. Why did the employees at Anniston get 13 medical examinations and lung x-rays while you were 14 there ? 15 A. Why was it? 16 Q. Yeah. Was it company policy? Was it union 17 contract? 18 A. There was a change in company policy. 19 Dr. Kelly recommended that this be adopted as a matter 20 of practice at all the plants, and Anniston agreed to it 21 and did it. 22 Q. When did that happen? 23 A. As I said earlier, the offer of wash time, 24 shower time, replacement clothing and all was in 25 practice or in place when I arrived, and I'm under the Gateway Reporting Associates, Inc. WATER PCB-SD0000070922 Gateway Reporting Associates, Inc. 138 1 understanding that the introduction of the annual 2 physical with the x-rays was instituted at about the 3 same time, but I personally don't know the exact timing, 4 the dates. 5 Q. Aside from exact timing and dates, do you 6 have any idea when that happened? Even decade I'll 7 take . 8 MR. SABETTA: For the Anniston plant only? 9 Q. Yes. ' 10 A. 1950 ' s. 11 Q. Do you know what the basis of Dr. Kelly's 12 recommendation for the change in policy was? 13 A. I do not. 14 Q. If you look at the next tab, has that 15 document been marked 385 for identification? 16 MR. SABETTA: Yes. 17 Q. That purports to be a letter from Dr. Kelly 18 to Dr. J. W. Barrett, two R's, two T's, September 20th, 19 1955, re your memo September 8 to Mr. Nason, N-A-S-O-N, 20 Aroclor toxicity. Do you see that? 21 A. I do. 22 Q. Have you ever seen that before? 23 A. It doeslookfamiliar. 24 Q. Was that in your two three-ring binders? 25 A. I would say yes'. Gateway Reporting Associates, Inc. WATER PCB-SD0000070923 Gateway Reporting Associates, Inc. 139 1 Q. Was that document ever sent to your 2 customers ? 3 A. I'm sorry? 4 Q. Was that document ever sent to your 5 customers, meaning Monsanto's? 6 A. No.To Monsanto'scustomers? 7 Q. Yes. 8 A. No . 9 Q. The secondparagraph says, "You comment 10 upon the difference in toxicity between Aroclor 1254 and 11 1242. This is not particularly surprising because in 12 the earlier work it was found that toxicity increased 13 with chlorination." Do you see that? 14 A. Yes. 15 Q. Do you know what earlier work Dr. Kelly is 16 referring to? . 17 A. He's talking about these acute toxicity 18 studies we talked about earlier where the four types of 19 Aroclors were tested with test animals. 20 Q. From theKettering Laboratory? 21 A. That was one of thelaboratories involved, 22 yes . 23 Q. Was there more than one? 24 A. Through the years, there were -- 25 Q. I'm just asking' about this particular memo Gateway Reporting Associates, Inc. WATER PCB-SD0000070924 Gateway Reporting Associates, Inc. 140 1 here, as to what he's referring to. 2 A. So '55 would be the Kettering report, yes. 3 Q. Now, Dr. Kelly goes on to discuss various 4 levels of vapors, and then in the next-to-last paragraph 5 says, "I don't know how you would get any particular 6 advantage in doing more work. What is it that you want 7 to prove? I believe your work should be directed 8 towards finding out what the concentrations are of 9 Aroclor during different operations whether it is 10 industrial or painting. The reports you have seen from 11 Kettering Laboratory are the result of approximately 12 $15,000 to $20,000 expenditure by MCC." Do you see 13 that ? 14 A. I do. 15 Q. Have you ever seen this memo, September 16 8th? 17 A. I think I remember the memo that 18 Dr. Barrett had sent. 19 Q. Was Dr. Barrett asking about doing more 20 testing? 21 A. He did raise the point of why don't we do 22 more, and Dr. Kelly is responding to that particular 23 thought. . 24 MR. McDONOUGH: I'll have a request for 25 documents at the end of the 'deposition, Mr. Sabetta, I Gateway Reporting Associates, Inc. WATER PCB-SD0000070925 Gateway Reporting Associates, Inc. 141 1 don't want to interrupt every time. 2 Q. Who is Dr. Barrett? 3 A. He was a Monsanto employee, a member of 4 Monsanto's European group. He was located in London. 5 He was a medical doctor, but he was also very active in 6 research, chemical research activities. 7 Q. Did he work with Dr. Newman? 8 A. I believe he reported to Dr. Newman, but 9 I'm not certain. ' 10 Q. The last paragraph says, "MCC's position 11 can be summarized in this fashion. We know Aroclors are 12 toxic but the actual limit has not been precisely 13 defined. It does not make too much difference, it seems 14 to me, because our main worry is what will happen if an 15 individual develops any type of liver disease and gives 16 a history of Aroclor exposure. I'm sure the juries 17 would not pay a great deal of attention to MAC'S." 18 That's capital MAC'S. Do you see that? 19 A. Yes. 20 Q. Do you know what Dr. Kelly is referring to 21 when he says the actual limit referring to toxicity has 22 not been precisely defined? 23 A. I don't know how to respond to that. It's 24 just what the sentence says. 25 Q. Okay. If you turn to the next page, Gateway Reporting Associates, Inc. WATER PCB-SD0000070926 Gateway Reporting Associates, Inc. 142 1 Dr. Kelly discusses the applications of the Aroclor use 2 and then says, "No amount of toxicity testing will 3 obviate this last dilemma and therefore I do not believe 4 any testing would be justified. Let's see what our 5 discussions with Dr. Newman and yourself bring out." Do 6 you see that? 7 A. I do. 8 Q. Do you know if there was any more toxicity 9 testing on Aroclors after this September 1955 date? 10 A. There was. 11 Q. Do you know if it was acute 12 A. Yes . 13 Q. Do you know if chronic testi 14 A. Yes . 15 Q. When was the next acute, test 16 A. I would suggest the middle ' 17 Q. Do you recall who did that t 18 A. As close as my memory will a 19 I'm under the recollection that it was 20 located in the St. Louis area. That's as close as I can 21 get to it at the moment. 22 Q. Would that be IBT? 23 A. ' No ,. They are not.in St. Lou 24 Q. Do you know whether this was 25 acute tests or more than one?? Gateway Reporting Associates, Inc. WATER PCB-SD0000070927 Gateway Reporting Associates, Inc. 143 1 A. Help me with "series". You mean -2 Q. Withdraw it. Are we talking about one 3 acute test? 4 A. We're talking about acute testing of at 5 least four types of PCBs or so by Monsanto. 6 Q. Do you know how the acute testing was done? 7 Was it animal testing? 8 A. It's a typical acute testing as described 9 by the toxicology professionals, a 30-day exposure at 10 which a given number of the test animals will 11 deliberately be exposed to the point of death so you can 12 establish the upper limit for that animal. 13 Q. Do you know what animals were used in these 14 tests? 15 A. Rats . 16 Q. Any particular kind of rat? 17 A. Oh, gosh! I don't know them all by 18 species . All I know is it's the white laboratory ra t . 19 Q. After that testing, was there more acut e 20 testing done by Monsanto? 21 A. More acute? 22 Q. Additional acute testing. 23 A. Additional acute. Not of the same type 24 Q. What do you mean not of the same type? 25 A. Well, because t~he word "acute" shows up in Gateway Reporting Associates, Inc. WATER PCB-SD0000070928 Gateway Reporting Associates, Inc. 144 1 the subacute studies. They were also done. 2 Q. Were chronic studies done at some point? 3 A. Yes . 4 _Q When? 5 A. From '69 through '71. 6 Q. And do you know who did those? 7 A. Yes . 8 .Q Who? 9 A. Industrial Bio-Test Laboratories. 10 Q. Now, you mentioned Monsanto did subacute 11 studies ? 12 A. Yes . 13 Q. What do you mean by subacute studies? 14 A. That's a 90-day study which later leads to 15 the chronic studies. . 16 Q. Do you know about when they were done? 17 A. Early '69. 18 Q. Were they being done at the same time as 19 the chronic studies ? 20 A. No. The chronic studies followed the 21 subacute. 22 Q. Do you know who did the subacute studies? 23 A. Industrial Bio-Test Laboratories. 24 Q. If you look at tab six, have we marked that 25 386 for identification? Gateway Reporting Associates, Inc. WATER PCB-SD0000070929 Gateway Reporting Associates, Inc. 145 1 A. Yes. 2 Q. That purports tobe a memo dated November 3 14th, 1955 from Jack Garrett to Mr. H. B. Patrick at 4 Krummrich plant, subject Department 246 (Aroclors), date 5 November 14th, 1955. Have you seen that before? 6 A. Yes. 7 Q. That document states it is theopinion of 8 the Medical Department that the eating of lunches should 9 not be allowed in this department for a number of 10 reasons, and then it. goes on with some reasons. Do you 11 see that? 12 A. I do. 13 Q. Item 3 says, "It has long been the opinion 14 of the Medical Department that eating in process 15 departments was a potentially hazardous procedure that 16 could lead to serious difficulties. While the Aroclors 17 are not particularly hazardous from our own experience, 18 this is a difficult problem to define because early 19 literature work claimed that chlorinated biphenyls were 20 quite toxic by ingestion or inhalation." Do you know 21 what early work Mr. Garrett is referring to? 22 A. I do not. 23 Q. Do you know whether this document was in 24 these binders that you were given in 1970? 25 A. I believe it wa's, yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000070930 Gateway Reporting Associates, Inc. 146 1 Q. The last sentence says, quote, "In any case 2 where a workman claimed physical harm from any 3 contaminated food, it would be extremely difficult on 4 the basis of past literature reports to counter such 5 claims." Do you see that? 6 A. Yes. 7 Q. Do you agree with that? 8 A. Yes. 9 Q. Now, in your work at Monsanto, did you ever 10 hear any discussions with respect to exposures of 11 workmen with respect to an explosion at BASF in Germany? 12 A. I do not remember that. 13 Q. Do you recall any discussions of concerns 14 about dioxins being emitted during that explosion which 15 was in the 1956 time period? 16 A. I don't remember that. I have no 17 recollection. 18 Q. Do you recall any discussions with 19 Dr. Kelly or Mr. Wheeler about claims of chloracne based 20 on exposure in those explosions? 21 A. That's news to me. 22 Q. There weren't any memos on it in these 23 three-ring binders that you described for me; were 24 there? 25 A. Not to my recollection. Gateway Reporting Associates, Inc. WATER PCB-SD0000070931 Gateway Reporting Associates, Inc. 147 1 Q. Do you know the name Boehringer, 2 B-O-E-H-R-I-N-G-E-R? 3 A . I do not. 4 Q. Do you know anything as to letters being 5 sent out in 1957 to all American manufacturers, 6 including Monsanto, identifying dioxin as a contaminant 7 in 245T? 8 A. No. I'm not familiar with that. 9 Q. Do you know whether 245T was made at Nitro, 10 West Virginia by Monsanto? 11 A. I'm not very certain, but it rings a faint 12 bell . 13 Q. Do you know whether 245T is a herbicide? 14 A. Yes, I know that. 15 Q. Do you know whether it was used for the 16 same purposes as Agent Orange? 17 MR. SABETTA: Objection to form. 18 A. Well, all I know is that they are both weed 19 killers. I do not know the specific application and 20. what vegetation they are used on. 21 MR. McDONOUGH: Let's take a five-minute 22 break, ten-minute break, whatever. 23 (Reporter marked Plaintiff's Exhibits 387 24 through 399.) ' 25 Q. I'm showing you' 387 for identification. Gateway Reporting Associates, Inc. WATER PCB-SD0000070932 Gateway Reporting Associates, Inc. 148 1 A. Yes. 2 Q. Mr. Papageorge, it's a document entitled 3 "Polychlorinated .Biphenyls (PCB's), A Report on Uses, 4 Environmental and Health Effects and Disposal". Have 5 you got that in front of you? 6 A. I do . 7 Q. Have you seen that document before? 8 A. Yes . 9 Q. Did you prepare it? 10 A. I was involved in its preparation, but 11 is really a composite of contributions from several 12 people. 13 Q. Okay. Do you know about when the document 14 was prepared? 15 A. Around 1972, '73. 16 Q. Well, since the graphs seem to go to 1977, 17 some of the information seems to go to 1977, and I see a 18 reference to a seminar in October of 1979, I think that 19 dating is probably off if you think it's '12. 20 MR. McDONOUGH: Off the record. 21 (Whereupon, there was an off-the-record 22 discussion) 23 Q. If you look at the index, it says "Section 24 1. History of Monsanto Production and Sales of 25 Chlorinated Biphenyls". Do you see that? Gateway Reporting Associates, Inc. WATER PCB-SD0000070933 Gateway Reporting Associates, Inc. 149 1 A. I do. 2 Q. Do you know who prepared that portion of 3 the document? 4 A. Well, I see some information in that 5 section of the document in which I did participate in 6 the preparation. That's the pages that have the FUR 7 003911 and 3912, up through the year '76 -- I'm sorry - 8 '75, I .had that information prepared for me by 9 Monsanto's accounting department. I do not know who 10 requested the data that takes it through 1977. That 11 also applies then to these graphs that follow. 12 Q. Graphs were prepared under your supervision 13 up through 1975 and then subsequent to that under 14 somebody else's supervision? 15 A. That's my understanding of what I'm looking 16 at here. Because I remember those graphs were put 17 together while I was still actively involved. 18 Q. Now, under Section 2 of the index, back at 19 the beginning, it says "Information on Health Effects". 20 Do you know who prepared that information? 21 A. Not a specific person, but within Monsanto, 22 it would have to be the Medical Department. 23 Q. Would that have been under Dr. Roush at 24 that time? 25 A. Let me see if i" can get a... Well, since Gateway Reporting Associates, Inc. WATER PCB-SD0000070934 Gateway Reporting Associates, Inc. 150 1 it does cover on into the end of '77, Dr. Roush would 2 have been in place in the position of Corporate Medical 3 Director, so whoever prepared this was to me obviously 4 reporting to Dr. Roush's organization. 5 Q. Did you prepare any parts of this section 6 dealing with health effects? 7 A. No . 8 Q. Under the index Section 3, "Monsanto's 9 Actions Resulting from Health Data," do you know who 10 prepared that section? 11 A . No, I don't. 12 Q. Section 4 is "Communicating with 13 Customers" Do you know who prepared that section? 14 A. I do not. 15 Q. Section 5, "PCB Disposal," do you know who 16 prepared that? 17 A. I do not. 18 Q. Okay. If you'll look at tab nine for me, 19 please, we've marked that Exhibit 388 for 20 identification. It purports to be, the first sheet, a 21 letter from D. Wood, Monsanto Europe, to G. R. Buchanan, 22 St. Louis, 1st December 1966. 23 A. I see that. 24 Q. Who's G. R. Buchanan? 25 A. Mr. Buchanan was a marketing representative Gateway Reporting Associates, Inc. WATER PCB-SD0000070935 Gateway Reporting Associates, Inc. 151 1 in St. Louis, and he was involved with the sale of PCBs 2 into the plasticizer applications. 3 Q. Have you seen this document before? 4 A. I don't remember it. 5 Q. I was referring to this first page. 6 A. I'm sorry. Do what with the first page? 7 Q. I was referring to the first page only of 8 388. Have you seen that before? 9 MR. SABETTA: What's the Bates number on 10 it? 11 MR. McDONOUGH: 3944. 12 A. Okay. No. That's the one I had not seen 13 before. 14 Q. Now, that purports be copied to Dr. Emmet 15 Kelly in St. Louis. 16 A. Yes . 17 Q. D.V.N. Hardy in London, R.A. Steenrod, 18 S-T-E-E-N-R-O-D, St. Louis, and A. Arpino, A-R-P-I-N-0, 19 Brussels. Who is Mr. Steenrod? 20 A. Mr. Steenrod was a member of the marketing 21 department with plasticizers located in St. Louis. 22 Q. That particular document, that first page 23 of 388, doesn't refer to plasticizers; does it? 24 A. It does not . 25 Q. It refers to Ardclor? Gateway Reporting Associates, Inc. WATER PCB-SD0000070936 Gateway Reporting Associates, Inc. 152 1 A. It does. 2 Q. Do you know who D. Wood is or was? 3 A. He was the Monsanto marketing 4 representative in Europe located -- His office was in 5 Brussels, Belgium, and he was involved with the 6 marketing of PCBs for what we called the plasticizer 7 applications. 8 Q. Did Monsanto have any plants in Europe that 9 manufactured Aroclors? ' 10 A. Yes. 11 Q. Where were the plants in Europe? 12 A. Newport, Wales. 13 Q. Do you know what Aroclors they manufactured 14 there ? 15 A. They, in essence, made the same groupings 16 that were made in the U.S. 17 Q. Did they have their ownresearch and 18 laboratory there? 19 A. Yes. 20 Q Did they have their own Medical Department 21 there? 22 A. Yes. 23 Q. Do you know if they maintained a library 24 there in the Medical Department? 25 A. Yes. ' Gateway Reporting Associates, Inc. WATER PCB-SD0000070937 Gateway Reporting Associates, Inc. 153 1 Q. Would that be the same facility where 2 Dr. Newman worked? 3 A. Yes. 4 Q. And Dr. Hardy? 5 A. Yes. 6 Q. This copy to D.V.N.Hardy, London, do you 7 know who that is? 8 A. He's a marketing person, Monsanto employee, 9 working out of the London office. 10 Q. Now, the next page of that Exhibit 388 11 purports to be a letter of November 28th, 1966 from a 12 Rising, R-I-S-I-N-G, and Strand, S-T-R-A-N-D. It ' 13 appears to be signed by an Ola, but I can't quite tell 14 from the copy. Is your copy better than mine? 15 A. I believe you're right. 16 Q. Would that be the Ola Palm that the 17 December 1st, 1966 letter refers to? 18 A. December 1st? Yes. Ola Pond, yes. 19 Q. Did Monsanto have facilities in Sweden? 20 A. No. 21 Q. Have you ever seen this letter, November 22 28th, 1966 before? 23 A. Yes. . 24 Q. When did you see that? 25 A. During my tutorial. Gateway Reporting Associates, Inc. WATER PCB-SD0000070938 Gateway Reporting Associates, Inc. 154 1 Q. Was that part of your notebooks? 2 A. Yes. 3 Q. That references some testing that was done 4 in Sweden; is that correct? 5 A. Yes. 6 Q. Now, do you know about when it was that you 7 saw the letter? Was that in 1970 when you started 8 there? , 9 A. About January '70, yes, sir. This is one 10 of the earliest documents I was shown. 11 Q. Do you know who showed it to you? 12 A. Elmer Wheeler. 13 Q. Did he discuss it withyou? 14 A. Yes. 15 Q. Did he indicatewhether Monsanto had done 16 anything in reference to this correspondence? 17 A. Yes. 18 Q. What did he tell you? 19 A. Well, initially David Wood located in 20 Brussels went to the University of Stockholm to 21 personally talk with the investigators who made the 22 report about finding a strange material in their samples 23 that was interfering with their analysis for DDT, and to 24 establish some sort of communications for reporting 25 further results and to get from those researchers a copy Gateway Reporting Associates, Inc. WATER PCB-SD0000070939 Gateway Reporting Associates, Inc. 155 1 of the procedures they followed to make their analyses. 2 Q. Mr. Willard told you that Mr. Wood did 3 that ? 4 A. Yes . 5 Q. Were the procedures given to Monsanto at 6 about that time? 7 A. Yes . 8 Q. Did you ever see those procedures? 9 A. Yes, I did. 10 Q. Did Monsanto have similar procedures in its 11 laboratories at about that time? 12 A. No. They were -- No, they didn't. 13 Q. What was the difference between any 14 procedures you had in the Monsanto labs and the 15 procedures here in Sweden? 16 A. The primary difference is the availability 17 of the latest in analytical instruments. It's a 18 specially-ordered instrument that had to be in place, 19 and that created the difference in capabilities between 20 the two labs. 21 Q. What was the name of the instrument? 22 A. I've forgotten now, but it's a gas liquid 23 chromatogram and spectrophotometer. 24 Q. Do you -- I'm sorry. 25 A. That 'sit. Gateway Reporting Associates, Inc. WATER PCB-SD0000070940 Gateway Reporting Associates, Inc. 156 1 Q. Do you recall who the manufacturer was? 2 A. No, I don't. 3 Q. Did Monsanto obtain one? 4 A. Yes. 5 Q. When? 6 A. As I remember, it took about a year for 7 delivery, and it was ordered in '67, so about 1968. 8 Q. Was that delivered to any particular 9 laboratory at Monsanto? 10 A. Yes. To Dr. Keller'sgroup. 11 Q. Did hebegin to perform analysis at that 12 time? 13 A. Oh, certainly, but he performed analyses 14 with the old style instruments before the new instrument 15 came along. 16 Q. What did he perform analysis on? 17 A. PCBs. 18 Q. What was the purpose of his analysis? 19 A. To be able to detect the presence of PCBs 20 in all types of samples at low levels. 21 Q. So, as I understand it, he took water, 22 earth, things of that sort, and then tested them to see 23 if he could determine if PCBs were present in them? 24 A. Yes. And in order to do that, he 25 delibe rately contaminated thrtem and then ran them through Gateway Reporting Associates, Inc. WATER PCB-SD0000070941 Gateway Reporting Associates, Inc. 157 1 the instrument to see if his numbers matched the input. 2 Q. Did they? 3 A. I 1 m sorry? 4 Q. Did his numbers match the input? 5 A. Not initially because they were still 6 learning, but with the analysis of the difference in 7 numbers, they were able to, in essence, close the gap, 8 and they got better and better with time. 9 Q. Did he do any analysis on material that he 10 hadn't contaminated deliberately with PCBs? 11 A. At what time? 12 Q. 1968, right after you got the equipment you 13 were referring to at Monsanto. 14 A. Yes. They did go out and get some soil 15 samples around the plants, soil near the operation and 16 so on. 17 Q. And did they find that these soils had PCBs 18 in them? 19 A. Yes . 20 Q. And did you know when that first was found? 21 A. Late 16 8 i s the best I can recall. 22 Q. Now, was that prior to obta ining the better 23 equipment? . 24 A. I think about the time the new equipment 25 came in place they were able' to feel more confident of Gateway Reporting Associates, Inc. WATER PCB-SD0000070942 Gateway Reporting Associates, Inc. 158 1 the numbers. 2 Q. What did the new equipment add to the 3 analysis from Monsanto's point of view? 4 A. It produced a graph that was consistent 5 each time they ran the sample, and by graph I'm talking 6 about the peaks and valleys of a chart which point out 7 the types of PCBs and the amounts. 8 Q. Did the new equipment quantify whereas the 9 old equipment did not quantify? 10 A. Well, it tried to, but once in a while it 11 would blend the peaks or skip and make a valley when it 12 shouldn't have. So it had its limitations. 13 Q. Was it possible to get some quantification 14 from the old equipment? 15 A. Yes. But they had difficulty duplicating. 16 They never felt comfortable with whatever number they 17 came up with. 18 Q. Did you ever have any discussions with 19 Dr. Keller about his results of these analyses that he 20 was performing in about 1968? 21 A. Yes. 22 Q. Was he surprised that there were PCBs in 23 the environment? . 24 A. Oh, yes. 25 Q. Why? T' Gateway Reporting Associates, Inc. WATER PCB-SD0000070943 Gateway Reporting Associates, Inc. 159 1 A. Primarily because of the presence in things 2 or samples that were not associated with industrial 3 applications, and PCBs from Monsanto's viewpoint were 4 looked upon as industrial chemicals. They are not the 5 kind you find in a pine forest, for example. How did it '6 get there? Those are the questions that these answers 7 were bringing up. 8 Q. Did Dr. Keller express surprise that you 9 found them in the soils around the Monsanto plants that 10 manufactured these chemicals? 11 A. No. He expected to find them there, and he 12 expected to find them in the same condition as they 13 would be right out of the manufacturing system. 14 Q. And why was that? 15 A. Because of the understanding that these 16 were nonreactive. They stayed the same no matter what 17 happened. 18 Q. They were inert or expected to be inert? 19 A. They were expected to be inert, inactive 20 Q. They were expected to be pebbles on the 21 beach? 22 A. Yes. 23 Q. So as I understand your answer, 24 Dr. Keller's surprise was with respect to the extent 25 that the PCBs had migrated f'irom the factories? Gateway Reporting Associates, Inc. WATER PCB-SD0000070944 Gateway Reporting Associates, Inc. 160 1 A. That was one of the surprises. 2 Q. What other surprises did he have? 3 A. The other surprises, as you proceeded 4 further from the plant, the composition of that PCB 5 would change, indicating that something was affecting 6 the lower chlorinated PCBs. 7 Q. Do you know if Dr. Keller attempted to do 8 any testing with either the old equipment or the new 9 equipment in 1968 with respect to dioxins or ' 10 dibenzofurans being present? 11 A. Not at that time. 12 Q. Did he do any testing on Pyranol in 1968 in 13 terms of presence of dioxins or dibenzofurans? 14 A. No. 15 Q. Did Dr. Keller produce reports with respect 16 to his test, his tests? 17 A. Certainly. 18 Q. These earlier tests thatyou've told me 19 about about the acute animal studies and the chronic 20 animal studies, was that usual that Monsanto would test 21 industrial chemicals in that manner? 22 MR. SABETTA: Objection to form. 23 A. This is thefirst.example thatMonsanto and 24 I personally heard of an industrial chemical being 25 tested in a manner similar tt> the tests given to Gateway Reporting Associates, Inc. WATER PCB-SD0000070945 Gateway Reporting Associates, Inc. 161 1 materials approved for food grade or pharmaceutical use, 2 so it was a first. 3 Q. As I understand it, the Department of 4 Agriculture makes you test for chemicals that are used 5 in foods? 6 A. The Food and Drug Administration is the one 7 that monitors and approves the use in foods. The 8 Department of Agriculture makes certain that what I'm 9 going to call the farm produced meat and so on meets 10 acceptable standards. 11 Q. Who tests for pharmacological chemicals? 12 A. Food and Drug Administration. ' 13 Q. So as I understand it, there's no 14 requirement, there was no government requirement for 15 testing Aroclors in this fashion that you did for acute 16 and chronic studies; is that correct? 17 A. That is correct. 18 Q. And this is the first chemical that 19 Monsanto has tested in that fashion? 20 A. That anyone has tested in that fashion. 21 Q. Why did you test it in that fashion? 22 A. To answer the question of if it's out there 23 what harm, if any, can it do. . 24 Q. And I think you told me that some of the 25 acute testing took place in -the 1950's; is that correct? Gateway Reporting Associates, Inc. WATER PCB-SD0000070946 Gateway Reporting Associates, Inc. 162 1 A. Yes. 2 Q. Did Monsanto know that it was out there in 3 the 1950's? 4 A. It didn't know, but it assumed that if any 5 did get out into the environment -- And the thing really 6 was associated with industrial sites. If it did get out 7 there, there was nothing to indicate any harm would be 8 done . 9 Q. That's why I'm asking what the basis for 10 doing the testing was in the 1950's, the animal testing. 11 A. Something came up to trigger the retesting. 12 Oh, as I remember, the -- I'm trying to remember the 13 name of the group. The American Institute of Government 14 Industrial Hygienists, AIGHI or IH, they were looking 15 for levels of exposure that they would include in their 16 published list of industrial chemicals, and Monsanto 17 conducted those tests to come up with the numbers that 18 were eventually adopted by the AIGIH. 19 Q. Was the lead investigator on those Treon? 20 A. Yes. That's the name I associate with it. 21 Q. And did Monsanto retain Treon as a 22 consultant ? 23 A. I don't know the official relationship. I 24 do know that there was a continual dialogue. I don't 25 know if he was an official cdnsultant. Gateway Reporting Associates, Inc. WATER PCB-SD0000070947 Gateway Reporting Associates, Inc. 163 1 Q. Let's get rid of the word "consultant". Do 2 you know if Monsanto sponsored the studies? 3 A. Yes. The studies that we saw earlier with 4 Kettering. 5 Q. Yes. 6 A. That was Monsanto's activity. 7 ' Q. Okay. Were the Treon studies -- Are they 8 the same as Kettering? 9 A. I'm under the impression they were the same 10 as the Kett ering. 11 Q. Did Monsanto pay for those studies? 12 A. That's my understanding. 13 Q. Can you tell me why? 14 A. This is a Monsanto product. Anything to do 15 with these products would immediately be associated with 16 Monsanto, so how could we expect others to do the 17 studying? 18 Q. But up until this point, as I understand 19 your opinion, they are like pebbles on the beach. I'm 20 trying to get at why Monsanto would do all of this 21 testing if they were like pebbles on the beach. 22 MR. SABETTA: Objection, asked and 23 answered. . 24 A. Well, the intent was to get data to help 25 the worker that is exposed to these chemicals at Gateway Reporting Associates, Inc. WATER PCB-SD0000070948 Gateway Reporting Associates, Inc. 164 1 Monsanto plants and the customers' plants, which is 2 different than the environmental effect that might be 3 out there. 4 Q. Haven't you said on many occasions 5 throughout the paper that you prepared for Monsanto that 6 there were no occasions where the workers were exposed 7 other than -- or suffered other than once that you knew 8 of ? 9 MR. SABETTA: Objection to form: 10 A. I guess that's true, but that's under 11 industrial conditions with respirators on the shelf to 12 grab, a change of shoes, a change of clothing, a lot 13 different than the average person on the street. 14 Q. What workers were you talking about? The 15 Monsanto workers or - 16 A. Any workers that are handling PCBs. 17 Q. If you turn to the next tab, please, we've 18 marked that 389 for identification. It purports to be a 19 letter, January 16th, 1968, from the United States 20 Department of the Interior, Fish and Wildlife Service. 21 Richard A. Wilson, to Monsanto Chemical Company. Have 22 you seen that before? 23 A. Yes. . 24 Q. Was that in your notebook? 25 A. Yes. " Gateway Reporting Associates, Inc. WATER PCB-SD0000070949 Gateway Reporting Associates, Inc. 165 1 Q. Do you know whether Monsanto sent samples 2 of Aroclors to the United States Department of the 3 Interior as requested? 4 A. Yes. 5 Q. Who sent them? 6 A. The samples were sent out of Monsanto from 7 Dr. Keller's group. I don't know the specific 8 individual who put them in the box and mailed them. 9 Q. Do you know if they were specially prepared 10 samples? 11 A. No. They come off the shelf. 12 Q. How do you know that? 13 A. That's the way it's done, the practice. 14 Q. Had Monsanto been requested forchemicals 15 before for testing by some government agency? 16 A. Oh, yeah. Many times. 17 Q. Was it Monsanto's practice to give the 18 agency a standard sample from a regular run of the 19 industrial chemical? 20 A. Yes. 21 Q. Did Monsanto have any practice of blending 22 chemicals together prior to sending them to agovernment 23 agency? 24 A. Oh, no. That would be -- No. That 25 wouldn't be condoned. It ha's to be associated with a Gateway Reporting Associates, Inc. WATER PCB-SD0000070950 Gateway Reporting Associates, Inc. 166 1 batch number, a lot number, and a date, and where was it 2 manufactured and who packaged it. There is a little 3 history that goes with it that's got to be kept and 4 respected. 5 Q. You can't think of any scientific basis for 6 why a company would submit a blend of a chemical to a 7 government agency that it asked for a chemical for 8 sampling? 9 MR. SABETTA: Objection to form; . 10 A. I personally would find that disturbing at 11 best. I'd like to know that this material I have is 12 associated with a process that started on a date and 13 these things happened and was put into this bottle on a 14 given date. 15 Q. Could we turn to the next tab we've marked 16 Exhibit 390, something entitled "Minutes of Meeting of 17 the Corporate Development Committee, April 22nd, 1968," 18 which purports to be an abbreviated redacted version of 19 minutes. Have you ever seen that before? 20 A. I don't recall seeing this. 21 Q. Do you know who the Corporate Development 22 Committee is or was at that time period? 23 A. In this particular exhibit, they are listed 24 on the front page. They are members. They include the 25 top official in Monsanto and' some of his senior vice Gateway Reporting Associates, Inc. WATER PCB-SD0000070951 Gateway Reporting Associates, Inc. 167 1 presidents and an individual who's designated as a 2 secretary to keep notes. 3 Q. Was there anybody in that group of eight 4 names listed on the first part of Exhibit 390 members of 5 Mr. Springgate's or Mr. Bergen's groups? 6 A. No. These people are several levels above 7 them. 8 Q. Are they above Mr. Minkler's level? 9 A. Oh, yes. - 10 Q. Do you know what the purpose of the 11 Corporate Development Committee is other than corporate 12 development ? 13 A. They are to serve as the group that guides 14 the corporation in some of its key activities. 15 Q. If you turn to the second page of Exhibit 16 390, in the first paragraph it says Dr., and I'll spell 17 it, A-N-A-G-N-O-S-T-O-P-O-U-L-O-S, "reviewed the 18 functional fluids group. Phosphate esters and Aroclor 19 are the two major products in this group. The product 20 group expects to be above the 1968 budget in terms of 21 ROI and on the objective line for net income." Do you 22 see that? 23 A. Yes. 24 Q. Do you know who that doctor referred to is? 25 A. Yes. He is the" individual that preceded Gateway Reporting Associates, Inc. WATER PCB-SD0000070952 Gateway Reporting Associates, Inc. 168 1 Mr. Bergen. Constantine that I tried to remember 2 earlier. He was the business group director of the 3 functional industrial fluids group. 4 Q. Would that allow you to place a date on 5 when Mr. Bergen started in that position? 6 A. Yes. That would zero in more and more on 7 1969 . 8 Q. Was Mr. Bergen there when you got to your 9 position in January 1970? 10 A. Yes. 11 Q. Do you know what ROI refers to? 12 A. Return on investment. ' 13 Q. Do you know what "on the objective line for 14 net income" means? 15 A. I can only share with you my interpretation 16 of that. It's a line that was plotted to designate the 17 objective of the business group. 18 Q. If you look at the last paragraph on that 19 page, it says, "In the case of Aroclor the key issue 20 becomes how to significantly increase the sales growth 21 while maintaining the domestic supply position and 22 profitability. It is believed that transformers and 23 heating systems provide the major opportunities. A 24 target of ten percent of the transformer market by 1972 25 has been set. In the case of Therminol we have about a Gateway Reporting Associates, Inc. WATER PCB-SD0000070953 Gateway Reporting Associates, Inc. 169 1 $1 M business in 1968 and a target of $10--20 M business 2 by 1972. In this area, a total systems approach is 3 being used; supply the fluids, design the system and 4 supply the hardware." Do you note that? 5 A. Yes. 6 Q. Do you know what M refers to? 7 A. M with a bar on top is million. 8 Q. What is M without a bar on top? 9 A. Thousand. 10 Q. What's the billion dollar mark that 11 Monsanto uses in its documents? Have you seen it? 12 A. . In its documents? ' 13 Q. Yeah. 14 A. All I recall is the M with the bar over it. 15 Q. What's Therminol? 16 A. Therminol is the registered trademark of 17 fluids used in heat transfer systems. 18 Q. Does that particular fluid contain 19 Aroclors ? 20 A. Some of them. 21 Q. Did there come a time when Aroclors were 22 not sold for that particular purpose? 23 A. Yes. . 24 Q. About when was that? 25 A. About '72. 197-2. Gateway Reporting Associates, Inc. WATER PCB-SD0000070954 Gateway Reporting Associates, Inc. 170 1 Q. All right. If you look at tab 13 for me, 2 please, we've marked as Exhibit 391 a two-page document 3 dated December 30th, 1968, W. R. Richard to W. A. Kuhn, 4 K-U-H-N on Aroclor -- Wildlife. Have you got that in 5 front of you? 6 A. I do. 7 Q. Have you ever seen that before? 8 A. Yes. 9 Q. Now, this was -- Withdraw that. ' Do you 10 know who W. R. Richard was? 11 A. Yes. 12 Q. Who was he? 13 A. He was the individual in charge of research 14 in the industrial fluids business group. 15 Q. Was he part of Dr. Keller's testing group? 16 A. No. No. Dr. Keller is analytical 17 chemistry. 18 Q. What's Mr. Richard? 19 A. It's a broader field of finding chemicals 20 or developing new chemicals and finding applications for 21 these new chemicals. 22 Q. Is he superior to Dr . Keller in terms of 23 A. ' I think they are - - 24 MR. SABETTA: Let him finish the question 25 Q. In terms of ther' structure there in research Gateway Reporting Associates, Inc. WATER PCB-SD0000070955 Gateway Reporting Associates, Inc. 171 1 and development? 2 A. I think they are peers within the overall 3 organization. 4 Q. I don't know if I asked you. Have you seen 5 this document before? 6 A. Yes. 7 Q. Now, it notes in the fourth paragraph down, 8 "We are taking three steps to protect ourself. Scott 9 Tucker and R. Keller are to repeat some of the 10 analytical identification work feeding Aroclor to 11 chickens and seeing if Aroclor is really present as 12 'shown' by the literature. I hope we have been falsely 13 accused but maybe Aroclor is present." Do you see that? 14 A. I do. 15 Q. Is that R. Keller Dr. Keller that we've 16 been referring to? 17 A. Yes. 18 Q. Did Dr. Keller participate in feeding 19 chickens? 20 A. No . 21 Q. Were there some chicken studies done about 22 then? 23 A. They were started, 24 Q. Who was doing that? 25 A. Industrial Bio-Test Laboratories. Gateway Reporting Associates, Inc. WATER PCB-SD0000070956 Gateway Reporting Associates, Inc. 172 1 Q. Do you know what it refers to when it says 2 "seeing if Aroclor is really present as 'shown' by the 3 literature"? Do you know what the author is referring 4 to? 5 A. Based on the information available at that 6 time, it has to refer to the University of Stockholm 7 studies. 8 Q. So does that indicate they were going to 9 test the chicken eggs to see if there was presence of 10 Aroclors? 11 A. You mean the University of Stockholm 12 studies ? 13 Q. No. The Monsanto studies, the chicken 14 feeding that R. Keller and Scott Tucker were supposed to 15 do . 16 A. Yeah. They were supposed to arrange for 17 some chickens to be fed and their tissue analyzed to see 18 if it stayed within their bodies. 19 Q. Were those tests done? 20 A. Eventually, yes. 21 Q. How eventually? 22 A. Late '71, as best I recall. 23 Q. And did Industrial Bio-Test do those? 24 A. They did the whole study and saved samples 25 and sent them to Dr. Keller -and Dr. Tucker to analyze. Gateway Reporting Associates, Inc. WATER PCB-SD0000070957 Gateway Reporting Associates, Inc. 173 1 Q. And did the results show whether Monsanto 2 had been falsely accused? 3 MR. SABETTA: Objection to form. 4 A. No. The PCBs were found. 5 Q. In the last paragraph, it says, "E. Wheeler 6 is having feeding tests done on animals to establish a 7 'safe' level for Aroclor feeding. If we can find a 8 'safe' level, Calandra's lab will do two year 9 experiments on animals including effects on succeeding 10 generations. This will help a bit, but the wildlife 11 people won't be stopped by this kind of evidence." Do 12 you see that? 13 A. Yes. 14 Q. What is the reference to Calandra's lab? 15 A. Dr. Calandra was the principal individual 16 with Industrial Bio-Test Laboratories. 17 Q. Was he subsequently indicted along with 18 three other Industrial Bio-Test employees for falsifying 19 test results for federal government analysis? 20 MR. SABETTA: Objection to form. 21 A. All I recall, and I got this from public 22 press, that Dr. Calandra was accused of some illegal 23 wrongdoing, and that's as much as I know. 24 Q. Do you know whether Monsanto ever went back 25 over the Industrial Bio-Test" test results and did an Gateway Reporting Associates, Inc. WATER PCB-SD0000070958 Gateway Reporting Associates, Inc. 174 1 analysis as to whether they were accurate or falsified? 2 MR. SABETTA: Objection to form. 3 A. Which products? 4 Q. Do you understand that Dr. Calandra and the 5 other Industrial Bio-Test individuals were indicted with 6 respect to Monsanto products that were not Aroclors? 7 MR. SABETTA: Objection. 8 A. That's my understanding. 9 Q. All right. Did Monsanto go back and test 10 the Industrial Bio-Test work that had been done to 11 determine if it was accurate with respect to those 12 products? 13 MR. SABETTA: Objection to form. Which 14 products are you referring to? The Aroclors or the 15 non-Aroclors? 16 Q. The products that they got indicted on. 17 A. I don 1t know. 18 Q. After Monsanto found out that Dr. Calandra 19 and the others had been indicted with respect to certain 20 products and test reports on certain products, did they 21 ever do a review or analysis on the results that 22 Industrial Bio-Test had been giving them on Aroclors? 23 A. Yes. 24 Q. Who did that? 25 A. Elmer Wheeler, Dr. Levinskas and Fred Gateway Reporting Associates, Inc. WATER PCB-SD0000070959 Gateway Reporting Associates, Inc. 175 1 Johansen. 2 Q. Was that review done in writing? 3 MR. SABETTA: Objection to form. 4 Q. I'll withdraw it. Were there any documents 5 produced as a result of that review? 6 A. I don't remember anypersonally. That 7 doesn't mean -- I just don't remember it. 8 Q. How do you know that it was done? 9 A. Well, I was informed that they were looking 10 over the study, and this was after, as best I recall, 11 after I was removed from the PCB issue. 12 Q. You mentioned a study in your answer. Was 13 there one particular study they were looking at? 14 A. No. The studies. 15 Q. If you turn the page on Exhibit 391, up at 16 the top of the second page, it says, "The third step is 17 to minimize exposure of Aroclor to reduce air and water 18 pollution, to restrict Aroclor to uses which can be 19 controlled. This is the only way I see to survive." Do 20 you see that? 21 A. I do. 22 Q. Do you know what that refers to? 23 MR. SABETTA: Objection to form. 24 Q. Withdraw it. DidMonsanto restrict Aroclor 25 to uses which can be control-led? Gateway Reporting Associates, Inc. WATER PCB-SD0000070960 Gateway Reporting Associates, Inc. 176 1 A. Yes. 2 Q. Do you know when they did that? 3 A. The first restriction became effective on 4 August 30, 1970. 5 Q. And do you know what product was entailed 6 in that restriction? 7 A. These were the PCBs used in what Monsanto 8 referred to as open uses. 9 Q. Can you tell me what those open uses were? 10 A. I can give a few examples. Like lacquers, 11 varnishes, caulking, the painted stripes on the 12 highways. Any application that was not inside a sealed 13 system. 14 Q. Did you restrict plasticizers at that 15 point ? 16 A. I thought that's what I said, yeah. 17 Q. Well, I didn't hear it. How are people 18 exposed to painted stripes on the highway? 19 A. Well, this refers to environmental 20 contamination. 21 Q. How is that environmental contamination 22 going to take place? Paint was going to wash off? 23 A. Eventually it does wear off and gets 24 distributed. 25 Q. Do you know whab percentage of Monsanto's Gateway Reporting Associates, Inc WATER PCB-SD0000070961 Gateway Reporting Associates, Inc. 177 1 PCB business was entailed in that August 30th, 1970 2 restriction? 3 A. I think you'll find it in the previous 4 document here. I don't remember the number. 5 Q. What uses were not restricted as of that 6 August 30th, 1970 time period? 7 A. The uses not restricted were the dielectric 8 applications, the industrial hydraulic fluids, and the 9 heat transfer systems. 10 Q. Can you give me an example of a heat 11 transfer system use of PCBs that you're referring to? 12 A. I'll try.. Let's suppose you have a process 13 that involves, say, the cooking of varnish, and by 14 putting a gas or oil flame under the pot that this 15 varnish is in, you run the risk of overflowing and 16 subsequent fire. In order to avoid that risk, you use a 17 heat transfer fluid in a closed system where the fluid 18 is heated in one building to a high temperature, and the 19 hot fluid is pumped into that second building where the 20 varnish is located, and with coils inside or outside of 21 that tank you heat the varnish. So any spillage that 22 occurs there won't catch fire. There is no flame. 23 Q. Do you know generally what temperatures 24 those heat transfer units operated at? 25 A. Generally about 400 Fahrenheit. Gateway Reporting Associates, Inc. WATER PCB-SD0000070962 Gateway Reporting Associates, Inc. 178 1 Q. How does that convert to centigrade? 2 A. Centigrade? Roughly half. 3 Q. Do you know if Monsanto was aware of the 4 Yusho incident in 1968? 5 A. In 1968? No, it was not aware of it. 6 Q. What do you base your answer on? 7 A. Because not even the government knew about 8 it until early '69 or so. 9 Q. The government doesn't know a lot of 10 things. 11 A. I understand that. 12 Q. Did Yusho occur in 1968?" 13 A. That's my understanding, yes. 14 Q. Did Monsanto have sales in Japan in 1968? 15 A. No . 16 Q. Did they have employees in Japan in 1968? 17 A. Yes. 18 Q. What were they doing with respect to 19 Monsanto' s work? 20 A. I don't understand the question 21 Q. Well, I think you told me there were 22 employees of Monsanto in 1968 in Japan. 23 A. Yes. . 24 Q. What were they doing? 25 A. Selling Monsanto products. Gateway Reporting Associates, Inc. WATER PCB-SD0000070963 Gateway Reporting Associates, Inc. 179 1 Q. Did that include Aroclors? 2 A. Not at that time. 3 Q. Why do you say not at that time? 4 A. A plant was finally built in Japan in a 5 joint venture, and Aroclors, Monsanto's trademark, were 6 marketed briefly. 7 Q. Was that a joint venture with Monsanto and 8 someone else? 9 A. Yes. 10 Q. Who was the someone else? 11 A. Mitsubishi. 12 Q. What period of time wereAroclors marketed 13 briefly? 14 A. '69. Say late '69, early '70. 15 Q. Was that less than a year that they were 16 marketed in Japan? 17 A. Yes. 18 Q. What happened with respect to that 19 particular plant production of Aroclors? 