Document GKD4gyrQojqZ0MLYpKBjaXL2N

MONSANTO'S PWB PROORAN W. B. PAPAOBORQK JUT^ X appreciate-the opportunity to share Monsanto's PCB experience with you and I hops the Information X have can help this committee plan and aehleve Its objectives. We at Monsanto first heard of PCB'a as potential environmental contaminants In early 1967 when we received copies of a talk given In Sweden by Professors Wldmark and Jensen of the University of Stockholm. In their paper they described how they were able to Identify a material which had been Interfering with pesticide analyses as being polychlorinated biphenyls. Our laboratories began work on the development of analytical methodology to confirm that PCB's Indeed were being found In the environment. During 1968 and 1969 as methodology Improved the evidence continued to Indicate that the higher chlorinated biphenyls were being. Identified- In the tissues of fish and birds. During this period Monsanto mounted an extensive program aimed at acquiring more knowledge about PCB's and their effect on the environment. We perfected our analytical methods, we started animal toxicity studies, began biodegradation work and evaluated alternative materials for those applications we felt were con tributing substantially to contamination. HONS 058765 -2 Our animal toxicity work was similar to the type we would have undertaken If we had wished to have PDA approval for food use. Chronic toxicity and reproduction studies were Bade on leghorn ahichans. Two year chronic feeding- studies were started on rats and dogp. Three generation reproduction studies were nede on rats. The PCB's used In the tests were Monsanto's Aroclor 1242, Aroclor 1254 and Aroclor 1260. These were selected since they represented the aore eoaaonly used PCB alxtures. The anlaals were fed con centrations of 1 ppa, 10 ppa and 100 ppa In their normal diets, . The results to date Indicate that at the levels used the rats and dogs showed no effects with Aroolor 1242. At 100 ppa both the rats and dogs exhibited decreased-'Weight gains and enlarged livers. The chickens were affected by Aroclor 1242 at the .10 ppa level. The hatchablllty of the eggs was significantly reduced. To summarise what I've said about Monsanto's sponsored anlaal toxicity work the highly chlorinated polyohlorlnated biphenyls at 100 ppa In the anlaal diet doM have some effect on maamals. The lower chlorinated polychlorinated biphenyls at 10 ppa in the diet hag. seas effect on leghorn chickens, and I say specifically, leghorn chickens because there Is mounting evidence that there are definite species variations as determined by the Pautuxet Laboratories here In Maryland with four types of wild birds. There Is a species variation noted which frustrates many scientists M0N5 058766 -3- I mi asked what we know about tha affaet on marina life. Monsanto did sponsor static fish toxicity work and we were completely frustrated because these PCB's have the tendency to plate out on surfaces. Our Information was garbled because In the static testing we were really exposing the fish to FCB environments a lot less than we thought we were. The data was so distorted It was meaningless. In the meantime, we found that there are any competent laboratories looking at fish and the effects on fish that we decided that maybe this Is an area that Is best left to the experts. He have been In touch with laboratories such as the Water Quality Laboratory of Duluth, Minnesota. They have conducted studies whloh Indicate there Is some effect on some species. There has been some work done In the Columbia, Missouri Bureau of Interior Flsh-Pestlclde Laboratory which Indicates, for example, magnifi cation about 50,000 times. By that I mean that the amount of KB detected In the fish tissues was 50,000 times that present In the water environment In which this fish waa exposed. There have bean reports of fish kills and some very drastic effects attributed to PCB's. I've tried to get evidence that these things have occurred- I have not been able to confirm any reported Incident. We have talked with scientists at the Oulf-Breese, Florida Commercial Fisheries Laboratory. They have conducted studies MCNS 0587*1 -a- with crab and shrimp. This la tea laboratory that did detect a build-up In crab and also tha lethal effect on Juvenile shrimp. Very, very low concentrations - 5 ppb in the water - do destroy Juvenile shrimp. - There la a growing thought among many of the raaponalble aelentlata that thla environmental problem Is most complex and It la not really any one Insult that Is thm demise of any particular species, but It could be the cumulative effect of all Insults a creature Is exposed to and usually the last Insult Is the one that gets blamed. Dr. Tom Duke of Oulf-Breese la a proponent of thla theory and he la conducting studies.to substantiate this. It could be the lack or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a cadmium or a mercury or an arsenic, and along comas a PCB and the fish dies. PCB might get blamed. This Is the kind of thing that does happen In tha environment. There Is a growing concern that we should be considering to a greater degree chronic effects of all these materials rather than eelylng on the old acute studies that used to serve as a screening for many, many chemicals. Z have sketchy data on marine life. We know that It does build up In the marine environment and there Is, of course, the published evidence that It does affect the fish eating birds. SONS 058768 -5 - There la bom Indication In tha Duluth atudlaa that reproduction and survival of the frye la affected. There seems to be Minimal affect on adult flah. It waa suggested earlier that I