Document GKnQgvjj94V78qQZ0NNjnbk67

Monsanto FROM T. D. Holman - C2SB - 4-2789 DATE September 18, 1991 cc: SUBJECT : Senate testimony REFERENCE TO Loren Wassell - G4WF * Attached is a copy of the letter Bob Harness prepared to complement his testimony before the Senate Ag. Committee. Garth Fort asked that you be given a copy, with specific interest, I believe, in employment and salary figures that might be affected by a loss of imports. Please call if you need further info. ThanVc; . bcin uu .Lilian DSW 135196 STLCOPCB4035165 2 Labor Secretary Lynn Martin said that partnerships among management, employees and OSHA, are the best way to assure the health and safety of America's working men and women. "VPP participants are a select group of facilities tha-t have designed excellent programs to effectively protect employees. Monsanto, in committing all of its plants to this program, is taking an important step toward becoming one of the nation's leaders in health and safety. We applaud them for stepping up to this challenge. I urge other manufacturers to follow their lead." To earn the Star designation, a plant must undergo a very rigorous OSHA audit showing its safety programs and practices reach various levels of excellence and its accident rate is below the rest of the industry. According to the Bureau of Labor Statistics, Monsanto's current injury rate is about one-third that of the chemical industry average, and less than one-fifth that of the average of all industries, which makes it one of the safest manufacturing companies in the U.S. The commitment helps to fulfill an element of the Monsanto Pledge, the company's seven-point commitment to improved environmental safety and health performance, which is, "To ensure no Monsanto operation poses any undue risk to our employees and our communities." (more) DSW 135874 STLCOPCB4035166 ROBERT L. HARNESS Vice President Environmental and Public Affairs Monsanto MONSANTO AGRICULTURAL COMPANY 800 N. Lindbergh Boulevard St. Louis. Missouri 63167 Phone:(314) 694-3713 September 17, 1991 The Honorable Patrick Leahy Chairman, Senate Agriculture, Nutrition and Forestry Committee United States Senate Washington, D.C. 20510 Dear Senator Leahy: I am writing in response to your September 6, 1991 letter to me, and in particular to respond to the questions raised in your September 4, 1991 letter to Mr. Earle H. Harbison, Jr., President and Chief Operating Officer of Monsanto Company. Question 1: Identification of products Monsanto Agricultural Company manufactures three pesticide products in the United States that would be affected by the provisions of S.898. These are Butachlor herbicide, which is registered for use in a number . of rice-producing countries. Acetochlor herbicide, which is used primarily on corn has received in 1991 an experimental use permit and temporary food tolerances from the U.S. Environmental Protection Agency. and Dithiopyr herbicide, which is registered for non-food use (turf) in the U.S. and registered for food uses (rice) in Japan (both registrations issued in the first half of 1991). _ A petition for a tolerance for dithiopyr on imported rice was submitted in August, 1991. . Butachlor would appear to fit into Category A and acetochlor into Category B of the choices presented in your September 4 letter. ' a unit of Monsanto Company OSinl 135197 STLCOPCB4035167 The Honorable Patrick Leahy September 17, 1991 Page 2 Dithiopyr has a non-crop U.S. registration and hence does not fit into any of the categories. Questions 2 and 3: Butachlor economic data Butachlor is produced at Monsanto's production facility in Muscatine, Iowa. This is a multi-purpose production facility. Monsanto considers sales and production data information to be trade secret and confidential information which is not disclosed to the public. Release of this information is likely to cause serious competitive damage to Monsanto. If this information is important in your consideration of the proposed legislation, Monsanto will be happy to discuss the preparation of a confidentiality protection agreement with your staff. This offer applies to all sections of this letter where we have noted that the information in question is trade secret and confidential information. For question 2(c), the 1990 annual average payroll cost for a worker involved in butachlor production at the Muscatine plant was slightly over $39,000. This figure includes fringe benefits and all payroll overhead-related costs. 3(a) Monsanto shipped butachlor to the following countries and/or world areas during the specified time period: Korea Japan Taiwan Other Asian countries India Peoples Republic of China Latin America Miscellaneous Europe/Africa countries 3(b) Monsanto considers this information to be trade secret and confidential information. - ' Also please note that there are in excess of 20 butachlor manufacturers in addition to Monsanto located in various parts of the world. Monsanto estimates that it supplies approximately one half of the world's butachlor, and that its share of the market is declining. . 