20 MR. SABETTA: Objection to form. 21 Q. Withdrawn. Why was it only marketed for a 22 year in Japan? ' 23 A. It was decided that in the face of these 24 reports that were coming in regarding the environment 25 and the plan within Monsanto' to start phasing out that Gateway Reporting Associates, Inc. WATER PCB-SD0000070964 Gateway Reporting Associates, Inc. 180 1 it was prudent not to market PCBs in Japan any longer. 2 Q. Did the Japanese government pass a ban on 3 marketing and manufacture of PCBs? 4 A. No. 5 Q. They did not? 6 A. I1m sorry? 7 Q. They did not? 8 A. They did not. 9 Q. Are PCBs still sold in Japan? - 10 A. The last I knew, yes. 11 Q. Who sells them? Do you know? 12 A. Kanega Fuchi. " 13 Q. Does Monsanto still sell them in Japan? 14 A. Sell what? 15 Q. PCBs . 16 A. Monsanto doesn't make any PCBs. 17 Q. What did -- After the discontinuance of the 18 marketing of PCBs by Monsanto in Japan, what did that 19 plant do? 20 A. I do not know. 21 Q. Do you know when Monsanto found out about 22 the Yusho incident ? 23 MR. SABETTA: Objection to form. 24 Q. Withdrawn. Did Monsanto find out about the 25 Yusho incident? ' Gateway Reporting Associates, Inc. WATER PCB-SD0000070965 Gateway Reporting Associates, Inc. 181 1 A. Yes.Eventually they did. 2 Q. And when was that? 3 MR. SABETTA: Objection to form. 4 A. I personally don't know when they found 5 out . 6 Q. When you started work in your job in 7 January of 1970, did Dr. Kelly and Mr. Wheeler know 8 about Yusho? 9 A. Yes. ' 10 Q. What did they tellyou about it? 11 A. They reported to me about the incident and 12 what they knew about it at the time. 13 Q. Did they tell you how long they had known 14 about the incident? 15 A. No. That never came up in their 16 discussion. 17 Q. Did you get any articles or journals or 18 literature or materials on Yusho in your notebooks? 19 A. I recall seeing a column article, but I 20 don't recall whether it was in that notebook or brought 21 to my attention later on in 1970. 22 MR. McDONOUGH: Could I have that answer 23 back, please? . 24 (Whereupon, the reporter read back witness' 25 answer.) " Gateway Reporting Associates, Inc. WATER PCB-SD0000070966 Gateway Reporting Associates, Inc. 182 1 Q. When you say "column article," are you 2 referring to a newspaper article? 3 MR. SABETTA: Just let him finish the 4 question before you answer. 5 A. It's similar to a newspaper column, but 6 that same kind of column appears in trade journals. 7 Q. What did Dr. Kelly and Mr. Wheeler tell you 8 about Yusho when you had your tutorial with them in 9 January 1970? ' 10 A. They mentioned that rice bran oil was 11 consumed by people in a certain locale. The individuals 12 who consumed it had some health problems, and they were 13 determined to have consumed an oil contaminated with 14 PCBs, and the PCBs got into the oil because of a leak in 15 the system where a PCB used as a heat transfer fluid 16 leaked into the oil that was later sold. 17 Q. Did they tell you in this tutorial in 18 January of 1990 that there was any involvement of 19 dibenzofurans with respect to that Yusho incident? 20 A. No. There was no inkling as to what could 21 be causing the health effects that were noted at that 22 time . 23 MR. SABETTA: If you have other questions 24 on this subject, I'll let you ask them, but I was going 25 to suggest maybe it would be" a good time to break for Gateway Reporting Associates, Inc. WATER PCB-SD0000070967 Gateway Reporting Associates, Inc. 183 1 the day because I don't want to push him too long on the 2 first day. If you want to finish up - 3 MR. McDONOUGH: What time is it? 4 MR. SABETTA: It's a little after 5:00. 5 Q. Why don't I finish with this exhibit 6 anyway. Do you feel okay? 7 A. Yes. 8 Q. I've only got about five more questions. 9 Who is this Mr. Kuhn referred to in this 391?' 10 A. - He was the Monsanto employee, a member of 11 the industrial fluid business group that was responsible 12 for manufacturing of the chemicals sold by that business 13 group. 14 Q. Was Mr. Richard Mr. Kuhn's boss at that 15 time? 16 A. No. They are peers. 17 Q. The next paragraph on page two says, "I 18 believe we should make sure that our plants have minimum 19 air or stream pollution. I believe Anniston is 20 vulnerable and that off-gas HC1 and Aroclors should be 21 100 percent controlled. Krummrich may also need help." 22 Do you know what he's referring to there? 23 A. Not really. . 24 Q. Do you know if Mr. Richard is a lawyer? 25 A. No. He's a research director. Gateway Reporting Associates, Inc. WATER PCB-SD0000070968 Gateway Reporting Associates, Inc. 184 1 Q. The next paragraph -- I'm sorry. 2 A. Go ahead. 3 Q. The next paragraph says, "I believe we 4 should demonstrate that Aroclor can be incinerated to 5 harmless products for disposal." Do you see that? 6 A. I do. 7 Q. Do you know whether Aroclor was ever 8 demonstrated to be incinerated to harmless products? 9 A. Yes. 10 Q. Do you know whenthat was? 11 . A. That was done in March of 1970. 12 Q. And do you know what particular employee of 13 Monsanto was involved in that project to determine if it 14 could be incinerated to harmless products? 15 A. Well, I was involved. Scott Tucker, the 16 analytical chemist, was involved. And I'm trying to 17 think of the individual from Monsanto's corporate 18 engineering department who was responsible for the 19 design and selection of the equipment. 20 Q. How was it determined that the material 21 could be incinerated to harmless products? 22 A. There were some preliminary studies made in 23 the laboratory, small amounts at which temperatures 24 could be controlled and measured, and the gases that 25 were released from this incineration could be captured Gateway Reporting Associates, Inc. WATER PCB-SD0000070969 Gateway Reporting Associates, Inc. 185 1 and analyzed. That information was passed on to the 2 designer of the incinerator, and he had a test unit 3 built that was demonstrated to be capable of doing what 4 was performed in the laboratory. . 5 Q. Do you know if Dr. Keller's analytical 6 group participated in that particular demonstration? 7 A. Scott Tucker represented that group. 8 Dr. Tucker. 9 Q. In the last paragraph it says in- the 10 next-to-last sentence -- Well, I'll read the whole 11 paragraph. "We probably have six months to one year 12 while they fight out the DDTcase. Iwantto use this 13 time to minimize our exposure. We willneed your help 14 in setting TSD targets." Do you see that? 15 A. Yes. 16 Q. Do you know what TSD targets means? 17 A. That is a department back at the plants, 18 and the letters stand for Technical Services Department. 19 Q. Do you know if TSD targets were set? 20 A. Oh, yes. 21 Q. Who set them? 22 A. Well, the level of exposure to employees 23 was set by this American Congress of Governmental 24 Industrial Hygienists. Now, all of this doesn't happen 25 overnight. This evolved. The amount in water was set Gateway Reporting Associates, Inc. WATER PCB-SD0000070970 Gateway Reporting Associates, Inc. 186 1 at ten parts per billion, which was the level that 2 Dr. Tucker and Dr. Keller felt was measurable and 3 reproducible. That kind of thing happened. 4 Q. There was a Technical Service Department as 5 I understand it at Monsanto at this time? 6 A. At each plant. At the Anniston plant, at 7 the Krummrich plant. 8 Q. And the head of that Technical Service 9 Department was at each one of those plants? ' 10 A. Yes. 11 Q. Who was at the Anniston plant that headed 12 it at that time? 13 A. I can see his face, but I can't remember 14 his name. 15 Q. Well, let 's save his face until tomorrow. 16 (Deposition was adjourned to be continued 17 to April 28, 1999 at 9:: 3 0 a . m . 18 19 20 21 22 23 24 25 Gateway Reporting Associates, Inc. WATER PCB-SD0000070971 Gateway Reporting Associates, Inc. 187 NOTARIAL CERTIFICATE STATE OF MISSOURI CITY OF ST. LOUIS ) ) -I, FAITH A. OLLIGES, a Registered Professional Reporter and a duly commissioned Notary Public within and for the State of Missouri, do hereby certify that there came before me at the offices of Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri, WILLIAM B. PAPAGEORGE, P.E., who was by me first duly sworn to testify to the truth and nothing but the truth of all knowledge touching and concerning the matters in controversy in this 'cause; that the witness was thereupon examined under oath and said examination was reduced to writing; that the signature of the witness was not waived by agreement of all parties, and this transcript is a true and correct record of the testimony given by the"' witness . I further certify that I am neither attorney nor counsel for nor related nor employed by any of the parties to the action in which this deposition is taken; further, that I am not a relative or employee of any attorney or counsel employed by the parties hereto or financially interested in this action. IN WITNESS WHEREOF, I have hereunto set my hand and seal on May 3, 1999. My commission expires March 21, 2001. Notary Public Gateway Reporting Associates, Inc. WATER PCB-SD0000070972 STATE OF NEW YORK SUPREME COURT: COUNTY OF BROOME JAMES L. and BARBARA A. FURCH, RICHARD F. and ) KATHRYN S. GARDNER, GERALD E. and LINDA O'NEILL, WILLIAM G. and HELEN STAUB, JAMES F. and KATHLEEN SNYDER, GEORGE S. and BARBARA L. ) ) ) ROGALAVICH, JACK L. and DOLORES P. MEDOVICH, JAMES S. and JOANN M. MCLAUGHLIN, GERALD F. and PATRICIA TITA, PAUL M. RYAN, JOHN G. and VIOLA J. DONNELLY, DAVID V. and CANDICE DeVIGILI, JOHN F. and ALBERTA CASEY, JAMES A. and ROSEMARY COLGAN, PAUL B. HORNICX, JOHN P. and ) ) ) ) ) ) MARY ELLEN WHALEN, CHARLES E. DEARBORN, GERALD F. ) and CAROL MULLINS, JAMES B. and DONNA MAHAR, BRIAN P. and MICHELLE O'LOUGKLIN, DONALD C. and ) ) KIM EDWARDS, RONALD L. and BAREARA McMAHON, BERNARD A. and SHARON MASSAR, WILLIAM F. and ) ) MARY ANNE KOZEL, ANTHONY J. ana EDITH WINKLER, ) TIMOTHY E. and DOROTHY M. KOLOSKI, RICHARD J. and RITA ANN KINNEY, RONALD E. and CAROLYN A. HOWE, CLIFFORD C. and NADINE COLGAN, THOMAS M. BUTCHKO, DONALD T. and JACQUELINE FOLEY, MARIO A. and MARIE E. PIROZZI, ROGER E. and GAIL JULIAN, ) ) ) ) ) ) Plaintiffs, ) -vs- ) ) ) GENERAL ELECTRIC COMPANY, NEW YORK STATE ELECTRIC ) & GAS CORPORATION, MONSANTO COMPANY, THE DOW ) ... CHEMICAL COMPANY, BEC ELECTRIC CO., INC., JOHN B. ) CUMMINGS and GEORGE H. PASH, JR., d/b/a CUMMINGS ) AND PASH, PHILLIPS L. ST. JOHN, HOWARD 0. WARD, )' EDWIN C. GENT, AND STEPHEN JONES, III, d/b/a ST. ) JOHN ASSOCIATES, ST. JOHN ASSOCIATES-ENGINEERS, ) and VINCENT J. SMITH, INC., ) .) Defendants. ) ACTION #1 Index No. 137082 . WATER PCB-SD0000070973 EDWARD MOSHER, MADALYN MOSHER, THOMAS KRESS, SUSAN KRESS, CHARLES SIMONS, ROSE SIMONS, JAMES E. NEISS, BETTY NEISS, and GARY M. O'NEILL, . Plaintiffs, -vs- GENERAL ELECTRIC COMPANY, NEW YORK STATE ELECTRIC & GAS CORPORATION, MONSANTO COMPANY, THE DOW CHEMICAL-COMPANY, BEC ELECTRIC CO., INC,, JOHN B. CUMMINGS and GEORGE H. PASH, JR., d/b/a CUMMINGS AND PASH, PHILLIPS L. ST. JOHN, HOWARD O. WARD, EDWIN C. GENT, AND STEPHEN JONES, III, d/b/a ST. JOHNASSOCIATES, ST. JOHNASSOCIATES-ENGINEERS, and VINCENT J.SMITH, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ACTION #2 Index No. 137081 DEFENDANT MONSANTO COMPANY'S RESPONSE TO PLAINTIFFS' INTERROGATORIES COMES NOW the defendant, Monsanto Company (hereinafter "Monsanto"), and for its response to plaintiffs' interrogatories, says as follows: GENERAL OBJECTIONS AND LIMITATIONS 1. Monsanto objects to any and all interrogatories to the extent that they seek privileged communications or attorney work product protected from disclosure under CPLR, 3101 and 4503 of the State of New York. 2. Monsanto objects to any and all interrogatories to the extent that they seek confidential, financial or business informa tion without the protection of an acceptable form of stipulation and protective order adequate to preserve the confidentiality of such information. -2- WATER PCB-SD0000070974 A MEMO OF DATA TRANSMITTAL GENERAL (S ELECTRIC COMPANY March 22, 1971 MEDIUM TRANSFORMER DEPARTMENT ' (date) ROME, GEORGIA CUSTOMER General Electric Supply Company Rfr to G.E. Req'n No. In Correspondence STATION OR PROJECT NO. CUSTOMER ORDER CUSTOMER REQR 7150-027268DX PRINTS ARE: FOR APPROVAL X X M FOR INSTALLATION | GJL CONTRACT | FOR REFERENCE Gi UQUIvnOM 306-36351 APPROVAL REQUIRED BY---------------------- ----(DATE) RETURN OF "FOR APPROVAL" PRINTS SHOULD BE ADDRESSED TO THE GENERAL ELECTRIC OFFICE WtTH WHOM YOUR ORDER IS PLACED. --NOT TO THE FACTORY-- Drawings are intended to oe in accordance with applicable purchase order specifications. Comments are solicited concerning any departures in this respect. Features not covered by purchase order specifications portray General Electric Company standard design practice. The' shipping date for this equipment is based on obtaining approval by the above specified date, and any delay in approval may extend the shipping schedule. Any requested changes from the purchase order specifications, resulting in additional engineering ond/or manufacturing costs, will entail an increase in price and the extension of the shipping schedule. Prints to: . 10- Bee Electric Company, P.0. Box 41, Easrwood Station, Syracuse, New York 13206 1- Carl Larrabee, Syracuse Office 1- I&SE, Syracuse Office 3- Roy Raymond, DAD, hainvrille Works 3- Bill Olashaw, DAD, Plainville Works 0A/FA-T-60-3750/4687(65)-12470-480Y/277 Transformer (Indoor) Outline 104D9219, Sh, 1 & 2, Rev. 3 Supersedes 104D9219, Sh. 1 & 2> Rev. 2 Previously Mailed Conn-JOr-agram 149B9105BA rAlatneplate 175B7682 gB00464 JOB NUMBER: 53Aq52577 PAINT: PEARL GRAY ANSI-61 OUTLINE TO: MARKETING SHIPPING LARGE ENG. SMALL ENG. MS TO PRODUCTION COPY OF GA--4A Mt a_/aSi t TO f ' PRINTS ARE NOT TO SCALE, or# loaned subject to return upon demand, and the express condition that they will not be used in any way detrimental to the General Electric Company. "T el REPRODUCTION UNIT WATER PCB-SD0000070975 I JN NB I i-l i__ !__ I__ L I 1 ( -i 1 I- u 2 X< Iu-- LzU uo i5 UJ J Cm SE J* tiS ON' VW) 1111 IN 'n ||z __ Os v<f<>OD S $ > 11 Ho CHS SCHE M,RETRA(t UJ 6, 88 < J - 6.25" 0w. < 7. PYRANOL TRANSFORMER NO. ________ CLASS OA/FA THREE-PHASE 60 HERTZ VOLTAGE RATING 12470 - 480Y/277 KVA RATING 3750 CONTINUOUS 65 C RISE SELF COOLED KVA RATING 4687 CONTINUOUS 65 C RISE FORCED AIR - IMPEDANCE VOLTS % 12470- 480Y VOLTS AT 3750 KVA i P-i D E S IG N E D F O R N O M IN A L . IM P E D A N C E V O L T 'S O F 5 7 5 %. *cTvj o o L V WINDING LIQUID LEVEL BELOW TOP SURFACE OF HIGHEST POINT OF MANHOLE FLANGE AT 25 CIS 6, SO INCHES. LIQUID LEVEL CHANGES ,52 INCH PER 10 C CHANGE IN LIQUID TEMPERATURE. ` MAXIMUM OPERATING PRESSURES OF LIQUID PRESERVATION SYSTEM 7.5 LBS POSITIVE TO 5 LBS NEGATIVE. TANK SUITABLE FOR 7.5 LBS VACUUM FILLING. APPROX. WEIGHTS IN POUNDS TOTAL 33300 UNTANKING 13000 TANK AND FITTINGS 6500 PYRANOL I060__GAL AI3B3B " 13800 NP I75B76Q2 CAUTION! BEFORE INSTALLING OR OPERATING READ INSTRUCTIONS . ffivaota nra uy., 0,, a,! j WATER PCB-SD0000070976 Oct 29, 1935 r. m, cuawk _ OIELECTRJC COMPOSITION fil*d Jan, IS. 1934 2,019,338 T\, Z. \ gil namrnnnifgjgsy. fA WrMmi,"y. 10f"m ) Inventor: Frank M. Clark, joy Ji&vujS. His Attorney. GEB00078 \iiyipifflBiniHiwiH1 juuj-jMliwiv^impji|ig^iaiyii^uii||iiijimmimi frTy.jpw} i jiuhji 1 PLAINTIFF'S DEPOSITION s- EXHIBIT !....37% ' WATER PCB-SD0000070977 ' ,n P&taatsd Oct 29, 1835 UNITED STATES PATENT OFFICE U1MU DmxcTajc composition hMi M. CUrt. ntuflrid, Km, iMiner P Gtmwai Klaetrte Company. a oar9*ntla at Km Tut A**UaUe<i Juw; I, 11S4, BtfM Na. 7M4U I Claim*. (0.351--1) Thu present Invention relate* to halogenated organic compaaltian* comprising wholly or In part unsaturated compound, 0j the olefin type, *uch compositions being ruiuhle tor use u dlciecI trie material* in electrical devices, uch M Crana- lormerj. capacitors, rwitches, and the like. A* deocribed in my prior United States Patents 1.831,373 and 14131,435, both Issued October 17, 1833, It 1* advantageous to employ In electrical dr13 ylcei a dielectric material comprising one or more liquid halogenated hydrocarbons containing a sufficiently high proportion of halogen to insure noa-lnflammablllty of suen gases as might be erolved by decomposition of a dielectric by an U arc or otherwise. Heretofore only halogenated aromatic hydrocarbons have proved to be suffi MciBently stable for this purpose. I have discovered that the chemical Instability retofore experienced with dielectric materials 20 comprising aliphatic halogenated compounds is associated with the chemical saturation of the carbon atom to which the halogen Is chemically attached, or. in other words, that chemically Cdtuntea carbon atoms possess an electronic cen ts ditlon which results in increased reactivity of the combined halogen under the conditions exist ing in an electrical device. I have also dis covered that, it the halogen atoms instead of being attached to a chemically saturated carbon are so attached to chemically unsaturated carbons, then in such case the h&lofenated compound lx stable as a dielectric material under the normal operat ing conditions of electrical devices. I have found that the chemical stability re ts suiting when the halogen atom u attached to a chemically unxaturatcd carbon appears to be olosely related to the electronic condition of the carbon atom of halogenated beaten* compounds characterized by similar chemical stability. 40 Aliphatic compounds which I have found to possess unlooked-for chemical stability are the #.halbgenated derivatives of the olefins, such, for example, a* the chlorinated ethylenes or propyl enes containing the chlorine atom or atoau at45 tached to the uhsaturated carbon or carbons, and also cyclic or aromatic derivatives of such com pounds with or without halogen substituted In the aromatic nucleus in addition to the halogen on the nieftnir carbons. The Introduction of the 50 aromatic group doe* not affect the chemical sta bility of the chlorine atoms chemically united to tha tinaaturated carbons. Chlorinated ityrolene and chlorinated divinyl benrenc cun tain - ' In* the chlorine atom* either attached to the un it saturated carbon* of the aromatic group or the olefin group are further illustrations of chemically stable halogenated olefin derivatives. If a ma terial Is desired which not only is non-inflammable in itself nut which under decomposition far any mason shall evolve only non-inflammable gases, j It Is necessary to introduce sufficient halogen into . the molecule that it contains an amount of halogen at least chemically equivalent to the amount of hydrogen present. Dielectric compositions Included in the present jo invention also comprise mixtures of one or more halogenated olefins and one or more halogenated aromatic hydrocarbons, such, for example, as mixtures of a chlorinated olefin and chlorinated diphenyl or chlorinated benaene, or both. 15 The accompanying drawing shows in Tig. 1 in side elevation and partly in section a trans former containing a halogenated olefin dielec tric composition and Pig. a is a graph showing the depression of point or congealing temperature r*- jp suiting when a halogenated cyclic compound is mixed with a halogenated olefin. The term "olefin" has been used herein to de scribe the compounds of a class which X have found to poasess chemical stability, including 25 both (1) the aliphatic compounds having the general formula CiH containing unsaturated carbon* and (3) substituted aliphatic compounds having the general formula CnHm--Ar, con taining unsaturated Carbons in the molecule in 30 which an aromAilc group, <Ar> (or groups, Ar) have been substituted for hydrogen. The aro matic group may be a phenyl group, or a con densed group, luch aa the naphthalene group, or a polyphenyl group such as the diphenyl group. 35 The term "halogenated olefin" is to be under stood a* limited to those compounds in which the halogen atom Is attached to an unsaturated carbon either of the olefin group itself or of an aromatic nucleus. *Q The liquid halogenated olefins possess also a viscosity which easily adapts these materials to dielectric purpose, especially In apparatus such as transformers, where low viscosity is demand ed for thermal reasons. Trichlor- or tetrachlor- 45 ethylene art examples of halogenated liquid ole fins suitable for dielectric use. These material* are inert and without corrosive action to metals present In electrical devices. These materials have a vtscoslty of about 30 seconds S&ybolt uni- so versa! and show little change In viscosity over a range of temperature*. The electrical charac teristic* of theae materials are good. The dielec tric strength, tested In a ,1" disc electrode gap, give* a value higher than 30 kilovolt*. The di- 54 GEB00079 r : 11 / t WATER PCB-SD0000070978 a 9,018,338 electric conatant of approximately 3.3 and the power factor of leu than 1% t IDOO cycles. 25' C, coupled with ft characteristic resistivity of about 1 * 1011 ohms per centimeter cube ftt 500 volt* I D, C., Buies these materials particularly welW adapted for general dielectric application In thwiafarrocri, circuit breakeri, capacitor*, cables, and tha like. The transformer ihown In Jig, l conititutea 10 one example of an electric*) device in which a liquid dielectric embodying my invention my bo used with advantageous results. A* well known, a transformer comprise* a Lank I containing a magnetic core I and electrical windings J. For 13 the sake of simplicity only a aingla terminal 4, provided with an insulator I haa been shown, this terminal being connected to one of the windings by a conductor I. Mounted on the cover 7, to gether with the terminal 1* condenser 5, providga *d with a Jacket i through which a cooling fluid may be circulated to condense vapors evolved from the body of dielectric material I*. Inlet and outlet ducts II, 12 art provided for the cool ing fluid which conveniently may consist of water. it To rendtr the drawing simple and to Indicate that Its height may be varied the condenser has been shown as broken. It la to be understood that the condenser has been indicated conventionally a* representative of any one of various types so of condensers either air-cooled or liquid-cooled. Halogenated olefins have a relatively low hail ing point or In other words a high volatility, For example, dlchior ethylene, CiHjCh. u a liquid which boils at about 55* C., trtchlor ethylene, 38 CiHClj. It a liquid which boll* at about 87 to 88* C,, alpha trichlor propylene, CiHsCb, is a liquid which boils at about 115* C,, and tetrachlor ethylene is a liquid which ball* t about 120* C, Vapors evolved from such compounds during the 40 operation of a transformer or other electric de vice are condensed to the liquid state in the con denser and returned to the main body of the cooling medium. The necessity of using a condenser may be 43 eliminated by the use of a substituted halogenated olefin, the molecule of which contains *n aromatic nucleus. Thus although synthetic dichlor ethyl ene bolls it 55* C.. the introduction of the ben zene nucleus results In dichlor styrolene, or jo styrene, <CiH.CCl:CHCU a product which boils at 221* C. For many electrical purposes the use of a halogenated olefin containing a substituted aromatic nucleus therefore Will be more advan tageous. 88 Many of the halogenated olefins possess a rel atively high congealing point which tends to reitrlct their use for dielectric purposes, a* already Indicated, a lower congealing temperature (paur point) may be secured by compounding the h*Jo80 genated olefin with a halogenated aromatic com pound at the type represented by a halogenated benzene, a halogenated polypheoyl, euch as hal ogenated diphenyl, or the halogenated deriva tives of diphenyl ketone, diphenyl methane, di08 phenyl benzene, or diphenyl oxide or with halo- genated naphthalene, a halogenated compound containing condensed nuclei. For moat purposes chlorine compound* are to be preferred over com pound* containing bromine or other halogen*. 7Q A* an UUuitration of the characteristics of such blended compositions, I cite the case of tetrachlor ethylene compounded or mixed with pentachlor diphenyl as an example of a chlorinated palyphenyl. In Fig. 2 is Indicated the extraordinary and unexpected decrease In pour point of liquid compoaitiom resulting In *uch case. The pour point* or congealing temperature* are plotted here at ordinates and the percentages of halo genated diphenyl os absciss*. In the specific case here taken, the diphenyl compound la the tech nical pentachlor diphenyl which Itself Is a vis cous material having a pour point of ahout +10* C. Tha pour points were determined by the standard methods adopted by the American So ciety for Testing Materials. As pentachlor di 10 phenyl Is present in increasing amounts In the mixture (accompanied by a corresponding de crease of tetrachlor ethylene), the pour point of ^ the mixture drops to a value lower than --50* C This extremely low pour point Is found in a mix- W* ture made up of equal parts by weight of tetra chlor ethylene and pentachlor diphenyl. As Indi cated by dotted Unea the exact pour point of the 50:50 mixture was not determined experimental ly because of the difficulty of working at such low to temperatures. The viscosity of such a mixture is not materi ally different from the viscosity of the pure tetrachlor ethylene alone, being 30 seconds Say- bolt universal at 37.8* C. Under the same lest- 28 lng conditions tetrachlor ethylene has a viscosity of 28 seconds Eaybolt. Pentachlor diphenyl ho* a very high viscosity. At the commonly used testing temperature at 37.8* C. the viscosity of pentachior diphenyl Is 1200 seconds Saybolt uni JO versal. ` Such mixed halogenated products constitute a m&teriai particularly well adapted for use in ap paratus exposed to low temperature conditions. Other mixtures of chlorinated olefins and chlor 3d inated cyclic compounds are characterized by ex traordinary low congealing temperatures. The pour point of a mixture of 25% by weight oijff* more of trtchlor ethylene and 75% or less dr*"* pentachlor diphenyl is lower than --80* C. The ao vlscoiity of the 50:50 mixture u about 34 sec ond* Baybolt universal. While I have Illustrated my invention with particular reference to chlorine as a particular halogen la products embodying my invention, products containing other halogens are not pre cluded and such products are to be considered as being included in the present invention. The term '`olefin" Is used heroin to designate ordinary form* of such compounds as distin- SO guixhed from solid resinous olefin polymerization products such as described In Clark and Kutz U. S. Patent 1,998,309 of March 16, 1935. Halogenated olefin products In many cases con be advantageously compounded with an oil, either a hydrocarbon oil, far example, a petroleum all; or a glyceride oil, for example, castor oil, In some Industrial fields, an admixture of a halo genated product, such, for example, as trtchlor, or tetrachlor ethylene, renders an oil better suited so for its purpoees while at the same time rendering it less inflammable. For most purposes the oU.^ should be In a preponderant proportion by vol ume in the mixture. Although I have herein re ferred mainly to dielectric and cooling uses of w composition* embodying my invention, other uses, such as use far lubrication, are not to be excluded. What I claim as new end desire to secure by Letter* Patent of the United States, Is; TO 1. A dielectric composition containing a halo genated olefin, in which halogen is attached only to unsaturated carbon, and a halogenated aroma tic hydrocarbon m nibstantlal ingredients. 2. A dielectric composition, a substantial pro- jj GEB00080 "py fijwi'iumiiiip 'Biliiiti j. wyi \ 'i u mwi qtauiJ' - -- |- I* -- - -- I fr *11 - - - 1 Ur dr I li --- ---- --V----- 1 *~1 * >u \ WATER PCB-SD0000070979 % 1,011,111 3 ' portion of which eooaiau at tricolor athykns &ai chlorinated diphaoji. S. a .dielectric oompodlUon caoUioinx Utra- .chior aihyieoa end a chior polypheny] u mb lUrnUal ihgrrdicnU, 4. A dieioculo ooBipotiuan coetaintn* ubitahtiai amount* of tatrachlor athylen* and pepUchior diphenyl. A. A ooaipetition of matter containing mb* Ifl rtantlal proportion* of a haioen*t<d olefin com pound containing an aromatic xtqup and a iub atantlai proportion of bnJoqemted cyclic hydro carbon compound. I. A oomportion of matter containing a tub- rtantiai proportion of halogeuated ityrolene and a luhatantlal proportion of fialoqenated poly pheny] compound. t. A compoatiap of matter coeUininj aa aub- $ atantui ingredient* chior olefin and chior poly phony!. I. A liquid ccmpoainoQ uitabl for UmiJaUn# uu in electrical apparatua cempruin* aa aub- atantlil Ingredient* liquid chior ethylene and 10 chior polyphenyL , TfU.UK UL CLARK. I r UET- ,i `lj p & itf i WATER PCB-SD0000070980 viyil THE JOURNAL OF INDUSTRIAL HYGIENE (AND TOXICOLOGY) KWT? VOLUME 19 JANUARY, 1937--DECEMBER, 1937 FUBL1SHED BY . : THE WILLIAMS & WILKINS COMPANY Baltimore, Md. " *< Z PLAINTIFF'S DEPOSITION EXHIBIT mO co o NJ GJ O CD WATER PCB-SD0000070981 THE JOURNAL OF INDUSTRIAL HYGIENE ! ' -W: Volume 19 AND TOXICOLOGY SEPTEMBER, 1937 NuMBEB 7 THE PROBLEM OF POSSIBLE SYSTEMIC EFFECTS FROM CERTAIN CHLORINATED HYDROCARBONS* v: Cecil K. Drinker, Madeleine Fdeld Warren and Granville A. Bennett Department of Phyrioloqy, Harvard School of Public Health and Department of Patholopg, Harvard Medical School, Bottom, Mat*. HE use of chlorinated naphtha rapidly and thoroughly as possible.! Tlenes and compounds of allied pharmacological possibilities ia In brief these cases were as follows: Patient I. Male, age 21. The preriotu extremely wide, and with the steamdeydical history of thia mao was in no wijr growth of the use of electricity is cer significant except for the fact that he had tain to expand much farther. For years it has been known that many of these compounds cause a troublesome acne, and there is a large literature upon this phase of the subject. Our an attack of jaundiee about 6 weeks prior to hie fatal illneaa. Late in December, 1236, he became badly constipated and had much abdominal pain and distention. When ad mitted to the hocpital he was (lightly jaun diced and waa evidently very ill. He was investigations have not been concerned with chloracne but with the possibility - of systemic effects following ingestion or inhalation of such products. In the somewhat anemic and his (ldn, particularly upon the ara(, face, cheat and back, showed many pustules. He died after a brief period in the hospital, and at autopsy waa found to spring of 1936, the Halowax Corpora : tkm, a division of the Bakelite Cor .. poratkwi, called our attention to three t The Halowax Company makes many products besides chlorinated naphthalenes, and it has come to our knowledge that all of these products are indiscriminately called '`halowaxee" by purchasers and users, and rasing chlorinated naphthalenes and ;; {^derinated diphenyl, and requested Aat the subject be investigated aa acne and even of systemic disease. Bines "halowax" is merely a trade designation, care should be taken to describe compounds by their chemical names and thus avoid condemnations which are both troublesome and misleading. im ,r rfkJ. Ti m mi. m o WATER PCB-SD0000070982 284 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [SPt. art bsve a cirrhosis of the liver with acute yel low atrophy luperimpoeed upon it. Thia man had been exposed to low concentration! of vapora arising from a mixture of tetra and pentachlomaphthalenei, together with approximately 10 per cent of a refined chlo rinated diphenyl. While both he and othen engaged in the tame work had ehloracne, there were no other disturbances of health in fellow workmen, nor was there any pre cipitating cause for the acute yellow atro phy such as treatment with arsphenamine or exposure to dangerous concentrations of carbon tetrachloride. Patient t. This wbj a young man who died in February, 1938, after an acute illness characterised by jaundice. He had been exposed to fumes arising from a mixture of penta and hexachlomaphthalenes. There is no record of ehloracne. The patient worked with a large number of other people of whom but one (Patient 3), a close friend, had significant illness. Patient S. Another young man employed with Patient 2. He became jaundiced in March, 1936, and died after an illness of 3 weeks. A careful autopsy resulted in a diagnosis of acute yellow atrophy of the liver Here again no history could be ob tained as to a precipitating cause, and there was no record of preceding attacks of jaundice. In addition to these three very re cent fatalities, we have learned of four other possible cases, none of them fatal. All of these have had jaundice and the entire group consists of iso lated individuals who have been picked out of large groups having the same exposure. In but one instance, Pa tient 1, in there record of antecedent disturbance of health, and the general health of fellow workers has been good. 8uch cases have not been reported in the medical literature and only occa sionally can one find reference to sys temic effects of any sort For exam ple, Courtoia-Suffit (1934) reports on work done by Touraine and his asso ciates (1934) who examined 60 workers who had been exposed to trichlornaphthalene. Of these 13 were found to have mild digestive complaints, anorexia, nausea and vertigo, but Courtois-Suffit remarks finally, "Ab sorption is certainly possible and we have for proof of it some of the diges tive and general complaints which have been due to it. But they appear to be of little consequence considering the mildness of the digestive troubles and the absence of respiratory phe nomena." In Touraine's cases the exposure was to a trichlomaphthalene, whereas the American cases of acute yellow atrophy were exposed to compounds of higher chlorination. Our own experiments indicate that trichlomaphthalencs re quire enormous dosage, far beyond anything encountered in industry, in order to produce liver damage. Teleky (1927) reported a number of cases of ehloracne in persona exposed to chlorinated naphthalenes with a chlo rine content ranging from 14 to 53 per cent. He found that the lower the chlorine content the less the acne. MittelstSdt (1935)'examined a number of cases of ehloracne due to trichlornaphthalene and reported a number of vague general complaints but nothing in the nature of serious disease. Re garding his animal experimentation, Lehmann (1919) reported that ani mals fed chlorinated naphthalenes re fused to eat after a time and that, whether poisoned by inhalation or by feeding, at death showed "peculiar" lesions in the liver. Flinn and Jarvik (1936) gave subcutaneous injections of enormous doees of chlorinated naph thalenes dissolved in paraffin oil to rabbits. The compounds used were as follows: m >' I WATER PCB-SD0000070983 EFFECTS OF CHLORINATED HYDROCARBONS V'.*- M/`ifVy Hr 'St- A mixture of tri and tetrachlornaphthalene. 2. A mixture of tetra and penta- chiomaphthalene. 3. A mixture of penta and hexa- chlornaph thalene.. In addition, sublimated from (2) and (3) were collected in oil and injected subcutaneously. None of the animals receiving (I) or the sublimate from (2) died, and even after 2 months were quite normal when autopsied. The first death in the ani mals receiving (3) occurred on the 12th day and the last died on the 26th day. Those receiving the sublimate from (3) were even more severely affected. Autopsy in these animals revealed striking changes in the liver, not, as described, entirely characteristic of acute yellow atrophy but sufficiently saggestive to cause the authors to con clude that "certain chlorinated naph thalenes or impurities contained in them are capable of producing yellow atrophy of the liver in the rabbit." At the beginning of their paper, Flinn and Jarvik (1936) mention the fact that there have been three cases of acute yellow atrophy of the liver in men working with chlorinated naph thalenes but give no details in regard to them. These cases are undoubtedly the same as those described in the beginning of this paper. One may summarise the meagre literature upon systemic effects from these substances as follows: t. 1. With the exception of the men tion of acute yellow atrophy by Flinn 'and Jarvik (1936) there are no reports or even suggestions of serious effects Upon human beings. 2. There is evidence (Teleky, 1927) . that the degree of chlorination is sig nificant in relation to the production of acne. In the work of Flinn and Jarvik (1936) the compounds produc ing serious liver injury were the most highly chlorinated of those tested, though the chlorine contents as given by analysis vary surprisingly little. 3. There are no published figures upon the amounts of various chlorin ated naphthalenes in the air which will produce injury of any sort, and while the work of Lehmann (1919) and of Flinn and Jarvik (1936) point to the liver as a possible site of injury this indication rests upon such extreme dosage as to fail to apply directly to human exposure. Experimental Work In appraising the possible toxicity of any substance met in industry it is first necessary to determine the prin cipal route of absorption. In the case of the compounds under consideration there can be no doubt that inhalation is their chief means of entering the body. They are used hot in a) great variety of operations and volatilize in varied degree. They are often applied in solution in such volatile solvents as carbon tetrachloride and toluene. The amounts reaching the air under such circumstances are hardly detectable. It will however be shown that carbon tetrachloride adds to the toxicity of the chlorinated naphthalenes and allied compounds, and if there is possibility of inhaling these compounds in other parts of the factory then inhalation of carbon tetrachloride adds a decided hazard. Under such circumstances solvents such as toluene should be used. Observation in a number of plants causes us to feel that even though WATER PCB-SD0000070984 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY 1-SVpr. ;.otr workmen may be ext remely: dirty and careless, comparatively little of these waxes is eaten. They are tenacious substances, insoluble in water, and if they get on the hands they stick there and are not transferred to the food. Skin absorption is the third possible means of entering the body. It may occur but at best must be slight when compared to the steady inhalation of finely divided or gaseous material in the air. tion. They thrive upon a diet very similar to man, and in the case of thv>r chlorinated compounds it is puv<ili|ithat diet may be very significant. Finally, their normal charactcrb'ies have been described so well as to make the detection of abnormalities 1 x>th easy and certain. Method of ejpoture.--The inhalation experiments were carried out in four large air-tight wooden boxes, en!i capable of holding ten rat cages, -i* iai. 19, nc ing the 'meter we the Row, could be from a deflector pipe into sure a i stream of At the outflow e *as exha fitted wit a large cc About Lbs 7-inch of fihe si ducied ini _cially de (figure 4), diameter . hold the ! were mad that exte .top of the 'this fitted length. 1 j^'.into a larg tightly inti pipe on thi flask in tu heater ma below the top. Rub side arm v __voir and a j'Abrough tl motion am ^ Into each fl ^centigrade .kept in pla time abov< *rhich it pa Approxm 'ihlor'r" mQ CD o Aj CO *--V O WATER PCB-SD0000070985 voi. If, no. 7j EFFECTS OF CHLORINATED HYDROCARBONS 287 ing the end of the box. An orifice meter was placed in the pipe line, and the flow of air in cubic feet per minute could be adjusted and read ofT directly from a calibration curve. A vane deflector placed at the entrance of the pipe into the box was adjusted to as sure a uniform distribution of the stream of air to the two tiers of cages. At the opposite end of the box--the outflow end--the air from each box was exhausted through a 7-inch pipe fitted with a damper and connected to a large central exhaust fan (figure 3). About 4 inches from the entrance of t.he "-inch pipe into the box, the fumes of the substances listed were intro duced into the inflowing air. Spe cially designed pyrex glass flasks (figure 4), inches long and with a diameter of 1$ inches, were used to hold the heated waxes. These flasks were made with a side arm and tube that extended to the bottom. The top of the flask was ground, and into this fitted a short tube 11 inches in length. This short tube was inserted h into a large rubber stopper that fitted . tightly into a hole cut out of the 7-inch -f; ; pipe on the under side (figure 2). The flask in turn was placed in an electric heater made to rover it completely below the side arm and ground glass top. Rubber tubing connected the aide arm with a compressed air reser voir and a gentle 6tream of air blown through the melted wax kept it in ' motion and assured uniform heating. A Into each flask was inserted a long stem centigrade thermometer which 'waa ; kept in place and could be read at any *' time above the 7-inch pipe through which it passed (figure 2). \. . Approximately 30 gm. of pulveriied chlorinated naphthalenes or 20 gm. of i rt chlorinated diphenyl were placed in the bottom of each flask and melted in the electric heater. Fresh samples were used every other day, but it was often found necessary to add 20 gm. of new material even after one run since so much had sublimed. Whatever the case, the collected sublimate was i: k- Fio. 2. Electric heater for maintaining chlorinated compounds at a constant tem perature in place at inflow end of box. alwayB removed from the upper part of the flask and a clean top used each day. No sample waa ever used for more than two runs. The flask plus the contents waa care fully weighed at the beginning of the run and at the end, and the loss in weight used to calculate the average m 'll T-J? m her WATER PCB-SD0000070986 RKW lW it! 288 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY (SepI. 1937 amount in a cubic meter of air per flowmeter readings. The figures ob minute as determined by a series of tained were not absolute because of slight variations in the air flowing through the boxes and because of deposition of material on the ther mometers and on the inside surfaces of the box, but they checked well with direct determinations through air samples. _ Approximately 1 hour was allowed for the wax in the flasks to melt and come to a constant temperature. At that time the box doors were tightly HUMS closed, air bubbled through the flasks, and the blowers turned on. This was the beginning of the exposure period. By means of rheostats on the fans and dampers in the outflow pipes, the amount of air flowing through the boxes was adjusted and an attempt Fic. 3. Outflow end of two boxes showing: connections to exhaust system. was made to keep the four boxes as uniform as possible--usually between 165 and 175 c.f.m. In the first group of experiments the following substances were tested: 1. A mixture of trichlornaphtha- lenesplusa trace of tetrachlor- napthalene. Chlorine content 49.9 per cent. 2. A mixture of penta and bexa- chlomaphthalenes. Chlorine content 62.6 per cent. 3. A mixture of 90 per cent penta and hexachlornaphthalenes plus 10 per cent refined chlorin ated diphenyl Chlorine con tent 63.0 per cent. 4. Chlorinated diphenyL Chlorine content 65.0 per cent. The compounds were selected as rep resenting a certain range in chlorina tion and also because of their industrial importance. In each instance 80 ani mals were exposed, 10 rats being placed Fig..4. Pj'rex glass flask in each cage. They were fed Purina ^ rol. 19, no. 7 Dog Chow /' egg8! milk i ' This first ' begun on l exposure to chlomaphti l' 16th. The >.. compounds 18th. On - tive animal ^ sure from gr `-killed after '' 15th, in orde y, CowprfiONs M ^.'Triebiomaphtl ~ tetrachloma Penta and hexi 90% penta an< &. leoea plua 10% Chlorinated dip period would the affected group 3 were . -exposure on < 'for examinetie The averagt fifl hours dad morning leeaaed, and 1 4:00 p.m. the ^Weighed, etc. Rfotnrity ^shifted WATER PCB-SD0000070987 s8fe: m?', no. 7] EFFECT8 OF CHLORINATED HYDROCARBONS 289 JQof Chow supplemented by lettuce, m; 8SS> milk and cod liver oiL This first group of experiments was 'tegun on July 1, 1936 and the last . exposure to number 2 (penta and hexa- eblornaphthalenea) was on November 16th. The exposure to the other three compounds ceased upon November lth. On October 15th representa tive animals were taken out of expo sure from groups 1, 2, and 4 and were IdDed after 2 months on December 15th, in order to see whether this clear wax concentrations were somewhat higher at the inflow end of the boxes. Preliminary runs showed that once properly adjusted, wax concentrations in the air remained very uniform from day to day, but to insure absolute safety readings of temperature, air flow, etc. were made every night be tween 10:00 and 12:00 p.m. as well as on starting and stopping. At dif ferent times during the course of the experiment tests for free chloride were made but were uniformly negative and \ TABLE I Cwrwnojn Maintains w Inhalation Exmiuksnt non Jult 1 to Nothou 16 and 18 .mmuii CKLO- mnrm coKTjrr TKMT, hr. covcnrmAnoit or axm or box TOTAJb *X- romi AT. UXLT tx- :i* * . TriehlomAphUxaleDes plui trace* of tatracUomaphthalene..................... % 49.9 >1? * . c. *./. Arw, 150-160 1.51 High 2.60 1896 Low 0.10 Iran in and hezachlornaphthalenea.... 62.6 `l*1 ' r0% pent* and hexaehlomaphthav hma plus 10% chlorinated diphenyl- 63.0 . .