might want to review the manufac ture of FCB-'s, tha many, applications. In which It waa uaed and what our present program la. To the beat of my Information, it was 1929 that these materials were Introduced aa very attractive fluids for use In transformers, and there are many In this audlance that are more familiar with this developMnt that I aa. PCB'a were uaed In tranaforMra as an Insulating cooling fluid because they are more resistant to breakdown, leaa apt to explode and burst Into flaMS and oauM property damage and human Injury. Through tha years, additional uaaa warn* found for these materials beoauae of these properties that I Mntloned earlier. They gradually at first, and of course with Increasing amounts, ended up In applications that Monsanto through Its ln-house usage referred to as plasticiser usages. That Is not a very good description, but It fit our needs for many years, and you'll find us using that expression. These are uses such as In paint formu lations, the specialty Ink uses, the plasticizer- In aealairts, adhesives, and paper ooatlnga of all sorts. There was a use that waa a real thorn In our side and you'll see at laaat bom of the earlier articles on PCB-'.s referring to pesticide use. There were some studies conducted by the Department of Agriculture In which PCB's were used to extend the effect of HONS 058769 -6 - Ilf* of pstlcIdea such as lindane. It ns never Intended for broadcasting as we visualise DDT was on food crops, cotton crops or orchards. The only widespread use that I could find was a limited trial to help prevent or curtail the dutch elm disease, and that proved to be a failure. The other uses were extremely snail In private formulations that were used to spray or coat hard surfaces - shelving, comers of floors and all for the typical crawling type Insects such as the roach and sllverflsh. In fact It was so snail that Monsanto did not market directly to pesticide formulatore; we gave this business to our distri butors. On the other hand, this use did cause considerable enotIon and was used by sone to explain the presence of PCB's in renote areas. We wrote to-ths-gsgarSnent'of Hgrwnlture suggesting that during 1970 when pesticides were being re registered that PCB's not be approved. Finally In October they did put out a notice to that effect. We have had questions raised, *Ie It In ay shower curtains at hone? Is It In the draperies? In the Carpeting?" The answers to those Is "not very likely". And I use those words because we really don't know. If It was put Into these applications. It was so snail we, Monsanto, were not aware of It. It was not used In aatonobtle- tlrem It wan- not used In brake- linings*. Other asjor uses Include the use in hydraulic fluids which are firs resistant. Monsanto marketed these fluids under Its trademark Pydraul. I an sure some of you remenber the Llvonls, HONS 058770 -7 - Michigan.'fires Thla was a disastrous fire In terms of property damage and was really a high marie In terms of convincing Industry that there was a need for fire resistant hydraulic fluids. But the application is not the type that-Is maintained to a degree where everything.Is leakproof. Many of these connections leak, hoses burst, and the tendency Is to keep producing by adding more fluid. So It is conceivable that many of these hydraulic fluids ended up in the sewer. Z do not Intend to criticise the custoaiers of our products. Prom the knowledge that we had at that time of the material the practice was considered acceptable Another fslrly widespread application of PCB's Is the use of these fluids as a heat transfer madia to achieve high temperatures, have a fir* resistant transfer fluid, end avoid the installation of high pressure equipment. These materials were Ideally suited for this application. We thought at one time that these were adaptable to close control and proper maintenance where we could logloally call then dosed systems. Some recent evldsnoe Indi cated that we were wrong and I'll get Into that when Z discuss our present applications. One application that was a fairly significant ons and ons that In our thinking Is associated with coatings Is the use In car bonless reproduction paper,||4th the emphasis on recycling paper wastes and with the persistence of PCB's there is a problem developing In that PCB's are being found In many paper products and many of these paper products end op in food packaging. HONS 05S7J1 8 Initially the evidence we were getting aeened to point to the higher chlorinated material* ae environmental pollutants. As soon as we ware aware of this, we sent a letter to all of our customers telling them that what little we knew Indicated that theae materials could be an environmental problem, and cace should be exercised In handling. When the results came In on our chicken toxicity studies they Indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that we better place some restrictions on these materials because there were to us some uses that deserved to be kept In aplte of the problems that we saw facing us. We decided that we've got to. get out of ttldft* application* 'where wo felt there was no earthly chance or It was beyond our ability .to control the Introduction Into the environment, so we got out of all the so-called plasticizer applications. August 30, 1970 was the targeted effective date. We then wont Into a very active program of reformulating the hydraulic fluids. There again. It required a lot of testing. We had to run these new materials through the Underwriters Laboratories for approval on fire, resistance. They had to be compatible with the machinery then In use. This Is not easily don*, but It was don*. W* decided that w* could and must continue to supply the trans former manufacturer, the capacitor manufacturer, and at that HONS 058112 -9- tlm* closed hast transfer systems based primarily on our concept that fire resistance was important in heat transfer. To plek up the point that was raised earlier about foreign im ports, we are to the best of our ability trying to monitor Imports. Tff'thlr'day; wo hare not Information-that any nave arrived in this country. On the other hand, we are getting some reports that sons of our former customers have made Inquiries of the foreign producers. 