0SW 135198 STLCOPCB4035168 The Honorable Patrick Leahy September 17, 1991 Page 3 3(c) Monsanto's butachlor is used primarily for weed control in rice crops in each of the countries and locations mentioned above. Questions 4 and 5 - Health and Safety questions Butachlor: 4(a) Butachlor is manufactured and formulated at the Monsanto plant in Muscatine, Iowa. Emissions of butachlor from the Muscatine plant for the years through 1990 are as follows: 1985 AIR WATER LAND 1985 1986 1987 1988 1989 1990 <100# <100# <100# <100# <100# <100# 1020# 930# 600# 1590# 990# 375# 92# 98# 59# 50# 47# 50# Granular activated carbon treatment of wastewater is being installed and future emissions of butachlor to water will be significantly reduced from historic levels. 4(b) All emissions cited above were the result of routine production operations. 4(c)(1) The Iowa Department of Natural Resources and EPA Region 6 regulate all environmental emissions from the Muscatine, Iowa facility. 4(c)(2) Sources of air emissions are authorized by construction permits granted by the Iowa Department of Natural Resources. Discharges to surface waters prior to March 6, 1989, were authorized, by an NPDES permit " granted by the Iowa Department of Natural Resources. Discharges to surface waters subseguent to March 6, 1989, were authorized by an administrative order issued by the Iowa Department of Natural-Resources. . Authorizations to dispose of solid waste are granted by the Iowa Department of Natural Resources and the Illinois Environmental Protection Agency. . DSW 13519.9 STLCOPCB4035169 The Honorable Patrick Leahy September 17, 1991 Page 4 4(c)(3) Routine inspections and review of permit applications are conducted by regulatory agencies. The Iowa Department of Natural Resources receives and reviews monthly monitoring reports for water discharges. 5 Attachment 1 to this letter contains a listing of health and safety studies conducted on butachlor. Note that dates are given for report issuance only. Start dates are difficult to define and much more difficult to obtain in our recordkeeping system. Generally, start dates will be in advance of the completion date by the length of time EPA allows for similar studies under data call-ins. All studies include the collection of scientific data on the effects of butachlor. No butachlor health and safety studies have been published by Monsanto. Summaries of health and safety data on butachlor are publicly available in the _ Material Safety Data Sheet. All studies completed prior to May, 1983 were submitted to EPA. No studies have been submitted to state or local government agencies. All studies have been submitted to the Japanese regulatory authorities and have been reviewed with regulatory authorities in other countries where butachlor is used. The complete butachlor toxicology and residue data base will be submitted to EPA in response to the Federal Register notice of September 4 requiring action on pending tolerance petitions. Questions 6 and 7 - Butachlor 6 Monsanto applied to EPA for registration of butachlor in June, 1978. Monsanto efforts to support that petition were suspended in 1983 as it became clear that despite our best technical efforts this product could not be made to fit U.S. cultural practices, and that support of key markets in Asia was a higher priority. The United States accounts for less than one per cent . of worldwide rice acreage, and almost none of that DSW 135200 STLCOPCB4035170 The Honorable Patrick Leahy September 17, 1991 Page 5 consists of transplanted rice. To date, Monsanto's petition has neither been granted nor denied. 7 Monsanto petitioned EPA for a food tolerance for rice in June, 1978. Monsanto efforts to support that petition were suspended in 1983 as it became clear that support of key markets in Asia was a higher priority. To date, Monsanto's petition has neither been granted nor denied. The complete butachlor toxicology and residue data base will be submitted to EPA in response to the Federal Register notice of September 4 requiring action on pending tolerance petitions. Questions 8 and 9 - Economic Questions, Acetochlor 8 Acetochlor has been produced at Monsanto Company's St. Louis, Missouri location. This is a multi-purpose production facility. Monsanto considers the information requested in ' questions 8(a) and 8(b) to be trade secret and confidential information. Public disclosure would - likely result in competitive harm to Monsanto's business. 