* ; . .' &Uorfn*ted diphenyL.......................... 65.0 160-170 1.16 High 2.19 Low 0.51 165-175 1.87 High 3.17 Low 0.64 165-175 0.57 High 1.19 Low 0.23 1864 1806 1896 16 M 16 *TV j period would bring about recovery in ' showed that under the temperatures tin affected livers. Animals from used no decomposition occurred. jpwop 3 were similarly removed from Table 1 shows the temperatures at jtipcwme on October 4th and killed which the various substances were examination on December 4th. held, the average concentrations per , r The average length of exposure was cubic meter of air, and the average h^-toure daily for 6 days a week, exposures from July 1 to November morning at about 9:00 exposure 16 and 18. 3, arid between this time and 77k concentration of chlorinated naph pan. the rats were cleaned, fed, thalene* and chlorinated diphenyl in the etc. In order to secure uni- air of vorhroom*.--Table 1 shows that of exposure 'the cages were animals have been exposed to varied on a regular schedule, since concentrations of the substances under m m GEB02313 WATER PCB-SD0000070988 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sep*. 1937 test. The concentrations employed may be regarded as fairly representa tive of industrial experience. Prior to the initiation of inhalation experi ments a number of estimates of chlo rinated hydrocarbons in the air of dif ferent factories were made and the in question is passed over heated plati num in an electrically heated quart/ tube and the effluent gas scrubbed in a column of glass beads moistened with sodium carbonate containing a trace of sodium sulfite. The beads are then washed down and the chloride deter- . It, *0. ?] aAiewhate Tebbens'a b devices are In both c rinated hyd add and s odium carl In our case apt to be i less than 1 quently the actually for so small thi either g?avi For this res use the nep! m sensitive as 0.1 mgm. It is dou ; should era conversion Jp^pSund to subsequent tfftlftflB the t jfr-SV Iciw. Anot sJvSfe-.k that the ^<VL.any chlori determined ` distinguish abut d< results puted in te k-5--. v * At the { formation , 1a t" rinated na| different p :^y instances tJ ^..repeated 1 Vttw amour ^thoae used .Anst. be i . ctn _ . tataa sorted fr^WiQsoo equips o m CD /S' CO WATER PCB-SD0000070989 ilvcf have been exposed for 16 hours to an if-S.'V. Tebbena's but the essentials of the two atmosphere constantly impregnated r device* are the same.*, with the substance under test, whereas t\ in both cases conversion of the chlo- human exposure is usually a variable rfnated hydrocarbons to hydrochloric quantity, intense for a short time and uad subsequent absorption as then negligible. It is our opinion at sodhim carbonate should be complete. the present time that the concentra 1 fa our case concentrations in air are tions of chlorinated hydrocarbons used hfc apt to be very low--the objective is in our experiments would be dangerous a& fast than 1 mgm. per cu. m. Conse- for workers in the case of compounds fMf/quently the amount of silver chloridaebove trichlomaphthalene in chlorina actually formed in the final reaction is tion. Fortunately it is easy to venti 00 small that H can not be determinleadte processes of manufacture which either graviraetrically or by titration. require these substances and to reduce for this reason we have been forced to air contamination practically to the . on the nephelometric procedure which vanishing point. Such treatment of fa. ^native to concentrations as low the problem at once removes both the <,v- M j nlgm. per cu. m. of air. possibility of systemic poisoning and It k doubtful if the sampling rate the annoyances that arise from cases dhould exceed 1 liter per minute aa of acne. edareraon of the chlorinated com"pound to hydrochloric acid and ita Rerulit of Inhalation Experiment. Wbwquent absorption are not efficient 1. Animals exposed to a mixture j tmJea* the velocity of the gas stream ia of trichlomaphthalene* plus small Icnf.' '' Another precaution to be noted amounts of tetrachlomapthalene. fi that the method is not selective-- Living animals were apparently en chlorinated substance will be tirely normal. Autopsies performed I^J&tfcnnhsed. ' Furthermore it does not near the end of exposure seemed to <&sdaguh between Bolid particlea and show slight- swelling of the liver, and t*sea but determines them all alike and microscopic examination occasionally i Tfie rewilts most, of course, be com- showed swollen and hypergranulax liver lifted in terms of total chlorine. cells. The changes were, however, ,vC^.b,At the present time we possess in- never more than slight, fonnatioo as to the amounts of chlo- 2. Animals exposed to a mixture of r-ffiatedL fiaphthalenea in the air of 30 penta and bexachlomaphthalenes. .`plants, and in a number of No abnormalities were observed in the the measurements have been living animal* Rata were killed and ^ 'teyeral times. Frequently autopsied every 6 weeks. In the first Amounts have been greater than animals sacrificed liver changes were fa our experiments, but H observed. These were swelling of ^^remembered that the rats cells, slight granulation and hyalinixa- feeobwtioo and absorption app*- Ul"* to field sampling ia now mad* ___ , Prodocia, Inc., Reading, Pa. 0Tlpewia includes flowmeter Bad a^emp wili carrying caae. tion. In September and October these conditions were somewhat more ad vanced, and in November the process became stationary. There were highly tV-r-r* 1 & co WATER PCB-SD0000070990 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sept. 1937 granular cells, hyaline inclusions and mitotic figures, but no more than 2 months previously. 3. Animals exposed to a mixture of 90 per cent penta and hexachlornaphthalenes plus 10 per cent refined chlorinated diphenyl No abnormali ties were seen in the living animals. After 6 weeks the livers showed changes similar to those in the animals exposed to penta and hexachlomaphthalenea, These advanced in grade during August and September and then became stationary. 4. Animals exposed to chlorinated diphenyl. No abnormalities were seen in the living rats. After 6 weeks' ex posure there was slight liver damage which advanced during the next 2 months. The changes consisted in slight to moderate swelling of the liver cells, an increased granularity and many mitotic figures. Hyaliniration was always present as a result of inhalation of chlorinated diphenyL Summary of the firsi inhalation ex periment.--In these experiments care ful observation of appearance, body weight, activity, blood, and urine showed no abnormalities of any sort. Yet after 6 weeks' exposure all the compounds with chlorination above trichlomaphthalene caused minor de grees of liver damage, and no changes whatsoever in other organs. There was no acute yellow atrophy or any thing suggesting it except that a slight degree of liver damage was always present and was quite clear in the liver sections examined microscopically. This damage had no detectable effect on the health of the animals... They held their weight, ate and behaved normally, being in every respect similar to the many people who have been exposed to these compounds without illness of any sort. The functional appraisal of the liver damage caused by certain chlorinated naphthalenes and by chlorinated di phenyl.--There are no tests of liver function useful in such minor degrees of liver damage as were produced in these experiments. Indeed the ani mals resisted the injury so perfectly as to display no abnormalities except upon histological examination of the liver. The situation was perhaps similar to that met in industry, where, barring acne, the health of workers in these compounds has been good with the exception of the fact that in iso lated instances jaundice has occurred which upon at least three occasions has gone on to acute yellow atrophy. During recent years this disease has been seen following administration of carbon tetrachloride, arsphenamine and dncophen. In the case of carbon tetrachloride it is known that a low calcium diet and alcohol favor the pro duction of liver damage. For the acute yellow atrophy that occasionally complicates use of the other two drugs no cause can be assigned. One cannot produce acute yellow atrophy with arsphenamine, but somehow or other this now and then does happen to pa tients under antisyphilitic treatment. It occurred to us that something of the same sort might be involved in this problem. The human cases have been scattered and few. They have been isolated instances out of large groups of healthy employees who have had equal degrees of exposure. It was our idea that perhaps many of these people got liver changes such as existed in our rats, changes not recognisable through It, no. ,'aay means ot nation. If, i such changes, disturbance, i not a very c which any of i this rel&tivel; over to acute r Knowing tl had liver eh: m- slight to cause we decided to substances kn ' 'Structkm. Cs alcohol were i marion that ] shloridd plus per kilogram i jj^-normal white r grjfvojs cc. cs cc. 'of eth ..J^h^-This mirtun tube to the f< mala and with ^.-^pflowing tabu ' .. 0.7f cc tstracXion'd T^,V . *}jfUenkapkl\altn4. ^UWB. 10 rat* Pmia and hi 9:80 Lm., No ' " died Nor 80 p.i 'fc-, 1 died Not. 1 T.'" 1 died Not. 1 m died Not, 11:30 aj 1 died Not. 1 Mb.-. 14th and died No-9 Not. IB ; Mth (atU tO par cent jhUm and 10 p* JP&U 10:00 sjb 33? G) m CD o moo CD f&AfifsJStl v WATER PCB-SD0000070991 gpy* ti, n EFFECTS OF CHLORINATED HYDROCARBONS Ejp'-i'-;. jay nieana other than autopsy exami^V' natioDu If, upon the substratum of such changes, they got an acute liver disturbance, acute catarrhal jaundice, sot a very common disease but one 1 died Nov. 10th between 6:00 and 10:30 p.m. 6 died Nov. 11th between 4:30 and 10:30 p.m. 1 died Nov. 11th between 4:30 p.m. and 9:00 a.m. Nov. 12th. which any of us may experience, would this relatively innocuous disease go over to acute yellow atrophy? Knowing that our inhalation rats had liver changes, but changes too 3 died Nov. 13th about 1:00 a.m. 1 died Nov. 13th between 5:00 and 10:00 p.m. 4. Chlorinated diphenyl. Fed at 10:00 a.m., Nov. 10, 1936. 10 rate. 1 killed Nov. 10th at 10:30 p.m. (almoet Egfat to cause recognizable symptoms, we decided to test their resistance to substances known to cause liver de struction. Carbon tetrachloride and alcohol were selected. Having infor dead). 3 died Nov. 11th between 4:30 and 10:30 pm 1 died Nov. 12th before 8:30 a.m. (atifT)< 1 died Nov. 13th between 9:30 and 11:00 a.m. mation that 1.0 cc. of carbon tetra chloride plus 1.0 cc. of ethyl alcohol per kilogram would kill 14 per cent of normal white rats, we reduced the dose 1 died Nov. 16th between 10:16 p.m. Nov. 16th and 9:00 a.m. Nov. 16th (itiff). ConiroU: Fed at 9:30 a.m., Nov. 12, 1936. 10 rati. 1 killed Nov. 13th for normal liver. K-;. 'to 0.75 cc. carbon tetrachloride and o.7S cc. of ethyl alcohol This tabulation summarizes into the * This nurture was given by stomach facts that: .. to the following groups of ani- 1. No normal rata were killed by ^d with the results found in the carbon tetrachloride and ethyl alcohol. ^following tabulation. 2. No trichlomaphthalene exposed Sate fti 0.7J cc. per Iflm. tack of carbon .. '{. tetrachloride and eth jrf alcohol bg '. ' tlomaeh tube rats were killed, and this finding agrees with our inability to find lesions of moment in the livers of the animals that inhaled this substance. . TruMomaphthalene pint tract of tdra- 3. The penta and hexachlorinated yjtUarmtp^tkaUtu, Fed at 9:00 am., Nov. ' .38, KB. 10 rata. No deaths. fcV/r-l. Pent* and kexachlornaphlhalentt. Fed *49:10 am, Nov. 10, 1930. 10 rati. 3 died Nov. 11th between 4:30 and ' 10:30 pm naphthalene, the mixture of these with 10 per cent chlorinated diphenyl, and finally the latter substance alone seem to have produced conditions lowering the resistance to an agent capable of jcuav * dW Nor. 13th at 3:30 p.m. (/?". 1 died Nov. 13th at 4:30 pm disd Nov. 13th between 9:30 and 11:81 amt . ;,1 dkd Xov. 18th between night of Nov. ,t\ }4th en4 13:30 pm Nov. 16th. 1 y$ji' ed Nov. ltth between 10:16 pm *' f; Hov. iith'aad 9:00 am Nov. (etHOf 9 text pend* end hexachlornapkd 10 ptr tent chlorinated diphtnpL St M:00 am, Nov. 10, 1930. 10 rata. producing serious liver disease. 4. The sole lesion produced by this test of liver function was acute yellow atrophy usually accompanied by jaundice. This teat of liver function was ac complished with a substance which itself is an organic chloride and curi ously enough it is the only substance we were able to find that was effective. ^n IK -I m WATER PCB-SD0000070992 294 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY In animals with the minor degree of liver injury which haa been described we were unable to produce acute yellow atrophy or any variety of liver effect with arsphenamine, cincophen, butyl chloride, ethylene chloride and tetrachlorethylene, but carbon tetrachlo ride was uniformly effective in dis closing the existence of liver damage. Recovery from liver damage following removal from exposure.--Animals ex posed to trichlornaphthalenes plua traces of tetrachlomaphthalene being practically normal on removal from exposure need no consideration. In the case of the penta and hexachlor- signa of liver injury will be many months in returning to normal. The effect of high concentrations of trichlornaphthalenes with traces of letrachlomaphlhalene.--The first group of inhalation experiments showed that this material in concentrations averag ing 1.31 mgm. per cu. m. of air was relatively innocuous, judged both by direct observation and by the carbon tetrachloride test. This is an in teresting fact since such compounds cause acne, though less potently than substances of higher chlorination. In order to explore the matter further one of the inhalation boxes was arranged TABLE 3 Conditions Maintainxd DcaiNO Inhalation or Hiqh Concxntations or TiucBLomNAraTBALiNia ncn TXTACHLONAHTHAl*N* MATnUAL me. Af. coxcxjrnu.no* or AX* DC MX TOTAX AT, DAXLT azrotcu EZjrOTCBJI Trichlomiphthalenes plus traces of tetrachlornsphthalene c. 137-200 10.97 Bifh 10.40 Low 5.78 Wi 1233 lermrt 16 naphthalene, rats after 2 months' re moval from exposure still showed swollen liver cells, increased granu larity, hyalinixation and mitotic fig ures. The condition was not advanced as compared with rats killed at the time of removal from exposure but on the other hand 2 months were insuffi cient for recovery. The same findings were true of the mixture of `pent* and hex&ehlorinated naphthalenes and chlorinated diphenyl and for chlorinated diphenyl alone. Apparently the changes induced in the liver cells by these substances are exceedingly persistent and one must expect that An individual showing any so that fumes from four glass contain ers were delivered to the air line instead of one. This resulted in the conditions shown in table 2. The animals sub jected to these conditions showed no clinical effects of any sort. After 1 month the liver cells were slightly swollen and over-granular and there were occasional mitotic figures. These changes were similar to the early effects of more highly chlorinated compounds, and progressed only slightly during the third and fourth months. When rata in this condition were given carbon tetrachloride and alcohol, in some instances their livers showed massive central necrosis and in others this die rata were used in one may concluc tWomaphthalene toxic aa those o they are not enti upon the liver if ^7' tratians are inha. *'i>' * The effects of penta and he There can be no jV:"' age done the live -u but in the coo< ported no sympt T`... could be; recog ^-.'nothing approa i eiiffCjuramon* Main aad bex&ch. `* atrophy oceum use of the cart &:p& December : Subjected to jTfcirfaed in labl iprifl terminated g^ihe animals Ioe _ l deaths beg! f .wtric '. Fifty-fiv ipwixa heavily j< microecopi ' 1 by the a _ t tired t ^xposors. Tlx I'^^ed fot exam degenen necrosis q iahawee WATER PCB-SD0000070993 7J EFFECTS OF CHLORINATED HYDROCARBONS 295 *? fa 'others this did not develop. Fifty' nia were used in this experiment and one may conclude that while the trichlomaphthalenes are in no degree as toxic as those of higher chlorination they are not entirely free from effects upon the liver if high enough concen trations are inhaled over long periods. The effects of high concentrations of penta and hexachlornaphthalenes.-- II There can be no doubt as to the dam age done the liver by these compounds but in the concentrations so far re ported no symptoms were caused that Could be recogniied clinically and nothing approaching acute yellow the liver after 35 days of freedom from inhalation. It is thus evident that penta and hexachJornaphthalenes are markedly toxic compounds and that recovery from their effects is extremely slow. The effects of penta arid hexachlor naphthalenes, the mixture of these with 10 per cent chlorinated diphenyl, and of chlorinated diphenyl alone, when inhaled in low concentrations through an 8-hour day instead of a 16-hour day as in the first experiment.--Since steady human exposure to any of the compounds tested would invariably be for 8 hours rather than 16-hour periods, a further TABLE 8 ^Condition a Maintained duaino Inhalation or High Concxntaations or Penta and >J .. HEXACHLORNAMTHAlXNXa . K. ^II X - '..'va BUT*RIAL Paata and hcxachlornaphthafenea......... mcp. c. 137-195 AT. COffCSmLATVON or Aim KM BOX >#./. m. 8.88 rwtfi Hi*h 14.0 Low 5.73 TOTAL AT. RAZX.T Dotru Bxroctra Ww 606 Wa 16 atrophy occurred except through the !V-,:;U8e of the carbon tetrachloride test. '-.On December 1, 1936, 80 rata were 'subjected to the conditions suminariaed in table 3. This experment terminated on January 21. All of a the animals lost weight and appetite _^|knd deaths began after 8 days of expo 'aore. Fifty-five rata died, most of rfhem heavily jaundiced, 8 were killed microscopic examination, 9 were : Jiffled by the carbon tetrachloride test 8 lived through the period of ^exposure- The livers of the animals foi examination showed marked degeneration, central in type i necrosis of liver cells. Surviving i showed pronounced changes in inhalation experiment was arranged under the conditions shown in table 4 which are quite comparable to those .in table 1 except for the shorter inhala tion periods. Eighty rats were used for each of the three compounds tested. None at any time showed the slightest evidence of illness. Microscopic ex amination beginning after 6 weeks' exposure showed swollen Over cells, excess granulation, hyaline inclusions and occasional mitotic figures. These changes did not progress and were very similar to those in the animals exposed for 16 hours under the conditions set forth in table 1. The carbon tetra chloride test was uniformly fatal to them and one must conclude that con- 4*1 m n if-*: a y- co WATER PCB-SD0000070994 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY centrations of these compounds such as were employed cause a certain de gree of liver damage even if inhaled for but 8 hours daily. This injury is resisted successfully by the rats just as was the 16-hour injury but it is none the less there and destroys the ability of the animal to resist the carbon tetrachloride test. Summary of inJialalion experiments. The findings that have been described briefly will be amplified upon the pathological aide in a further paper by Dr. G. A. Bennett. What has been given is, however, sufficient to indi men never inhale enough of any of these substances to get acute yellow atrophy. They may, however, acquire a substratum of liver damage upon which acute yellow atrophy may de velop. Experience in a number of plants has shown how easy it is to reduce concentrations of these com pounds practically to the vanishing point, and every effort should be made to attain such conditions. Gross Feeding Experiments The various compounds used were ground as finely as possible and mixed with a standard balanced ration for TABLE 4 Conditions Maintained dxthnq Inhalation or Low CoNcsNTEAtioNa or Tama CourooNDa DtntiNQ 8-Houe Instead or 18-Houe Periods ttimub TUT. ato. croawicbmoxr-rmsoAxTiajr TOTAL AT. DAO.T XXPOOU *XTO*ClA c. Penta and bexachlornaphthalenea......... 140-193 t. 1.44 90% pent* and bexachlornaphthalenes plua 10% chlorinated diphenyl........... 150-107 i.ea Chlorinated diphenyLi............................ 153-174 0.03 r**f* High 2.58 Low 0.42 High 3.90 Low 0.50 High 3.23 Low 0.03 Am 020 Am 8 012 8 020 8 cate that compounds more highly chlorinated than trichlornaphthalene are capable of causing liver injury when inhaled steadily in quite low concentrations. It is an extraordinary thing that even the moot searching examination fails to show injury in any other region. It is not easy to grade the toxicity of the different compounds tested, but the chlorinated diphenyl is certainly capable of doing harmin very low concentrations and is probably the most dangerous. Industrial experi ence combined with these experiments make H appear probable that work tha white rat. The food was placed in a single container, at which the 10 animals in a cage had an equal chance, the amount of the compounds added being reduced as the number of rats lessened during the feeding period. The experiments were designed to give an idea as to the possible toxicity of the compounds selected and, if toxicity was obeerved, some idea as to the site or sites of damage.. The experiments were successful in both respects, and indeed one may anticipate that future appraisals of the possible toxicity of chlorinated hydro- ` EFI carbons may often .. feeding and do not _ rate apparatus and sary for inhalation essential reason for in the identity of tl by both methods, bj ... different compoum f seem to arrange the so far as toxicity i - ever way they are ' Trichlornaphthale leirachlomaphlhalen fe'/-.. on May 4, 193d until November 2,1 it- hing 3 gm. of this n -to the food for 1 andthis concentrati throughout the ex] . animala were killei 'which died on Nov. -loas of' weight and illness of an; ..death was due to s> v. spiratory infection t tion to the material '.* Histological exa: V slight changes in the i'hf great significance. '+r Tetra and pentad . Feeding began on J dosage of 0.5 gm. da 'All the animals sicke V'were either killed o '^39, 1936. At autopsy both logically the liver wi Effected. The liver uh&r hypergranulatic aloha' and vacuola necrotic cells w 'was a tremendous ac *J*jbta and hexach 'ceding bevan May >ed. t Om CD O ro to too WATER PCB-SD0000070995 Vol. 19, m>. 7] *' EFFECTS OF CHLORINATED HYDROCARBONS 1 297 carbons may often be made by simple feeding and do not require the elabo rate apparatus and the expense neces sary for inhalation experiments. The essential reason for this opinion resides in the identity of the lesions produced by both methods, and the fact that the different compounds so far studied seem to arrange themselves identically so far as toxicity is concerned which ever way they are administered. Trichlomaphthalene plus traces of tetrachlomaphthalene --Feeding began on May 4, 1936 and continued until November 2,1936. In the begin ning 3 gm. of this mixture were added to the food for 10 rats each day, and this concentration was maintained throughout the experiment. All the animals were killed except the last which died on Nov. 2. There was no Io&s of weight and no appearance of wasting illness of any sort. The single death was due to some variety of re spiratory infection which had no rela tion to the material inhaled. i Histological examination showed slight changes in the liver but nothing, of great significance. Tetra and penlachlomaphlhalenet.-- ' Feeding began on June 29, 1936. A dosage of 0.5 gm. daily was employed. AH the animals sickened gradually and were either killed or died by August . . 29,1938. At autopsy both grossly and histo- ' logically the liver was the single organ -- affected. The liver cells showed swell- -7`ing, hypergranulation, hyaline inclu- `v sons and vacuolation. Here and there necrotic cells were found. There NViwas a tremendous accumulation of fat. .,.* Ftiia and' hezachlomaphlhalene*.-- Feeding began May 4, 1Q38, a 3 gm. being used. By June 6, nine rata had died. The last one was obvi ously ill and was killed for autopsy examination. All animals lost weight from the beginning and were ill. At autopsy the liver alone was affected, the lesions observed being similar to those that have been described for tetra and pentachlomaphthalenes but worse. . 90 per cent penla and hexachlor- naphihalenea and 10 per cent chlorinated diphenyl.--Feeding began May 4, 1938 on a 3 gm. dosage. On May 16th feeding was stopped but all the animals went on to death, the last dying on June 8th. An autopsy the liver lesions were extremely severe and of the usual type. . On account of the high toxicity of the 3 gm. dosage, four rats were given a 0.5 gm. dose every other day. Feed ing began June 24, 1936 and the last animal was killed Sept. 11th. There were no deaths but all the animals lost weight. At autopsy the liver as usual was the single organ affected, the lesions being characteristic and ex tensive. Chlorinated diphenyl.--Feeding be gan May 4, 1936 on a 3 gm. dosage and was discontinued on May 10th. Seven of the 10 rats were dead by May 12th. The three remaining rata gained in weight but were sacrificed for autopsy purposes on July 8th. The liver changes began at once. There were no changes in other organs. A second group of 10 rats was fed a much smaller doee--0.5 gm. every other day. Feeding began May 20, 1938. The first rat died on May 29th and four more before June 24th. The remaining were sacrificed. Those rata that died showed losses in weight, while those sacrificed had recovered i to oo to WATER PCB-SD0000070996 298 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sep/. 1037 their initial loss in weight and were gaining. The liver lesions were similar to those found in rats fed penta and hexachlomaphthalenea plus TO per cent chlorinated diphenyl but not so marked. Summary of gross feeding experi ments.--Of the various materials fed rats in large doses trichlomaphthalene plus traces of tetrachlomaphthalene was quite innocuous. Tetra and pentachlornaphthalene showed definite liver damage. Penta and hexachlornaphthalenes caused a similar grade of injury. The addition of chlorinated diphenyl to penta and hexachlomaphthalenes increased the toxicity. Chlo rinated diphenyl alone produced liver lesions but in the dosage used was le*s effective than when mixed with highly chlorinated naphthalenes. In no case did the compounds used produce acute yellow atrophy but the lesions ob served indicate this might be possible if one found a dosage which could act for the proper period of time. Feeding Precise Doses by Stomach Tube The compounds employed were sus pended in gum acacia. In figuring the dosage the total amount a man of 50 kg. would inhale in an 8-hour day assuming an air concentration of 20 rngm. per cu. m. was first calculated and reduced to milligrams per kilo gram. The rats and rabbits received this dose each day. The compounds used were those employed in the gross feeding experiments and the results were essentially similar though the lesions were less severe. Subcutaneous Injections The same gum acacia suspensions were injected subcutaneously into rata and rabbits, the dosage being calcu lated on the basis of 4 rngm. per cu. m. of air. Again similar results were obtained. In all such experiments there must of necessity be differences in the degree of effect but invariably the liver was the sole organ affected and the lesions were those already described many times. Discussion These experiments leave no doubt as to the possibility of systemic effects from the chlorinated naphthalenes and chlorinated diphenyl. As in the case of the effects upon the sldn, the degree of chlorination seems to determine the / systemic toxicity, and it is a striking thing that when trichlomaphthalene is reached systemic effects are never marked and are produced with the greatest difficulty. It is most remark able, too, that all the compounds tested attack the liver and the liver alone. During the past few months we have determined the organically combined chloride in the livers of ani mals very severely poisoned by penta and hexachlomaphthalenes but have found no increase over normal figures, though the livers, as determined histo logically, were very severely affected. At the present time we are conducting inhalation experiments on' a chlorin ated diphenyl containing 55 per cent of chlorine instead of 64 per cent as in the case of the experiments reported in this paper and on a compound with a chlorine content between tri and tetrachlomaphthalene. We are also determining the degree to which the diet may increase or decrease toxicity, this being suggested by similar work upon carbon tetrachloride. . In the basis of these experiments ' pot? 10, no, i A-X- 10^ 011 Irdifferent c i'rooms, it I Mainly eas ."that the a. -j ' more than j .>",/of these < naphthaler ' compound F* perm j ''XT many exan plants that /--T.been great!; :&Xr 20 years, ai . fact that -M-r - been -inexc 2//'_ human expc change thesi but today v r safe. Impn } -' ' arrangement p-- "hydrocarbon . .safeguard. lead tetraetl Coc*Tois-Scrr profession! :talins. A (103-4). A! A., AXD 1 k*. J^Vr- \IcL.VAr.*rwN.*' profession!! es derive : 335 (1B34). -_CrT:" Fukw, F. B., a certain chic : liver. Pro< , 118 (193< : .i Lskmuth, K. .rj-i 1 - .- ArtxiU-um Leipxif, WATER PCB-SD0000070997 tel. It, no. 71 EFFECTS OF CHLORINATED HYDROCARBONS 299 and on many field determinations of different compounds in the air of work rooms, it appears safe and it is cer tainly easily attained, to ventilate so that the air breathed does not contain more than 0.5 mgm. per cu. m. of any of these compounds above trichlor naphthalene. In the case of the latter compound concentrations of 10.0 mgm. are permissible. We know from many examinations in many different plants that such concentrations have been greatly exceeded during the past 20 years, and we are conscious of the fact that our rat exposures have been inexorably constant whereas human exposure is never so ordered. Time and careful observation may change these opinions as to standards, but today we are convinced they are safe. Impregnating tanks and other arrangements utilizing the chlorinated hydrocarbons are easy to hood and to safeguard. Compared with benzene, lead tetraethyl and many other com pounds, these substances are very little toxic and operations employing them can easily be safeguarded. It may be argued that where possible trichlomaphthalene should be used, but this compound will cause acne and if employed very carelessly might do more,. .Furthermore, higher chlorina tion is often essential for highly prac tical reasons. The solution consists in thoroughly adequate ventilation plus good housekeeping around all wax containers. A final word of caution bears upon the use of carbon tetrachloride as a wax solvent. Obviously this compound adds readily to the toxicity of the highly chlorinated waxes. If carbon tetrachloride is used, ventilation should be excellent, but in our opinion it would be better to dispense with car bon tetrachloride'and depend on other solvents, especially upon those con taining no chlorine. BIBLIOGRAPHY Covrrou-ScrnT: Etude ur I'intorication professionnelle par le trichloronaph- laline. Ann. de mid. ligale, 14, 422 (1934). Abatr. of paper by TotmAina, A., Ufs MtxtTEiL, B.: Dermatoae* ' profeationnelle* par la naphtaline et : . tt* derivia. Prat. mid. Iran;., If, 336 (1934). Fuxx, F. B., ahd Juni, N. E.: Action of certain chlorinated naphthalenes on the llrer. Proc. Soc. Erper. Biol. A Med., , 118 (1936). . LuoiAXX, K. B.: Kurzea Lehrbuch der Arbeita-und Geverbehygiene. S. Hir- MittilstXdt, O.: Gewerbeschidigungen durch Haft&x (Trichlomaphthalin). Inaug. dissert., Jena, 1933. Tissrxe, B. D.: Portable combustion ap paratus for field determinations of chlorinated hydrocarbons. Tma J., It, 204 (1937). Tkucxt, L.: Die Pernairankheit (Chloracne). Klin. Wchnsohr., 8, 897 (1927). Tomunra, A., Solxht*, MfaiiTajsL, B., . awd Action: Cinquante-quatre cas de ! dermatite* par trichloronaphtaline. . Bull. Soc. dermat. et ayph., 41, 263 (1934). WATER 300 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY tSST Discussion Il ' ` Dm Cecil K. Dukub: We have had incline them to. First of sll I shall aak quite a tong morning, but lince Dr. Ton Oet- Dr. Sayers if he will open the discussion tin gen has to leave, I am going to aak him for us. to say a word. Da. R. R. Sanaa (Chief, Division of Da. W. F. von Oettinobn (Director, Industrial Hygiene, National Institute of Haskell Laboratory of Industrial Toxicol Health, U. 8. Public Health Service, Wash ogy, Wilmington, Delaware): I wish to con ington, D. C.): Dr. Drinker, Ladies and gratulate Dr. Drinker and his group on the Gentlemen: It gave me a great deal of pleas very interesting and excellent work on the ure to have the opportunity to listen to the subject. I also wish to congratulate the excellent and interesting discussion and Halowax Corporation on the fact that they presentations made this morning. Dr. didn't spare any effort to elucidate the prob Drinker, and I might add, the membert of lem so that the dangers which apparently the Halowax Corporation, have discussed are connected with the use of this material this matter with us,' as well as the manu can be controlled. facturers of the diphenyls. I personally believe that there is no toxic We have been doing some work but not material which cannot be used safely if it ia nearly as extensive ss that carried on here. handled properly. In order to handle such The work that we have been doing seems to materials properly during the different oper confirm the work that Dr. Drinker has car ations it is absolutely essential to be famil ried on. I think there are certain parts of it iar with the toxicity and especially with the that we can very well keep in mind. mechanism of the action. Since there ia no We are dealing with toxic substances, but animal which corresponds in all its physio we are dealing with toxic substances each logical characteristics to the human being and every day in industry--harmful sub it is important that such compounds be stances, hazardous substances. That these studied with different species of animals so can be controlled is well known, no matter that one can get a croes-section of the poten what they are, and that we can use them and tial dangers. use them in a safe manner. Dr. Drinker In addition, this fact illustrates the im has called your attention to the fact that portance of the pre-employment and peri this apparently has been done and can be odical examination of workers in such work. done in any of the plants where halowax is As was pointed out by Dr. Drinker, there used. I have information from one or two are individuals who are apparently more of the otbet men who are in the audience susceptible to certain toxic agents than that in plants where damage has been done others. On the other hand, we hare to try --skin damage and apparently liver damage to detect the very first signs of incipient to some of the workers--the manufacturers poisoning in order to prevent more serious have since corrected the conditions and ap damage. In the present instance it is very parently have adequate engineering con difficult to find these very first symptoms trol supplemented with adequate medical because there are no adequate methods, but control. I trust that in time the scientific profession After all, the proof of the pudding is in will supply the medical profession with the eating. If the man does not get the dis adequate methods which will allow the ease your engineering control is successful. physician to determine incipient damage of If he does get the disease, no matter what the organ before serious clinical symptoms you have done in the way of engineering, become manifest. you haven't been succeeafuL We must go Thank you. hand in band. Neither profession alone Afternoon Sutton can be successful. We have got to work together whether we like it or not. I hap Da, Cecil K. Dsnui: In this discus pen to like it. sion I will call on one or two individuals and There is one other thing. As far as mate 1 shall expect others to speak as their notes rials are concerned I think we ought to be i f.V 'r rol. IS, no. 5 smart enoug ' cesafulty. I t ' H A. . ' adapted for {- - it. Another vious to this ? **;; * - was fiammsl ;V V- ' . approximate - say approxii . never just s : . It might hsv * a wtre quite si . happened wl with this ms electric oabl A., ' armor on the > * * - and was bein proximately . to a steel ro . - bottom of thi inspecting it bide cap-lam " the fire kille< : .;A ; . mine. Man; .. . Here we b __Now we hav due to the evaluate thei 1 am inform not just suri flammability chlorination also increas creases, acc< think that c! have these b control then we can. . Perhaps w are better ei . present time better.' I an . submarines, . noo-flammab , of their elect : Da Cecil you ears to i !r K "- . -W.r';; Da* Alsk Mjr- of Oceupatii t,: necfcictrt Dej ' Conn.): Dr. anything tha this material a WATER PCB-SD0000070999 i i--V- tol. 19, no. 71 EFFECTS OF CHLORINATED HYDROCARBONS 301 ^\V~: . smart enough to use every one of them sue- number of so-called cases. Ail I can say is eesafully. If this material is particularly a confession of ignorance on our part at that adapted for a certain purpose we should use time and I was very glad to see that your yV" it. Another material that was used pre- digging into the literature as thoroughly as V' vious to this for insulation purposes, which you have hasn't elicited any further infor : _Z\__was flammable, caused a disaster in which mation than we were able to get, basically. ' approximately 167 men lost their live*. I About all we could find was about the two ' say approximately 167 because they were cats that our friend, Lehmann, experi . never just sure whether it was 167 or 168. mented with. We got in touch_with him and i ; It might have been one or two more but they he confessed that the amount that he had -r-w-.j were quite sure that 167 lost their lives. It given the cats and his method of determin ' i - happened when they had insulated a cable ing it were probably subject to very serious ' with this material. They had an armored scientific oriticiam, and we agreed with him , ' electric cable. It was covered with lead on that point. ' '-yr'-- armor on the outside. It was 1200 feet long We felt, and I am very glad that it is what j '77 and was being lowered into a mine shaft ap- you feel as a result of your experiments, \ '.!Y . proximately 3000 feet deep. It was lashed that if we put in an efficient ventilation sys . to a steel rope. It slipped and fell to the tem sufficient to prevent the dermatitis, we ' ; bottom of the shaft. When the foreman was probably wouldn't have liver damage. i , tT inspecting it he set it on fire with his cax- That is what we did entirely empirically. bide cap-lamp. The carbon monoxide from I think that is about ail I have to say. I - the fire killed those men that were in that have been delighted to be here and to have mine. Many of course escaped. as many members of my staff here as I could ' ~. Here we have one haxard, a fire haxard. jack out of the office. We have been de Now we have another one, a health hazard lighted to listen to the discussion. due to the toxic materials. We have to evaluate them. Certain of these materials, Da. Cecil* K. DsiKxim: May we sow ...... I am informed, are also flammable. I am make the discussion general and those who not just sure how flammable they are but have questions please volunteer. ' ' . ._ flammability probably decreases as your chlorination increases. But your toxicity also increases as your chlorination in creases, according to Dr. Drinker, and I Ms. ManrUSD Bowrnrc* (Director, Division of Occupational Hygiene, Massa chusetts Department of Labor and Indus I II l. think that checks with other findings. We tries, Boston, Mass.): I would like to second . have these haxards to balance but we can very strongly what Dr. Sayers has said with ' control them. I feel quite eonfident'that regard to the approach to this problem in ` ** eta* - proper control rather than by prohibition,- /v,..; .. Perhaps we can find other substances that which seems to me wholly unnecessary not y are better even than this material. At the only in this case but in the case of other .' ' present time I am advised that we have no toxic substances with which we hare to deal. ~2 ^ \ better. I am advised that in ships, such aa The problem of proper ventilation seems to . f " submarines, it is quite important to have a me relatively simple from what I have heard non-flammable substance for the insulation of the situation thus far. The problem of e< their electrical wire. maintaining that ventilation properly does not teem to me quite so simple. I think it Ha, CecaK. Danma: Dr. Gray, would is going to be quite necessary that there, , you care to say a word? should be a very adequate inspection of the plants using the materials and I ean ; .. AiaaaT 8. Gsat (Director, Bureau assure you that that will be the case here in : Occupational Diseases, 8tate of Coo- Massachusetts. . . - .- / .:Xr>r .aecticut Department of Health, Hartford, When this trouble first broke in thii state v'5V&" ^ona-): Hr. Drinker, I don't think there is a little over a year ago we ieeued a quite anything that I can say except that we used strongly worded warning letter to all plants , '. this material in Connecticut and we had a using these substances and it has all along WATER PCB-SD0000071000 302 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [<p/. 1337 been my plan to follow that up with a fur ther letter bringing tbe situation as we now know it, u a reult of Dr. Drinker's work, to the Attention of users in this state. In that letter we shall unquestionably advo cate the concentrations that Dr. Drinker has suggested this morning. One point that I think is worth comment ing on in that connection is the question of identification of the substahces. It is ex tremely important from the state adminis trative point of view that employers using these substances should know what they are using. They are identified at present only by numbers. If we list those numbers in a warning letter which we send out there are likely to be changes in thoee numbers. The Halowax Corporation is a progressive con cern and it is going to be putting out bigger and better halowaxes all the time. The company's cooperation in this present inves tigation has been such that I feel assured that they will take the proper steps to see that we in the state offices and also the users of the products will know what we are using. I wonder whether Mr. Brown would care to say anything about that. Mn. Saunronn Bnoww (President, Halowax Corporation, New York, N. Y.): There are some aspects of this situation on which I think I can enlighten the medical and state and civic authorities, with respect to the commercial and practical aspects. If you go into the research laboratories of any large chemical manufacturing company today you will find anything from one to a thousand different new chemical products which have not yet been put on the market. Some of thoee may or may not be toxic. The problem so far as the chemical manu facturer is concerned is a question of tuning. You have heard this excellent presentation given this morning by the Drinker brothers as to the work that they have done here. Should you take a product of which you have developed, say, 6 or 10 gm. and spend >60,000 on research to determine whether or not it is toxic or should you wait until youhave determined whether you have a market foritf If you are producing only one hundred ubstancea a year you can see that that would run into boxcar numbers in the way of dollars and cents before you ever sold any. That is the problem wo have had in this caae. It has been on the market for 26 years. Until within the past 4 or 6 years there has never been any intimation that it would cause any systemic effects. Thou sands and thousands of workmen have dealt with millions and millions of pounds of cer tain of these materials, particularly the trichlomaphthalenes. Then we come to the higher stages, combined with chlorinated diphenyl and other products, and suddenly this problem la presented to us. We bad asked various authorities in terested in public health, going back over a period of 16 to 20 years, to investigate it but there wasn't much enthusiasm for it. Mr. Bowditch suggested that we take it up with the Drinker brothers at this institu tion, which we did. You know the results of that work. Now so far as these changes are con cerned, they are beyond our control to a certain extent. We will manufacture a product--let's call it 1234. It ha* certain chemical'and physical characteristics. It is supplied to a cable manufacturer. It is composed of certain constituents. There may be some tetrachlornaphthalene, trichiomaphthalene, paraffin, a little pilch or bitumen, and possibly some chlorinated diphenyl. It does a certain Job but he want* it to a little more plastic or he wants its viscosity or the specific gravity changed. Possibly by a change in those constituent* of only 1 per cent we can get that particular property. We can't sell it to him as the same product 0 we put a new number on it. Basically, however, if the variation in the chlorinated naphthalene or the chlorinated diphenyl constituent hasn't changed, the toxic property of that will not change. , When it comes to a question of eofiperatIng with the state authorities in that con nection, if there were some major change made in a product we would have no hesi tancy in advising them and we would also advise our customers. Virtually every con sumer of theee materials at some time or another has been given their technical or chqmical designation along with their vari ous properties, whether they be physical or chemical. ' Thoee are some of the practical problems ' .