1 an alao told by some Canadian provincial agency people that they had heard and were going to further Investigate that PCB's were entering Canada and from there moved Into the United States. I have talked to representatives of the Japanese produoer, the Kanegafuchl Company, and I am led to believe that they are mpst reluotant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering the U.S. market. I have talked to representatives of the French companies. They assure na that they don't want any part of this business. In Nay, 1970 Congressman William Fits Ryan Introduced a proposed bill which would In essence place Into law the very things that Monsanto had proposed doing on a voluntary basis. The bill provided that PCB's be banned except for those situations where the Secretary of HBW would give special permission or license. We went through the latter part of 'TO and early part of this year feeling, however, that we were still walking on thin ice. MONS 058773 10 - But we thought that we had sade sob* tremendous stride# in the right direction to preserve those uses which we thought were essential while eliminating those uses which were grossly con taminating the environment. This summer our hopes of control In the heat transfer business vanished when we found that a ueer of PCB did not appreciate the problem, did not maintain his equipment and created the recent chicken, egg, fishmeal problem. Because of this incident. Congressman Ryan withdrew the first bill that was subsiltted and has now placed before the same com mittee a bill which totally bans PCB and does not provide for any use whatever. And there are, of course, penalties for the marketing, manufacture, or nee of PCB in tlfls'WBntry. A Very drastic measure which does cause or can cause a lot of concern among those of ue who feel that PCB has a place In our society under proper conditions. As a result of this incident, we were forced to re-evaluate our position. Ve decided that,although heat transfer systeste could be closed unite, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the situation where even a pinhole leak can create tremendous pro blems before It can be discovered. So we have taken, again, an arbitrary position and Informed all of our customers In the food (whether It's animal or human food) packaging business, and the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. : HONS 0S87J4 In addition, we will no longer market to any naw haat tranafar applications. Our efforts will be concentrated on reducing thoae that we market today. This business should decrease aa time goea on. . To get back to legislation... as many of you probably know, there la before Senator Phillip Hart's committee a bill referred to as the Toxic Substances Act of 1971. The purpose of this bill Is to prevent the Introduction Into our society of hazardous materials. It also provides for the review of materials now In our society and the curtailment of the use of the more hazardous ones. Initial hearings were held In August, to which a select few Individuals were Invited to testify. PCB was brought out as an example of a material Introduced lntoeoclety and thought at one time to be most valuable, but Is now considered a serious threat to all of us. The meetings will be resumed In October; I do not know the exact date as yet,, and I'm led to believe that this would be the opportunity for Industry to speak up In Its behalf. I an assuming that since PCB's were brought up as an example of the type of substance this bill is supposed to prevent that Monsanto as sole producer In this country will be either Invited or we may choose to ask to be Invited (we don't know at this point Just what Is the proper approach here) to speak on the merits of retaining PCB's In transfomsrs, capacitors and fire resistant heat transfer systems, non-food applications. MOWS 050775 - 12 - I Mention this Mil because it la our opinion, and we could ba wrong, that rather than act on Congressman Ryan's bill, which ' la specific toward PCB's, we suspect that the Toxic Substances Aet will have In It provisions which, will refer to auch materials ss PCB's. He feel we have good technical data to Justify our staying In the business for United applications. But we cannot overlook the emotions that have set In. And believe me there are many and they are deep. It is difficult to combat emotions, as you know, and the references In the popular presa to hasardous poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we?talk about per sistant versions of PCB and degradable versions of'KB I"-euapeet, and this Is a personal opinion, that there would be many who Just discount this kind of Information. This Is a very real problem; In ay opinion It Is s difficult problem. As a little more background 1st ms deaerlbe what I understood from a meeting we held last week with representatives of the Pood and Drug Administration. It la my personal opinion that the Pood and Drug people are as conscientious as can be In trying to cope with the PCB problem. They are objective people trying to work with a minimum of data. I suspect they