8(c) _ The 1990 annual average payroll cost for a worker involved in acetochlor production at the St. Louis, Missouri facility was over $52,000. This figure includes fringe benefits and all payroll overheadrelated costs. 9(a) During the specified time period Monsanto shipped acetochlor to the following countries: Argentina Soviet Union South Africa Hungary Czechoslovakia ~ - _ 9(b) Monsanto considers this information to be trade secret and confidential information. Also please note that there are other acetochlor manufacturers located in various parts of the world. DSW 135201 STLCOPCB4035171 The Honorable Patrick Leahy September 17, 1991 Page 6 9(c) Monsanto's acetochlor is primarily labeled for the control of weeds in corn crops. It is also labeled for weed control use in soybeans, potatoes, ground nuts and sugar cane in some countries. Questions 10 and 11 - Health and Safety, Acetochlor 10(a) Acetochlor has been manufactured at the Monsanto plant in St. Louis, Missouri. Acetochlor has been formulated at the Monsanto plant in Muscatine, Iowa. Emissions of acetochlor from these facilities for the through 1990 are as follows: ST. LOUIS PLANT AIR WATER* LAND 1985 1986 1987 1988 1989 1990 <100# <100# <100# <100# <100# <100# 11,680# 649# 21,975# 56,974# 5,692# 18,870# None None None None None None * Discharges are to the publicly owned wastewater treatment plant There will be no future emissions of acetochlor from the St. Louis plant, as manufacture of acetochlor has ceased. MUSCATINE PLANT There were no emissions of acetochlor from the Muscatine plant. 10(b) All emissions -cited above were the result of routine production operations. 10(c)l The City of St. Louis Division of Air Pollution Control regulates and monitors air emissions at the St. Louis plant. The Metropolitan St. Louis Sewer District regulates and monitors water emissions. The Missouri Department of Natural Resources, Division of Environmental Quality regulates and monitors releases to the land. EPA-Region 6 has federal oversight of all DSW 135202 STLCOPCB4035172 The Honorable Patrick Leahy September 17, 1991 Page 7 environmental regulatory programs at the state and local level. The Iowa Department of Natural Resources and EPARegion 6 regulate all environmental emissions at the Muscatine plant. 10(c)(2) The City of St. Louis Air Pollution Control Division controls air emissions at the St. Louis plant through an ordinance which requires the registration of all air pollution vent sources. The Metropolitan St. Louis Sewer District (MSD) controls all water discharges through an ordinance. MSD is issuing individual permits as an additional control mechanism. No permits are necessary for emissions to the land as there are none. As there are no emissions at the Muscatine plant, no permits are necessary. 10(c) (3) Routine inspections and review of permit applications are conducted by regulatory agencies. 11 Attachment 2 to this letter contains a listing of health and safety studies conducted on acetochlor. Note that dates are given for report issuance only. Start dates are difficult to define and much more difficult to obtain in our recordkeeping system. Generally start dates will be in advance of the completion date by the length of time EPA allows for similar studies under data call-ins. All studies include the collection of scientific data on the effects of acetochlor. All acetochlor studies have been submitted to EPA. No acetochlor health and safety studies have been published by Monsanto. Summaries of health and safety data on acetochlor are publicly available in the Material Safety Data Sheet. \ Questions 12 and 13 - Acetochlor 12 Monsanto applied to EPA for registration of acetochlor under Section 3 of FIFRA in September, 1983. Efforts DSW 135203 STLCOPCB4035173 The Honorable Patrick Leahy September 17, 1991 Page 8 to support that petition were cut back in 1985 but revived in 1988. In June of 1991, EPA granted an EUP with temporary tolerance for the use of acetochlor on corn on up to 4,000 acres. Monsanto expects to complete all remaining data requirements to achieve registration of acetochlor by mid-1992. It is noteworthy that a European-based company, ICI Americas, Inc., has also petitioned the EPA for registration of acetochlor. 