^ J9> ru>. 7) * - - with which ali are confrontec synthetic orga meat is so rap can't even kee merits sometin doing. M*. F. R. ager, York Wu York, Pa.): I s3i=: v this opportun . reference to t our York plai i'c-P1-' y'again in this ( Vvvjrx,'. .Acly-; the best tea< problem at 1 through the * It i* only 1 ; neighborhood various degrr ' * ..all know. E . 'R-t.vwfey-ii- 'severely afflii u their akin . man died anc ; ated his d< - v . .. . vapors but 1 ':' . was an strop oftheautopi that it was - ' work. Kno ' ., was employ* tion that h< . . thin, pallid - ".v>~ v not say fre physical ms be presente ever, it was the time o( plained of t advised ths rapidly dev in the hosp ~s'-~Jr/- d1l.M<.Lore ser that we tuu I -A?' tabs as far ! first react! had was U p1"1- Tl thatlffoo:rtT said, but n . we^ ha1 . V. triads and rfvHt.- .-V i 0m n-r-r CP o f<Otc-sO>n WATER PCB-SD0000071001 tol. IS, no. 7] EFFECTS OF CHLORINATED HYDROCARBONS 303 with which *11 manufacturer* of chemical* there was no substitute and there is none are confronted today, particularly in the today in spite of all the efforts we have made lynthetic organic field where the develop through our own research laboratories to ment i* *o rapid that our sale* department* find one. can't even keep up with the re*earch depart But we did develop--and I was most ment* eometime*, in knowing what they are closely associated with it--and set up a doing. routine for bringing these men back to nor mal health conditions. A number of them Ma. F. R. Kaivih (Aisiitant to Man were sent to Dr. John H. Stokes and to Dr. ' "' tger, York Wirework*, General Electric Co., 0. H. Perry Pepper of the University of York, Pa.): I am certainly pleaaed to have Pennsylvania Hospital, and the others to this opportunity to aay a few word* with Dr. Isaao R. Pels at Johns Hopkins. reference to the experience we have had at Through their recommendations and studies our York plant. I perhap* should ay that we employed a trained nurse and two local a' again in this case experience alone ha* been physicians and you might say established a ' the beet teacher. I have lived with the small hospital and its facilities at the plant. problem at York with the men who went Through the application of quarts light, through the experience from it* beginning. x-ray, mechanical removal of comedones It i* only 11 year* ago that we had in the and the treatment of postules that de neighborhood of 50 to 60 men afflicted with veloped in later stages, an utterly strict . various degree* of this acne about which you routine where the worst cases were adminis all know. Eight or ten of them were very tered to each day for a period of 15 to 20 severely afflicted--horrible specimens as far minute*, another group who were lea* seri as their skin condition wa concerned. One ous three times a week, and still another man died and the diagnosis may have attrib group once a week, we have in this year and uted his death to exposure to halowax a half brought each and every man back to vapors but we are not sure of that. There a normal skin condition. Those who were was an atrophied condition found as a result very seriously afflicted do show scars, but of the autopsy but we are not definitely sure otherwise their skin is as healthy in appear that it was or was not connected with hi* ance as my own. I tell you we are very work. Knowing the man as I did when he proud of the fact that they are still all em wa* employed, with the superficial examina ployed and the amount of halowax that w* tion that he had, he appeared to me very are using today is even greater in quantity . thin, pallid in hi* appearance, and I would and in type* than we were using a year and not say from my poor knowledge of the a half ago. ' physical make-up of the human being that With the adequate ventilation system we he presented a healthy appearance. How have installed, with the routine for change ' ever, it was only for a 0 months' period from of clothing from street clothing to work the time of hi* employment that he eom- clothing when they come to work and the plained of this constipated condition and we reverse of that process, with the assurance ' ' advised that he see his home physician. It that a shower will be taken before the street . _ rapidly developed to the point where he wa* clothing is again put on, we have found no ....... in the hospital and in a very short time he recurrence of this akin trouble. Each and - died. every man working with halowax products, More serious than that perhap* is the fact either from solution, from solid compound* . that we had 50 other men in very bad condi or handling the wire insulated and treated , ... tion as far as the acne wa* concerned. The with it, is examined twice yearly with a com .jyr . first reaction that several of our executives plete physical examination, including blood . .. -Ctjv . had wa* to throw it out--get It out of our analysis and effort* to determine any liver :^fT .plant. They didn't want anything like damage. ' ' . that for treating wire. But that waa easily However, there Is the point which waa said but not so easily done. We might just very definitely brought out this morning. " ipTr ** well have thrown our business to the four We do not know as yet when this thing ` . wind* and said, "We'll eloee up," because starts. I believe it would be of great belp J 304 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sepf. 1937 to us all in industry if some very funda ments! work was done on humans, as Dr. Jones mentioned before we came into this meeting, some control in fundamental work to determine some method whereby we may determine the inception of any liver dis order. We have had our men examined in groups three times since the trouble developed and nothing has shown up in any one man. We have learned and appreciate the fact that we must handle haxardous materials, but we have learned how to handle them. It has been a very great experience for us and for myself, and again the best teacher. Ds. Cecil K. Dbiniib: Can you recol lect the air concentration that you are main taining now with your present ventilating equipment? Ms. F. R. Kaimeb: We have had two examinations made of the air by Mr. Wil liam F. Hemperly and they average from 0.2 to 0.8 mgm. per cu. m. We recently dis covered one condition which was found as the cause of a high reading in one of the examinations. The compound is one that is not manufactured by the Halowax Cor poration that is used rather infrequently, perhaps not more than SO gallons of it in a ^ month period. It is in the form of a paste, reduced with solvent to a paste form, and it was not known that it contained a chlorin ated solvent in certain percentage. We dis covered it only recently through the analy sis of a sample and we found that that was the cause of throwing the results off to a high value. It was then about 8 mgm. perou. in., I believe. That is going to be eliminated now. That is a combination of toluene and carbon tetrachloride solvent. When that compound is exposed to the air the chlorin ated solvent odor is completely masked by the toluene. It is lost. I was able to detect it only by removing the head of the drum and immediately smelling the odor of carbon tetrachloride. 'As soon as that head was removed for a period of 10 seconds the tolu ene predominated and we had no knowledge of the other being In there. M*. Abthtjr G. Bitib (Research Engi neer, United American Bosch Corporation, Springfield, Mass.): Do I understand you to say that those men who were afflicted are back on the same jobT Ms. F. R. Kaeueb: They all returned to normal skin health, as I say, and are work ing on the same job. Dr. Cecil K. DBtHrxm: Dr. Schwartz, you have seen a good deal of this general subject. _ Da. Louis Schwabts (Medical Director, Dermatoses Investigations, United States Public Health Service, New York, N. Y.): I am primarily interested in dermatitis and it was only because of my researches in that field that I happened to come across infor mation given to me by Dr. Gray that there were some cases of yellow atrophy of the liver attributed to halowax. I can only talk from personal experience about the skin cases. I know from what I have seen and from what I have heard from doctors who have been treating these eases that if they are treated like an ordinary acne vulgaris and kept away from further large exposure they all get well, with the same results as acne vulgaris. Those who have large pus tules may have scars resulting and those who have superficial pustules or only come dones won't have any scars. As far as prevention goes, I felt even be fore this investigation was undertaken that this substance, like any other poisonous substance, can be handled and used in in dustry provided proper safety precautions are taken, and I so advocated at the meeting in Pennsylvania when this was discussed. About ventilation and safety precau tions, I think that while we cannot, with our present knowledge, detect by any chemical tests the early symptoms of intoxication from this substance, the skin offers an easy way of proving whether your method of ventilation is efficient or not. If there are any cases of acne or of this dermatitis occur ring in a plant where halowax or the chlorin ated naphthalene or chlorinated diphenyls are used, then that shows that there is suf ficient concentration of these substances in the air to cause plugging of the follicles and to cause a skin condition. If there is suffi cient concentration to do that there may be !i , e-pof., f. i %:< '"' *>oion | -1.., bone. them. people ' ' ,tance diseasi very n in Ger -i. igSSSfciw.-' 1 ** t'3 ! '*>? 1 Wbj metho< of ven if you any ac this m sufficie acne a be dai hypers - Da. tical p< mining pointesevers It has men w pie of learn ir eonfini ratus, compa to plat I do the su an idei : : 'J ._ Brand '. detern a whil ' . aral Jr WATER PCB-SD0000071003 pol. 19, no. 7) EFFECTS OF CHLORINATED HYDROCARBONS 305 sufficient concentration to cause systemio poisoning in the few people who are'hyper* , sensitive to the action of these hydrocar bons. Everybody is not hypersensitive to them. If they were, of the thousands of people who have been handling these sub stances, more would have contracted this disease and it would have been reported very much earlier. This material was used in Germany as early as 191-4 or 19115. , While I cannot add anything to the methods outlined here for safety in the way of ventilation and so forth, I can say that if you go into a plant and find that there is any acne present among the workers with this material you will know that there is sufficient of the substance in the air to cause acne and consequently sufficient perhaps to be dangerous to the few people who are hypersensitive to its action. Dh. Cecil K. Drinker: There is a prac tical point in regard to the question of deter mining these substances in air. My brother pointed out this morning that there are several pieces of apparatus for doing this. It has seemed desirable to a number of the men who are here that during the next cou ple of years, while we are in a position of learning, that we endeavor, if we can, to confine our analyses to one piece of appa ratus, so that at least our results will be as comparable as we can make them from place to place. I don't know much about this phase of the subject: perhaps, Mr. Cook, you have an idea or two about that. Me. Warrin A. Cook (Chief Industrial Hygienist, Bureau of Occupational Dis eases, State of Connecticut Department of Health, Hartford, Conn.). On the deter mination of the halowax I wonder if It wouldn't be preferable to have Mr. Hemperly discuss the method he has been using throughout the country for the determina tion of chlorinated naphthalene*. ' Da. Caen, K. Danrxaa: I think so far as that is concerned it is best to leave that to diacuajions with Mr. Hemperly and Dr. Brandt afterward. But the question of determining some uniformity of technic for _ a while at least is, I think, a matter of gen eral interest to us. Mb. Wahrxn A. Cook: I am not quite sure that I have in mind exactly what you want in that regard. In connection with sampling? ' Dr. Cecil K. Drinker: Yes, In con nection with the whole technic of determin ing the material in air, length of sampling, type of apparatus, and so forth. It has been suggested that we endeavor to agree upon some uniform procedure for that and as figures begin to come in, as they will in the course of the next couple of years, we will at least have them on a comparable basis. Mr. Warren A. Cook: In that regard there is no question but what the determina tions and results of analyses of the concen tration of injurious materials in air, corre lated with pathological findings or freedom from pathological findings, are real factors in further substantiating toxic limits which are originally given us from animal experi mentation. In order to obtain data which are of value along that line it is desirable to know to what extent, in terms of milligrams per cubic meter, workers are exposed to in breathing any potentially injurious material. It seems to me that one of the things that should be done, which many of the plants and many of the organizations equipped to make determinations of injurious materials in air should do, is to make an effort to develop one group and series of results which will represent average exposures of workers to chlorinated naphthalenes. In getting that figure I think that it is of great importance that we should consider average daily exposure. There is a tendency very often in taking samples of-air to determine maximum exposures, to get the exposure over a 15 or 20 minute period when th* worker may be actually tending a pot where the material is being used, whereas during the subsequent half hour he may be 40 or BO feet away from that particular location. Therefore, for one thing. It seems to me it would be extremely desirable to obtain in formation in as many plants and as many locations as possible of the average expo sure, taking into consideration not only the worker's maximum exposure while actually 308 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sept. 1937 at work with these materials but also hia before the A. P. H. A. in October as one of much smaller exposure and possibly eren the projects which we shall carry out at lack of exposure as he may go to other parts that time. of the room or even to other departments As I have not given this consideration, I during the course of the day. am afraid my discussion is not as connected Another type of determination which as I might wish it to be. We have a real seems to be extremely desirable to have is problem here and one that deserves some concentrations of the chlorinated naph study. thalenes at certain reference points. I believe that Mr. Hemperly very carefully D. Cecil K. Dbikees: Would it be of duplicated these reference points in each service to the American Public Health Asso of the plants where he took hia determina ciation Committee if a sub-committee from tions. He took the samples, I believe, at this meeting, collected perhape by my breathing level and a certain measured dis brother and those of you involved with these tance from the pots where the chlorinated problems, were to make a recommendation naphthalenes were being handled, so that to the A. P. H. A. as to the things you have next year he could go back to those same brought up and as to suitable apparatus, locations or others could take determina and let the final statement come from the tions at those same locations, which are Association after they have considered that definitely fixed and recorded, and learn material? whether, due perhaps to clogged pipe lines or to fans which might become loaded with M*. Wabrxw A. Cooe: I think that the condensed chlorinated naphthalene, would be -a splendid idea because we have there might be poorer ventilation than origi a bulk of information on this particular nally designed and higher concentrations material. A number of individuals have of the chlorinated naphthalene than origi given much thought to the development of nally determined. apparatus, both the combustion method It seems to me that it would be an ex which we have here and also the continuous tremely desirable thing to have made avail record type of apparatus which Professor able for all of us who are making these Drinker mentioned this morning. I think determinations these reference points so that it is a sufficiently important project that in Massachusetts and in Connecticut, .that a sub-committee made up from this at one plant or at another, a considerable group could give that committee a very group of workers could be taking samples at definite steer. this one particular point with reference to (Personnel of the Sub-committee: W. A. the source of generation of the vapor. Such Cook, chairman, A. L. Coleman, H. B. El results would permit a comparison of knowl-' kins, W. B. Fulton, 3. W. Gurney, E. R. edge between plants. Hayhurst, W. F. Hemperly, F. W. Sehl, and In that regard it happens that there is a A. N. Setterlind.] committee of the American Publio Health Association which is charged with the devel Ma. Hemtxt B. Elkws (Chemist, Divi opment of chemical methods for determina sion of Occupational Hygiene, Massachu tion of atmospheric contamination such as setts State Department of Labor and Indus that now under consideration. It seems to tries, Boston, Mass.): In connection with me that it might be a very desirable project what Dr. Schwarts has said, I am not surs for that committee to consult with the in that I am in complete agreement as regards vestigator of the Halowax Corporation and the use of akin lesions as warning agents. suggest to all of those who are doing work It is my understanding that in insulated of this type, after some discussion, what wire plants the chlorinated diphenyls are reference points could be adopted and also very commonly compounded with the chlo what should be done in connection with get rinated naphthalenes. It is also my under ting these average exposures. As a matter standing that these are more likely to cause of fact our committee will discuss that very a severe akin Irritation than the straight feature and possibly include it in our report chlorinated naphthalenes. On the other 1 sol. 19, no. 7} EFI hand, from Dr. Drin judge that the straif .$& thalene was nearly a mixture of it with a : rinated diphenyl. In the condenser I our cases there is no used and no acne of ; .. *Vr ' the reports on the im . .Da. R. EimrrrKi ;ieal Co., St. Louis, M ^anything to the labor: -has been quite s littl tlon in the last sever 'our plants where we 1 inf this chlorinated i our observation that aion we did have a i series of akin eruptioi - able to attribute as U impurity in the bensi the chlorinated diphe any systemic reactic We have examined t from what laboratc might help us and f point. Also from . alone there have bee poisoning reported. I don't believe ths laboratory results ir without paying eon the volatility of diffei - "*<* ',V' way they are being > . Ds. Johw A. Hoc matologiat, Halowax Mich.): I have had ( .with the dermatolog lem. The experienc at Wyandotte definit toeis did increase i used rather than tl naphthalenes. . . From the discuss! I think the observai that tha chances ai problems will disapp .la probably true. 1 ..certain precautions, ..Ves, you might ss hiring men who ax- --oducts, eve: WATER PCB-SD0000071005 Krf. /P, no. ri EFFECTS OF CHLORINATED HYDROCARBONS 307 hand, from Dr. Drinker's work one would judge that tbe itr&ight chlorinated nsph thalene wia nearly as toxic at ieaat aa the mixture of it with a email amount of chlo? . rinated diphenyl. ' In the condenser factory where we had our cases there is no chlorinated diphenyl ----------- uied and no acne of the type described in . the reports on the insulated wire factories. Da. R. Emmett Kellt (Monsanto Chem ical Co., St. Louis, Mo.): I can't contribute ` ' anything to the laboratory studies but there ';has been quite a little human experimenta" . tion In the last several years, especially at _. _ our plants where we have been manufactur___ ing this chlorinated diphenyl. It has been our observation that although on one occa. . sion we did have a more or less extensive . . series of skin eruptions which we were never .... able to attribute aa to cause, whether it was ' ' Impurity in the benxene we were using or to . the chlorinated diphenyl, we have never had any systemic reactions at all in our men. _____ We have examined them very closely both . from what laboratory testa we thought might help us and from the clinical view point. Also from chlorinated diphenyl ' alone there have been no cases of systemic " poisoning reported. I don't believe that we can transpose tbe laboratory results into the actual humans without paying considerable attention to the volatility of different substances and the way they are being used. Da. Joint A. Hooext (Consulting Der . . i.'. j- matologist, Halowax Corporation, Detroit, ' -.ii'-- Mich.): I have had considerable experience with the dermatological angle of this prob- ~V >; ten. Tbe experience at the Halowax plant r .V. . t Wyandotte definitely was that the derma- te*is did Increase when compounds were rather than the straight chlorinated ^"^.naphthalenee. . ^rom Ik discussion wa have heard today the observation Dr. Drinker made | r the chances are that dermatological ; i.\-^^ Prohlems will disappear along with the other is probably true. However, I think that -T-^Tirr-'^artaln precautions, certain insurance meaa- '.v S*!y.-`vurea, you might say, should be taken In f.^fc^'C^Wng men who are going to work with Products, even though wa are going to attempt to get the concentrations low. We saw this morning that the effect of these producta was on the liver and that if aome one working in these products developed liver d&msge from eome other source the chances of his having serious trouble was increased. Therefore, inasmuch as there is no test to tell whether a person has had liver disease, certainly in the preliminary medical examination of applicants for vrork the his tory at least should be gone into very care fully for a history of previous liver disease*. There are other things that should be taken into consideration also. One is the history of syphilis, because syphilis doe* have an effect on the liver. If there is any history of syphilis I don't think that that man should be hired. A Kahn test should be taken and I think that it would be a good plan to take Kahn tests on men at stated intervals, because they might develop syphilis aiter they are hired. I think those things should be done even though we feel that if the concentration of these vapors in the air is kept as low as was recommended this morning, the chances of having toxic effects are very small. Ma. F. R. Kanos*: I would like to clarity a point of Dr. Hookey1*. You mentioned at the beginning of your talk that your experience in acne condition was more pronounced from the compound* of various materials with chloronsphthalene than with the straight chloronaphthalenea. Did you mean by that, that the acne condi tion actually was more pronounced with the compound* than with the straight ehloronaphthalene or was that due to the fact that you were in a plant operated in a different fashion! In other words, you handled your numerous wire compounds in more of a batch operation. That is my understand ing from Mr. Brown. I* it a fact that the straight chloronaph thalenea are lea* harmful in eo far aa acne I* concerned or 1* it because of the handling of batch compound#! - Da. Josh A. Hooxst: That Is a question that would be difficult to answer. I based my statement on the fact that in taking a general survey of these cases after 1 started working with them the men in the plant aald I. ! Mi tggwsgmOTnBfgs^ 308 JOURNAL OF INDUSTRIAL HYGIENE ANP TOXICOLOGY [Sepf. ISST that they developed acne more often and more severely after they atarted making compound*. It may be that it waa in the method of the handling. Mb. F. R. Kaimer: You aay that the con dition increases with the increased chlorine content and we are attributing the acne pri marily to the chlorine radical. If that Is true, what are we to associate insofar aa these various other constituent* are con cerned, such a* various plasticising agents? How much do we know about those insofar as development of acne is concerned? Some of these compounds have a half dozen con stituents in them other than chlorodiphenyl and chloronaphthalene. We are at the present time considering the chloronaphthalene aa the basic element responsible for the acne condition which we have. We know very little about what the other mate rials may or may not do. Dr. John A. Hooeet: I don't know about these other materials. Perhaps Dr. Schwarts would know something more about them. ' Dr. Louis Schwarts: It is well known in industry that there are many compound* that cause acne. For instance, paraffin acne* and oil acne* have been known for a long time. Paraffin acnes, wax acne*, are simply a mechanical plugging of the fol licles of the skin by the minute particle* of wax that fail on the skin. I think that the acne caused by these chlorinated naph thalene* and diphenyl*, because it is caused by both--I wa* down at the Swan Chemical Company where they make chlorinated di phenyl* and they have acne there just the same a* over at Wyandotte where they make the chlorinated naphthalene*--I believe that that is caused by the tame thing, a blocking up of the follicles of the skin, the formation of the eomedone and then the comedone become* infected and form* a pustule. They don't all pustulate because they don't all become Infected. Many of these men never have any pustule*. They just hare little white elevation* on their kin. In those people who are in the acne age, the youngster* of 18, 20, 22 and 23, acne vulgari* is mo*t apt to occur. The sebace ous glands are most active and they seem to have it much more than the older people in whom the sebaceous glands are not so active. We keep a clipping of all articles relating to industrial dermatitis in my office and I recently read an article in a German maga zine In which they report In Germany a similar acne condition from chlorinated phenol* and chlorinated benzenes and solid waxes. It seem* that this acne-like condi tion is not peculiar to halowax or chlorin ated naphthalene* or diphenyl* but can occur with any condition that block* up the sebaceous follicles of the akin. D*. Rotal Meiesr (8pecial Agent, State of Connecticut Department of Labor. Hartford, Conn.): I am full of question*. As a statistician I am a little bit suspicious of average*, so I should think that we should take maxima a* well aa averages in getting at the threshold dose or the dangerous im pregnation of the atmosphere with thcie poisonous compounds. I just wanted to drop that as a hint for thia committee to consider in it* work. In spite of what you said at luncheon, Dr. Drinker, I still think it it rather impor tant to determine how the plugging of the pores actually does occur, whether they are plugged as Dr. Schwartz has suggested, from the particles failing on the outside of the akin or whether they are plugged, aa so many doctors have informed me, from inside as it were. The fumes sre breathed, the substance gets into the blood stream. It is thrown off through the pores of the skin and the pore* are plugged. I think it la rather important to determine that because it seems to me, from the slight knowledge that I have of the industrial application of halowax compounds in insulating wires, that the plugging of the skin, if it is just an out side plugging, msy take place either from handling a solid substance or from the coating on the wire after it become* cold. I haven't heard anybody aay anything about those Massachusetts cases of very severe dermatitis and I am not so sure but what there waa some question of liver dam age there. Nobody has said anything about them at all. There is no question there r-;*i;s. ' . Igs r - .. woe fumi Inati "'tor fov*:. .w jilse . &r:-s:~r- WATER PCB-SD0000071007 . . *>l. tt, no. 7] EFFECTS OF CHLORINATED HYDROCARBONS 309 that the condition, whatever the complica tion* might have been, came from handling cold wire, in a confined area of course. I think this needs a great deal more study, Dr. Drinker, than you and your aaaoclatea ' have been able to give it aa yet. All I am curious about ia the way we can administer the protective labor tawi in order to protect both the employer and the employee. ' . . . I listened with very great interest to the exposition* of suggested pots for the appli- cation of haiowax, chlorinated naphthalene ' and diphenyl. It seemed to me that they . _ ' left very much to be desired. I don't see why the application of the haiowax com pound, if it is necessary, aa I assume it is, . . to use this rather dangerous substance, can't ' be done in a practically closed pot. If you ........... please, Dr. Drinker, I wish you would ask Mr. Reeves of the Rockbestos Products Corporation to tell how they have handled it. If I am any judge of equipment and ----------- safety devices they have come aa near to eliminating entirely from the atmosphere all contamination from fumigated or evapo rated haiowax as anyone. All of the appli cation of haiowax, either in the melting pots or where it is applied to the wire, is done under hooding and with ventilating appa ratus, and it seem* to be entirely adequate. wax we had a head itart a* far as the ventilating system was concerned, since oura was already Installed and adaptable to a compound with a bensene solvent rather than a melted haiowax compound. In order to keep the fumes of a highly volatile sol- vent under control we did develop a prac tically complete enclosure for the container in which the compound was placed and exhausted that container in order to prevent any escape of the fumes from it. When we changed to the haiowax compounds we fol- lowed the same scheme of applying the compounds and used a completely enclosed pot. There is a hole In one side for the wire to go In and one on the other side for the wire to come out. There Is enough exhaust suction on the enclosure to prevent any fumea from getting out of the opening* where the wire enters and leaves. Of coarse periodically it is necessary to open the pot to replenish the compound or make adjust ments. In that case we have the ventilat ing system interlocked with the door that the operator opena so that when he opens It he increases the amount of air travel about ten-fold. ' '' > . . Dm. Rorai. Mxtxxm: What is the velooity when the door is open? - : * -; " - . " "i " M*. B. H. Rxxvxa (Vice-president and General Manager, Rockbestos Products ._ Corporation, New Haven, Conn.): I will be -' -. very glad to tell of our experience if it will . :'! help the picture along. Our experience has - - been more or less parallel with Mr, Kaimer's in as much as we manufacture the same type ` V of wire. We have avoided the serious pic- -j. ture that he ran into, probably due to the * . fact that shortly after 1923 we were using . -.r r bensene as a solvent for asphaltic materials. . . ' W* got into anemia difficulties with ben- r'i'--;) ne fumes and had to install a complete .S*,y ventilating system to remove all those _ -s . fume* from the machines that applied the "* ^ v compounds to the wire. Following the VS?*? ' Installation of that equipment we were able .' to get * substitute for bensene, so we got it soutof**"P^ure. ' ./TvCij'o' i We are still In the same fix as every one -`Vvi'-ir* 1* a* far as finding a substitute for halo- W4X* There is none that we know of. Con- Mquently when we went to the use of halo * *, \ /.* /.** *. v. /.* * ; \i- : . . Mm. B. H. Rxmvxa: With the door wide open, at breathing level the velocity is 200 feet. That is ' the linear velocity. We check that every week on every opening at every machine with a velometer, a small Instrument which Is easy enough to operate and reads directly. Whenever the velocity falls below that figure the pipe connecting that machine is taken down and cleaned, because there will be condensation inside the pipe to cut down the air flow and reduce the ventilation .efficiency. Da, Rotax, Mxxxxm: What do you think of that trap device ahownT M*. B. H. Rjuttm: I don't know what to think of that. I don't know whether it would be practical or not. I was going to ask Dr. Drinker whether in passing the air laden with haiowax fumes through the boxes of rate there was any deposit of haiowax in the enclosure. ' WATER PCB-SD0000071008 310 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY (Sept. 19S7 Db. Cecil K. Drinker: Yea. It ia detectable readily through the outflow pipe. Mi. B. H. Reives: Those in the far end probably didn't get the concentration. Da. Cecil K. Drinker: We change the position of the boxes each day. The ones furthest away move into the nearest posi tion, so that over a period of weeks all are exposed equally. complaints were bona fide. We had no dif ficulty in bandling cold wire and the men had no akin trouble. Yet when they did the same thing with possibly the application of heat in tunnels, ships and so forth, they actually did develop trouble. We have used, of course, the icterus index in following some carbon tetrachloride cases and I wondered what you have to say about that. Ia that of no value at all In the case of liver damage in this material? Da. Eiciht R. Hathcmt (Consultant in Industrial Hygiene, State Department of Health, Columbus, Ohio): I would like to ask if it wouldn't be possible to put a cold water line around that trap and deposit it all before the air escapes from the trap. Mr. B. H. Reives: We have tried cool ing the surface of the exhaust pipes in order to concentrate the deposit In one place and make it unnecessary to remove long lengths of the ventilating system. While we have found a slight advantage in doing so it hasn't at all paid for the expense. It is much easier to take the piping down. Con sequently I doubt the possibility of remov ing it all by cooling the surfaces of the trap. It might be possible, by building a labyrinth of refrigerating coils, to collect it. But then you would have the problem of remov ing it from the coils after you had collected it and it would involve rather complicated procedure. Dr, B. L. VoaauaoH (Medical Director, General Electric Company, Schenectady, New York): We have heard about the pos sibility of preventing liver damage and skin trouble among manufacturers of wires and cables and so forth, but like the old rhyme, every dog has fleas and the fleas have fleas, we also have customers who use wires and cables in tunnels, in enclosed spaces, splic ing them together and doing all aorta of thingi. I am not at all certain that wa know what the concentration of these chlorinated hydrocarbons la under those condition*. About tha time we were having so much trouble at our York factory some of our customers began complaining. We thought we were having a hysteria of halowax mania throughout the country. Some of their Dr. Cecil K. Drinker: I don't think so until it gets so extreme that we know it any way. Da. B. L. Vosbobqh: I did write down a few questions that came to mind. Some of them have been answered and some are foolish but I shall ask them anyhow. It occurred to me that if trichloraaphthalene has been proved to be practically innocuous, isn't it a problem of research largely for the Halowax Corporation to use only that one material adopted with other known chlorinated compounds to meet the requirement* of customers? That is one of the foolish ones probably, but I shall just ask it. Furthermore, how long it it reasonable to expect the liver to recover after it has been pretty well damaged. I talked to you and you aald you hadn't worked that out with the animals as yet. Da. Cecil X. Drjnxir: In that case we set aside a certain number of animals to recover, after knowing that a certain amount of damage had been done. Then we started to kill them but we invariably ran out of rats before they ran out of lesions. We don't know how long it last*. Da. B. L. Voshtroh: Have you given them calcium and glucose ai you would with carbon tetrachloride? Da. Cecil K. Drinxxr: Not yet, but we are doing an experiment now with one group on a very high calcium diet and another group on a ealoium free diet. The whole question of calcium In the diet, of giving milk daily to three people may be worth while. . voi. it, no. 7} EF: Da. B. L. Vosbd . questions in mind. i i. whst Mr. Brown woi bility of using oni; . j As * : chlorinated napbths ' ,, M*. BxKnroRD ? simplify our problen . , v -u- from the commercie .the toxicity standpi /.tiC'it ' I think that Mr. Ki .to object because he the technical effects The same thing ap[ industry where we ".^AV - ^hlortnated product A?'' Tha problem as which we Intend to our program for th ' will be done undi --. . Drinker brothers), . - demarcation and w .. complicated chem ! r'C,-; ' sows one thing th/ - w* eou^ take hr ' ' remove 1 percent' ' uent with which ' ' and eliminate the . ___ .a lovely solution. able to attain thr - one of the things .Km I said befor with which all m thetic organic pi , tome stage, eithe commercial deve question of timir . ths work, how . . . whether you kne ' to learn that fin " ?'V I.'; ' . Dr. Cecil K. some other imp< th* meeting adj Dr. R. R. I mors with reg*/ ` on syphilis? I .. ^rour work rv~*~ ' ^'.'i"'''irA WATER PCB-SD0000071009 *,1. 19, no. 7] EFFECTS OF CHLORINATED HYDROCARBONS 311 Dr. B. L. Vosburcjh: I just had those questions in mind. 1 would like to hear what Mr. Brown would say as to the possi bility of using only this one innocuous chlorinated naphthalene. Ms. Sandroan Brown: That would simplify our problem exceedingly, not only from the commercial standpoint but from the toxicity standpoint. But if we did so I think that Mr. Kaimer would be the first to object because he wouldn't be able to get the technical effects he desires in the cable. The same thing applies throughout all the Industry where we are using these higher chlorinated products. The problem as we see it, and it is one which we intend to study further (we have our program for this continuous work that will be done under the direction of the Drinker brothers), is to try to find a line of demarcation and whether or not within this complicated chemical structure there is some one thing that causes the trouble. If we could take hexachlornaphthalene and remove l per cent of some unknown constit uent with which we are not now familiar and eliminate the toxicity, that would be a lovely solution. Whether we will ever be able to attain that I don't know. That is one of the things we have in mind. As I said before, that is one of the things with which all manufacturers of these syn thetic organic products are confronted at some stage, either in their laboratories or in commercial developments. It is largely a question of timing as to when you should do the work, how much you should do, and whether you know how to do it. You hare to learn that first. - Dr. CsctlK. Drinks: Unless there Is ' some other important matter I will declare the meeting adjourned. - . v ... Dm. R. R. Banns: May I say a word . more with regard to what Dr. Hookey stated , on syphilis! If you are going to eliminate ~all'jour workers who happen to develop syphilis during the time they are working for you, you are probabty going to lose some very important employees. It would seem that it would be worth while to give serious consideration to seeing that conditions are proper and suitable for them to continue working for you and that they have proper treatment. In other words, I don't believe that is a good or sufficient reason for dis charging those employees who do derelop syphilis. We have not found that to be true in other places and I question whether this is one of the place*. I may be in error. Mr. SaNDroRD Brown: I want to take this occasion to express on behalf of the Halowax Corporation my thank* for the excellent cooperation we have received from various state authorities and our customers as well in this investigation. I believe you have all formed the opinion, based on what you have heard this morning, that our whole motive here is to conduct this on an ethical, scientific and constructive basis. In collaboration with the MonsantoChemical Company we have a much more comprehensive program In view to cany on. Therefore we want to continue that same type of cooperation. There is one thing that I want to bring up in that connection, which will have to be observed by the state authorities, when they go out to make these inspections. That ii the necessity of not creating mob hysteria on the part of the workmen in the plants where these inspections are made. Mr. Hemperly has run into some very interest ing situations in the various examinations he has made. I know that he would be glad to relate them and give the benefit of his experience to the heads of any of these state departments who will have the direction of this work. Otherwise I can see where we will be unable to get the full cooperation of not only the individual workmen but the plant foremen and the management, and we must have that if we are to get the results that we are shooting for over the next sev eral months or years. This thing may con tinue, probably will continue for years. _ . WATER PCB-SD0000071011 .jr V f r( V KZPCET TO THE LSSSJCJTO CEZJSCAL CaPANT by Cecil XL. Drlntar, 11.3. Doan and Prafaooor of Fhyiiolcgy Eai-rard School of Public Health, Boacon, Maas. J -mA r S4pteror 13, 13 ZQ e * h CC J >, j c no WATER PCB-SD0000071012 V < V V i Experiments to determine the possible toxicity of aubatancea: ................................................................................. 1. Chlorcosans ............................................................................ 2. ' Diphenyl phthalats ........................ .... ................................. 3. Chlorinated diphenyl #1258 ........................................... 4. liixiuro of chlorinated diphenyl and chlorinated diphenyl benzene #5460 ..................................................... 2 2 3 4 7 II. Sens general considerations:....................................................................... 9 1. Dridence far the destruction of a mixture of ponta and baxAchlornaphthalenes (#1006) in the body.................... 9 2. The effect of increasing the sodium chloride in the- .. diet upon animads recolTing tenia doses of #1CG6 .... 10 3. The effect of high and lenr calcium intake on animals inhaling high concentrations of #1006 ...................................... 10 4. The effect of injections of xanthine on animals <"ha! <r.g high concentrations of #1006 ...................................... 11 >... - /? > k V . - TV . .u CC3^1 WATER PCB-SD0000071013 1. CZLCP.COSA'G On July 14, 1937, w> were informed by 7. D. Smith that each 6 ounce bottle of a soft drink night contain 60 to 70 ngn. of chlorcosano. Thara \ras no pharmacological reason to balirra the confound would be irritating or toxic in any way, and tharafora it mi decided to dose rata with it Tery haaTily, the argument being that if they aurriTed heavy dosage without any evidence of damage a Tardlct of no tcxicity night be giren and auch tin* sarrad. If, on the other hand, the large doses proved poisonous it would be neceaaary to reduce doaage until a non-toxic level was reached. The first of theao altematiTea proved correct. . ' Sxpgringnta. -- August 10, 19 3 7 . 20 adult white rata ranging in weight frca. 162 to 210 gn. were each fed 70 ngn. of chlcrcosane in 1 cc. of olive oil daily by stomach tuba. These a n Ire la showed no evidence of danago in any way attributable to chlcrcoeano. They were examined aicrsacopically from the 35th to the 92nd day. The only constant change observed was a possible alight increase in the granularity of the cells of the liTer ecrds, but the "p'at'ho'lo'gist "in"'charge" f #"lt "t hia' "to'be wi thin normal "limits. This finding is doubly reassuring since many of the animals developed a chronic suppurative lung condition very prevalent in 3oatoa stock rata at the time. But even with this added handicap thara was no evidence of damage and we thus conclude that chlorooeane even in enormous dosage is an inert material in the body and in al_ probability passes through the intestine unchanged. Au r WATER PCB-SD0000071014 rv. v -c VV - 2. DITEZSTL Pzrzmzs On iuiguat 23, 1337, wo were informed try Dr. H. I. Kel*l-yV th*-3*- ur_0 --/ -- phtbalata night bo abacrbed through tho sldn or right bo inhaled md swallowed during a praying operation*. -AX tor consultation it was decided to fead haaTliy, and if tharo woro indicationa of toxicity to project other axparireata. Error in sat a. -- September 20, 1937. 