are as frustrated as any group of people can be ss to what Is the right way to go. There are treawndous pressures on the Pood and Drug people today ss well as the Department of Agriculture brought about by critics. MONS 058776 Theae agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. The PDA people really don't at this point in time have much infor mation thee will- lead them to a regulation as to how much FCB should be tolerated In food. They have established some guide lines baaed on what little Information they have from their own laboratories and the information that Monsanto has shared with them. The PDA will permit fish at 5 ppm on the market place; milk at .2 ppm or less; eggs .5 ppm; pountry (they have a double standard) 5 ppm in the fatty tissue and 5 ppm in the nieele tissue. Another problem that is disturbing to the FDA, la the recycle paper problem. The cereal boxas, the cracker boxes, all of these boxes that are made from what la known as chipboard, are made from recycle paper. Fairly high levels of PCB's are being found In this recycle board. It probably comes from about three or four different sources. It may coma from aoma Ink application in the paat, some adhesive application, some coating application, as well aa the carbonless reproduction paper appli cation. There have been some pilot studies made by the American Paper Institute to Isolate the carbonlese reproduction paper from the recycle batch. They still found PCB's In that batch. They are probably looking at maybe the second or third genera tion of recycle. And with the emphasis on recycle, I cannot eee any way out of thla dlleme except that there will be more and more FCB'a In these cartons. HONS 058771 - 14 - A. thought wa must *11 heap in mind, too. Is that we've got to llva with ths PCB's we Introduced Into the environment for the past 40 years. They have not disappeared overnight; they will not disappear overnight. We do not' have any testa that tell us^how-lawg lt-wlM- talas. We' can only made an educated guess and we might say they will be out there for another generation, 25 to 30 years yet. Hopefully, It will be a decreasing amount as time goes on. Monsanto has conducted biodegradation tests on Its products. We have three programs that are now active. One program we are conducting In our laboratories In Kuabon, Wales In which we are making what X would refer to as scientifically basic studies in terms of whlcn isomers are most degradable and with what type or microbe. This Is a little bit on the lmpractloal side at this point In time. We have as a consultant. Professor Charles gvans of Bangor University In South Wales, who Is a noted authority worldwide In this kind of activity. He has Isolated at least three microbes that seem to thrive on polychlorinated biphenyls. ThaadLmlerobaa. he developed from coll that he obtained from his garden. What this tells us is that there are microbes out there In the environment that will eventually destroy these materials. In the St. Louis area, we have two types of tests going. One la the use of rlvac water with Its normal biota In It, In which we introduced theme polychlorinated biphenyls and look for the disappearance rat*. It Is a very quick and rather unsophisticated type of study. The other type of test Is the on* that simulates HONS 058778 thorn condition* which ar* apt to be found In a normal municipal Sewage treatment plant. It'a an aerobic teat using an activated sludge from a St. Loula waat* treatment plant. Aa a standard, w* uaa a aoft detergent because It ip well known to other laboratories What we ar* doing, really Is using our expertize that we established back In the days when th* hard versus soft detergent controversy as quite coimeon. And mo are using these soft detergents that do degrade as our controls and comparing the PCB's to these con trols. The studies so far show that there are Isomers within eaoh of these mixtures that do degrade. The lower the chlorine level, the faster they disappear, th* higher the chlorine level the more resistant they ar*. Which'only confirms what many of us had suspected. We Mere not too surprised by this data. X will attempt to summarise ... X think we can conclude that ^CB's ar* In the environment. There la no question about it. Many of these PCB's are manmade and were Introduced to the environ ment because.of our lack of understanding of what these materials can do to th* environment. In this country Monsanto, as sole producer, has attested to Improve the situation by limiting the applications to which these materials are used. Studies today would Indicate that these PCB's ar* not. and cannot be classified as highly toxic. Therm Is still a lot of Information that la needed to help us determine the long term effect on human beings. We feel that the properties of these materials ask* them, at least as of today, the moat suitable material for us* In trans formers, capacitors and heat tranafer syatems. W* also believe that under proper conditions we can control the amount 'of these HONS 058779 - 16 - that do antar tha anvlronaant to tho point where the advaraa affacta ara not graat and that tha beneflta wa darlva far out weigh tha ainor advaraa affacta that aa night notiea. Now thara ara nany of ua in tha tranafornar and capaeitor application that hava mada tranandoua atridaa in eontroling thaaa aatariala. Z auapaet our objective ia to furthar iaprove our ability to oontral thia notarial. In ay paraonal opinion tha anotion that la now prevailing regarding PCB'a la eoaething that we uat contend with. Whether wa believe in it or not, thara ivho are nany people that alncerely believe PCB'a ahould be totally banned. *QNS 05B7*0