13 Monsanto petitioned the EPA for food tolerances for acetochlor on corn and soybeans in September, 1983. This petition was amended in 1985 to a petition for corn only. Efforts to support that petition were cut back in 1985 but revived in 1988. In June of 1991, EPA granted an EUP with temporary tolerance for the use of acetochlor on corn on up to 4,000 acres. The balance of this letter will be devoted to responding to the same questions for dithiopyr, the third Monsanto product that would be affected by the proposed legislation. Dithiopyr is a new product for Monsanto. It is a herbicide which received registration in the United States in 1991 for weed control in turf grass. The product also received full ` registration in Japan for use on rice as well as on commercial turf. Economic Questions - Dithiopyr Dithiopyr has been manufactured in small quantities at Monsanto's Dayton, Ohio facility. This is a multi-purpose production facility. As with the other Monsanto products, Monsanto considers production value information to be trade secret and confidential information. Public disclosure would likely result in - competitive harm to Monsanto's business. Given the fact that dithiopyr is a new product, limited quantities have been produced for export at this point. _ The 1990 annual average payroll cost for a worker involved in dithiopyr production at the Dayton, Ohio facility was nearly $37,000. This figure includes fringe benefits and all payroll overhead-related costs. DSlnf 135204 STLCOPCB4035174 The Honorable Patrick Leahy September 17, 1991 Page 9 As stated above, dithiopyr is registered only in the United States (turf) and Japan (rice and turf). Monsanto considers information regarding export of dithiopyr to be trade secret confidential information. the and Health and Safety Questions - Dithiopyr Dithiopyr is manufactured and formulated at the Monsanto plant in Dayton, Ohio. Emissions of dithiopyr from the Dayton plant for the years 1985 through 1990 are as follows: AIR WATER* LAND 1985 1986 1987 1988 1989 1990 None None None None <1# <1# None None None None 115# 170# None None None None None None * Discharges are to the publicly owned wastewater treatment plant The Regional Air Pollution Control Agency regulates and monitors air emissions at the Dayton plant. The City of Dayton, Division of Wastewater Treatment regulates and monitors water emissions. The Ohio EPA regulates and monitors releases to the land. EPARegion 5 has federal oversight of all environmental regulatory programs at the state and local level. Monsanto has obtained a permit to install the dithiopyr process from the Regional Air Pollution Control Agency. The City of Dayton controls all water discharges through an ordinance and administrative orders. No permits are necessary for emissions to the land as there are none. Routine inspections and review of permit applications are conducted by regulatory agencies. " Attachment 3 to this letter-contains a listing of health and safety studies conducted on dithiopyr. - _~ Note that dates are given for report issuance only. Start dates are difficult to define and much more difficult to obtain in our. recordkeeping system. Generally start dates will be in advance of the completion date by the length of time EPA allows for similar studies under data call-ins. DSW 135205 STLCOPCB4035175 The Honorable Patrick Leahy September 17, 1991 Page 10 All studies included the collection of scientific data on the effects of dithiopyr. All studies supporting registration of dithiopyr for use on turf in the U.S. have been submitted to the EPA. Subsequent to EPA approval of the registration, the data or summaries of the data, depending on the requirements of the state, have been submitted to California, Florida and New York. In August, 1991, all remaining toxicology studies in addition to residue studies conducted on rice in Japan were submitted to EPA in support of a petition for a tolerance on imported rice. No dithiopyr health and safety studies have been published. Summaries of health and safety data on dithiopyr are publicly available in the Material Safety Data Sheet. Regulatory Questions - Dithiopyr Monsanto applied to EPA for a registration of dithiopyr for use as a herbicide in turf in January, 1989. A conditional registration was granted in June of 1991. In August, 1991, Monsanto submitted a petition for a tolerance for dithiopyr on imported rice. This petition is currently being reviewed by the Agency. In addition to the above responses, I would like to point out that Section 105(a)(6) would severely restrict American companies' ability to develop new products for foreign markets. Our industry is working hard to develop other safer and environmentally compatible products, not just for U.S., crops but globally. In fact, U.S. companies are actively working on products for crops not generally grown in the United States, such as canola and oil palm. This bill would restrict U.S. companies'" ability to test products in foreign countries. If you have questions regarding the information contained in this letter, please do not hesitate to contact me. Very truly yours Robert L. Harness DSW 135206 STLCOPCB4035176 Ml' ' M 1 I United States Senate COMMITTEE ON AUn.CUL-UJHt- NUTRITION. AND KJHf-STRY washinc; ion. DC 205 10-6000 September 6, 1991 Mr. Robert L. Harness Vice President of Environmental and Public Affairs Mail Code C2SB Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri (50107 Dear Dr. Harness: I appreciate your willingness to testify on behalf of Monsanto at the September 20, 1991 Senate Agriculture, Nutrition, and Forestry CommiLtee hearing on S.898, the Circle of Poison Prevention Act." Thu hearing will focus on how American consumers are effected by U.S.