20 adult white rata ranging In weight frcn 242 to 301 go. ware each fad 0.5 mga. of diphenyl phthal'ata auaponded in 1 cc. of water by stomach tube daily. The animals were frcn new stock: and ' .* with one exception remained cloar of the lung condition which axiated in tho % chlorcooano group. During the period of axporinont, which lasted 92 day a, practically all the animala gained waight. Examination of 8 animals 3d Hod at Intar-rala during thia period of teat reaultad ae follow: The organa waro norml groaaly, and on nicroacopic exanination tho liTer alcno wras of poaaibla intaroat. The cbangoa in the liTer Tariod fron thoaa in which the calls of tho liver c'cria wore almost normal, haring only a alight a welling and gr t of thair cytcrplajra, to thnao in which theao change* were pronounced. In tho latter there was a moderate degree of racuciization ' 'and''a"* rare'* byrdiho "b'od^-V"" Iheo'e 'alt or at Iona it" must be understood" were t ha result of Tory certain doaage, since the compound waa giTon by stomach tuba and the animals had no poaaible way of aToiding.il. 1'aither the pathologist nor myself was able to consider them of enough moment to cause ua to maJbs further experiments. I am confident that with the ordinary precautic--j accompanyng ax--.ay lacquering no poaeible bam could bo done, eren if the concentration of diphenyl phthalate in the lacquer waa far above the 3 ter cent figura given ua by R. 2. Kelly. .-u CC3-. 23 do WATER PCB-SD0000071015 This natorial was furnished by tha licmsanto Chemical Company, it WSS said to haT# a chloric content of 68 pr cent,, tha highest chlorine f ' -- 5 of any compound t##td by us during th# past thro# years. It had been our impression that toxicity and chlcrirus content followed cue another closely, but this hu not turned out to b tha caaa for #1 P.6B .TTtrf-r-*-i: >^^1. Trir.\ cntarxxxxrperrtxx rurthar diacusaion of this point will follow tha description of tha experimental obaorrations and thair results. Hmsrimants. -- August 2, 1937. Tha compound #1268 was administered by inhalation, tha techniq.ua being that described in tha paper entitled The Problem of Possible Systemic Zff9cta from Certain Chlorinated Hydrocarbons. Journal of Industrial Hygiene, 1937, 19. 283. For tha first obaorrations 60 adult whit# rats were usad. They war# exposed as follows: Group 1. -- 60 anial.1. Temperature to which tha compound was heated to introduce fume into air line 140-190 C. Arerago concantraticn in air breathed by rata 0.33 rgy- per cubic rotor. ATerage daily expoeura 16 hours. The experiment was continued for 119 days, animals being eacrificed at interrals for pathological examination and for th# carboa.t_etrachlorido__and alcohol. .test^^..^ (see paper preTiously cited). The conditions described abore caused swelling and increase of granularity of the liTer colls. Hyalin# inclusions were rax#. Thes# changoe ware quite uniform in all animals examined after th# 31st day, but wore not certainly progre#eiT#. Tha rata war# T*ry healthy throughout tha period and there was an almost uniform gain in weight. The carbon tatrachlcrido-olcohol teat was positiT# after 32 days, which indicates that though liter damage was apparently slight some degree of harm had been done tha organ. There was no eridanc# cf * " " ' ' ` rgp C C 3 j w 26 WATER PCB-SD0000071016 r V v c V( damage in any part of the body except the liver. At the and of 93 (Lays 10 rata, apparently in excellent ccnditic" were removed from the experiment and aot aalda for observations upon liver recovery. Those recovery animals shewed no clinical changes of any sort. pve3 sacrificed 72 and 141 days after removal fret: exposure it was obaarved that the swelling of tha liver cells had disappeared, but the granular and hyalins material regained in tha li7or cells and had apparently become permanent. Thera was absolutely so progression of damga after removal from exposure. Those changes nay be compared with.those produced in rats by inhalation of chlorinated diphenyl #4463, administered in a similar manner in concentra tions of 0.57 to 0.93 ngn. per cubic motor error similar periods of tin*. In tha case of this compound the conspicuous difference was tha far greater incidence of hyalinination of the liver cells, which in our opinion was the characteristic lesion caused by #4465 and mixtures containing it. One can therefore conclude that #1258 in low concentrations is definitely less toxic than #'4455. Group 2. -- After 119 days, the low concentration of #1253 having proved but slightly poisonous, it was decided to increase the ccncentrntion in the air breathed by the 54 rats then rgraining. Temperature and other conditions vers 'maintained as during tha first 119 days, but by the use of 4 vaperiners instead of 1 tha average ccmcentraticn of #1258 in the air was brought to 6.23 mgn. per cubic matsr of air. Zxposur* to this very high concentration was continued for 87 days, Under these :cmo conditions the animals again remained in p: >alth. The carbon tetrachloride and alcohol test was positive but tiers vas absolutely no other indication cf liver damage and no evidence of disturbance to other organs. CC3`'3 *> WATER PCB-SD0000071017 ntan examined at autopsy at t La end of 87 days -- the er.i-.i ^ v.d . experienced a total exposure of 2C6 days -- tharo vara 0.0 gross evida-cea of abnormality In any part. Cn microscopic axsr.i r at Ion no organ shewed changes axcopt tha liter. The number of calls containing hyaline and the amount of hyaline In tha calls inrolrad increased during tils period of arpoaura to tha Mgher concentration of #1258. Tha hyaiina was most abundant in tha portal zon of tha lobule with Tar7 little In tha central area. Aftar 42 days of expooura 10 rata ware set aaida and wore aacrificod 73 days later. Hay were in excelled condition whan removed and did not change. Grossly, at autopsy, they shared nothing abnormal, and on microscopic examination the liver cells had lest theirswelling but retained increased granularity and hyaline inclusions. The experiments on inhalations of high concentrations of #1258 reenforce the conclusion that this compound is of low toxicity as compared with #4465 cr with chlorinated naphthalenes aboTe trichlornaphthalene. Tha question as to why #1253, the moat highly chlorinated compound tested, proTed tut slightly harmful cannot be answered with any dofiritaness. It has been suggested that the toxicity of * 1 1 these chlorinated compounds, even though of vtriod composition, may depend on the ability of the animal to decompose than after lodgment in tha tissues, and that this decomposition might be shewn by an increase in the chlcri: In. the urine in suitably conducted feeding experinants. In experiments upon, thi: point we hare shown a definite increase in the urinary chlorides when dogs and rats were fed a mixture of ponta and haxachlcmaphthalanes (#1005), a compound highly injurious to the liTor and containing 62.5 per cent of chlorine, but 3 ini I observations haTo not been made with any of tha chlcrina:ad diphenyls cr allied compounds. It may, however, be that whan about 65 per cent chlorination is reach the substances formed are quite stable in the bed- and so c aus a a minium of damage. huf1 Clisoc WATER PCB-SD0000071018 V la conclusion, #1263, if handled with ordinary precautions as to ventila tion should b entirely hartalea a to wcriman. TThila it .cannot ha give- e_m absolutely cloaa bill u to health, it is profarable to #4465 and -5460. 4. HTC7JR3 CJ CELOHIHAIHD DIFEZNYI. AND CHLCP.liAlZD DDFEZl.T!. 33KZE0C -- COMPOUND #5460 . This eubatsace -was furnished by the Monsanto Chemical Company and rma said to have a chlorine, content of 60 par cent, being in this respect below #4465 and far below #1263. ' Ebcoerirants. -- The Inhalation technique was used as in the case of #1263 and #4465. . August 2, 1937. 80 adult white rata were the subjects. Temperature tc which, the compound was heated to Introduce fume into the air line 140-196 C. Average concentration in air breathed b7 rata 0.CE5 ugn. per cubic meter. Average daily exposure 16 hours. The'experiment lasted 119 days, a certain nunbar of animals Irene sacrificed for pathological examination, others wore used for tha carbon tetrachloride and alcohol toot, and still ethers eat aside for observations as to rocovory from possible damage. In spite of the fact that the concentration in the air breathed by the rata averaged about 1/6 that obtained at comparable temperatures from #1268, a number erf these became olei and lost weight towards the end of the second month of exposure. TThan tilled, such Individuals showed gross mottling of the liver but no changes In other organs. Cn microscopic examination swelling of tha liver cells, lncrsasod granularity and hyaline inclusions ware noted in tnimain tilled as #inly as the 16th day of exposure. These changes csTicusly occurred rapidly. Hyaline deposits ware refer as numerous as with #1263. Animals > i 27 29 WATER PCB-SD0000071019 removed forlreccrrary aftar 51 and 119 days of exposure did net gain narkadly In -weight, and on* dial Tor no obvious causa. TThon examined at autopsy tbs . mailing of''tha liTor calls had subsided, but abnormal granularity and hyalinination racaiaad. ` Needless to say the carbon tetrachloride and alcohol test was positive a-hensveiNUsed. ` IaTl8Wof tha fact that #5460 in such low concentration proved ao definitaly toxic, no higher concentrations wora tasted. It seers irperative that -t'Krwwr; this compound is used in industry, great care ba taken to knap concentrations in tha air at an extremely low lerel. No liberties can be taken vith idr., as with #1263. C C 2 * .5 c 30 WATER PCB-SD0000071020 'V v C v H. sets crrzRAL cc?: Ia additioa to those taati of conpouadi, certain experiranta sera dona which are of interest to thcae manufacturing or using chloriaatod hydrocarbcas, Details a_a %a these experiranta are of course arailablo but aro not included ia this report aiaco they ara not' of dlract industrial latereat. < - -ir_. 1. .S7Z32ICS ICE TEZ UZS'SUCTIOl? O' A IUXEJHZ C? PHTTA AIO HZJACZLCEKAPHTSAL^ES (#1006) El TZZ 3CET ' It baa always been a question aa to whether the chlorinated hydrocarbons which have bean examined by ourselves aad by others do ham per ae cr whether toxicity dapeada on their breakdown la the'body with the .liberation of some thing harmful to the liTer. A partial answer has boon obtaiaed by feeding flOOS to rats and dogs which were oa a lew chloride diet with unifem excretica of chlorides la the urine, when these animis received the chlorinated hydrocarbon (?1CC6) the urinary chlcridea rose. Ihi idicatas that the body certainly has power to detach chicriao from this c: L, and 1 -It 1-a- - prob abi o -that-'-the- s mr'iradi t i trPl s' -1 ru b - f Cr 'alii s d toxic' cc"p curin'." "'If3 would be moat interesting to see whether ingestion of ?12S3 results 1a similar findings ox whethar ia the case of this relatively nca-toxic compound thero ia practically ao splitting off of chicriao. Neither tire acr our fiaaacial resources permitted such tests. c l-C 3 h 3 31 WATER PCB-SD0000071021 r K \. - .r * c (( 2. Thi at*'uCT C7 dCmiSim ''- * SCDPH. vno | OPQT ANDdALS RZCZTTZC Idle DCSZS C7 jflCC`6 On the ground that chlorides might bo fundamentally asaociatad *i:h toxicity, a group of IS rata vas fad a lorn toxic dcao of #1CC6 and compared with a similar group on the jam doaaga of flCQ6 plua a narked increase chlorlda intake secured by giving 3 cc. per kilograr of body unigim 0f 4 per. cent NaCl solution daily. - Wo difference* were found between the two groups, and it ray be concluded that chlorine incroaea secured through the diet does not enhance toxicity. This experiment was done in order to find out whether increase in chloride Intake during hot weather night be hamful. A particular phaae of the problem, the poesibla enhance rent of typical akin leaiona by increasing chloride intake, cannot be decided by experiments on fur-bearing an 1,rails with no sebaceous glands. All that can be said' at the recant is that increased chloride intake does not increase systemic toxicity. ' 3. TSZ U7BCT C? HIGH AKD LOV/ CAICini Z7Z1ZZ Cl AirH'AlS ' HEALHIG HIGH CClICZWZ'JuTC.'S C? flCC6 It is well known that a diet rich in calcium is markedly effective in preventing the acute yellow atrophy of the liver produced carbon totrachlorida (The Prevention and Treatmant of Carbon Tetrachloride Intoxication, By P. D. Larson, WJJ., A. 3. Uinct, Ph.D., and 3. H. Bobbins, 11.2., Journal of the American kedical Association, 1923, to lure 50, page 2-i 3) . To discover whether calcium in the diet would protect against liver inr WATER PCB-SD0000071022 r V V e free a "telle chlorinatad hydrocarbon, 30 adult white rata vara ;l--e^ --- a dlat of loan horaoneat, itarch and. lard, a combination adacuata................................... but Tory lew la calcium. Another group was giren a diet coasts*'-- -v* j,,, . J v w* Wv6 chow, nili, lettuce and *553, with added calcium lactato -- a ratten Tory high la calcium. Both groups war* exposed aimultaneoualy to la halation of hig^ concentra tions of flOOS, aa aTsraga of 11.21 ngm. p*r cubia cater for IS hours a day.' After 16 days, 12 high calcium diat rata wars' aliTs and 7 of the low calcium group. At latarTaLa tains la were killed for examination. In both groups ths liTer was abnormal grossly and nlcroscoplcally, and. in both, groups * animals died from. llrer damage. It was impossible to consider that the high . calcium diat was in. tho least degrea protactiTa. It nay, thorofera, ba . concluded that adding calcium to tha diat of workers either in tha form of extra milk or of calcium lactate will not prarant llTar damage. 4. TrZ ZPF2CT CF HJJZCTICOS C? lANTHuia Clf A1.T23AL3 TN-FlT.T?:r. Hica CaNCZhTPAITC.'S C? f 1CC6 la 1937, H. C. Noel# publiahad a brief paper (Tha ProtactiTa Action of Certain Purines against LiTer Kecrceis Produced by Carbon Tetrachloride and Chloroform. Solenca, 1937, Tolume 86, page 83). Ea claimed that rata lnjeoted with sodium xanthine became markedly resistant to carbon tetrachloride. This suggested that xanthine might hare s imilar protoctiTo power over liTer damage from tha chlorinated hydrocarbons on examlna cn .n laboratory. .accordingly 38 adult whits rata wars causod to inhale -12C6 in oontontratiens aTeragim? 13 ngm. per cubic meter fer 15 hours daily. Cns group of 20 rata was giTen 20 ngm. of ranthin* subcutaneously rrery other lay and to mgr dO CCl^sl 33 WATER PCB-SD0000071023 V at xantbiaa trj tccaeh tub* cm tbs altamats days. Tbs ssccnd group of 13 rata bad tbs sens axjosuro to i*10C6 without xantbiaa treatment. Ko dlff&rtacea Vrora notd tad on* o&nnot arpact any efficacy from xant bln* itbr in tbs prsrenticn or treatment of liTsr diasoas du* to this chlorinated hydrocarbon, and in all probability tbs asms nsgatlTs rsrult oould b* enccuatsrad la connection with allisd toxic oocpctmda. T ii "V ** ;; 3 s i WATER_PCB-SD0000071024 WATER PCB-SD0000071025 V ?J?C3T c: +445 Inhalation Frogrtract a Animals. fhita rata haTO boan employed throughout. They p^nnit tha ua of a. Largs number of animals In a relatively .small Inhalation installation. They thrirs upon a diot very similar to roan, n twfl caas of thaas chlorinated ccnpounda It la poaalbls that diet nay ba vary aignificaci. Finally, thol'r nornal characteriatlca hava been described ao vail aa to make tha detection of ahnarralitloa both aaay and certain. Hat hod of Exposure. The Inhalation experiments vero carried out ' .s in four large air-tight wooden boxes, each capable of holding ten rat cagoo, alza 22" X 22" x 14", In two tiara'of five cagoa each. Khan the experiment waa not in progroaa the doora were opened vide and the cagea kept la place- (see Figuro l). . At the center of one end of each box -- the inflow ond -- air was introduced through a pipa 7 inchaa In diameter (aee Figuro 2). Zach box waa equipped with an individual electric blower which blew the air through aoreral feet of 7-inch, pipa before entering the end of the box. An orifice was placod in tha pipe line, and tha flow of air in cubic fort per minute could be road off directly free calibrated flew met era. A damper placed at the entrance of the pi?o into the box woe adjusted to aaauro a unifera diatributlcn cf the atrsem of air to tha two tiers of cages. At tha oppoeite end of tha bex -- the out flew ond -- the sir flan each box was exhausted through a 7-lnch pipe fitted with a damper and eonnoctod to a largo central exhaust fan (soo Figure 2). About 4 inchaa from tha ontramca of tha 7-lnch pipe into the box, the funaa of the substance ware introduced into the inflowing air. . 2 <, 1 uo WATER PCB-SD0000071026 Specially dosigned pyrox glass flasks (Jiguro *), 7 3/4" long and a diameter of 1 l/2", war# used to hold tha heated waxes. Tieae riask.s / nora cad# with a aids ora and tuba which extend#! to tha fcottan V top of tha flask wa ground, and into this fitted a short tube 1 1/2" < length. Thlo short tuba waa inserted into a largo rubber atcppar uxich fitted tightly into a hole cut out of tha 7-lnch pipe ca the under aid# (aaa Tigura 2). The flask in turn was placed in an electric heater rndo to coTor it completely below tha aid# arm and ground glass top. Rubber tubing connactad tha aida era with a compressed air reservoir and a gentla stream of air blown through tha iheltod wax kept it in . motion and asaurod uniform heating. Into each final: was Inserted d long stem caatigrada thermometer which waa kept in placo and could bo read at any tine abom tha 7-inch pipo through which it passed (see Jiguro 2). Approximately 29 gm. of pulverized ghctonanaao.jLxip.nv-cvVLxlv:xx chlorinated diphonyl wore placed in tha YapbriziAgsniu flask and malted in tha electric heater. Trash samples were used every other V. day,, tarxitn--n-i ,, killanidm.l, 1:'rrxxnnnrrxxkxxniicscfc zkkxni. xSs a_x A.^ [ho collected sublixnto was always rcmoTed from the upper part cf tho flask end a clean top used each day. No sample was over used for more than two runs. Tha flask plus tha contents was carefully weighed at the beginning of tha run and at tha and, and th# loss in weight used to csiloulata tha sTeraga amount in s cubic meter of air peer minute as determined by a Berios of flow natar rsadlngs. Tha figures obtained wara not sbaoluta because of slight variations Ln the eir flcTtng through the boxea and boesusa of deposition of material co the thermome ters end cn the inside surfaces cf tho bex, but they chocked with dlroat determinations through air samples. . -w u 41 WATER PCB-SD0000071027 Apprcairately one hour was allowed for the wax in the riarle :0 and ccae to a. ocmstant temperature. At that tine the box doers were tightly cloaed, air bubbled through the flaaka, end the blowers furred cr This was the beginning of the expoauro period. By no ex a of the theoatata oq the fans and. tho dampars in the outflow plpee, the amount of air flowing through, the bcaea was adjusted and an attempt waa nndo to keep the four boxea aa uniform aa possible -- usually between 155 end 175 cubic foot per minute*. . ' Zx-oorlnenta Exposure to chlorinated diphenyl'was begun cn July 1, 1926 and * ceased cn November 18 of the same year. The average length of expoauro waa 16 hours daily for 6 days a week. Each morning at about 9:00 % exposure ceased, and betwoon this time and -4:00 p.a. the rata were cleaned, fed, weighed, eto. In order to secure uniformity of exposure tho cages wore shifted on a regular schedule, wince wax concentrations ' were somewhat higher at the inflow end of the boxea. Preliminary runs . showed that onco properly adjusted, wax concentrations in the air remained very uniform from day to day, but to insure absolute safety readings of temperature, air-flow, otc. were cade every night between 10:00 and 12:00 p.m. aa well ae on starting and stopping. At different tinea during the course of tho experiment teats for free chloride wore made but were uniformly nagatiTe and showed that under tho tecperaruros uaed no decomposition oocurred* '. Table 1 *> CCJs. Conditions lialnteined in Inhalation Zxporlnant from July 1 to Not. IB Jdateriol Chlorinated <*i?banyl amperature . Average eoncemtratl on of air in box Total lengt of exposure 152-175 lio . /c u. a*~7- Hi-s 1.19 Low 0.22 hours 129 5 Average dal oxpcsur o 16 4 WATER PCB-SD0000071028 Reunite of Inhalation Exrgrlnaata Ko abnormalities were a a an. at any time in tho liTing rata. and urina axa.nlnatIona vara made; thera were no loaaea in neigh:, and ona would hava oonaidarad that tha animala wore perfectly sound. However rata sacrificed after 6 weeks exposure showed alight liver damage, which advanced during tha next two months. Tha ohangoa oonaiatod in alight to moderate swelling of tha liver cella, incraaaod granularity, and many mitotic figures. Hyaline inclusions were present and ware invariably plentiful in animals receiving chlorinated diphenyl by inhalation or by mouth. _' One ia forood to conclude from the experiments that an average concentration of 0.37 mg. per cubic mater inhaled IS hours daily producos definite alight changes in tha liver and in this organ alone. Theaa changes are resisted efficiently by the animals and cause no depreciation of health. Tha situation ia not unlike that aeon in factories where acute yellow atrophy of the liver has occurred. In the case of ouch ' instances the patients have bean singled out in eona way or other fren largo groups of fellow workmen who havo beon perfectly healthy. In considering tho entire natter it seamed to us that the chlorinated hydro-carbons,/if inhaled in eufflciont concentration, might causo a slight dogroa of damage to the liver. This damage is resisted efficiently and cauaaa no depreciation of health, but if the Individual in question happens to euffar acme ordinary dioeaso of tho liver tha condition is superimposed upca a substratum of Injury. In accordance with thia hypothesis we doteralnod that a dose of 0.73 co. cf carbon tetrachlori ds plus 0.75 co. of othyl alcohol per kilogram of rat w. i anti roly noa-t oxl c to normal animals. V/hon, howsTor, this dcso ms / V. given to animal a which had Inhaled chlorinated diphenyl as has boon dascribed ia this experiment, the result vas acute yellc* atrophy w3scc 43 WATER PCB-SD0000071029 of tha liver. It would aooa therefor* that inhalation of a conce-* -- *< of chlorinated si iphenyl La tha manner I haTe daacribed is capable of produotng a ooadition w.hich say be dangerous to the individual inhal--'-v>- < -i though of Itself no Tiaibla ham will bo dcaa. Animals moored from exposure to chlorinated diphenyl after two months inhalatlm and given tro months for recoTory still showed livar changes when killed and examined, so that it is evident tha alterations . produced by this hydro-carbon are persistent and individuals who havo been caused trouble by It should bo rerovod completely and for a long tiro. . The uEnhalati cn of a sonswhat hi,then concentration of .* chlorinated dtnhenvl over an B hour dnv The circumstances attending this experiment are given in Table 2. * . : liatarial ' ` Table 2 Tenporaturo o C ' Iverego ccncoatraticn of air in box .'dr . /c u. r. ?.nr e . Total length Average of exposure daily exp Hours Hour s Chlorinated diphsnyl ' 133-174 ' 0.93 High 3.23 Low 0.C3 920 8 JLgaln BO rata worn used in this experiment. Hone at any tire showed tho alight eat eTideaoa of lllnosa. liicroecopio examinations, however, showed a degroa of chango Tory comparable to that found in the IS hour experiments which haro been described and tha carbon totrachlcrida tost was uniformly fatal. ' General sAmmrvFrom these xperLrontfl v~n are forced to conclude tint cr:smrt*.'.n: cf chlorinated'diphenyl in workrooms should not be allowed to rise above 0.5 rg. p-er cubio meter of air. Thia ccncentraticn is readily obtained by careful WATER PCB-SD0000071030 f V hoodie. It la la 0^ opinion sale for rorknan rho would act to exposed tha absolute steedinees characteristic of our experiments on rata and ouch a concentration Unit would probably do axay with the troublesome atla loeiona which taTa been. tta particular cauaa fcr worry in regard to thaaa conpcunda in tba past. . In addition to tba inhalation oxporlnanta many reading experiments nort dona vith/chlorinatad diphenyl. The general changea in the liver wore the sane aa thoaa already described. i?o diarrhea or gastro-intoatlnal aspects eoeicad to be present. H.'-' - I 45 WATER PCB-SD0000071031 Toxicology Department Monsanto Chemioal Company St. Louis, Missouri Dear Sirsi One of our Indiana industries is using your ARCLOR 1240 (tetrachlorodiphenyl) as a heat tranafor media ( up to 400 F) in the extrusion of Tenite 2 plastic. Considerable vapor of ardor is present in the workroom duo to leaks in the "dosed" system. Several workers have reportedly become ill due to the inhalation of those vapors. This plant oalled us as to any knowledge relative to the toxicity of this product. Vfo did not havo any data that could be transmitted to them. The so called illness was vague in that we could not learn from the plant what the exact complaints were. We would appreciate any information which you havo on the toxicology of this material. * Yours very truly, , LWS: pa Louis W. Spolyar, M. D., Director Division of Industrial Hygiene Indiana State Board of Health FUR 003273 puauc health la "the apt and cience or rnrvcNTiNa oitiAqt. PftOLONOINO LITE ANO PROMOTING PHYSICAL and mental irri. CIENCY THROUGH ORGANIZED COMMUNITY ErrORT." C.-E. A. WlH.LOW. WATER PCB-SD0000071032 ejuLi Dr. II.R. lawman. Hewport, England. February 12th, 1954. I/. K v.-f 1 **-* We do not know vhat the maximum allowable concentration of Aroolor is. One milligram per cubic meter has been eat vp. We hare run animals for about 60 days at 7 times this and found some liver flomgo. We are now running this at a lower level. We bare never found any liver trouble In any of the workers In our plant, but v watch the control of the fumes lb our customers' plants and always reooBaend exhaust ventilation. I am sure you realise that 1 mg per cubio meter is reooamendod for an 8-hour day for Indefinite periods of time. In painting a room we have found 1 - 2 mg for a dey or so, but after that the level drops down to nothing. What we were really worrying about was the jvossibllity that a man would develop hepatitis, on an idiopathic, viral, or serum basis and on questioning would reoajX~that he had painted a room with Aroolor paint and state that he had smelled it very strongly. I am afraid then we might be oonvicted by association even though vo were sure one oould not got a level high enough to oause trouble. We have, however., bean conoerned with the level of Aroolor during spray painting, but I think that lord can only be determined by actual measurements. " Please do not worry about asking me these questions booausa we certainly Want you to have the entire ploture about Aroolor toxicity. As soon as 1 get a report on the work at Kettering, I will let you know. R. Kmmet folly, M.D. RKX/MFL. FUR 003274 WATER PCB-SD0000071033 I Copy No, PROCESS FOR; THE PRODUCTION OF ' AROCLORS,; PYRANOLS, ETC. . AT THE ANNISTON AND A$D THE WM. 0, KRUMMRICH PLANT April 1955 --................... E. Mather Distribution List: 1. 2, 5. 4. 5. ^6, 7. 8. 9. 10. Mr. J. S. Brough, London Dr. N, B. Dyson, Ne\fcport Mr, G. V. Taylor, Newport Mr. 0. V. Taylor, Newport Mr. W. E. Hamer, Ru^bon Mr. J. F. Stickley,------- Krummrich Plant Mr. J. F. Stickley, ----------- St. Louis Library M. C. L. file at St\ Louis Mr. D. B. Hosmer, Arjniston Spare . FuR 003397 2 PLAINTIFF'S DEPOSITION EXHIBIT . yr/. I WATER PCB-SD0000071034 XI. HAZARDS. XI - I Hazards Toxicity There are many literature refexienceB*to harmful effects of the type of "chlor acne" resulting from exposure to chlorinated diphenyls, especially in cases where people working with small electrical com ponents have been exposed to tlje fumes of hot, highly chlorinated, Aroclors. Chlor acne is sometimes accompanied by gastric troubles, and there are literature references to liver troubles. There was some trouble of this kind among the production workers at Anniston in the early days of the development of the Aroclors. At that time highly chlorinated Aroclors were being made from diphenyl which had come from low grade benzene. Since good benzene haB been used, the same Aroclors have been made without trouble. In March 1955 it was reported that the Anniston diphenyl and Aroclor plants had run 12 years without lost time accident. From the start of Aroclor manu Tacture at the Krummrich plant the operators have been supplied a clean change of clothes every day, and time has-been allowed at the end of the shift for bathing. Operators are advised to waBh hands and face before eating. The Anniston operators do not have the same issue of clean clothes. Percy May, "Chemistry of Sy;nthetic Drugs" , 3rd edition, page 19, The "Chemist Analyst", Sep pember 19*17/ Volume 36, No.2 page 33, and a report by Dr. M. C. Lfe ster, Anniston plant7 1957/ give data on the toxicity of diphenyl MCC Bulletin P-ll5/4enne.wtioendsllfc 0.5'to 1.0 mg. per cbm in air as the highest Bafe concentration bf higher Aroclors, and 10 ng, for more highly chlorinated Arojclors H, B. Edkins "Chemistry of CEndustrlal Toxicology", page 1^9 gives 0.5 to 1,0 mg. as the allovflable limit In working rooms. The MCC Bulletin "Physical Properties of Aroclors" mentions sys temic effects arising from the oral injection of Aroclors. See the letters, E. Mather to P.J.C.Haywood, December 17, 195^, and Mather to Newman, January 1952, reviewing the literature on the toxicity of Aroclors. FUR 003781 See also correspondence relating to the article in Chem. & Eng. News May 17, 195*1/ pages 2038 -J and the warnine labels mentioned on page VI-3*1 above. WATER PCB-SD0000071035 XI. HAZARDS, contd. XI - 2 Hazards St. Louis, Main Office Mr. P. J. C. Haywood Newport (Airmail) cc: Mr. W. E. Hamer, Ruabon Mr, W. H. Ritchie, Ruabon Dr. H. R. Newman, Ruabon Mr. S. M. Kulifay,. Kruminrlch Dr. D. S. Weddell, St. Louis Mr. P. T. Marshall, St. Louis December 11, 1951 AROCLORS:{TOXICITY Since writing to you on Depember 5rd I have come across a letter of mine to Mr. W.J-M. Cooper> London, June 24, 1948, (copies to W.D.S., w.H.G., and others), calling attention to an article in[ the J. T. Baker Company's "Chemist Analyst", Volume E6, No. 2, page 55/ September 1947. I attach a copy of this arjjticle, and I think you will agree that the warning rel]Stes only to really bad exposure, not such as should occur i ordinary analytical work. On October 27, 1947 Mr. Ba)rbre of the Krummrich plant sent a copy of the Journal to Dr. Jenkins at Anniston for comment. Dr. Jenkins did hot make any comments at the time. but the following extract From Mr, Barbre's letter 1b inter- estlng: "During the 11 years i production here only one man evidenced de atitis. He had also shown similar symptom^ in several other departments. When ma}dLng Aroclor #1270 which is flaked, a noticeabjL e amount of fine fume solidifies in the air If men are exposed to it during hot humid wfather, the skin is irritated, but we hav^ not had any difficulty in curing cases of de bnatitis from it".- FUR 003782 E. Mather WATER PCB-SD0000071036 XI - HAZARDS, contd. XI - 5 Hazards The Chemist Analys Vol. J>6, No. 2, page J>J> J. T. Baker Chemlc il Co., Philllpsburg, N. J S jptember 1947 ON THE TOXICITY OP THE "AROCHLORS" (sic) Robert M. Brown, Chief Industrial Hygiene Section, Division of Health Dept, of Public We Ifare. City of St.Louis, Mo. A recently published article ( Mkglio, M. Martin, Chemist Analyst, 9.4.-(1946) ), has recommendeji the substitution of one of the "Arocblors" as the melting-poin bath liquid in preference to the customary sulphuric acid. As s tated In that article "Arochlors" are a group of- chlorinated diphp nyls produced by the Monsanto Chemical Company. There is need therefore to' give warning. Por the toxicity of these compounds has been repeat dly demonstrated, both from the standpoints of their absorption from the inspired air, as well as from their effects in produ ing a serious and disfiguring dermatitis when allowed to remajl n in contact with the skin, Since these effects have been -rj^peatedly observed, industrial hygienists have taken care to BP e that the proper controls have been established wherever these products are used. Por example, the maximum allowable concentrab ion of chlorinated diphenyl for an 8-hour working day is 1 mill[L gram per cubic meter of air. It is probable that nothing like an uncontrolled industrial expo sure will.occur in the laboratory. However, whether an individual is subjected to a possible acute exposure to chlorinated diphenyl, and its serious consequences, will depend upon the size of the melting-point bath, the caution! with which it is used, and the temperature to which it may be heated. Likewise, with careless handling of the material and the resulting contamination of the skin, clothing, laboratory towels, work table surfaces, etc. the way is left open for the producing of dermatitis. Scrupulous cleanliness must be insisted upon wherever this material is handled. The foregoing remarks have been! prompted by the belief that in re commending the use of a materia|L with which is associated a potential hazard from the health standpoint, it is very important that the possible consequences be presented together with recommendations for correct handling. ; FUR 003783 WATER PCB-SD0000071037 XI. HAZARDS, contd. XI - 4 Hazards Mr. A. C, W. Pennington of Newport, reporting on hie American tour, December 29, 1950, page [5, writes: `' "HEALTH AND SAFETY": "At Anniston, no special protective clothing is provided for the Diphenyl and Aroclors operators. A daily change of clothing was provided in the past but this practice ceased before the war. Gauntlet leather gloves and fejce shields are, of course, available as required on the plant. I . i " Tins of cold cream olrjtment, theatrical quality, are to hand in the building, but the application of the cream is left to the operators decision of the job tin question. The men are expected to take a bath, in their own time, at the end of the shift. A good . quality soap, and alcohol for [rubbing down purposes, are provided. The operators are sufficiently trained in the need for personal cleanliness that a record of tiath taking is not warranted. "Emergency showers are provided on each floor of the Diphenyl building and safety notices arje widely used. "At St. Louis, Plant B, |the Aroclors building is rated a toxic department. Each operator is provided with a complete set of clothing comprising hat, cckt, trousers, combination under clothes, socks and rubber shoe. A clean change of clothing, except shoes, is placed in the operator's locker in time for the following shift. Men working extra shifts are given a clean set of clothing. Canvas gloves and goggles are provided and 'Ply' hand barrier cream is available for use when necessary. "Twenty minutes' paid ti>ne is allotted for bathing at the end of the shift but, again, n p record is kept that baths are actually taken. Theoretically , food is not allowed to be eaten within the Aroclors building, Instructions are Issued that hands and face should be washed well' before eating. "Employees in toxic depaItrtmentB are given an annual medical examination and a lung'X-ray every three years." FUR 003784 il ! WATER PCB-SD0000071038 I i XI - 5 Hazards XI. HAZARDS, contd. Toxicity, contd. ---------------- ' : i; A good deal of work has been dcine on determination of- the-vapour pressure of the Aroclors, and on the determination of/concentration of Aroclors in air. See pages 9-, Section III, above, for a summary of this work. In 1950 (letter April 20, N. F Rapps to E. Mather) the Admiralty expressed interest in the dete ^mlnation of micro-quantities of Aroclors. MCC have a method f4 r the determination of traces in air by means of the "Halidomet4 Mr. Ellenburg, March 15, 195^> mentions work done by H. B. Richards Jr., of MCC, June 17, 1955, on the determination of the concentration of Aroclors in air. Mr. Ellenty urg also states: 11------------ work on. the safe limits of Aroclor vapour concentration in air is being c^rried on by the Medical Department at the Kettering Laboratof,ies in Cincinnati. This work on animals is well under way and will help us to know a ilttle better jUBt what is the s ife limit of Aroclor Vapours that one might work in." A question has been asked about the possible harm to plants if Aroclorcontaining paints are used in greenhouses. The reply is that most paints are somewhat harmful, and there is no evidence that Aroclors make them worse. Aroclors have been used as rabbit repellants, with out doing any harm to vegetation. Care is needed in laboratories etc. where Aroclors are used in heating baths; there should b$ very positive ventilation. The vapours of hot Aroclors ar$ distinctly irritating to eyes and nose above a concentration of ibout 5 mg per cbm in air, Newport plant report for December 1951 records burns by hot Aroclor -- a case of a splash into a man's $ye -- without serious damage. Packages of Aroclors leaving the Krummrich plant bear a label calling attention to possible toxic effects. FUR 003785 WATER PCB-SD0000071039 t XI - 6 Hazards XI. HAZARDS, contd. Fire Hazards Diphenyl, of course, will burn. and reasonable care is needed in handling it. Precautions with toluene are mentioned also on pages VI-29, and under "Special Risks , below. The Aroclors are handled as if ijion-inf lammable. Drums of material are melted in the middle of the operating building, by open gas flames, and open gas flames are freely used to heat pipe lines. An instruction, dated April 28, 1948, calls for a daily inspection of safety showers, fire extinguishers and gas masks, a check list being provided. Flanged joints on Aroclor heating system can be a source of fume. See the notes on gaskets, page 2, Section XII, below. Phosgene may be generated in electrical flashes and fires in trans formers containing Aroclors, but. this is not thought to be a major riBk. ' I Safety Equipment j ' Each operator in the Krummrich Aroclor plant is supplied with goggles, rubber covered gloves, canvas gjoves, rubber shoes and fume respirator. See also page XI-1. A spare su t of clothes is kept in a case in the department. The department has the usual first aid cabinet, gas masks, (chlorine), fire extinguisher, ^toluene, diphenyl), stretcher, safety showers, drinking fountain, eye[bath. Special Risks The usual care is necessary in pealing with chlorine, in lighting the gas furnaces, and in handlii^g hot materials, steam lines etc. Diphenyl might start to burn in chlorine gas If conditions in the chlorlnator were badly out of 1 ne. A Davis "Vapotester", model M-l Type A, (Division of Davis Emergency Equipment Co., Inc., Newark, N. .) is held in the department for use in testing the air of the workliji g building after toluene has been used, and for testing vessels fore men are permitted to enter, and before "flame certificates" are given. The instrument contains a FUR 003786 WATER PCB-SD0000071040 XI - 7 ' Hazards XI. HAZARDS, contd. Special Risks, contd. catalytic cell electrically hea ;ed to a fixed temperature, and the air to be tested is aspirated through it by means of a "squeeze ball". If combustible vapours ire present, the temperature of the cell rises, and the indicating thermocouple registers on a cali brated scale. . The instrument has a zero adjustment, and it is checked twice a month by the instrument department. Flame certificates must give the number of the Vapotester us d, also the data of itB laBt calibratlon by the instrument depar ment. The instrument has been use ful in detecting gas escapes, and in tracing spills of gasoline, etc., from a neighbouring oil rpfinery into a public sewer which runs under Monsanto territory. Mr. Benignus, of St. Louis, September 1955, disoussed the dangers of using Aroclors in.inioor paints. He discounted the possible dangers from phosgene formed by flash discharges in transformers charged with Aroclbrs. . See the references to safe hand^L.lng of glycidyl phenyl ether on pages IX-161 etc. j I FUR 003787 11 WATER PCB-SD0000071041 XII. EQUIPMENT LIST XII - I Equipment List The following details are largely drawn from pages 18 - of the report by Lyles, Soffranko and pecker, November 1946, and., they relate to the plant "B" (now Knummrich Plant) equipment, unless otherwise stated. A list of Aijoclor equipment at the Anniston plant was sent to MCL June 7, j^-946. . General Note Sinoe diphenyl and some of the Aroclors become solid, or viscous, at ordinary temperature, atten on has to be paid to steam tracing or Jacketing of pipe lines, anc} to the provision of gas flames for local heating where necessary With due care, because of the presence of diphenyl and in sorie cases of toluene and butyl acetate, naked flames are quite fneely used in the plant. (See operating instructions. Section XVy below). Pipelines used for Aroclors ne ^d heat insulation, also proper allowance for expansion where High temperatures are involved. Flanged crosses are freely useq to assist' in locating and clearing blockages in the pipe lines, l^ines for diphenyl and heavy Aroclors should be blown clear after us4 This .also refers to outdoor water and steam lines, for exainple r4il tank colls, in cold weather at the Krummrich plant. Schwarting and others, "Process Description -- for Aroclors" November 12, 1953/ page j5 statq "Since iron has a deleterious effect on Aroclor electrical properties, the distilled product is handled in monel, raonel-clac,., zinc or tin-sprayed, and 504 stainless equipment, Galvanized iron or stainless steel is used for the process piping beyond the distillation stage --- ii FUR 003788 WATER PCB-SD0000071042 .! XII. EQUIPMENT LIST, contd. j XII - 2 Equipment List Gaskets and Packings ! The following gaskets have be^n found suitable for use. in the Aroclor process(1948) #901 Oarlock - 1/16" 1 l" _ 2" - 5" and 4". Used for all crude material transfer lines. #900 - Yellow Oarlock ^,/8"and l/l6", sheet Gasket. Used for finished mate J-ial transfer lines. Metallic Asbestos Ooet? e gaskets 1" - 2" and 3". Used for solid Aroclor line flanges; will stand heat. Goetze Aluminium Asbesios. 16" I.D. 2l" I.D. and 9" I.D. Used for Pyranol Car heads. Goetze Metallic Asbestos 2" flange gaskets used inside, top and bottom of 18" sparkler press. I #262. 1/2"x 2/8" square Garlock gasket. Used in flange face of Sweetland pres^. Gum rubber flange gaskets used in HC1 valves and lines #900 Garlock gaskets u tjed on all Chlorine flanges, tank manhole .covers, inspec $1 on plates, inspection plates, and between all pump and tdnk flange connections. Gum or Garlock red rubber gasket material used on all HC1 tank flange connections. ' II Samples of Goetze corrugated <jopper-asbestos gaskets were sent to MCL, April 9, 1947, and again [June 24, 1948. The 2" I.D. x 4" gaskets at that time cost 'f'O.189 each. FUR 003789 WATER PCB-SD0000071043 XII. EQUIPMENT LIST, contd I XII - 5 Equipment Li B t Gaskets and Packings, contd. j See also the London Engineering Dept. Final Report on the start-up of the Newport plant, for a dlpcussion of gland packings for use against hot Aroclors. : See also MCL Research reports bn packings and gaskets for hydraulic fluids, for example: -- 547 50/175/2 November 1950 555E 51/91/11151 DF 54/26/5- August 1951 June 1954 - DF 54/27/l1152 DF 5 4/14/5 April 1954 April 1955 tSome gaskets failed under tes others damaged the goods. Samples of the washers used for the bungs on Aroclor drums were sent to MCL, April 9, 1947. The 1" size cost $0,004 each. 1 FUR 003790 1 WATER PCB-SD0000071044 XII. EQUIPMENT LIST, contd. XII - 4 EquipmentList ' PUMP PACKING LIST EQUIP.NO. PUMPS ' SERVI 3E p-0629 " 578 " 579 " 1056 " 731 " 575 " 604 " 573 " 574 " 580 " 1509 " 59^ " 1277 " 565 " 1258 " 378 " 1054 " 1260 " 585 " 592 " 584 " 583 " 929 " 617 #1 Chlor Pump #2 " " #3 " " #4 " " #1 Scrubber Pump #2 " " #3 " #4 " " " #IA " " #1 Blow Tank Pump #2 1, i" ;' ." #l.<.i3tlll'.Pump-' *2 : - ' #i*lSt.-' 11 Rec. Pum 5 ^2 11 ,.n 11 City Water-Pump-t 5 Tourrill 11 If 11 11 Tantalum 18" Sparkler Pres 3, Pump 18" " Head Gasket #1 Diphenyl Stg.T (C. Pump #2 " "1 11 #3 Aroclor Stg. T: ink Pump #4 " #5 " " " 1 11 1 II CT03 ^7 - Dlpheny: Stg. Pump SIZE PACK. TYPE AND NO, OP PACKING 5/l8 inch 11 11 v 3/8 II II II 11 5/1.6 II 1/2 II 3/8 11 1/8 II #234 Oarlock 11 11 II . II K If II II m 11 II II II tl 11 ti n 11 11 11 ir K H 11 Palmetto II #117 Garlock M 11 3/16 1/2 X 3/8 1/2 11 II 11 #262 #234 V II 11 " " 11 11 11 n 11 II 11 ti 3/8 Palmetto P-0595 P-0427 P-0943 P-01119 P-0725 P-0346 P-01111 Flaker Drum 1170 Stg. Pot Agl' pator #1 Still Condense: h Pump D 218 Dept. Inhibitor Acid Pui 4P Wllfley Pump at #: HCL Stg. " " " hc: Tr.Tk. Dept. A-246 #7 Sweetland & GE Press Pump #6 Stg. Tank Pump TCB Unloading Pum* 1/2 3/4 1/8 1/4 -- -- 3/8" -3/8" FUR 003791 #2.34 Garlock #234 Garlock #117 Garlock #234 Garlock Do not use pckg. n 11 11 11 Cutno or Palmetto No Pckg. req'd. -- Palmetto WATER PCB-SD0000071045 I ! XIV. HISTORY OP THE PROCESS IN MONSANTO. XIV - 1 History of the Process In the years 1927 - 1928, the Swann Chemical Company developed a proceco for making diphenyl but as the expected demand for it did not continue, other outle^ s were Bought for the diphenyl. Aroclors.were produced in the laboratory in 1929, and as they showed good electrical proper ^ies, fire resistance, and general inertness, the General Electrl c Company became interested, and developed the UBe of Aroclors in transformers and capacltators . A plant was Installed to produce 5000 lbs,/day at Anniston. In 1955 Monsanto acquired the Swann Company, so gaining access to their Aroclor patents. As the demand for Aroclors increased, additional production equipment was installed, located at the Monsanto Illinois factory (th en plant "B" and now called the Krummrich plant). This equipment came on stream in September 1956. The Krummrich plant site was ^hose partly because of the av'ailability of chlorine there, but when chlorine consumption overtook the production, and chlorine Aad to be purchased, proximity to the diphenyl production at Annis t$n had more weight, and additional capacity, largely designed on the plant "B" model, was Installed at Anniston in 1941. By 1946 both plants had doubly d their capacity, to give a tdtal production capacity approachl 2 million poundB a month. About 1954 chlorine cells were lnstd lied at Anniston. The Newport plant was designed mainly on Krummrich plant lnformation, but to a less extent 01} Anniston Information, under Newport Project No. 12 of the London Central Engineering Department. Chlorination started at Newpo3ft in June 1951> Mr. Clegom from AnniBton spending Borne time a4 Newport to assist in starting the diphenyl and Aroclor plants there. The first production of Pyran<^ 1 by MCC was in 1936, when Pyranol 1488 was made for tie General Electric Company, the blending being done at first in rail tanks. Pyranol 1495 was made in July 1938. The use of tin-tetraphenyl started in 1944, since when the main production haB been of 1467 (TCB - 1260 mixture plus tin-tetraphenyl). FUR 003886 WATER PCB-SD0000071046 COPY Dr. D.V.N. Hardy Dr. H.R. Newman. Monsanto Chemical Company St. Louis, Missouri ' September 20, 1955 - ......... Dr. J.W. Barrett London Your memo September 8 to Mr. Nason AROCLOR TOXICITY - '- Howard Nason has given me your memo of September 8. I will be happy to discuss this with Dr. Newman during his visit here. I think, however, there are several points that I can answer you now. You comment upon the difference in toxicity between Aroclor 1254 and 1242. This is not particularly surprising because in the earlier work it was found that toxicity increased with chlorination. Of course, from the standpoint of vol atility in the case of inhalation or absorption from the gut from the point of view of ingestion are important. Frankly, there was not too great a difference between the two compounds, however. As you know, the maximum allowable concentrate is 0.1 ml/cubic meter in the case of 1254, and as high as 10.0 mgm in the case of 1268. I think the former is too low and the latter is too high. In this country they don't use the MACs very routinely, but certainly in England I think it would be alright to consider 0.2 mgm/cubic meter as perfectly safe, I don't know how you would get any particular advantage in doing more work. What is it that you want to prove? I believe your work should be directed towards finding out what the concentrations are of Aroclor during different operations .whether it is industrial or painting,. The re ports you have seen from Kettering Laboratory are the re sult of approximately 015,000 to 020,000 expenditure by MCC. MCC's position can be summarized in this fashion. We know Aroclors are toxic but the actual limit has not been pre cisely defined. It does not make too much difference, it seems to me, because our main worry is what will happen if an individual developes any type of liver disease and gives a history of Aroclor exposure. I am sure the juries would not pay a great deal of attention to MACs. FUR 003904 WATER PCB-SD0000071047 COPY Page 2 September 20, 1955 AROCLOR TOXICITY We, therefore, review every new Aroclor use from this point of view. If it is an industrial application where we can get air concentrations and have some reasonable expectation that the air concentrations will stay the same, we are much more liberal in the use of Aroclor, If, however, it is distributed to householders where it can be used in almost any shape and form and we are never able to know how much of the concentration they are exposed to, we are much more strict. No amount of toxicity testing will obviate this last dilemma and therefore I do not believe any more test ing would be justified. Let's see what our discussions with Dr. Newman and yourself bring out. REK:k R. Emmet Kelly, K.D. FUR 003905 WATER PCB-SD0000071048 rrom Monsanto Chemical Company At St. Louis ccMr. J. Cresce -Krumrn. Pll Mi'. ET?. 1W.T . LTi<eben _-"" " Mr. R. M. Webber Date November 14, 1955 To Mr. H. B. Patrick Reference At Krummrich Plant Subject DEPARTMENT 246 (AROCLORS) It is the opinion of the Medical Department that the eating of lunches should not be allowed in this department for a number of reasons. (1) Aroclor vapors and other process vapors could con taminate the lunches unless they were properly pro tected, ' (2) When working with this material, the chance of contamlnating hands and subsequently contaminating the food is a definite possibllty. (3) It has long been the opinion of the Medical Department that eating in process departments is a potentially hazardous procedure that could lead to serious diffi culties. While the Aroclors are not particularly hazardous from our own experience, this is a diffi cult problem to define because early literature work claimed that chlorinated biphenyls were quite toxic materials by ingestion or inhalation. In any case where a workman claimed physical harm from any contaminated food, it would be extremely difficult on the basis of past literature reports to counter such claims. JTG:SMB n J \H 10 FUR 00390G WATER PCB-SD0000071049 POLYCHLORINATED BIPHENYLS PCBs A Report on Uses, Environmental and Health Effects and Disposal FUR 003907 Monsanto WATER PCB-SD0000071050 INDEX Preface Section 1. History of Monsanto Production and Sales of Chlorinated Biphenyls. Section 2. Information on Health Effects. Section 3. Monsanto Actions Resulting from Health Data. Section 4. Communicating with Customers. Section 5. PCB Disposal. i FUR 003908 WATER PCB-SD0000071051 PREFACE The following report is a frank, comprehensive presentation of relevant aspects of.tb.e PCB issue. From Monsanto Company's perspective, PCBs are a classic case history of a true risk/benefit dilemma. Monsanto is proud of its conduct with respect to the PCB issue and stands on its record, described in this report, as being totally responsive and responsible to the public interest. The com pany has continued, since termination of production and sales, to provide the resources to help establish good testing practices. The company further supports ongoing research to more definitively establish the possible risks associated with PCBs in the environment, and funds studies to identify innovative approaches aimed at reducing PCBs in the environment. In addition, Monsanto continues to respond to legitimate requests for technical advice and assistance. Monsanto believes that this continuing allocation of its resources futher demonstrates its commitment to serve the public interest. FUR 003909 WATER PCB-SD0000071052 HISTORY OF MONSANTO PRODUCTION AND SALES OF CHLORINATED BIPHENYLS Section 1 Page 1 Monsanto entered the chlorinated biphenyls business in 1935 when it purchased the Swann Chemical Company. Production and distribution increased until the early 1970's, when, in response to reports of its presence in the environment, Monsanto restricted sales of chlorinated biphenyls. In 1977, the company ceased production and distribution of chlorinated biphenyls in CQoperation with the electrical industry. Chlorinated biphenyls were banned (except for certain applications) in the U.S. in 1979. Sales and Distribution The chemical structure of the polychlorinated biphenyls has been known for nearly 100 years. Commercial production of these materials was initiated in 1929 by the Swann Chemical Company in response to the electrical industry's need for improved dielectric insulating fluids which would also provide increased fire resistance when used in transformers and capacitors. As the unique functional characteristics of these materials became more fully understood, additional uses were found. Their fire resistance made them an excellent choice in high pressure hydraulic applications associated with high risk of fire such as die casting and steel production. Their thermal stability and fire resistance were valuable in heat transfer systems. Their stability, low water solubility, low vapor pressure and solvency power made them attrac tive in carbonless paper systems. Their fire resistance, thermal stability and viscosity characteristics made their use desirable in hot melt adhesives and other plasticizer applications. Chlorinated biphenyls, therefore, evolved as a unique class of chemicals which met important needs for both industry and society. In some instances, fire and building codes required the protec tion of life and property offered by chlorinated biphenyls. It was within this framework that Monsanto and other producers developed a growing worldwide business for these versatile products. The following charts show the data for chlorinated biphenyls through Monsanto's voluntary phaseout program to termination of production and sales in 1977. Significant points in these charts are: a. Heat Transfer--Between 1970 and 1972, a task force of Monsanto engineers worked closely with customers to replace chlorinated biphenyl fluids with materials of equivalent thermal stability but with unavoidable lower fire resistance. Phaseout was completed in 1972. b. Hydraulic Fluid--Development of replacement fluids began in 1970, and sales of chlorinated biphenyl-based fluids were discontinued in 1971. c. Plasticizer Applications--Sales of most chlorinated biphenyl plasticizers were terminated in 1970, with phaseout completed in 1971. d. Miscellaneous Industrial Uses (such as vacuum pump fluids)--Sales ended by 1971. These voluntary restrictions resulted in a 64 percent reduction in Monsanto sales of chlorinated biphenyls from 1970 to 1972. However, termination of sales for dielectric uses would have resulted in severe economic and social dislocation. This was recognized by the federal Interdepartmental Task Force on PCBs111 which concluded in 1972 that "Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disrup tion of electrical service which would result from a ban on PCB use." FUR 003910 WATER PCB-SD0000071053 PCB MANUFACTURING AND SALES MONSANTO INDUSTRIAL CHEMICALS COMPANY 1957 thru 1978 (Thousands of Pounds) 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 U.S. PRODUCTION DOMESTIC SALES (1) (1) (1) 37919 36515 38353 44734 50833 60480- 65849 32299 26061 31310 35214 37538 38043 38132 44869 51796 59078 U.S. EXPORT SALES (2) (2) (2) (2) (2) (2) 3647 4096 4234 6852 DOMESTIC SALES BY CATEGORY Heat Transfer 0 0 0 0 0 157 582 929 1237 1766 Hydraulics/Lubricants 1612 1549 2685 2523 4110 3915 3945 4374 4616 4258 Misc. Industrial 704 755 1569 1559 2114 1681 1528 1692 1841 1779 Transformer 12955 5719 5984 7921 6281 7984 7290 7997 8657 8910 Capacitor 17028 14099 16499 16967 15935 15382 15606 19540 23749 28884 Plasticizer Applications Petroleum Additives (1) 3939 00 4573 0 6244 0 9098 0 8924 0 9181 10337 11696 13481 00 00 DOMESTIC SALES BY PCB GRADE Aroclor 1221 23 16 254 103 94 140 361 596 369 528 Aroclor 1232 196 113 240 155 241 224 13 13 7 16 Aroclor 1242 18222 10444 13598 18196 19827 20654 18510 23571 31533 39557 Aroclor 1248 1779 2559 3384 2827 4023 3463 5013 5238 5565 5015 Aroclor 1254 4461 6691 6754 6088 6294 6325 5911 6280 7737 7035 Aroclor 1260 7587 5982 6619 7330 6540 6595 7626 8535 5831 5875 Aroclor 1262 31 184 359 326 361 432 414 446 558 768 Aroclor 1268 0 72 102 189 158 210 284 190 196 284 Aroclor 1016 00 0 0 0 000 00 (1) Production figures and Plasticizer Applications figures unavailable during year indicated. (2) U.S. Export Sales figures unavailable during year indicated. FUR 003911 WATER PCB-SD0000071054 1967 1968 1969 1970 1971 r 1972 1973 1974 1975 1976 1977 1978 75309 82854 76389 85054 45417 38600 42178 40118 29710 29592 13330 0 62466 65116 67194 73061 34301 32242 37742 34406 25611 24329 12701' - o'"' 8124 11231 10624 13651 10648 6388 8346 5395 5712 4744 1548 0 2262 2529 3050 3958 3060 752 0 0 0 00 4643 5765 8039 7403 1552 0 0 0 0 00 1426 1283 1079 1627 1155 0 0 0 0 00 11071 11585 12105 13828 11134 11314 14176 12394 12763 6002 1617 29703 29550 25022 26708 14141 20176 23566 22012 12848 18327 11084 13361 14404 16460 19537 3259 0 0 0 0 00 0 0 1439 0 00 0 0 0 00 0 0 0 0 0 0 0 442 136 507 1476 2215 26 35 57 28 20 0 25 90 273 260 171 0 0 0 0 0 0 43055 44853 45491 48588 21981 5537 6200 6207 6435 4418 51 4704 4894 5650 4073 213 0 0 0 0 0 0 6696 8891 9822 12421 4661 6115 7976 6185 6328 1584 1566 6417 5252 4439 4890 1725 414 0 0 0 0 0 840 720 712 1023 1 0 0 0 0 0 0 287 280 300 330 0 0 0 0 0 0 0 0 0 0 0 3334 20150 23531 21955 12820 18307 11084 0 0 0 0 0 0 0 0 0 mi niji||iiiii| mill mi i ini in ii i n'li i in in i n u mi iiiiiiitiiiiiiiii ill 11 I mi ~ FUR 003912 WATER PCB-SD0000071055 U.S. DOMESTIC SALES OF PCBs BY CATEGORY (The Uppermost Curve Represents the Total Sales) U.S. Domestic Sales in Millions of Pounds 1963 1965 1967 1969 1971 YEAR 1973 1975 1977 ' 1979 FUR 003913 WATER PCB-SD0000071056 ______ U.S. DOMESTIC SALES OF PCBs BY GRADE (The Uppermost Curve Represents the Total Sales) .? m U.S. Domestic Sales in Millions of Pounds WATER PCB-SD0000071057 Section 1 Page 2 HISTORY OF MONSANTO PRODUCTION AND SALES OF CHLORINATED BIPHENYLS Therefore, Monsanto agreed to continue supplying the products to manufacturers of electrical power distribution equipment who use chlorinated biphenyls only in sealed systems such as capa citors and transformers. In continuing to sell to such customers, however, Monsanto required assurances that the materials would be safely handled and properly disposed. '" In making this decision Monsanto believed 1} that entry of chlorinated biphenyls to the envi ronment could be effectively limited and controlled by users'21; 2) proper maintenance and decom missioning practices could limit fluid escape from transformer operations, and 3) withdrawal from production for these applications would have stopped production of equipment essential to the safe and efficient distribution and use of electrical energy. In addition, a more biodegradable lower chlorinated product (AROCLOR 1016) had been developed by Monsanto for use by the capacitor industry. Steps Taken in Labeling and Transport Practices for Ongoing Dielectric Sales, 1972-1977 Monsanto shipped PCB fluids in both bulk carriers and in drums. Bulk shipments were made in Monsanto-owned railroad tank cars, which were used exclusively for that service, or in customerowned tank trucks. Drum shipments were made in special reinforced drums. A multilingual warning label was affixed to each package giving a brief description of the nature of the contents and appro priate actions to be taken in the event of a spill or leak. We also supplied a label to be used on return shipments for incineration, which gave similar information. Industry Guidelines In June, 1970, the Board of Directors of the Power Equipment Division of the National Elec trical Manufacturers Association appointed a committee to review the chlorinated biphenyl situation as it affected electrical usage. Asa result, in April, 1971, American National Standards Committee Cl 07 was established to develop guidelines for the safe use, maintenance and disposal of askarel* and askarel-soaked materials used in electrical equipment. Monsanto participated in this committee. A final draft was completed by November, 1972, and the Standard Guideline was published in 1974(3). Monsanto's Withdrawal from the Chlorinated Biphenyl Business When Monsanto decided in 1970 to restrict sales of chlorinated biphenyls, there were no satis factory alternate materials for closed-system dielectric uses. This view was later affirmed by the EPA. At least as late as a 1975 press conference, the EPA reiterated it would not ask Monsanto to stop production because that would shut down the electrical power industry and the railroads in short order. The EPA objective was to find a way to proceed without shutting down the country. That was precisely the objective to which Monsanto had been committed since 1970. The problems encountered in replacing chlorinated biphenyls were rooted in their unique fire resistant and dielectric characteristics and in their role in electrical and industrial applications for (p) AROCLOR is a trademark of Monsanto Company. '"Askarel" is a generic name for fire resistant dielectric fluids, including those which contained polychlorinated biphenyls, made to meet specifications set by transformers and capacitor manufacturers. FUR 003915 WATER PCB-SD0000071058 HISTORY OF MONSANTO PRODUCTION AND SALES OF CHLORINATED BIPHENYLS Section 1 Page 3 45 years. The challenge facing the electrical industry was to replace chlorinated biphenyls in an orderly manner, without creating other hazards of equal or potentially greater magnitude, and at the same time avoiding serious power and transportation disruptions. '' Monsanto expended considerable effort and money in major research programs aimed at developing environmentally compatible replacement fluids for the electrical industry-.-The level of this research was greatly reduced in 1976 when the electrical industry developed the technology to adapt other compounds to its needs. It now appears the ongoing demand for liquid-cooled trans formers will be satisfied by using silicone compounds. In the capacitor industry, the trend has been toward materials such as phthalate esters. . In adopting these substitutes, the electrical industry has been forced to accept lower fire resis- ' tance. New safety devices have been required to ensure that replacement equipment will not lead to increased risk to society from fire hazards. In our press statement of October 5, 1976, Monsanto said we would complete distribution of all inventories and withdraw from the chlorinated biphenyl dielectric business by October 31, 1977. In making the announcement, Monsanto said the company would have targeted an even earlier shut down date had transformer and capacitor manufacturers' conversion timetables permitted. All chlorinated biphenyl production was halted by Monsanto in July, 1977, and all customer shipments were completed by September, 1977. At the time we stopped PCB production, Monsanto established policies which precluded licensing of chlorinated biphenyl technology and restricted sales of biphenyl to uses which would not involve halogenation. ' PCBs continue to be manufactured by other firms in Germany, France, Spain, Italy and certain eastern European countries. They continue to be widely used throughout the world. Reasons for Monsanto Phaseout Scientific knowledge about the presence of PCBs in the environment, and about its possible significance, began to evolve during the late 1960's. That evolutionary process, which is still incom plete, began with two events--one in Japan and the other in Sweden. In 1968, about 1,000 people in Japan became ill from eating rice oil heavily contaminated with Japanese-produced PCBs as a result of an industrial accident which has come to be known as the Yusho incident. The level of PCB contamination in the rice oil was 2000 to 3000 parts per million, extremely high concentrations. Conclusions about that incident have been clouded by the unknown impact of impurities in the Japanese-made PCB. However, the incident sounded a cautionary signal. In Sweden, Soren Jensen, using new analytical technology to investigate DDT residues in the environment, reported the possible presence of PCBs in fish tissue. Monsanto and others began immediately to study the Swedish work, following preliminary news media reports in late 1966. Before the findings could be confirmed or duplicated in the U.S., analytical methods had to be refined in order to definitively separate PCBs from other chlorinated hydrocarbons that were known to be present in the environment. New techniques were required to enable researchers to detect these chemicals in the low parts per billion ranges being reported. The presence of PCBs in the environment in the U.S. was confirmed by 1970, but little was known about their potential impact. Because PCBs were reported in the environment and tests indicated they could accumulate in the food chain, Monsanto voluntarily decided to terminate sales FUR 003916 WATER PCB-SD0000071059 Section 1 Page 4 HISTORY OF MONSANTO PRODUCTION AND SALES OF CHLORINATED BIPHENYLS of chlorinated biphenyls to open applications--those which could result in losses to the environment. Plasticizer and carbonless paper applications fell into this category. Because of the contamination of rice oil in Japan, food processors using Monsanto's chlorinated biphenyl heat transfer fluids were advised to change to alternative heating methods and Monsanto reemphasized the need for improved monitoring of finished food products to preclude contamination by any heat transfer fluid. The decision was made in 1971 to terminate all heat transfer fluid sales of chlorinated biphenyls, substituting other products with equivalent thermal stability. High operating pressures cause hydraulic systems to leak. Monsanto therefore alerted users to manage wastes to eliminate PCB discharge to the environment. As new hydraulic fluids were devel oped in 1971, we terminated sales of those containing PCBs. As described earlier, Monsanto agreed with the electrical industry and government that the benefits to society of continued chlorinated biphenyl dielectric use outweighed the low risk of uncon trolled release from these sealed applications. The key to managing the risk was sound maintenance practice and disposal control. With particular reference to the use of PCBs in human food and animal feed processing facilities, the FDA proposed usage regulations in 1972, which were adopted in 1973, and continue in force today(4). Although a variety of effects of PCBs has been postulated from research of widely varying quality, there is no evidence of environmental levels of PCBs being a major human health hazard. However, it became apparent that the public perceived risks associated with continued PCB dielectric use and preferred to forego its undoubted functional benefits. Therefore, in October of 1976, we advised dielectric customers that it was our intent, consistent with their progress with substitute products, to terminate chlorinated biphenyl production and sale by October, 1977. Each of them forecast how much product would be required to effect an orderly technical transition. In 1977, we made sufficient dielectric chlorinated biphenyl to satisfy the forecast transition demand and made final shipments in September. The small residual inventory was incinerated in our pyrolysis unit, bringing to a close our chlorinated biphenyl business. In summary, Monsanto's decision to withdraw from the PCB business was based on concerns about environmental presence rather than health effects. FUR 003917 WATER PCB-SD0000071060 BIBLIOGRAPHY Section 1 1. Federal Interdepartmental Task Force on PCBs. (1972) p. 4. 2. Westinghouse Report. National Industrial Pollution Control Council Meeting (Jan. 3, 1972). 3. American National Standards Committee guideline, ANSI C10.7.1-1974. 4. Food and Drug Administration regulation: 21 CFR 109.15; 110.40(b); 500.45 (1973). FUR 003918 WATER PCB-SD0000071061 Section 2 Page 1__ INFORMATION ON HEALTH EFFECTS Chlorinated biphenyls range from liquid to solid, depending upon the degree of chlorination. On the basis of single dose animal tests commonly used to identify and label hazardous materials, they would be considered to be relatively harmless substances. Monsanto has conducted such acute toxicity and irritation tests on several chlorinated biphenyls over the years111. - . -- Questions have been raised in four areas of possible health effects of chlorinated biphenyls. These have been related to 1) skin (reddening, chloracne); 2) systemic effects (liver damage, res piratory effects); 3) environmental exposure, and 4) potential carcinogenicity. A review of the literature from the 1930's and 1940's on the health effects of chlorinated biphenyls contains statements such as "Much of the literature that refers to chlorinated diphenyls is referring to the mixture of chlorinated diphenyl with chlorinated naphthalene." and "A number of the references recorded under chlorinated naphthalenes also discussed chlorinated diphenyl. It is difficult to determine the role played by the chlorinated diphenyls, as, in most instances, they were mixed with chlorinated naphthalene"*21. A parallel situation occurred during the late 1960's when reports of the detection of polychlorinated biphenyls in the environment began to appear. There was confusion and disagreement as to whether polychlorinated biphenyls or other halogenated hydro carbons such as DDT were being measured, since the latter had already been identified as environ mental contaminants. Skin . Sometime before 1934, Swann Chemical Co. observed dermatological symptoms in workers exposed to chlorinated biphenyls. In May, 1934, Swann Research, Inc., requested Dr. F. B. Flinn of Columbia University's College of Physicians and Surgeons to conduct an investigation "to determine whether or not the various chlorinated diphenyl compounds submitted or some impurities contained therein might be the causative agent producing the dermatitis which had developed among some of the workmen in the plant." He commented on these studies as follows: "One is impressed with the fact that each of the Aroclors giving a positive reaction were of a fluid nature. Attempts were made to expose the animals to vapors but observations made us conclude that the only difference was that the animal would be exposed to the hot material and it was well-known that the reaction where such an exposure is given is more severe. . "One cannot but feet that any styrene compound which may be found to be present as an impurity is the cause of your trouble. / was rather surprised that more of the com pounds submitted did not show or give reactions with the skin, it has been shown in some investigations that chlorine did not produce a dermatitis when metallic electrodes were used but did if the metallic electrodes were replaced by carbon electrodes. The theory was advanced that some organic chlorine compounds were produced in the latter case. "I would suggest that you study your ventilation system in places where fumes are given off. That means be provided for the men to take a bath with soap and water if they come in contact with the type of materia! found to be positive. By this / mean if a leak or spillage occurs. The immediate bathing under these circumstances should be insisted on. / found that where l had gotten the materia! on my hands if I washed them thoroughly no trouble arose." FUR 003919 WATER PCB-SD0000071062 INFORMATION ON HEALTH EFFECTS Section 2 Page 2 In his transmittal letter to Dr. J. N. Carothers of Swann Research, Inc., Anniston, Alabama, Dr. Flinn stated: : "it may interest you to know that the dermatitis which was produced by your materials . in the case of rabbits cleared up in a couple of weeks, indicating that unless there are repeated exposures the effects are only of a temporary nature. As I said before, I believe that if wash ing facilities are present and the men are instructed to use them it will do much to supple ment the increased ventilation which you have installed. ,'<3, In the published literature, "the first observations on the development of acne-like lesions among workers in the United States coming in contact with chloronaphthalenes and chlorodiphenyls as well as acute yellow atrophy of the liver occurring among such workers were reported in 1935"(41. Results of Swann studies were published in 1936l5). There is a letter report dated December 22, 1949, to Dr. R. E. Kelly (Monsanto) from Dr. L. K. Halpern of the Barnard Free Skin and Cancer Hospital (St. Louis) describing a human patch study. This consisted of applying film treated with 11.5 percent AROCLOR and gauze moistened with 100 percent AROCLOR to skin of the upper arm of 218 volunteers using the technique developed by Dr. Louis Schwartz, Medical Director of the United States Public Health Service. Dr. Halpern reported "If the procedure recommended by the United States Public Health Service is sufficient to distinguish between chemical compounds that are innocuous when applied to the skin and other compounds that are primary irritants or sensitizers, then it would seem that Aroclor has no primary irritant effect nor is it a sensitizer of high potency."(6) Monsanto records show that this study was conducted with AROCLOR 1254. ' In 1963, Monsanto received reports of subacute rabbit dermal studies it had sponsored on several chlorinated diphenyls. Salient features of these studies, conducted according to then-currently acceptable procedures, are summarized below11 AROCLOR 1221 1242 1248 1254 1268 No effect level* LluD50 ** Local skin effects Systemic injury 150 250 none none 50 75 none none 10 50 none liver injury 10 75 yes liver injury 500 1250 yes liver injury * All dosages in mg/kg/day **Based on 20-day dosing and 14-day observation periods . These studies showed that repeated and prolonged skin contact with the higher chlorinated biphenyls could produce skin irritation and that harmful amounts could be absorbed under such conditions. They also demonstrated that there was a safe level of exposure for each material, and that they could be handled safely if the earlier precautions to avoid excessive skin contact were observed. FUR 003920 WATER PCB-SD0000071063 Section 2 Page 3 INFORMATION ON HEALTH EFFECTS Systemic Effects On June 30, 1937, a symposium bn systemic effects resulting from inhalation of chlorinated hydrocarbons was held at the Harvard School of Public Health. Dr. R. E. Kelly of Monsanto parti cipated in the sessions at which results of investigations requested by manufacturers of.-cWorinated ' hydrocarbons were presented. Subsequently, three papers summarizing the results of those studies appeared in the scientific literature17, 8-91. With respect to chlorodiphenyls, the Harvard group concluded that ". .. it appears safe and it is certainly easily attained, to ventilate so that the air breathed does not contain more than 0.5 mgm. per cu.m, of any of these compounds. . .". In a - separate unpublished report to Monsanto Company1101 Dr. C. E. Drinker of Harvard described the results of inhalation studies conducted with compound #1268, having a chlorine content of 68 per cent. He concluded, "#1268, if handled with ordinary precautions as to ventilation, should be entirely harmless to workmen." Monsanto sponsored a study at the University of Cincinnati's Kettering Laboratory on "The Toxicity of the Vapors of AROCLOR 1242 and AROCLOR 1254." A report of those studies1111, presented at the 1956 meeting of the American Industrial Hygiene Association, stated that the investigation ". . . was undertaken because in the earlier literature dealing with the toxic effects of Aroclors, no distinction has been drawn between the toxic effects of chlorinated biphenyls and those of chlorinated napthalenes ...". ' No injury was observed after prolonged intermittent exposure of several species of animals to AROCLOR 1242 at air concentrations of 1.90 to 8.63 micrograms per liter. Animals subjected to comparable exposures of AROCLOR 1254 showed signs of apparently reversible liver cell injury. The authors concluded their observations by saying "It should be noted that it was necessary to heat these Aroclors in order to increase the rate of volatilization sufficiently to attain the concentrations maintained in these experiments. To the extent that their industrial usage is carried out at ordinary temperatures, the hazard of their inhalation may well be slight or entirely absent." These studies confirmed earlier work which indicated that no harmful effects were to be expected if these materials were used with adequate ventilation since it was necessary to heat the substances to generate sufficiently high air concentrations to injure the test animals. Prior to 1956, the American Conference of Governmental Industrial Hygienists (ACGIH) had established a Threshold Limit Value (TLV) of 1 mg/m3 for chlorodiphenyl. In 1956, the listing was changed to read chlorodiphenyl (42% chlorine) as 1 mg/m3. The 1957 list showed chlorodiphenyl (42% chlorine) as 1 mg/m3 and an added TLV of 0.5 mg/m3 for chlorodiphenyl (54% chlorine). The latter two values have been unchanged since then*121. Results of the Monsanto-sponsored study1111 contributed to the decision of the ACGIH to lower the TLV for the more highly chlorinated biphenyls11. Environmental Exposure In response to reports of the presence of some PCBs in the environment, Monsanto, in 1969, initiated preliminary toxicity studies which led to a series of long-term tests. These tests, on the three predominant commercial polychlorinated biphenyls (AROCLOR 1242, AROCLOR 1254, AROCLOR 1260), consisted of 2-year (lifetime) feeding to rats, 2-year feeding to dogs, 3-generation rat repro duction studies with 2 litters cast per generation, rat teratology studies and dominant lethal muta genic studies in mice. Toxicity and reproduction studies in chickens were performed to evaluate FUR 003921 WATER PCB-SD0000071064 INFORMATION ON HEALTH EFFECTS Section 2 Page 4 possible untoward effects in birds such as decreases in eggshell thickness. This series of studies*11 re presented the most comprehensive safety tests of the time, and was similar to the tests required for food additives, although Monsanto certainly had no intention of applying for a food additive permit. The highest dietary level (100 ppm) in the lifetime rat feeding studies produced a weight depression at 24 months in females fed AROCLOR 1254 and liver weight increases in all groups except males fed AROCLOR 1242. As with other halogenated hydrocarbons, the important histo pathologic changes were present in the livers of animals sacrificed at the end of the study. These con sisted of hepatocellular (liver) alternations such as focal hypertrophy (localized enlargement), cyto plasmic lipid changes and in some animals from the 100 ppm groups, hepatomas or cholangiohepat- omas (benign tumors). There was no evidence of hepatocellular carcinogenicity with any of the AROCLOR products. In the dog 2-year studies, some slight decreases in body weight gain were noted. At the highest feeding level (100 ppm) or AROCLOR 1260, there was evidence of gastrointestinal inflammatory lesions and ulcerations. In the rat reproduction studies, none of the AROCLOR products produced adverse effects in the 2 litters of the first generation. In the second and third generations, there was a reduction in the mating index and a decrease in the incidence of pregnancy at the 2 highest feeding levels (10 ppm and 100 ppm). The ability of females to carry pups to delivery, once conception had occurred, and to successfully nourish the young was not affected by the three AROCLOR products. No changes were produced in the reproductive tracts of either male or female rats by any of the 3 AROCLOR products. There was no evidence of teratogenic or mutagenic changes with any of the chlorinated biphenyls at maximally tolerated dose levels in rats and mice. ' In the chicken toxicity/reproduction study, AROCLOR 1260 was without effect at all test levels. AROCLOR 1242 and AROCLOR 1254 at 100 ppm in the diet decreased egg hatchability. Poor hatchability of eggs was found from hens fed 8 ppm of AROCLOR 1242. AROCLOR 1242 at 10 and 100 ppm and AROCLOR 1254 at 100 ppm were associated with reduced eggshell thickness. Chick viability was affected by both substances at a dietary level of 10 ppm. Data developed by Monsanto and information gained from the Yusho incident in Japan were cited by the Food and Drug Administration (FDA) as a basis for establishing tolerances for chlorin ated biphenyls in various foods in 1973(141. Subsequently, the FDA proposed a reduction in those tolerances*151. In 1976 it was reported that AROCLOR 1248 in the diet of monkeys, at or below FDA toler ance levels for chlorinated biphenyls, adversely affected reproduction*161. FDA limits on PCBs in the human diet are related to a safe level of 1 Mg/kg body weight/day*141. The studies carried out by Allen and co-workers*161 were at dosage levels of approximately 89 and 183pg/kg/day. Their work suggested that there could be a previously unknown effect on reproduction in primates and they failed to de- . fine a no-effect level. Monsanto, therefore, undertook a detailed monkey reproduction study with carefully administered dosages at and below those previously studied. In the Monsanto study, 32 female and 16 male rhesus monkeys, divided into 4 groups each consisting of 8 females and 4 males, were given daily dosages of 0, 5 jug/kg, 25 /ig/kg or 100 ^cg/kg of AROCLOR 1254. The in-life portion of that study, which lasted about 14 months, has been completed. FUR 003922 WATER PCB-SD0000071065 Section 2 Page 5 ___________________ INFORMATION ON HEALTH EFFECTS At Monsanto's highest dosage (lOO/ig/kg/day), which corresponded to the low level in the Allen study, we find that AROCLOR 1254 has similar effects to those reported earlier for AROCLOR 1248. The results at the lower levels are not completely evaluated. Potential Carcinogenicity--Animal Studies In 1975, Dr. Renate Kimbrough reported the induction of liver carcinomas in female rats fed . AROCLOR 1260 for two years*171. The same lot of AROCLOR 1260 was used in her study as in Monsanto's earlier test. Monsanto's study showed that AROCLOR 1260 as well as AROCLOR 1242 " and AROCLOR 1254, produced liver injury, but no cancers. Therefore, an extensive reevaluation was made of the original liver slides from the Monsanto studies as well as additional liver sections from all rats in the Monsanto two-year feeding studies. These slides were examined independently by Dr. D. Gordon of Industrial BIO-TEST Laboratories, by Professor W. Richter of the University of Chicago and by Professor Parvis Pour of the Eppley Institute for Research in Cancer. In addition, Dr. Pour evaluated sections of liver from rats in Dr. Kimbrough's study. No carcinomas were seen in the livers of rats from the Monsanto studies, and Dr. Pour did not concur with Dr. Kimbrough's diagnosis of liver cancer in rats from her study*181. The different criteria by which pathologists diagnose cancer, and the reported findings of cancer induced by polychlorinated biphenyls in various animal species, have been discussed by Dr. J. C. Calandra*191. In 1977, the National Cancer Institute reported results of a bioassay for possible carcinogenicity of AROCLOR 1254. That report stated that AROCLOR 1254 was not carcinogenic under the test conditions*201. Human Epidemiology Studies The toxicity testing described above has provided a foundation for understanding the potential effects of chlorinated biphenyls. However, firm conclusions cannot be drawn without human epi demiological data drawn from exposed populations. "The view that human health risks resulting from exposure to chemicals may be determined experimentally by testing laboratory animals is one that is widely accepted in the scientific community and has been adopted by EPA. Because experimentation on human beings raises ethical questions and because epidemiological studies often provide incomplete information, toxicology studies on labora tory animals are often necessary. However, because the extrapolation from animals to man is subject to some uncertainty, corroboration of laboratory test data with sound epidemiological information is desirable." (U.S. EPA, Support Document/Draft Voluntary Environmental Impact Statement for Polychlorinated Biphenyls, 1978). Such epidemiological data on PCBs is now becoming available. Monsanto is aware of seven epidemiological studies done in the U.S. of persons exposed to PCBs. They include persons with occupational as well as community exposure, and the effects studied range from deviations in biological parameters, through reported symptoms and illnesses, to the occurrence of death from various causes. Selikoff and colleagues studied 326 volunteers who were occupationally exposed to PCBs. They report the percentage of those workers with various dermatological, gastrointestinal, neurological and other symptoms, as well as the percentage with abnormal values of clinical chemistry parameters and of pulmonary function. They concluded that reported symptoms and abnormal findings in FUR 003923 WATER PCB-SD0000071066 INFORMATION ON HEALTH EFFECTS Section 2 Page 6 physical examinations were not related to duration of employment or level of PCBs in the blood, except for abnormal dermatological findings and abnormal levels of some indicators of liver function. Although the authors claim to have found an unusual impairment of pulmonary function in their study population, no effort was apparently made to determine whether this impairmentwas related to the other findings. In spite of a correlation of some liver function parameters with PCB exposure, the prevalence of abnormal liver function was low. The authors state, "The paucity of other abnor malities on physical examination was striking; this included a very low prevalence of abnormal liver findings." (emphasis in original). The Center for Disease Control examined liver function and blood levels of chlorinated bi phenyls in a sample of PCB workers, their families, and exposed persons in the community, in Bloomington, Indiana. This study found very mild liver dysfunction (increased levels of the enzyme GGTP) and increased blood levels of a cholesterol-like substance in persons with higher blood levels of PCBs. It is not clear if these findings have any relationship to actual illness. The Michigan Department of Public Health conducted a study of 182 persons who regularly consumed sports fish, a source of PCB, and classified as "exposed," "intermediate" and "controls" according to the amount of fish consumed. A direct relationship was found between the amount of fish consumed and blood level of PCB. However, no significant difference was found between the controls and the exposed in the incidence of 18 health conditions, many of which described the symptoms reported for Yusho disease. Furthermore, in 12 of the 18 conditions, people with the condition had lower blood PCB levels than those without the condition. The authors conclude, "As a group, the exposed participants had no health problems or medical conditions that could be correlated with PCB levels, exposure to Lake Michigan fish, or known symptoms of PCB poisoning." NIOSH has completed a study of mortality rates in workers in a transformer plant where there was exposure to PCBs, but Monsanto is unable to comment because a report of the study is not yet available. The South Carolina State Department of Health and Environmental Control recently completed a study of 32 workers in a capacitor plant, 10 of whom were regularly exposed to PCBs. Details of the study available to Monsanto are limited to those contained in newspaper reports, but the study apparently involved a medical examination and a determination of blood PCB level. The authors state that the study "clearly shows that at present there is no evidence of physical harm resulting from working with PCBs." These four recent studies appear to constitute the most extensive epidemiological work yet done on chlorinated biphenyls. They each indicate an absence of morbidity (ill health) associated with significant exposure to PCBs. The Mobil Corporation carried out a study of the occurrence of cases of cancer in a population exposed for varying lengths of time between 1949 and 1957. Plant medical records were used to determine the occurrence of cancer in this group between 1958 and 1975. However, records were not available for about 20 percent of the eligible study group. The 41 men who were actually studied differed from the populations described above in that they were employed in a chemical plant which manufactured a number of different materials to which they might have been exposed during their working careers. The study found an excess of skin cancer (melanoma) based on three cases. After a preliminary report of these findings was made, the Mobil Corporation informed NIOSH that there fur 003924 WATER PCB-SD0000071067 Section 2 Page 7 INFORMATION ON HEALTH EFFECTS had been "a substantial change" in the definition of the cohort, and that an analysis of the changed cohort might show quite different results. As far as Monsanto is aware, that analysis has not yet been completed. _ In 1975, independent of the Mobil effort, Monsanto began to gather information for a mortality study of employees exposed to PCBs at its W. G. Krummrich plant in Sauget, Illinois. Because the plant had manufactured a number of chemicals, those persons exposed to PCBs typically had a mixed exposure to other substances as they moved from job to job. Because the work histories of past employees were not computerized, it would have been necessary to identify those who had worked with PCBs by a manual search through 6,000 records. A preliminary identification was made of 50 deaths from various causes among past workers with PCB exposure, and a review of these suggested a possible excess of lung cancer, but not of skin or pancreatic cancer. This preliminary finding was announced in 1976. A further attempt to identify a cohort yielded 89 men who had been exposed for at least six months in the period 1945-1965, who were then followed to determine their vital status as of the end of 1977. There were no excess deaths from pancreatic cancer, but 4 lung cancer deaths were found'where about 1.5 would be expected. Smoking histories were not available. The accuracy of the determination of this cohort was limited by the necessity of conducting a manual search of the records. At the present time, computerization of the Krummrich work histories is underway, and should be completed early in 1980. At that time it may be possible to better define the exposed population, and to better determine the other substances to which the population.was exposed. However, because of the mixed nature of exposures in a chemical plant, it is unlikely that the Monsanto study can ever be as specifically related to PCBs as those conducted by Dr. Selikoff, CDC, the Michigan DOH, and the South Carolina DOH. FUR 003925 WATER PCB-SD0000071068 BIBLIOGRAPHY Section 2 1. Unpublished reports of studies conducted for Monsanto Company. 