-made pesticides which are banned or have no U.S. registration nor food tolerance Several witnesses, including pesticide manufacturers and Administration officials, will testify at. the September 20 hearing. While we want to give all witnesses ample opportunity to present their case, the large number of witnesses will create time constraints for us. Therefore, to facilitate the hearing, please provide the Cumimi-Lee staff with your written statement by September 13. Since the full written statement will be included in the hearing record, you will be asked to give a brief (three minute* oral summary of Monsanto's views at the hearing. You wall also have an opportunity to make any points you wish during the question and answer period. At the September 20 hearing, I plan to ask detailed questions concerning the impact of S.898 on Monsanto, the pesticide industry, employment and compensation. Monsanto's responses are important because there are a number of areas whore the Environmental Protection Agency simpiy lacks adequate information. DSW 135207 STLCOPCB4035177 VI 1 Mr. Robert L. Harness September 6, 1991 Page 2 In an effort to save time at the hearing, I have outlined some of those questions in my September 4, 1991 letter to Earle H. Harbison Jr., President and Chief Operating Officer of Monsanto (a copy of which is enclosed). I would appreciate Monsanto providing me with written responses to them by September 13. If you have any questions concerning this request or wish to meet with the Senate Agriculture Commit Lee staff before or after Monsanto completes it, please contact Carolyn Brickev at. 1202) 221-5207. . Thank you for your cooperation. Sincerely, PATRICK J. T.EAHY Chairman PJL:jh cc: Chester T. E)ickerRon, Jr. Director, Agricultural Affairs DSW 135208 STLCOPCB4035178 .ft WN mA*M> UMAX 111 illlli pijil ,, V >> Ml ! Mil MOIltll s An-..I )( i>.Af> Wii.Mi.r.irn Will l .l i /k MIIV | I.HAHi ltAM( ,i;hM 'J'Mliim l.AlillifcNM* < liAMIL* I l.llA*, .l 1'iAA United States Senate CflMMI I ffcfc ON AGUlCULTUflE NUTRITION. AM} KJHfcSTRY WASHINGTON. OC HO'il i> liOOO September *1, 101)1 Parle il I lyrbiaori Jr, President and Chief Operating Officer Monsanto Company H()() N. Lindbergh Boulevard St. Louis, Missouri (id 107 ! )ear Mi". 1 iarbison: ' 1 am disappointed that Monsunto will not be testifying at either the June 6 or September 20, 1991 Senate Agriculture, Nutrition, and Forestry Committee hearings on S.898, the 'Circle of Poison Prevention Act. ' Pesticides that Monsanto makes were discussed at the June 5 hearing and I expect them to be l aisi-d again on September 20. That, latter hearing will focus on how American consumers are effected by U.S.-made pesticides which are banned or have no U.S. regisI ralion nor food tolerance. ~~ Several pesticide manufacturers will testify at the September 20 hearing. Their coimneitt.s arid views are important because there are a number of areas -- such as the impact of S.89F on the pesticide industry, employment, and compensation -- whore the Lnvinmmeiilai Protection Agency simply lacks adequate information. Kwii though .Monsanto -will not testify at the hearing, 1 would appreciate its pi moling' mo with a written response to the following questions by September K3. I'hr.-e s.uiie questions have been sent, to the companies which are testifying at the lu-a ring. Pe.-aicide identification _ - : i'least* idem ii\ ail pesticides w men Monsanto manufactures, formulates, or ' 'e-tormuiates in the U..S. that would not be exportable from the United D5W 135209 STLCOPCB4035179 Earle Jl. llarbison *Jr. September-4, 1991 l`age 2 rilaLes should S.898 bo enacted as written. Please specify which of the following categories most closely describes each pesticide (select only one category! II' it, dues not fit into any of the categories, please state why, a. a pesticide which presently has neither a U.S. registration nor food tolerance but could be granted either a U.S. registration or food tolerance because that pesticide is currently registered in one or more countries that have comparable pesticide standards to the U.S. and are members of the Organization for Economic Development and Cooperation. (Note, for each pesticide which fils this category, please identity all OECD countries which have granted it a registration, and ijuv which have granted, but later canceled, its registration.) b. a pesticide which presently lias neither a U.S. registration nor food tolerance but could be granted either a U.S. registration