2. Irish, D. D. "Chlorinated Diphenyls, pp. 1340-1343 in Industrial Hygiene and Toxicology, Patty, F.A., ed., Interscience Publishers, New York, 2nd rev. ed., 1963. 3. Flinn, F.B. "Report of Frederick B. Flinn of Patch Tests Made on Material Received from Swann Research, Inc." May 25, 1934. ' ' 4. Schwartz, L. "On Outbreaks of Halowax Acne ("Cable Rash") Among Electricians." J. Am. Med. Assoc. (1943) 122: 158-61. 5. Jones, J. W. and Alden, H. S. "An Acneform Dermatergosis." Arch. Derm. & Syphilol. (1936): 33, 1022-1034. 6. Halpern, L. K. "Project W-31 Aroclor (Report on Patch Testing)." December 22, 1949. 7. Drinker, C. K., Warren, M. F. and Bennett, G. A. "The Problem of Possible Systemic Effects From Certain Chlorinated Hydrocarbons." J. Ind. Hyg. & Toxicol. (1937) |9:(7), 283-311. 8. Bennett, G. A., Drinker, C. K. and Warren, M. F. "Morphological Changes in the Livers of Rats Resulting from Exposure to Certain Chlorinated Hydrocarbons." J. Ind. Hyg. & Toxicol. 20:(2), 97-123. 9. Drinker, C. K. "Further Observations on the Possible Systemic Toxicity of Certain of the Chlorinated Hydrocarbons With Suggestions For Permissible Concentrations in the Air of Work rooms." J. Ind. Hyg. & Toxicol. \ 1939) 21: (5), 155-159. ' 10. Drinker, C. K. "Report to the Monsanto Company." September 15, 1938. 11. Treon, J. F., Cleveland, F. P., Cappel, J. W. and Atchley, R. W. "The Toxicity of the Vapors of Aroclor 1242 and Aroclor 1254." Am. Indust. Hyg. Assoc. Quart. (1956) J7:(2), 204-213. 12. American Conference of Governmental Industrial Hygienists. "Threshold Limit Values for 1955." AMA Arch. Indust. Health (1955)_M: 521-524. "Threshold Limit Values for 1956." AMA Arch. Indust. Health (1956) 14: 186-189. "Threshold Limit Values for 1957." AMA Arch. Indust. Health (1957) J6: 261-265. "TLVs Threshold Limit Values for Chemical Substances in Workroom Air Adopted by ACGIH for 1979." 13. American Conference of Governmental Industrial Hygienists. "Documentation of Threshold Limit Values For Substances in Workroom Air." (1977) 4th printing, Cincinnati, pp. 51-52. 14. "Polychlorinated Biphenyls (PCBs)." Fed. Regis. 38: (.129), July 6, 1973, pp. 18096-18104. 15. "Polychlorinated Biphenyls (PCBs)." Fed. Regis. 42: (63), April 1, 1977, pp. 17487-17494. 16. Barsotti, D. A., Marlar, R. J. and Allen, J. R. "Reproductive Dysfunction in Rhesus Monkeys Exposed to Low Levels of Polychlorinated Biphenyls (Aroclor 1248)." Fd. Cosmet. Toxicol. (1976) T4: 99-103. 17. Kimbrough, R. D., Squire, R. A., Linden, R. E., Strandberg, J. D., Montali, R. J. and Burse, V.W. "Induction of Liver Tumors in Sherman Strain Female Rats by Polychlorinated Biphenyl Aroclor 1260." J. Nat Cane. Inst (1975) 55: 1453-1459. 18. "Histopathological Reevaluation of Livers from Rats Treated with AROCLOR." (Industrial Bio-Test Laboratories, Inc. Reports and Eppley Institute Reports.) 19. Calandra, J. C. "Review of the Technical and Regulatory Aspects of Aroclors" June 27, 1975. 20. "Bioassay of Aroclor 1254 for Possible Carcinogenicity." National Cancer Institute Technical Report Series. No. 38. (1978). FUR 003926 WATER PCB-SD0000071069 Section 3 Page 1___________ MONSANTO ACTIONS RESULTING FROM HEALTH DATA Monsanto has been responsive to health questions about chlorinated biphenyls over the years. Those responses have been consistent'with "state of the art" procedures available at the time the questions were raised. It should be noted that Monsanto's decision to leave the PCB business was based on concerns over environmental presence, not health effects. ............. Skin and Systemic Effects . When first reported in 1935*1-21, the occurrence of skin and systemic effects from chloro- naphthalenes and chlorodiphenyls constituted a new occupational health problem. It rapidly became of concern to federal and state occupational health personnel ancf to their industrial counterparts. Monsanto was among the sponsors of and a participant in the studies and the subsequent symposium held on this subject at Harvard University. In addition, Monsanto conducted its own studies on various polychlorinated biphenyls14'5'6'71. Earlier, Swann Research, Inc. had conducted human patch tests on these materials181. Results of these efforts suggested that controlling skin contact and vapor inhalation would permit safe industrial use of these substances. In 1936, Monsanto began developing a corporate medical program. From the start, Monsanto's Medical Director ensured that chlorinated biphenyl workers at Anniston were included in this program. This consisted of periodic physical examinations, good work practices to ensure personal cleanliness of employees, adequate ventilation of the work areas, and overall good industrial hygiene practices. The buildings at the Anniston plant were relatively open and most of the processing was done in closed equipment. Therefore, employee exposure was relatively low. However, since some customers were using chlorinated biphenyls at elevated temperatures, with a greater potential for exposure, precautionary statements for handling them were prepared for customer use as early as 1937l9). As additional information developed, it was incorporated into Monsanto work practices and distributed to customers by way of correspondence, technical bulletins, and other corporate publications. In addition, upon request, Monsanto technical and medical personnel visited customer plants to advise them on safe handling of polychlorinated biphenyls. Finally, the Monsanto-sponsored studies on AROCLOR 1242 and AROCLOR 1254 led the American Conference of Governmental Industrial Hygienists (ACGIH) to lower the Threshold Limit Value (TLV) for the higher chlorinated biphenyls in 1957,10). Environmental Presence in late 1966, Soren Jensen of the Karolinska Institute in Sweden reported the detection of poly chlorinated biphenyls in the environment. This was confirmed by 1970. In the interim, Monsanto's European office had entered into discussions with the Karolinska Institute in an attempt to obtain details of the findings. In early 1969, representatives of Monsanto went from St. Louis to Sweden to meet with Jensen. He was not available, and discussions were held with his professor. Dr. Widmark. At about the same time, Monsanto decided to develop data on the chronic oral toxicity of chlorinated biphenyls. Although there was no intention of petitioning for such use, the extent of these tests was typical of those designed for the evaluation and establishment of the safety of direct and indirect food additives. This series of tests was undertaken because it represented the most comprehensive requirement of safety at that time*111. FDA was informed of the voluntary testing program in October, 1969*121. Subsequently, as evidence of environmental presence increased, those studies were FUR 003927 WATER PCB-SD0000071070 MONSANTO ACTIONS RESULTING FROM HEALTH DATA Section 3 Page 2 expanded in scope. Chicken studies to determine the effects of chlorinated biphenyls on avian species were completed in 1970 and 1971. Results of all these studies have been distributed to the FDA and other regulatory agencies. During this time period, Monsanto expanded the warnings on its product labels to include cautions against allowing escape to the environment. When, in 1976, reproductive disorders were reported in monkeys fed chlorinated -biphenyls'131, ' Monsanto undertook a study to determine the validity of those findings. The Monsanto study is . being conducted with AROCLOR 1254, a large volume material, instead of the relatively low value . AROCLOR 1248 used by the earlier investigators. Potential Carcinogenicity In 1975, after Dr. Kimbrough reported that AROCLOR 1260 produced liver cancer in rats'141, Monsanto undertook a review of liver sections from its earlier studies on AROCLOR 1242, AROCLOR 1254, and AROCLOR 1260. In addition, it retained Dr. Pour of the Eppley Institute for Research in Cancer to review all liver sections from all of the AROCLOR studies, i.e., Monsanto's and Dr. Kimbrough's'151. That review showed no occurrence of liver cancers. Finally, Dr. Calandra was retained to review and comment on available literature dealing with carcinogenicity of poly chlorinated biphenyls'161. Results of those evaluations have been made available to regulatory agencies. MUC '..U .mumuuww*- FUR 003928 WATER PCB-SD0000071071 Section 3 BIBLIOGRAPHY 1. Schwartz, L. "An Outbreak of Halowax Acne ("Cable Rash") Among Electricians."./. Am. Med. Assoc. (1943)122: 158-161. 2. Jones, J. W. and Alden, H. S. "An Acneform Dermatergosis.'Mrr/?. Derm. & Syphilol. (1936) 33:1022-1034. ' ' " "" 3. Bennett, G. A., Drinker, C. K. and Warren, M. F. "Morphological Changes in the Livers of Rats Resulting From Exposure to Certain Chlorinated Hydrocarbons." J. Ind. Hyg. & Toxicol. 20: (2), 97-123. . 4. Drinker. C. K. "Report to the Monsanto Company." September 15, 1938. 5. Halpern, L. K. "Project W-31 Aroclor (Report on Patch Testing)." December 22, 1949. 6. Treon, J. F., Cleveland, F. P., Cappel, J. W., and Atchley, R. W. "The Toxicity of the Vapors of Aroclor 1242 and Aroclor 1254." Am. Indust. Hyg. Assoc. Quart. (1956) J7: (2), 204-213. 7. Unpublished reports of studies conducted for Monsanto Company.- 8. Flinn, F. B. "Report of Frederick B. Flinn of Patch Tests Made on Material Received from Swann Research, Inc." May 25, 1934. 9. Watt, L. A. Monsanto internal memorandum. October 11, 1937. 10. American Conference of Governmental Industrial Hygienists "Threshold Limit Values for 1955." AMA Arch. Indust. Health (1955) JJj 521-524. "Threshold Limit Values for 1956." AMA Arch. Indust. Health (1956)_14: 186-187. "Threshold Limit Values for 1957." AMA Arch. Indust. Health (1957) J6: 261-265. 11. Unpublished reports of studies conducted for Monsanto Company. 12. Wheeler, E. P. Letter to A. R. Glasgow, October 3, 1969. . 13. Barsotti, D. A., Marlar, R. J. and Allen, J. R. "Reproductive Dysfunction in Rhesus Monkeys Exposed to Low Levels of Polychlorinated Biphenyls (Aroclor 1248)." Fd. Cosmet. Toxicol. (1976) J4: 99-103. 14. Kimbrough, R. D., Squire, R. A., Linder, R. E., Strandberg, J. D., Montali, R. J. and Burse, V. W. "Induction of Liver Tumors in Sherman Strain Female Rats by Polychlorinated Biphenyl Aroclor 1260." J. Nat. Cane. Inst. (1975) 55: 1453-1459. 15. "Histopathological Reevaluation of Livers from Rats Treated with AROCLOR." (Industrial BIO-TEST Laboratories, Inc. Reports and Eppley Institute Reports.] . 16. Calandra, J. C. "Review of the Technical and Regulatory Aspects of Aroclors." June 27, 1975. FUR 003929 WATER PCB-SD0000071072 COMMUNICATING WITH CUSTOMERS Section 4 Page 1 Notification Procedures Beginning in February, 1970, Monsanto notified its customers of the early reports that PCBs had been detected in the environment. Additional information was transmitted to customers as it became available, along with details of Monsanto's phaseout. The notification letters included the priority given to terminating applications that seemed relatively likely to lead to environmental release, were food related, or used the more highly chlorinated products. We cooperated with users of hydraulic fluids and heat transfer fluids to discontinue PCB use. Simultaneously we introduced AROCLOR 1016, a lower chlorinated product for capacitor use, and restricted transformer fluid sales to equipment manufacturers only. In the case of both capacitor and transformer producers, we emphasized the need for control of PCBs. In 1974, Monsanto revised its dielectric literature to conform to the ANSI guideline which resulted from the industry work with ANSI referred to earlier. In 1976 the ANSI committee was reconvened to consider the need for revision of the guidelines. Completion of this task has been deferred pending issuance of EPA regulations on PCBs. Monsanto Provided PCB Disposal Assistance to Customers In 1969 Monsanto started testing the efficiency of PCB destruction by high temperature pyroly sis and constructed a 6 million pounds/year unit which was completed in May, 1971. This incinerator was designed, and was demonstrated, to destroy PCB wastes at 99.9998 percent efficiency. By September, 1971, this unit was in continuous operation and was destroying both waste from our production and PCBs returned by customers as they converted to non-PCB replacements. When phaseout from nonelectrical applications was complete, the incinerator was used to destroy waste PCB which collected from ongoing dielectric use. A system was developed to properly handle customer return of wastes. When some customers ' did not follow our suggested procedures, Monsanto reemphasized the need for proper packaging. To assist in proper handling, posters were prepared and distributed to further educate those responsible for collection and handling of PCB wastes. In the period 1975-1976, large (approximately 80 million pounds/year) commercial facilities became available which could handle controlled PCB incineration more efficiently and economically than Monsanto's small prototype unit. These units incinerated PCBs until their operations were cur tailed by the need for a specific permit under the EPA.disposal regulations for PCBs, which became effective on April 18, 1978. The first permit has yet to be issued. The potential risks of accidental PCB contamination have undoubtedly increased because of the delay in EPA implementation of its incineration policy (see Section 5). .. Label Warnings In 1970 Monsanto modified the labeling of PCB packages to emphasize the need to keep it from the environment. Subsequently, labels on drums were written in seven languages. Assistance with Identification of PCBs Because of the changes in composition of PCB dielectric fluids since their introduction, Monsanto worked with the I EC to document such changes. This led to ASTM standard D2283, FUR 003930 WATER PCB-SD0000071073 Section 4 Page 2 COMMUNICATING WITH CUSTOMERS which lists the composition of all transformer askarels used at various times since 1932. Monsanto researchers worked within ASTM to develop refined technology for determination of PCBs in the environment. This resulted in approval of ASTM D3304 which has become standard methodology for PCB quantification. While many laboratories have the necessary equiprrten't, pro ficiency in the methodology varies widely. Monsanto's Applied Sciences group regularly consufts with laboratories as they gain experience in testing for PCBs. Regulations require many such tests to be performed. The testing load has been greatly increased by the policy EPA adopted in controlling PCB-contaminated oils at the 50-500 ppm level. This is causing serious delays in reporting of test results. We recognized that after Monsanto terminated production of chlorinated biphenyls, small samples of products which had previous commercial significance would be required for research and standardization of detection equipment. Arrangements were concluded with a laboratory supply house to take custody of a limited drum quantity and to supply such samples. Continuing Research Monsanto is funding studies at two major universities which are directed at finding innovative approaches to reducing PCB levels in the environment. FUR 003931 WATER PCB-SD0000071074 PCB DISPOSAL Section 5 Page 1 During the years Monsanto made chlorinated biphenyls, the quantity of waste produced was relatively low and consisted chiefly of distillation residues, after separation of the useful product mix. Until 1971 these residues were landfilled. From 1971 to 1977 production waste was incinerated. In the 1970's, PCBs were frequently singled out by the EPA, legislators, environmentalists and the news media as the symbolic example of why tough, new toxic substance control regulations (TOSCA) were needed in the United States. In the process, the hazards of PCBs were greatly exaggerated. Adjectives like "deadly toxins" and "potent cancer-causing agents" were and still are typically used to describe PCBs in government handouts and press accounts. The result is that the public becomes hysterical at the mere mention of these compounds, and with small wonder. The present EPA moratorium on disposal of PCB waste products is another by-product of this hysteria. Once a disposal program is approved, it's almost certain that the problem will shift to obtain ing disposal permits in the face of public opposition to disposal facilities. John Dickinson, chief of the hazardous waste section of EPA Region IV in Atlanta, Ga., spoke to this point at a Toxic Sub stances Control Institute Seminar, Oct. 15-19, 1979. He termed PCBs "political pollutants" which he defined as pollutants which can be safely and securely disposed of, but ones which no one wants to handle because of public opposition. He pointed out that other chemicals are much more dangerous than PCBs, but PCBs have received the major share of media attention. At the same seminar, Raymond D. Harbison, director of the Toxic Substances Control Labora tory at Vanderbilt University, said PCBs are totally immobile and are not carcinogenic to humans. FUR 003932 WATER PCB-SD0000071075 FUR 003933 1 -4296 -0680- Litho in V . 5 WATER PCB-SD0000071076 FUR 003934 Monsanto Company / Public Relations Department / 800 N. Lindbergh Blvd. / St. Louis, Mo. 63166 / (314) 694-2891 WATER PCB-SD0000071077 Monsanto EUROPE S.A. FROM .Brussels, Belgium (NAMl A LOCATION) DATE ,1st December, 1966 ...,. . SUBJECT .Aroclor''Swede.n . ~ - ..REFERENCE .DWjgb;- . TO . G. R. 'Buchanan b St. Louis CCA. Arpino - Brusseb Dr. Emmet Kelly - St. Louis D.V.N. Hardy - London R.A. Steenrod - St. Louis Dear George, i attach a copy of a letter received from Ola Palm in Stockholm. ' I have sent copies of this letter also to the appropriate departments within our own organisation. In consideration of the importance ' we are placing on development of the Swedish market for Aroclor over the next five years, we would be grateful if you could arrange for this information to be considered by the appropriate departments ..in St. Louis and their comments transmitted to us as soon as possible. Based on the recommendations made by our medical departments weshall have to decide whether to arrange for publication of data in Sweden or not. ' In ..relation to the specific problem mentioned of disposal of used materials, we would be interested to learn how this problem is handled in America. In the U.K. many companies have been burying .... material in drums, material in the drums having been absorbed into ' 7v.erm.icul ite or some similar porous material. Has any entirely safe -. method been developed for the disposal of waste Aroclor ? Best wishes.' D. Wood. P.S.- Thinking of the total quantities of Aroclor used in Sweden compared with the much larger volumes of Pentachlorophenol and Sodium Pentachlorophenate, for water treatment in the paper industry and s.apstain control in the timberindustry. Is it likely that the chlorinated phenols show similar chromatographic traces to the chlorinated bi-phenols? FUR 003944 WATER PCB-SD0000071078 cc: Mr. D.S. xmeron - ME RISING & STRAND OP/BO AKTI EBOLAG TEUCFON; 3< 01 B5 TELEQRAM ; HENRIS TELEX I 1624 rOSTOlRO: B 44 43 BANKOlROi 73-044B 1Q66November ,STOCKHOLM Va SVEAVAcEN 4 7 28 Monsanto Europe BRUSSELS,J Belgium For the attention of Mr. D. WOOD .Dear David, re: ARGCLORS As mentioned, there has been some publicity in Sweden./ concerning investigations made at the Institurijoru^r Analytical Chemistry at the Stockholm University. These have revealed that a group of products called Polychlorinated Bi-Phenols - PCB for short - accumulated in certain organs of animals. They are said to be related to DDT and equally poisonuous. The findings were discussed at a meeting of scientists at. the .Wenner-Gren Centre in Stockholm on November 22, Below'please find a translation of an article in the Swedish'dally paper "Dagens Nyheter":- "It is found in salmon and in pike. It .is found in sea eagle living on fish. It is found,' t-h^- sur face of the needles of the fir trees, t^hat isjui the air. It is found in the hair of-a-five months baby... * ' . L ' )i The scientists working with biocides have for a'llong time seen this something as unknown;-,"peeks" onjtiheir gas chromatographs and at a meeting'^t the Wenner- Gren Center, Research Assistant Sbren'"Jansen of the Institution for Analytical Chemistry at the Stock holm University could reveal the identity of these peeks. It has been found that they consist of a group of poisons. Polychlorinated Biphenols (for short PCBj which are closely related to, and equally poisonous as, DDT. PCB is broken down considerably slower than DDT and gives rise to damag/of liver and skin. PCB is not FUR 003945 \ WATER PCB-SD0000071079 1< I s. i h c. fc strand MESA, Brussels - Mr. D. Wood 2. used as a herbicide. It is not manufactured in Sweden but is supposed to used by the industry to quite some extent. No speoial industry can so far be accused of being the source of contamination"" Research Asst. S. Jensen has tested 200 fishes and a number of birds. He has taken several samples of air and has reached the conclusion that PCB is equally oommon in Nature as chlorinated hydrocarbons of the type of DDT, DDE, and Lindane. Even fish in Laddjojaure in-Lapland contain PCB. Mr, Jensen has also'found that PCB doeB not appear in animals living on a vegetarian diet, such as the elk. In the course of his'work, Mr. Jensen has not found . ... anything indicating.that the source of contamina- . tion oomes from agricultural additives. It is, . however, obvious already now that PCB is most frequently found in organisms living in-water or feeding from water animals. In all examined pikes PCB was found. In a sea eagle found dead outside ' Stockholm it was found that the liver contained 30 mg of mercury per kilo, 76 mg DDT and oonsider' ably more PCB. The exact figure has not yet been determined. PCB is found in water and in air, and not only in . the Swedish air, but also in e.g. London air. Mr. Jensen has not yet been in London for sampling but could identify the poison by studying a gas chromatogram of air published in a British techni cal Journal. . Mr. Jensen har also examined the hair of his family . and-himself and has .found PCB on all samples. Most PCB was'found in the hair of his wife but most sensational was that the girl aged 5 months . had more PCB in her hair than her brothers and sisters of 3 and 6 years. Probably the girl had got the poison via the mother's milk. In the State Museum Mr. Jensen has examined the ; - - whole collection of sea eagles dating back to 1880. By testing it could be established that PCB was ' present only, in birds from 19^ and thereafter while birds collected before 19^4 were quite free from PCB. The use of PCB in Sweden is not established in detail. According to American sources these types of products are used in the manufacture of a variety of heat . y resistant materials. They 'are used for electrical insulation, for fire-proof heat transport in ' hydraulic. oils, in lubricating oils used at high FUR 003946 WATER PCB-SD0000071080 . U1L .1,11111111;,1....... Ill 5 I N C A STRAND ESA, Brussels - Mr. D. Woo 3- temperature and pressure, in paints and as pig ments in various plastics. PCB is not imported only as such. It is also part of several finished ...products. Nothing is known as to the way 'ihr'wKich it reaches the water and the air. According to _Mr. Jensen, products containing PCB should have `this openly declared. PCB is equally harmful whether absorbed via the skin, through the food, or by inhalation. In con tact with the skin it can cause oe dema. For DDT . the highest permissible concentration in the air has been set at 0.5 - 1 mg/cu.metre. ' For PCB it has been mentioned to be 0.5 mg/cu.metre. Mr. Jensen will now try to get more complete analytical material. He hopes eventually to be able to disclose the source of the contamination and'will also increase his cooperation with toxocolo'gists and geneologists." Another daily paper, Svenska Dagbladet, has a similar article. Here it is mentioned that Mr. Jensen, work ing under Laborator (Professor) Gunnar Widmark, has disclosed facts which will have far-reaching importance since the findings have .proved a new source of pollu tion .of the nature. One of the participants at the meeting was Dr. A.V. Holden of Scotland, scientific contact man between the twelve O.E.CiD. countries, who has established coordinated analysis of chemicals used and found in nature. , I suppose there is no doubt that what has been termed ' '.. Polychlorinated Biphenyls is equal to Aroclor. There ' Is also no. doubt that the published facts will cause considerable unrest in several quarters. We probably will; have to have Aroclor registered with the Swedish Board of Poisonous Substances and the industry will have to be particularly careful in handling the material. The problem in some cases of course may be the disposal .of used material. . I understand that there hardly exists a convenient method of destroying Aroclor and that possibly burying unuseable material may be the only answer. We shall be glad to hear from you soon. Yours sincerely FUR 003947 WATER PCB-SD0000071081 3 UNITED STATES DEPARTMENT OF THE INTERIOR. FJSH AND WILDLIFE SERVICE bureau of sport fisheries and wildlife 6UILOING 16. DENVER FEDERAL CENTER ' DENVER. COLORADO 00225 ' January 16, 1968 WRcs Monsanto Chemical Company 800 N. Lindbergh Boulevard St. Louis, Missouri ` . . . Gentlemen: .' . It has been brought to our attention that presumptive evidence of chlorinated biphenyl and chlorinated polypTenyl coupoiinds have been found in avinn and animal tissues. \le are in the process of further investigation of compounds of this series and would appreciate your sending us samples of your Arochlor compounds numbers 1242, 1254, 12o0, 1268 and any others vlvich might be extensively used. Sincerely yours, Richard A. Wilson)--Sr. Research Chemist (Biochemistry) FUR 003948 WATER PCB-SD0000071082 102 Minutes of Meeting of the CORPORATE DEVELOPMENT COMMITTEE April 22, 1968 Present: C. H. Sommer Chairman E. J. Bock J. L. Christian J L* Gillis R. K. Mueller E. A. O'Neal M. C. Throdahf R. K. Flitcraft - Secretary FUR 003336 WATER PCB-SD0000071083 103 Dr. Anagnostopoulos reviewed the functional fluids group. Phosphate esters and AROCLOR are the two major products in this group. The product group expects to be above the 1968 budget in terms of ROI and on the objective line for net income. . The major issue in the SKYDROL area becomes one of accelerated competition and more stringent performance requirements. The over-all strategy will be to stay ahead of our competition by providing a demonstrated significant performance edge over potentially competitive products. SKYDROL HT is believed to be a long term solution in this market area, with SKYDROL 500-C being an interim solution between now and 1970. In the case of jet engine lubricants, the key issue is how to commercially exploit the research investment in jet lubricants. It is believed that we have materials that are ahead of our competition in most categories. The strategy between now and the middle 1970's will be to become suppliers of formulated lubricants to one or more of the oil companies. In the case of AROCLOR the key issue becomes how to significantly increase the sales growth while maintaining the domestic supply position and profitability. It is believed that transformers and heating systems provide the major opportunities. A target of 10 per cent of the transformer market by 1^972 has been set. In the case of THERMINOL we have about a $1 M business in 19 68, and a target of a $10--20 M business by 1972. In this area, a total systems approach is being used; supply the fluids, design the system and supply the hardware. FUR 003337 WATER PCB-SD0000071084 ION l December 30, 1968 'AROCLOR -WILDLIFE W. A. Kuhn - WKUH-N cc, H. Bergen P. Hodges - E. Wheeler Tucker D. 01Bon R. Kountz ' R. Davis W. Johnson HBSRG PHODG EWHKK JFQ DOLSO RKOUN RDAVI V/JOHM Bill, you wanted to become more familiar with the legal-political problems facing Aroclor v;ith regard to pollution and the accusations in the . literature that chlorinated biphenyls are poison ing and killing wildlife. These wildlife people have to be taken seriously. They have taken the DDT industry to court in Wis consin to prevent the. use and sale of DDT in Wisconsin and if they win in that state, DDT will be banned In many others.. This case was on National Television last week. The wildlife people are dedicated to the demise of DDT. Our problem is that Aroclor has been ''identified" along with DDT residues and. hence we are almost certain of being drawn into the court records and may "also be one'of the scapegoats of the DDT defense. The wildlife people have ac.cysed Aroclor of doing all the bad.things of DDT. ' We are taking 3 steps to. protect ourselves. Scott Tucker and R. Keller are to repeat some of the 'analytical identification work- feeding Aroclor to chickens and seeing if Aroclor is really present as "shown" by the literature. I hope we have been falsely accused but maybe Aroclor is present. E. Wheeler Is having feeding tests done on animals to establish a "safe" level for. Aroclor feeding. If we can find a "safe" level Calandra's Lab will do 2 year experiments on animals including effects on succeeding generations. This will help a bit but the wildlife people won't be stopped by this kind of evidence. ... 1 PLAINTIFF'S DEPOSITION ' EXHIBIT fur o3949 WATER PCB-SD0000071085 W. A. Kuhn -2 Dec. 90, I960 Thk third step is to minimize exposure of Aroclor, to'reduce air'and water pollution, to restrict .Aroclor to uses which can be controlled. This is the only way I see to survive. ' I believe we should make sure that our plants have minimum air or stream pollution. I believe Anniston is vulnerable and that, off-gas HC1.and Aroclor . should be 100# controlled. Krummrich may also need help. . .. '' . ' ' ' ' X believe we should demonstrate that Aroclor can be incinerated to harmless products for disposal. I believe v/e should help our customers dispose of off-grade or non-reworkable Anoclor, either by in cinerating or by toxic dump, . . I believe plasticizer group marketing should know where their product is going and be. able to mini mize exposure"risk if Aroclor has truly been identi fied as a pollutant. We probably have 6 months to 1 year while they fight out the DDT case, I want to use this' time to minimize our exposure. We will need your help in setting TSD targets............................ .... ............ V. ? ms . .. W,, R. Richard FUR 003950 WATER PCB-SD0000071086 Monsanto COMPANY 600 N. Lindbergh Boulevard St. Louie, Miaoouri 63166 (314) OXford 4-1000 March 3, 1969 OMAHtC CHEMICALS DIVISION On February 24, the San Francisco Chronicle carried a major feature about "a menancing new pollutant" found in the San Francisco Bay area. The article was based on marine life re search carried out by Dr. Robert Risebrough of the University of California. It stated that residues of polychlorinated biphenyl (PCB) were killing certain marine birds and posed a long-term threat to humans. This story has caused considerable comment on the West Coast and its claims may be repeated elsewhere. As you know, Monsanto manufactures polychlorinated biphenyl and markets it under our Aroclor trade name. We, therefore, would like to present some additional facts. The work done by Dr. Risebrough dates back to earlier research by other scientists to analyze the amount of pesticides in wildlife, soil and water. The initial pesticide research was extremely difficult since any search to detect materials in the parts-perbillion range also brings out other "interferring" substances. 1 PLAINTIFF'S DEPOSITION i EXHIBIT FUR 03967 WATER PCB-SD0000071087 2- - Several years ago, two Swedish scientists at Stockholm University's Institution of Analytical Chemistry, Professor Gunnar Widmark and Soren Jensen, reported they had identified the other substances which were appearing during analysis of chlorinated pesticide resi dues. They said some of the materials were polychlorinated biphenyls or PCB. The amount reported was in the parts-per-billion range, or less. Since PCB's are not "broadcast" or spread around the land as are pesticides, the scientists theorized that the source must be the industrial wastes of PCB users. Dr. Risebrough's more recent work reports the identification of PCB, along with DDT and DDE pesticides, in the tissues of birds and fish on the West Coast. The conclusionsof these scientists are puzzling from several aspects. Polychlorinated biphenyls are stable chemical compounds which are essentially insoluble in water. Their use does not make them easily released into the natural environment. A principal market for PCB is in electrical applications where they are used as insulating fluids for transformers and capacitors, In this use, the chemical is completely sealed in metal containers. Another market is for heat transfer applications where the PCB fluid functions in a closed system. PCB's are also used in several "plastic type" applications. Here the chemical is incorporated into the polymer as an integral part of the solid material. This applies whether the polymer is used as an adhesive, an elastomer or a surface coating. The Swedish and American scientists also imply that polychlorinated biphenyls are "highly toxic" chemicals. This is simply not true. The toxicity of any material, whether it be chemicals, drugs, natural plants or even foods, is relative. Compared to the thousands of industrial chemicals and home products, PCB's are not toxic unless they arc mishandled or misused. During more than thirty years of U.S. production and use, cases of any toxic effect have been extremely rare -- and then only where the simple precautions recommended for use were not followed. FV3R03968 WATER PCB-SD0000071088 -3- To our knowledge, polychlorinated biphenyls are not sprayed or dusted on crops, woodlands or any other areas, as are pesticides. It is, therefore, not only puzzling, but extremely difficult to con ceive how commercially produced PCB can show up in wildlife_as DDT and other pesticides appear to be. This raises the question whether the substance identified in the Swedish work, and now in California, is actually PCB -- or whether they are materials which, due to the metabolism of other materials in the marine environment, appears to be PCB. Unfortunately, even though techniques for analyzing tissue samples have become quite precise, the ability to analyze the possible impact of naturally occurring substances in the food cycle ofliving organisms has not made comparable advances. Monsanto has a research program to confirm the identity of the compounds reported to be PCB by the Swedish and California scientists. We also cooperate, on a regular basis, with federal, state and university laboratories in their analysis of chlorinated hydrocarbon residues. Additionally, Monsanto will continue to exercise the highest degree of control in its manufacturing, shipping and storage of PCB -- as we do with all products. In the functional fluids market, we have carried out a program for several years for the reclamation of used PCB's to avoid disposal of these valuable materials. The source of the marine life residue identified as PCB is not yet known. It will take extensive research, on a worldwide basis, to confirm or deny the initial scientific conclusions. We will keep you advised of our own research and are available to answer questions as they may arise. Very truly yours, /ecd Elmer P. Wheeler Manager Environmental Health fORO^69 WATER PCB-SD0000071089 Mohs a ii to men mMclosMioNi V/'. R, Richard I/iAH 10 RK'D Research Center OM l tunnci , KitIHCNCt TO : March 6, 1969 AROCLOR WILDLIFE ACCUSATIONS E. Wheeler - EWHEE --_ co H. Bergen J. Springate W. Schalk D. Olson R. Kelly J. Garrett P. Hodges -?. Park R. Keller E. Tucker II BERG JSPRI WSCHA DOLSO RKELL JGARR PHODG PPARK JFQ JFQ Rlsebrough in a recent paper "Nature", Vol. 220, Dec. lJi, 19' attacked chlorinated biphenyls in three ways: (3) a pollutant - widely spread by air-water; therefore an un controllable pollutant. (2) a toxic substance - with no permissible allowable levels , causing extinction of peregrine falcon by Induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. ' (2) a toxic substance endangering man himself; implying that the peregrine falcon is a leading indicator of things to come. As outlined in Science,Vcl. 163, Pg. 5*18, Environmental Defense Fund (EDF) 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 in acute or chromic (injury) to animal, plant or aquatic life". Wisconsin is one of 7 states which now have federally approved water quality standards. According to Bern W'right, acting chief of the Federal Water Pollution Control Administration's Water Quality Standards Branch, DDT would fit the definition of a pollutant upon a showing that it is harmful to aquatic life. ' These people in F.DF are saying we must not put stress on any 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 DDT and PCB's and are using these arguments to prove that very small .amounts of chlorinated hydrocarbons are "harmful". Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations.. (a) Monsar.bc is preparing itself to identify trace ppb quantitl es of c.hlor.'.nabed -biphenyls in water samples, in concentrated collected air samples, and in animal tissues. We will know whether we have been falsely identified and accused or not. We will eventually know where any pollution is taking place and the extent of the pollution. FUR 003970 WATER PCB-SD0000071090 E. Wheeler -2- March 6, 1969 (b) We are not prepared to defend ourselves against the accusa- tlons 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 limits of chlorinated biphenyls for certain blrds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. We may be able to answer reproductive ability in some animals. DDT 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 does this leave us? Under identification and control of exposure - we will be able to identify and analyze residues as well or better than anyone in the world. We will probably find residues other than DDT and PCB's. We will probably wind up sharing the blame in the ppm to ppb con centration level. We can take steps to minimize pollution from 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 work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users. . But, we can't easily control hydraulic fluid .losses in small plants. It will be still more difficult to control other end uses such as cutting oils,-adhesives, plastics and NCR-paper. in these appli cations exposure to consumers is'greater and the disposal problem becomes complex. If chlorinated biphenyl is shown to have some long term enzyme or hormone activity in the ppm range, the appli cations with consumer exposure would cause difficulty. Risebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which have exposure problems. Since Risebrough's paper in "Nature", Dec. 1968 has Just been published, it is timely, perhaps imperative, that this paper and its implications be discussed with certain customers. This is a rough one because it could mean loss of business on empty and false claims by Risebrough. Well prepared discussions with Ina. Bio-Test, Monsanto biochemists, the medical and legal departments must take place now. The . WATER PCB-SD0000071091 E. Wheeler 3- - March 6, 1969 position of DOT manufacturers should be determined as a guide. We are being accused of the same things attributed to DOT. I have written this memo to clarify some of the Issues. May I please have comments. , Thanks, . ms Att. V/. R. Richard FUR 39n WATER PCB-SD0000071092 Monsanto FROM INAME & LOCATION ) St. Louis - General Office 0'-TE = March 17, 19 69 -^ccr ?efehence : REGIONAL WATER QUALITY CONTROL BOARD i Their letter to you of March 7 from Mr. Fred H. Dierker TO S. Bergen - HBERG * About Aroclor used in the dielectric area, we respond to items 4, 5, 6, and 7 of Mr. Dierker's letter as follows: 4) The solubility of Aroclor in tap water at 25 C. is as follows: Product 6 Aroclor 1242 Aroclor 1248 Aroclor 1254 Solubility in Water 203 i 10 ppm 106 1 14 ppm 50 1 z ppm Although the solubility of Aroclor 1260 has not been determined, the above data certainly serves to indicate that the more highly chlorinated Aroclors such as 1260 are the least soluble in water. Accordingly, it is quite reasonable to say that the solubility of Aroclor 1260 in water would be significantly lower than 50 ppm. 5) Aroclor 1242 and a small amount of Aroclor 1254 are used in hermetically sealed capacitors. The hermetically sealed can construction is of aluminum, mild steel, and stainless steel. These capacitors are used imbedded in asphalt in fluorescent lighting systems. They are used for power factor correction on utility lines. They are also used as motor run capacitors for air conditioning systems. Attached are the specifications for Aroclors 1242, 1254, 1248, and 1260, which describes the physical properties of these materials. Aroclor 1260, and to a lesser extent Aroclors 1242 and 1254, are used as components in transformer fluids of the askarel type. In general, the amount of Aroclor used in the trans formers fluid ranges from 45 percent to 60 percent. WATER PCB-SD0000071093 H. S. Bergen -2- March 17, 1969 On the West Coast in 1968, about 300, 000 pounds of Aroclor was contained in the transformer askarel fluid used in that region to make transformers. These askarel transformers are also hermetically- sealed, non-breathing apparatus. Very little of the fluid is used to replace spent fluid. Askarel trans former failure that would require replacement of the fluid is very rare. For example, the Edison Electric Institute found that the incident of such failure is in the range of 0. 05 percent. 6) No Aroclor capacitors are made on the West Coast. Transformer manufacturers on the West Coast who handle Aroclor containing fluid include: Federal Pacific - Santa Clara, California Hill Magnetics - Redwood City, California H. K. Porter - Bellmont, California Sierra Transformer - Redwood City, California Spokane Transformer - Spokane, Washington 7}/ In the normal use of capacitor or transformer fluid / containing Aroclor, Monsanto advises the capacitor ' and transformer manufacturers to avoid breathing vapors that would be emitted from the fluid if it were .heated to elevated temperatures. Monsanto also advises the user of the fluids to avoid continu ous contact with the skin. If clothing becomes saturated, the workman is advised to launder it before wearing it again. If there has been spillage on the skin, it should be removed by washing with soap and water. Normal, ordinary good housekeeping practice is recommended. \ Normal filtration of the fluid as done in the electrical \ industry has not presented health hazard provided \ that ordinary normal cleanliness is followed. FUR 003325 WATER PCB-SD0000071094 H. S. Bergen -3- March 17, 1969 The amount of Aroclor dielectric fluid discarded is indeed relatively small. However, such relatively small amounts have been discarded in drums by removal to dumping areas.- In rare instances, when a significant amount has become available for disposal, Monsanto practices having the fluid sent back to our plant for reworking and reuse in non-electrical areas. We would suggest answering Mr. Dierker's questions about Aroclor dielectrics in accordance with the above. As he also seeks our views on PCB materials used in non-electrical areas such as hydraulic fluid, heat transfer media, plastics, etc., may I assume that you have asked people handling those areas to submit their views? /ecd Enclosure s P. G. Benignus FUR 003326 WATER PCB-SD0000071095 AROCLOR 1242 (Trichlorobiphenyl) Specification Properties - September 27, 1962 PROPERTY TYPICAL Vise, at 37. 8C. (ASTM D88-56) Specific Gravity at 25/15.5 C. (ASTM D1810) Color, APHA Condition Acidity, mg. KOH/g. (ASTM D974, D664) Pour Point, C. (ASTM D97-57) Inorganic Chlorides (ASTM D1821) Refractive Index at 25C. (ASTM D1807) Distillation Range (ASTM D20-56) ' C. corrected for stem and barometric pressure Water content (ASTM D1533-60) Resistivity, 100C. 500 volts DC ` at 0. 1 inch gap. (ASTM D1169) Dielectric constant, 100 C. at 1,000 cycles (ASTM D924-49) Flash Point, Cleve. open cup (ASTM D92-57)* Fire Point* Sulfates (ASTM D117-31)* Fixed Chlorine Content (Carius)* Specific Heat at 25 C.* 82 - 93 seconds Saybolt Universal 1.381 - 1.392 50 max. Clear 0.01 max. -14 or lower 0.05 ppm. max. 1.6Z<0 - 1. 6260 . 10% 325 min. 90% 360 max. 35 ppm. max 500 X 109 ohm -cm. min. 4. 7 to 4.9 170 to 200 0 C. None to boiling point None 43 + 0. 5% 0. 29 Evaporation at 100C. for 6 hrs.* Dielectric strength (ASTM D877-49) at 25 C. KV min. * Hydrolyzable Chlorine Compounds, (ASTM D1820-61) ppm. chlorides, max. Thermal Stability (ASTM D1936) ppm. chlorides, max. Coefficient of Thermal Expansion* (ASTM D1903) 0. 4% max. 35 0.5 . 0. 4 0. 00068 cc./cc./C. *Not determined unless by special request. FUR 003327 WATER PCB-SD0000071096 AROCLOR 1248 PROPERTY Visei @ 54.4C. (ASTM d-88) Spec. Grav. @ 65/15,5C. (ASTM D-287) Color, APHA Condition Acidity, mg. KOH/g. Pour Point C. (ASTM D-97) Refrac . Index @ 20C. ,Dist. Range (ASTM.D-20) Water Content, ppm. Resis. 100C. 500 v D.C. @ 0.1" gap Dielectric Constant, 100C. 1000 cycle Dielectric Strength 25 C.* Flash Point, (C.O.C.)* Fixed Chlorine (Carius)* Specific Heat @ 25 C.* TYPICAL 73-80, sec. Saybolt Univer. 1.404^1.4l4 100 max. Clear 0.01 max. -7 I.630-I.631 343 - 373C. 35 500 x 10^ ohm-cm, min. 4.6 35 KV min. 193C. 47.5 - 48.5^ 0.27 *Not determined unless by special request. FOR003328 WATER PCB-SD0000071097 AROCLOR 1254 (Pentachlorobiphenyl) Spec ification Properties - September 27, 1962 PROPERTY TYPICAL Vise, at 98. 9C. (ASTM D88-56) Specific Gravity at 65/15.5 C. (ASTM D1810) Color, APHA . Condition . Acidity, mg. KOH/g. (ASTM D974, D664) Pour Point C. (ASTM D97-57) Inorganic Chlorides, ppm. (ASTMD1821) Refractive Index at 25C. (ASTM D1807) Distillation Range (ASTM D20-56) Corrected for stem and barometric pressure. Water Content, ppm. (ASTM D1533.-60) Resistivity 100C., 500 v. D. C. at 0. 1" gap (ASTM D1169) Dielectric Constant, 100 .C. 1000 cycles (ASTM D924-49) Dielectric Strength 25C.* (ASTM D877) Burn Point (ASTM D92)* Sulfates (ASTM D117-31)* Fixed Chlorine Content (Carius)* Evaporation at 100 C. for 6 hours* Specific Heat at 25C. * 44 - 48 secs. Saybolt Universal 1.495 - 1.505 50 max. Clear 0.01 max. 7-12 . 0.05 max. 1.6370 - 1. 6390` 10% 366 - 378C. 50% 371 - 3830C. 90% 378 - 394C. 35 max. 500 X 10^ ohm-cm. , min. 4. 15 - 4. 35 35 KV. , min. Higher than 350 C. None 55 + 0.5% 0. 4% max. 0. 26 Hydrolyzable Chlorine Compounds, (ASTM D1820-61) ppm. chlorides, max. . 1.0 Thermal Stability (ASTM D1936) ppm. chlorides, max. 0.5 Coefficient of Thermal Expansion* (ASTMD1903) 0.00066 cc. /cc./C. *Not determined unless by special request. FUR 003329 WATER PCB-SD0000071098 AROCLOR 1260 PROPERTY TYPICAL Vise, at 98. 9C. (ASTM D88) Specific Gravity at 90 C. / 15. 5 C. (ASTMD287) Color, APHA : Condition Acidity, mg. KOH/g. Pour Pt. , C. (ASTMD97) Inorganic ChlorideE, ppm. Refractive Index, 25C. Distillation Range (ASTM D20) Corrected for stem and barometric pressure Corf os ion 72 - 78 seconds Saybolt Univ. 1.555 - 1.566 150 max. Clear 0.01 max. 25 - 34 0. 10 max. 1.6455 - 1.6470 10% 385 - 398C. 50% 390 - 404*C. 90% 400 - 420 C. . After heating with aluminum for 6 hrs. at 210C. + 10C., the aluminum must not be corroded either on visual or weight in spection and the Aroclor 1260 should meet the following specs: Water content, ppm. Resistivity, 100C. 500 volts at 0. 1" gap Dielectric Strength 50C.* Dielectric Strength 100C.* Dielectric Constant 100C. at 1000 cycles*. Burn Pt. (ASTM D92)* Sulfates (ASTM D117-31)* Fixed chlorine content (Carius)* Evaporation at 100C. for 6 hrs.* Stability* . Specific Heat at 25C.* Color, APHA Free Chlorides, ppm. Acidity, mg. KOH/g. Condition 35 max. 150 max. 0. 10 max. 0.01 max. Clear 500 x 10 9 o- hm-cm. , 30 KV. , min. 30 KY. , min. 3. 6 - 3.8 min. Higher than 350C. None 60+0.5% 0.2% max. There shall be no liberation of chlorine or chlorides when the material is heated at 100C. in a glass vessel in contact with air for periods of at least one month. ' 0. 23 . *Not determined unless by special request. FUR 003330 WATER PCB-SD0000071099 .' O .12 cr. 2/ 2.. Eenig. : lord' suffice dr/:- answers to y sessions 2s he .mvo only reecrtly * a..--... ; ;d v;ith a icn.r-.u :i/ng 1 nrc -try oo undertake . 1; t tx: . ry studi.a/- '"lu = so t .0 1.-/./ solubility of ccl/c ;rt:n~.. , biphenyl in :ater a:. indicated in four bel_ / ' . s ...os be surgm .ing i..-0 fail ;o get a 96-heur Depending on 0 results c._ the ir.l ...... 1-studiesj \ 2 t ,0 do at le: ' 2' ay exposure e...:erirnenc;:.. V/e will keep yes. informed of any res^l.-s _y. obtain- . yA *" ; ' * ;S _ ... The ?;u. . ipunole;;. . 1 _gnifleant in sknt 1 . j .'.100 series are . 1 .... .; . l:a extent/indicated by one last two nu.'b:rs. . : . ..... . . . - ' or 12-42 /is biphenyl chlorinated to the extant el . 1. 1 .`OOQ.'compounds are sc-rpharpls again with the last ; ... . .r-3' indicating the percentage of chlorination. . .fOO compounds are r:.ix: ires of biphenyls itv. serpran, ..s - . ...-ihated to thg^pero ibn: indicated by t.ns two :. . .-"S "3. '...." "1. have added to the be . t :. -i these pages the .-vs -.It .. ....rate animal toxic!ov e. . a showing tl:_- ....'. '. 1 . --_'cs and the skin .:.!..... .v.: : lethal dosevfnen .py ,.t .. a 'lias. You will note ;ht t the sampleswere .. i .' .luted or as soIu;icr.-3 sponsion in corn . ;e tue viscosity and 0 a labile ;y of the materia/... thronic inhalation data 1 and 1254 and a reps In kles is enclosed^/!* s =.. .as for an industrial a/ - - ** -* "* t " o Ilo 3 t~ e11:an 7rnfrf nas been obtains,.. . discussing the r^.\li. c t.-.or suggests three . .. irorent of 2.0 mg per : u . ;er cu r.eter for P.r' .t - r. ~ p " ~2S *+--------*' " fur 003331 WATER PCB-SD0000071100 Vu Kj You will note in the table irhese materials tha t the 1 cxcrenely high distillacio. members have to be. distil lei under high vacuus:, -iresc- >ctn attest to the low vapor pressure of the materials at ambient temperatures. _ In cur mere than 39-years cf manufacture, cases of harmful effects in the industrial use of the materials have 'seen _ c:; crane ly rare. V/e believe this is due to the low volatility fir;:': reduces any possible inhalation at ambient c cm sera turns and secernly the fact that infuses pfn.ere the .material is heated the system is X closed jen^ so- that exposures are . limited to the occasion that when due to accidents the hot materials might escape from a"system briefly. Where such incidents have occurred the jlrri cation caused by -the vapors from the hot materialsynave" limited voluntary exposures such that systemic toxic effects are rare. osures FUR 003332 WATER PCB-SD0000071101 STATE OF CALIFORNIA--RESOURCES AGENCY SAN FRANCISCO BAY REGION REGIONAL WATER QUALITY CONTROL BOARD 344 FOURTEENTH STREET OAKLAND 94412 RONALD REAGAN, Govern, March 7, 1969 In reply please refer to File No. 2119-1075 Monsanto Company 800 N. Lindbergh St. Louis, Missouri 63166 Attention Mr. Howard S. Burgen, Business Director Functional Fluids Organic Chemicals Division Subject: Polychlorinated biphenyls ("PCB's") Gentlemen: Confirming recent telephone discussions between your Mr. Burgen and Hobart C. Knapp of this office, we request the following information about your poly chlorinated biphenyls: . ^1. Data from fish bioassays which you are now performing; please include 96-hour TI^ and the data pages recording laboratory observations. ^ 2. Existing data on toxicity, including long-term effects. / 3. Maximum allowable concentrations in industrial work areas. 4. Solubility in water. 5. Industrial applications by specific Monsanto product item number, and physical nature of these items; please include: Dielectric fluids Plasticizers for paints, plastics, elastomers, etc., and the uses of products containing "PCB", e.g. tire stocks, floor tile. Please inform about the diffusion or other escape of "PCB" from such products, both in normal use and in the environment of refuse dumps. Hydraulic fluid for aircraft, industrial equipment, etc. Heat transfer applications. Other. 6. Current volume of sales of "PCB" in the San Francisco Bay Area and in California for each' of the above applications and extent to which this is > to replace spent "PCB". (We understand current inventory turnover at > 1 your Santa Clara warehouse is around 40,000 lbs per month, but we have t ' been able to account for only two bbl. per year in purchases.) Please name Bay Area users of "PCB" for these applications. FUR 003333 WATER PCB-SD0000071102 Monsanto Company -2~ March 7, 1969 7. Monsanto's advice to its customers for handling "PCB" in normal use, and for its disposal when discarded, e.g., of filtration residues from processing dielectric fluids, discarding the fluids when they must be replaced in dielectric, hydraulic, or heat transfer service, disposal methods for emptied containers, spills, etc.. In view of the recent allegations in the technical press about the serious detrimental effects of "PCB" on fish and wildlife, we are most anxious to receive this information soon. Your cooperation in this matter will be appreciated. Sincerely,- HCK,FHD/emj FRED H. DIERKER Executive Officer FUR 003334 WATER PCB-SD0000071103 Monsanto ROM (NAME 6 L Tom C. Ford - General Offices 3AT March 14, 1969 subject reference; TO Mr. E. P, Wheeler Regarding the request for detailed information on.PCB from the San Francisco Regional Water Quality Board, I have only one observation. ' I know our detailed literature on Aroclors lists darn near every potential market where PCB might be used. I understand spme of these references will be deleted from future literature. I have been told in discussions with you and other people that Aroclors are not used, "to our knowledge", in house paints, vinyl plastics, automobile tires, floor tile or pesticides. Of course, these are the potential "polluters" which come to the public's mind. If I am wrong, or if we give contradictory information to the board, please let me know immediately. TCF:sfh FUR 003335 WATER PCB-SD0000071104 Monsanto PnOH INAMC A LOCATION! V/. R, Richard - Research Center DAT r UJICT fttrtntNCi TO April lb, 1969 DISPOSAL AND INCINERATION 6F~7iHUCXo}T ; P. Benlgnus - PBENI cc' D, A. Olson J. Bryant ^R'. M. Kountz -W, A. Kuhn N. T. Johnson DOLSO JBRYA RKOUN WKUHN NJOHN To defend the Aroclor position, it seems that we should provide for disposal of and incineration of off-grade fluid and work with Westinghouse and Pindett on the disposal of the off-grade capacitors as well. I think we can foresee that control of the total material bal ance for Aroclor will be Important for future operation. We should therefore help control the entire cycle of a capacitor. At present we are putting reclaim Aroclor Into new Pydraul hydraulic fluid. We can't really satisfy pollution people with this explanation. This will . just bring the focal point- to hydraulic fluids that much sooner. Will you please look over the figure for capacitors, add any disposal Aroclor from transformers. Please convey our guesstimate to Bob Kountz for preliminary sizing of Incinerator. Capacitor Industry '. At Present For Hyd Fluid For Disposal O.E. 180,000 Ibs/yr 1,6^ Production 450 Drums 250,000 lbs ,6# Prod 66,000 lbs Westinghouse 216,000 Ibs/yr 6.0% Production 20~b0 Drums 20,000 lbs Sa'ngamo 200,000 lbs/yr 6.05& Production Capac.. Industry Say 2;6=500,000 . Ibs/yr l Say 156=250,000 Future For Disposal r00o .v*000 2% Prod lbs/j 256 Prod 80,000 lbs/: 000 0 VO 256 prod lbs/; Say 2% 500,000 lbs IH 10 ft IV II.S Recycleand Destruction of Off-Grade Capacitors for Westinghouse- j PLAINTIFF'S DEPOSITION . EXHIBIT FUR 003973 WATER PCB-SD0000071105 2- Westinghouse prefers not to bury capacitor - want to drain ' Aroclor, salvage parts, destroy the rest. Pindett-Monsanto asked to see what we can do. Transformer Industry Transformer Rebuilders Transformers Scrapped - W, R. Richard ms FUR 003974 WATER PCB-SD0000071106 Minutes of Meeting of the CORPORATE DEVELOPMENT COMMITTEE April 28, 1969 Messrs. E. J. H . H. J. L. E. J. C. H. M. C . J. N. Bock, Chairman Bible G1 1 1 is Pu t z e 1 1 S omme r T h rod a h 1 Ehlers, Secretary ORGANIC DIVISION - RUBBER CHEMICALS INSTRUMENT & EQUIPMENT PROPOSAL Present: Messrs. H. L. Mlnckler, ~Cfi if] Anagnostopoulos and A. ObeI Monsanto Is a major supplier of monomers, fibers and chemicals to the '$40.billion tire and rubber industry. . Opportunities exist for expansion in cord and wire, " accelerators, antldegradants and increasingly in precision instruments and equipment for quality control. - Monsanto's technological contributions are recognized by t he industry. 7 he rubber Industry Is facing major issues of -- - Reduction of labor costs through greater automation. - High.quality control requirements created by competition 'and government safety regulations -- to meet these, the Indus try -wI 11 Increasingly rely upon precision instruments . a nd- s pec 1 a 1 e q u 1 pme n t__w 11 h market expected to grow from " $50 H In '68 to $250 H in '75. - The rubber Industry needs spec I a 1 equipment suppliers who can contribute Innovative technology and engineering, as well as manufacturing capabilities. Reliable Ma n u f a c t u r I ng Company In Akron, Ohio, is a specialty equipment manufacturer selling 85% of its output to the rubber industry. FUR 003975 WATER PCB-SD0000071107 SB. - I969 sales estimated to be $2.5 M and after-tax profit of $250,000. ' - It has a good reputation with the industry and is capably managed.: Targets f_o r rubber chemicals and specialty equipment businesses are $19 M sales by '7^_and with acquisition of a comparabj.e. European business, $6. H sales in Europe. Projected returns on sales (AT) are 11 - 13$ and with ROI of 20 - 33$. . Recommendation: Authority to explore the possibility of acquisition of Reliable Manufactur1ng Company. Conclusions: . The requested authority Is granted. The Division to clear the negotiating arrangements with Hr. Putzell. (Excerpt to Messrs. H. L. Minckler, T. K. Smith, R. Harris, F. Morgan and T. H. Rasmussen.) is INTERNATIONAL DIVISION - PLANS FOR RENEWAL AND GROWTH Present: Messrs. A. J. A. Bryan, G. F. Wlngard, E. W, Burr, A. D. Lapthorne, H. 0, Vos Monsanto's International business was summarized by Mr. Bryan. - Foreign manufacturing and exports produced $1)11 M sales and $31 H net income in 19^8 with ex-ll.S. gross Investment of $394 M. - R0I from local manufacture Increased from 1.5$ In 1965 (a low year) to I). 6 $ budgeted in 1 969 (a strong year). - Net Income In *69 to be approximately 50-50 from fibers and chemicals plastics. - Foreign and export sales (amounting to 22$ of HC total) produced 28$ of HC profits. Wea knes s es noted: - 7 product lines of 71 accounted for most of the profits. - Over 1/3 of the ex-U.S. investment, amounting to $|I)3 M, is operating at a loss. Thermoplastics a problem area. - Local manufacturing suffers from small, dispersed plants, weak raw material position and poor l.o gist leal support. Growth obJectIve Is to produce 33$ of Monsanto's net income, or $122 M, by 1977; 65$ from Europe and 25$ from Canada and Latin Ame r lea. - Present divisional plans and NED activities will not achieve this. - New businesses and acquisitions will be required, based on a strong commercial development effort. FUR 003976 WATER PCB-SD0000071108 2 90 . European Renewal D Growth (A, 0. Lapthorne) Our European operations must attain critical size to effectively compete with local producers who have comparable technology and are growing by merger and developing sound raw material bases. Major issues, facing us arc: . - Fibers: need to reach critical size and economic polymer and nylon salt position. - Thermoplastics: need to expand polystyrene and ABS polymers to critical size; resolution of LDPE problem and obtain petrochemical supply position. - Raw materials requirements are sizeable and not in balance with naphtha cracking output. - Organic product lines do not fill out the organic family tree potential. Agricultural: organization. need for local manufacturing and full marketing Planned Manpower Development Program to be Instituted (E . W. Burr) - Divisions regularly assign key employes to ex-U.S. operations In their advancement paths and hire a portion of their . college recruits with potential for international assignment. - Area management Identify high potential national employes for U.S. assignment and recruit with this view. - Achieve management of people resources on a comparable basis ' worldwide with flexibility of assignment of professional managers. .International Financial Management (G. F. WIngard) Objectives of this newly-instituted function are: - Develop financial plan to support growth goals requiring $1 B European Investment by '78. - Develop a financial plan for each area and each major ent i ty cover Ing cash requirements and minimizing devaluation exposure. - Develop worldwide plans for devaluation protection and money mobilization program in Europe. - Prepare for local ownership In Mexico, Canada and - Australia. FUR 003977 WATER PCB-SD0000071109 291 . Financial Reporting (H. D. Vos) One objective Is to improve operating statements to better reflect management performance. This Is complicated by reporting for 71 product groups from $ management areas and over 90 corporate entities New operating report system will report actual sales, COGS and direct SARE by product groups and will allocate shared SARE, net-finance expense and other income charges and Income taxes by a g r eelT'b udg e t e d amounts.' - Net Income will reflect performance by business manager and permit concentration on controllable Items. - Area directors will be responsible for shared SARE. . - Treasury and Tax Departments, respectively, with International Division, will be responsible for net finance expenses and taxes. . A second objective Is to recast U.S. export and ex-U.S. financial statements to better reflect our international operations. - Non-product Income Items such as third party royalties, . Interest, etc., will be carried as a separate I tern. - Royalties fromsubs Idlarles to be included In ex-U.S.A. manufacture Income as their share of U.S. technical costs are presently allocated to them. - Sales and Income will be reported on a marketplace basis. The Committee accepted the recommendations of the Internationa I Division s follows; ' 1. The plan for manpower development was approved. {Excerpt to Hr. W. B. Daume.) 2. The financial planning objectives and the modifications of the reporting and accounting systems were approved In principle. The Committee requests the Finance Department and the International Division to advise It as to the proper means of evaluating new projects and computing R0I as one meant for evaluating project performances In light of Incentives available abroad, such as cash grants, tax forgiveness, accelerated depreciation, etc. (Excerpt to Hr. F. Horgan.) 3. The growth plan and financI a 1_goa1s to develop 33$ of Monsanto net Income, or $122 M, by 1977 (65$ from Europe and 25$ from Lat.in America and Canada) recommended by the Division, were approved,- . .. a. Growth plans by areas should be developed by the operating divisions In conjunction with the International Division, with plans for Europe to have first priority and to be prepared by year-end. . FUR 003978 WATER PCB-SD0000071110 292 . b. The area directors shall be responsible for coordinating the operating divisions' plans In terms of an overall area plan and to develop supplemental programs as may be needed to achieve . che overall area goal. (Excerpt to the General Managers, Group Vice Presidents and Mr. F. Morgan.) (Excerpt to Mr. A. J. A. Bryan.) APPROPRIATION REQUESTS - - -- The President advised that he would recommend to the Board of Directors for approval- Organic Division Appropriation Request No. CEA-2080 for $1,100,000 for solid Aroclor expansion - Anniston and would approve -- Organic Division Appropriation Request No. 0 2 6 for_ $585,000 to expand Benzyl Chloride from 50 M to 60 M ibs./yr. - Delaware River MMK Appropriation Request No. 87 for $389,000 (MC share SIS1),500) for hydrogenated Terphenyl facilities PPtR Division Appropriation Request No. ^32-A Overrun of $135,000 for waste treatment - Trenton Resins. J. N. Ehlers Secretary FUR 003979 -i WATER PCB-SD0000071111 MEETING OP TKE BOARD OP DIRECTORS : May 22, 1Q6 The regular monthly meeting of the Board of Directors. .of-IIonspnto Company was neld on ...sy 22, 196, at 9:00 A.MV at the St. Lout's County, Missouri, offices of the Company. Present:. Messrs. Charles K. Sommer, Edward J. Bock Dillon Anderson, David R. Calhoun, John L. Gillis, Edward A. O'Neal Charles Allen Thomas and Monte C. Throdahl. Messrs. Fredrick I'li *nton, Herbert hoo/er, Jr. and oames S. Rockefeller 'were absent. *' FUR 003980 d PLAINTIFF'S DEPOSITrIiOoNs EXHIBIT f 3 0~? WATER PCB-SD0000071112 Memorandum of Messrs. H. L. Minckler and T. K. Smith, Jr., dated April 15, 1&69 recommending the expenditure of $1,100,000 for the expansion of the nolid Aroolorfacilities at the Anniston, Alabama plant, was submitted to the members in advance of the meeting* This expansion will enable the Company to supply into the mid-1970'B all forecasted U.S. chlorinated polyphenyl needs and also to provide a significant share of ex-USA demands. Upon motion made and seconded, the following resolution was unanimously adopted: BESOLVED, that the expenditure of 11,100,000 for . the expansion of the solid Aroclor5facilities at the Anniston, Alabama plant, is hereby approved. FUR 003981 WATER PCB-SD0000071113 COHFIDEHTIM MINUTES OF AROCLOR "AD HOC" COMMITTEE First Meeting Date: September 9* 1969. ' Present; M. V/. Farrar P. B. Hodges, Secretary E. V. John W. R. Richard E. P. Wheeler, Chairman ' . - ... -- ' Objectives; (Agreed to by the Committee) Submit recommendations for action which will; 1, Permit continued sales and profits of Aroclors and Terphenyls. ` . 2t Permit continued development of uses and sales. ' 3. Protect Image of Organic Division and of the Cor poration. Dackground Discussion of Problem: " 1. Agreed that we should concentrate on Aroclor 129*1 and 1260. Aroclor 12*12 has not yet been incriminated for these possible reasons: ' a. Nature of uses of 12*12 minimizes environmental . contamination. . . b. It may degrade biologically. . ' c. Unless analytical techniques are performed care- fully, 12*)2 can be destroyed by oxidation during the analyses. ' 2. PCB has been found in: ' a. Fish, oysters, shrimp, birds. b. Along coastlines of industrialized areas such as Great.Britain, Sweden, Rhine River, low countries, .. Lake Michigan, Pensacola Bay, in Western wild life " (eagles). It may be a global contaminant. -3. PCB has been tied to DDT in effects on disappearance of . wild birds which have fish diets. Ratio of PCD to DDT " has been about *10-90:1 generally. Dr. Reisboro reported almost 1:1 ratio. . PCB may be contributing to or exag gerating the effects of other chlorinated aromatics. FUR 003982 WATER PCB-SD0000071114 i ; k.. \ 2- - Sample acceptance from the numerous researchers was discussed. This has been done on a limited basis. Our corroboration of testing of-their samples adds to our knowledge and demonstrates a willingness by Mon santo to help define the problem, but it is expensive and also tightens any possible legal cases against us -- it rules out possibilities that Aroclors are not involved. 5. Toxicity levels: Aroclors have been shown to be safe for man in rea sonable exposure concentrations. We are testing 100 ppm in diet of rats and dogs on a rule-of-thumb basis that 1/100 of toxicity level is safe and 1 ppm is probably the upper limit in total diet. "Allowable levels" are probably lower than DDT. The worst example to date is the test at Pensacola where . 5 ppb was found to be toxic to shrimp in 18 days exposure. One problem we are facing is to keep the "safe level" for shrimp from being applied to e.g. Lake Michigan where more tolerant fish species probably exist. V/e need to show the safe level in 'shrimp, clams, oysters and several species of fish. (?) Many toxicity studies on PCB are underway and it was agreed to be desirable to keep contact with all lab oratories which have requested Aroclor samples. One- half to two-thirds of the sample requests have come from state labs (who would let us know what they are doing) and about 1/3 have come from universities (who may give us the "brush-off"). Question of who should call on the laboratories was not resolved. 6. Escambia River Problem: For a clearer understanding of the general problem, ' the situation at Pensacola was reviewed. From a rela tively negligible discharge of 1-3 gal/day into a large river, 1/4 mile downstream levels of 42 ppb in water and 476 ppm in mud were found. Although use of Aroclor .was-ha3ted Immediately, we can expect the water contam ination'to continue for a lengthy period by leaching from the contaminated mud. No downstream samples have yet been taken to measure the decrease in contamination (as of 9/8/69). FUR 003983 WATER PCB-SD0000071115 -3- Problem in Producing Plants: . P. Hodges reviewed what was being done to stop gross . losses at Anniston and at WGK. Basically, the work to date consists of stopping or trapping any sewering of free Aroclor with return to process or land fill disposal of the trapped Aroclor. This will reduce ~ levels in plant effluents to below solubility ranges, particularly as we move to Install traps (or sumps) back into the waste source points where flows are'small and as yet undiluted by Aroclor-free waste streams. -The question of exactly how far to reduce (how much money to spend) is not yet clear and expenditures to date have been comparatively small. It was agreed that, until., the problems of gross environmental contamination by our . customers have been alleviated, there is little object in going to expensive extremes in limiting discharges from the plants. . One. problem that has been interfering with logical development of our plant Aroclor waste reduction pro grams has been delays in obtaining analytical results from in-plant and ex-plant sampling. It was agreed that additional help was necessary in Dr; Tucker's lab but no specific actions were proposed. In addition to in-plant work, the plants are sampling the receiving streams. . Air pollution reduction has not been considered by the plants to date except as Incidental prevention of pro duct contamination during tank car and drum loading operations. Long range (1-2 year) improvements at Anniston are planned to reduce product contamination (and air emissions) in car loading operations. It was agreed that a comprehensive air sampling and testing --.program would be very expensive and is probably not justified at this stage of the problem. . Environmental Contamination by Customers: Our in-plant problems are very small vs. problems of dealing with environmental contamination by customers. In one application alone (highway paints), one million Ibs/year- are used. Through abrasion and leaching we . can assume that nearly all of this Aroclor winds up in the environment. Because the rate of natural (bio-degradation) is very low, other degradation must destroy PCD equal to the ' rate of environmental exposure in order to avoid build-up of contamination. . A general discussion was held on philosophy of controlling sales or working with customers to prevent pollution by PCB^ FUR 003984 WATER PCB-SD0000071116 Action Planned; Each member of the group will submit to the other members for consideration possible Ideas and programs to help accomplish the overall objectives set by the Committee. Following review of the suggestions, the Committee will meet again at an early' date to.be arranged by the Chairman. P. B-. Hodges Secretary ju. fur 003985 WATER PCB-SD0000071117 I PCB ENVIRONMENTAL POLLUTION' ABATEMENT PLAN Introduction __ On 15 October the "AD HOC" Committee consisting of Messrs. M. Farrar, P. Hodges, E. John, W. Richard, and E. Wheeler Issued a report summarizing the polychlorinated biphenyl (PCB) pollution problems from the known available information to date. Out of this report came considerable information, conclusions, and recommendations which we have attempted to tie together into a plan of action in this document. Our objective has been to take a reasonable and responsible approach to the entire problem. Before we get into the problem, we should clarify the meaning of PCB, the nature of the entire line, and .how these tie into our product line of Aroclors. WATER PCB-SD0000071118 Monsanto entered the Aroclor market in 1930 by acquiring Swain Electrical Company or known today as our Anniston., Alabama plant. The first load of Aroclor which'incidentally was Aroclor 1254 -- went out of Anniston, Alabama to GE in 1931: Since that time the market has grown to 170 to 200M/, worldwide. Chemical Biphenyl . Monsanto Product Line Nature of Material at Ambient Solid Monochlorobiphenyl vC| IC hfoYO DI | C( "^ricKlorobiphenyl ' "pOS Quafiterchlorobiphenyl Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Pentachlorobiphenyl Aroclor 1254 Hexaphlor.obiphenyl rc 1 Heptachlorohiphenyl ` "Clc( - cf Cl ' t OC tchlorobiphepy1 ef Be cachTo roUTplieny 1 ^ (f Aroclor 1260 Aroclor 1262 Aroclor 1268 Aroclor 12715 thin liquid (oil) thin flush water oily type fluid material Thicker - transmission oil Heavy-Molasses Thick - tar Very thick - liquid Solid Solid FUR 003989 WATER PCB-SD0000071119 Total possibility are 210 theoretically possible chlorinated biphenyT'6' Santowax or terphenyl Solid Aroc.lor 5^60 Solid _ Damage to the ecological system by contamination from polychlorinated / vi'-y/ O' hi. biphenyl (PCB). Extensiveness ' The problem involves the entire United States, Canada, and sections of iP>/ Europe especially the United Kingdom and Sweden. As the investigation broadens other areas of Europe, Asia and Latin America will surely become involved. Evidence of contamination have been shown i$ some of the very remote parts of the world. The involvement could and most likely will follow the DDT investigations. IV. Nature of the Problem Professors V/idmark and Jensen of the Institute of Analytical Chemistry at Stockholm, Sweden, in November 1966, announced and confirmed finding: PCB in fish, birds, and eggs. Subsequent findings were made in I9S7 in Great Britain. In February 1969* Professor Risebrough of the University of California published an article in the San Francisco Chronicle relaying his findings of PCB in the environment of the United States. Monsanto confirmed the presence of PCB's in mid-1969 and confirmed the adequacy of work by Widmark and Jensen and others; truly, the PCB's are a worldwide ecolological problem. FUR 003990 ^ WATER PCB-SD0000071120 Analysis indicates the environmental presence of the 5 and higher chlorinated biphenyls which take the appearance of Aroclor 1254 and Aroclor 1260. ' We have strong Indications that Aroclor 1242 or at least part of it degrades biologically. Since the Aroclor 1242 contains arour 7 percent of the 5 chlorine biphenyl or higher we cannot rule out the possibility that the observations may be a concentration"affect of the higher chlorinated biphenyls of Aroclor 1242. To date there have been no reports of finding Aroclor 1242 present in the environment (except outside the effluent of our plants where we know Aroclor 1242 is present). The seriousness of the problem can best be spelled out as follows: 1. Fish - Marine or aquatic species concentrate PCB in the fatty ^ tissue. Toxic is small quantities (down to 5 ppl*) to sensitive mari: ' life such as shrimp. 2. Birds - Predatory species feeding on the marine or aquatic life can further concentrate PCB to possible harmful effects. Specifically in birds PCB can affect the calcium metabolism leading to egg shell Imperfections which prevents proper hatch of the young. In fact,, Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCB's in controlled tests. 3. Man -'There is no harmful effect known to man or other mammals after 40 years of production. sources. Investigations are underway by various FUR 003991 4. Political and Public Emotion - PCB's are falsely linked with" DDT because PCB's show up in the analysis for DDT. PCB's are linked with other permanent type chlorinated hydrocarbon pesticides. This becomes particularly serious since about every article.of food in the country is being examined for a trace of these materials. '5 \Vai( `>XA,y 0---- 3 J. . c- . /'. > t.-.t ,(m LL. .r- c.r~, .. . 1 ! ^ WATER PCB-SD0000071121 -d- V. Effect on Monsanto Business potential at stake on a worldwide basis: Fluids Plasticizers Total/Year 70M lbs. 3 lbs. 104m lbs. $16m $6m $22M $6-8m g.p. $2-3M G.P. $8-iim G.P. Already competition is using certain data against us in competitive situations. . ` A. Legal Liability Direct lawsuits are possible. The materials are already present in nature having done their "alleged damage". All customers using these products have not beai officially notified about known effects nor dc pur labels carry this Information. These are only a few of the possible legal implications which would best be covered by the legal department. B. Public Image The corporate image of Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environ ment will be adversely affected with increased publicity. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond questioning. This combined with certain scare publications is certai; l/!t to give an adverse image. Guilty^association (with DDT) will pre vail as the background while actual facts may be sparse. ' C. Customer Relations FUR 003994 Some customers who presently use these materials will be "scared off" to other competitive products. Products associated with the same name or "trademark" will be adversely affected ie., Therminolj _ Pydraul and Aroclor. Competitors will use the information for-an WATER PCB-SD0000071122 influence on Monsanto products. Customers will seek other "outs" rather than become involved. VI. Effect on Customers and Ultimate Consumers One of the unique'features of PCB's is their fire resistance. Here, the basic decision whether to risk lives due to fire or risk extinction of, some species of birds. In this case the PCB would probably be accepted 4 as a necessary pollutant and tolerated under controller conditions. A. Electrical Industry - Capacitors and Transformers use Aroclor ' because it is the best inexpensive dielectric fluid available. B. Pood Processing - Bulk "deep frying" units for potato chips, fish, and doughnuts use the fire resistance fluid as an indirect heating . medium. C. Die Caster -- and other hot metal working industries fire resistance fluids to protect the worker^ Affects a wide range of plastics and adhesives because the PCB serves as the plasticizer. . A wide range of paints and coatings are affected. The "Carbonless" carbon paper used so widely would disappear. VII. Involvement With Other Producers Although Monsanto is most probably responsible for the U.S. contaminatic and jointly responsible with MCL for the United Kingdom problem, we cannot accept responsibility for the world. There are five known producers in the free world, several possible producers behind the iron curtain and couple of additional companies making overtures about entering the business. Monsanto representatives have on one occasion discussed this problem with a couple of these producers but.they . expressed no great concern. In fact, it is highly possible that one of FUR 003995 WATER PCB-SD0000071123 these manufacturers is dumping his waste into the Rhine River. Certainl; any action taken by one producer will most assuredly affect the other. It is entirely possible that a 'joint plan of action could be developed but will most probably have to be spearheaded by Monsanto. It is also likely that producers of other chlorinated products used with PCB's will be dragged into the investigation. ' VIII. Sources of Contamination . Although there may be some soil and air contamination involved, by -far the most critical problem at present is water contamination. To our knowledge to date the contamination can be broken down into two general ..categories, open and indirect pollution. - A. Open Pollution - Our manufacturing facilities sewered a sizeable quantity of PCB's in a years time. 1. Fluids Fluids are probably the most open source of pollution because of their mobility. They also may be the least serious because they are generally the lower chlorinated materials. 2. Electrical Electrical customers have in the past sewered their wastes. 3. Heat Transfer * Heat transfer customers have sewered their objectionable and their spilled material. 4. Industrial These fluids have generally been sprayed into drains, washed down sewers and generally regarded as very harmless. ('ll 3- All of the fluids have had the joi-nk" constituent dumped on dirt roads as a "dedusting agent" which inadvertently found its way back to the stream. FUR 003996 WATER PCB-SD0000071124 -y- . environment today which was deposited over the past forty years. 'We _jttuei:must state that responsible people throughout the industry have taken corrective action to reduce contamination in the last two years. There have also been technical advances which have brought about the use of lower chlorinated biphenyls which may be an advantage because to date th low chlorinated ones have not been identified present-iff'nature. 1. Electrical The large customers have established collect systems ar the waste is recovered. Incinerators are being investigated.and built for the disposal of the materials. There has been a shift away from the higher chlorinated types products and could probably shift almost entirely away from those products. ' 2. Heat Transfer - System have been tightened up and redesigned to .confine the contents Here^to^>' the trend has been to shift away from the higher chlorinated materials. & 3- Industrial - Selling ponds have been built by the large manufacturer to catch the material and decant off the PC3 for reprocessing. The trend here as the other fluid areas has been towards the lower chlorinated materials. . 4. Plants ^ The plants effluent has been passed through limestone which provides surface to catch some of the material. But high concen trations can be found in our effluent (that is relative to those findings in nature causing the problem). B. Plasticizer . Quite opposite to fluids the trend in plasticizer Aroclor has been to th higher chlorinated biphenyls. In plasticizers the lower chlorinated biphenyl will not be an acceptable solution however, the lower chlorinat terphenylvcould offer a possible solution. FUf? 003998 WATER PCB-SD0000071125 Courses of Action A. Do Nothing ' We cannot deny the findings and the acquisitions by the various agencies. If we took no action we would likely face numerous suits, . We would let government tolerances be based on public and -. -political pressure along with any experimental or developed data which they may generate. We would most likely be forced out of this business. Other product areas would be adversely affected-r We would project an image as an irresponsible member of the business world. Project poor customer relations. The only advantage to this technique offers is it reduces the cost but this too must be weighed against potential loss of business. B. Discontinue Manufacture of All Polychlorinated Biphenyls (PCB) ' Although we all realize this could be an eventually unfortunately the solution is not this simple-:"' Assuming we did stop manufacture immediately, the pollutants are present in the environment, the liability is present and possibly by the shifting to the lower .a chlorinated materials and the recovery techniques the contamination may already be reduced to an acceptable level. Obviously the entire business would be lost without any or very few substitutes to be offered. Other product areas would be affected. Financial loss could be considered due to raw material contracts, customer contract and royalty -- secrecy contracts. Competition would take advantage on all fronts. We would be admitting guilt by our actions. Loss of capitol investment in the plant, associated utilities, and asso ciated processes. Vie would possibly gain a little public image on this action. FUR 003999 C. Respond responsibly, admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is- generated to correct the problem. ' WATER PCB-SD0000071126 This approach would enable us to phase out the higher chlorinated materials in many applications where they are no longer necessary or really desired. Wecould maximize the corporate image by publicizing this act. We would reduce a known pollutant. Additionally we could'gain precious time needed to develop new*products and investigate further the lower chlorinated materials. As new research data is generated our course may be altered considerably. Certain limited actions may reduce or limit the problem. FUR 004000 WATER PCB-SD0000071127 12 XI. Recommended Course of Action - , Based on the information available today the only recommendation we can honestly make is respond responsibly admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. ' -- XII. Implementation of the Recommended Course of Action A. Immediate (By 12-1-69) 1. Set up a task force under a project manager or the equivalent responsible for initiating, directing and implementing all actio! that Monsanto decides to take. This includes sufficient budget necessary to cope with the immediate problems. This task force . should include representatives from Medical, Legal, Research . and the two involved Marketing Groups and Public Relations and must conduct liaison with MCL and other locations involved in the problem. 2. Decide on timing and content of any public and/or customer notifi cation of PCB problem. B. Interim (Within 3 months) Fluids Plasticizers 1. Confirm Aroclor 1254/Aroclor 1. Announce differential betv/een 1260 are found in the envi fluids/plasticizer uses. ronment. 2. Publicize the difficult anal. 2. Announce safety of other PCB's tasks. chlorinated terphenyl. . 3. Protect other PCB/chl. terph. 3. Educate customers on control o effluent for all products. 4. Announce plans to reformulate Initiate program to develop A/ certain Therminols and Pydraul * 1254 & 1260 substitutes where control of the product is difficult. FUR 004001 WATER PCB-SD0000071128 CD >L>. 5. Emphasize better control over 5. Investigate with manufactur other Aroclor 1254 & 1260 the feasibility of alternat uses. products. 6. Initiate customer education or 6-.--AnaTyz-e--1242 need for effluent control of all products. ' 7. Determine composition of all PCB's. - Develop a comprehensive Program ' C. Short Term (within the next 12 months) 1. Research - Expand program for more meaningful biodegradation Medical . studies and confirming analytical results. Expand toxicity studies. Follow developments concerning publicity and those developments covering political implications of PCB contamination. 2. Marketing - Discontinue or substitute replacement products for those applications of Aroclors 1254 and 1260 where the Aroclor remains mobile. Work with customers to clean up plants on other Aroclors. Report the hahitual violators or "do nothings" to the product group. . Reclaim or safely dispose of fluids. FUR 004002 Consider renaming products that do not contain PCB. Follow and report market developments such as customer disposal systems. Follow and report any political or public feedback whichmay affect the contamination problems and must be coordinated with Medical, Research and Legal.' 3. Production - Clean up plants and stop gross contamination. 4. Legal - Define our present position, recommend reasonable action that will not unduely alarm the market but reduce the exposure- ^ in terms of liability. Coordinate recommendations with Marketin WATER PCB-SD0000071129 15 - c. Set reclaim or disposal of fluids d. Work on name association problems 5. Patent '' Investigate trademarks registered ., Cover with patents any work felt patentable 6. Environmental Control ." ' Develop cheap disposal systems for customers a. Incineration or pyrolysis b. ` Biodegradation unit etc. - c. Consultants in pollution control 7. 'Legal Investigate and define our position on Royalty secrecy ' ' agreements. Contracts - Raw Material and Customer 8. Public Relations Portray to public positive actions at correcting the ' contamination problem. Release periodical statements covering our position. XIII. Probability of Success . FUR 004004 * WATER PCB-SD0000071130 - 16 - XIV. Cost of Program Neither the program nor the costs have been clearly defined at this tim However, a cost estimate of $220,000 for toxicological work alone has been presented. Tentative figures indicated under the worst conditions the entire program could run as high as $2.0-2.5M. At this stage it is very difficult if not impossible to develop a reasonable cost figure bu one point is clear it will be larger than the normal research budget ca handle. For this reason, assuming the approach is acceptable, we shall be forced to ask for additional appropriations to fund the program. XV. Future Follow developments on the problem as they unfold. Develop an aggressive research program to confirm or deny findings and better understand the problem. Develop costs for the duplementation of the Recommended course of action. . Develop specific actions with each department involved Submit the actions with costs for approval Develop a timetable to solve the overall problem. Prepare for "precipitious pullout" or drastic legislative action althoug we do not feel this is a likely possibility. WATER PCB-SD0000071131 rti/yf-ir fiuD i/s r<m