or food tolerance once a data set, sufficient to meet U.S. standards has been completed. c. a pesticide which presently has neither a U.S. registration nor food tulerance and probably could not be granted either because it cannot meet, the standards of Lhe Delaney Clause. i!. ;i pesticide which presently has neither a U.E. registration nor food tolerance but could be granted either a U.S. registration or food '..ulerMtice if'current law was changed from the Delaney Clause to a negligible risk mne in a million) standard. e. a pesticide winch presently has neither a U.S. registration nor food tolerance because it is used for crops not grown in, nor imported into, the U.ri.. but could be granted a L'.ri. loud tolerance if its manufacturer applied for one. At tins time. w< are mily aware of two pesticides -- bul-achior (Machete) and - acei octiiur ihai Mmi'anio iuain.ilhcl.iii es. formulates, or re-formuiat es and which i- vs i'run one <sl (lie live categories above. Foi this reason, the following questions nnlv -.peril v hi.iarhinr and acelochior. However, if Monsanto makes pesticides. - ! Ium than luiluchl"--' and acelochior. that lit the live categories, please answer the ! 11! J11 v. 111 l quc^l .*ii i" O/i i a i 11 .' t 111< >se pcs t lcides. ' DSW 135210 STLCOPCB4035180 Knrle H. Hardison Jr. September 4, 1991 Page :s Hcnnomic Questions -- butachlor 2. At winch facilities operated by Monsanto is butachlor manufactured, formulated, or re-formulated? For each facility, and for each year from 1986 to 1990 inclusive, please specify: a. the value Un U.S. dollars) of butachlor manufactured, formulated or re-formulated. . . h. the value (ifi U.S. dollars) of ail products (including butachlor) manufactured, formulated or re-formulated. r. the mean annual compensation (including base pay, overtime, employer tax contributions and fringe benefits) of all employees of that facility. a. For each year from 1986 to 1990, please specify: a. each country that received the butaehlur which Monsanto produced, _ manufactured, formulated or re-formulated; I). the quantity of butachlor used in that country. . the purposes lor- which butachlor is used in each of these countries. Health ana Safety Questions -- butachlor 1 For each facility identified above, and for each year from 1985 to 1990, please specify the quantity uf butachlor which has been released from the ianitt v, m any form other than as a commercial product. a. I Mease separately specify the quantity released to air. water, and land. ' ._ ` b For each emission identified, please specify the annual quantity of (missions that wen: 1 > accidental or unplanned; and 2) planned or the conseimencc of ordinary production operations. " DSW 135211 STLCOPCB4035181 Karla H. Hnrhison dr. September 1991 Pagr 4 c. Sor each facility: 1. which state, federal or local government agencies regulate or monitor snc.h releases? 2. what permits, licenses or authorizations has Monsanto obtained for such releases? :i. what legal, regulatory or other official action or review has been undertaken with regard to any release of butachlor? J las Monsanto conducted, or caused to be conducted, any studies concerning tlu* liealtli and/or environmental effects of butachlor on production workers, nd users, or consumers of food? a. if so, please describe the effects studied and the dates on which the study was hogun and completed. 1 Did the study include collection of scientific data on the effects of butachlor, or was it strictly based on the review of data collected in other studies? 2. T'o whal suite, local, and federal government agencies has the .study has been submitted, and when was it submitted? i. If the study was published, please provide a bibliographical citation for the publication. _ Kei/ulalorv (.jurst.ions -- butachlor is .Has Monsanto ever applied tu KPA to register a product containing hrtaihlor with the KPA under section .'3 of KTFRA? If so, why and when us i be uppli'c.-iiiun submitted and what is its status or outcome? . lias Monsanto ever petitioned t.he MPA to established a "food tolerance' under PI FRA for butachlor. us residues or us metabolites? If so, why and a hi n uri" i In- application submitted and what is its status or outcome? .' _ . . ' ,| DSk 135212 STLCOPCB4035182 Karle tf. Hnrhison rJr. September 4, 1991 Page 5 Economic Questions -- acetochlor 8. At which facilities operated by Monsanto is acetochlor manufactured, formulated, or re-formulated? For each facility, and for each year from 1986 to 1990 inclusive, please specify: a. the value (in U.S. dollars) of acetochlor manufactured, formulated or re-formulated. . 1). the value (in U.S. dollars) of all products (including acetochlor) manufactured, formulated or re-formulated. c. the mean annual compensation (including base pay, overtime, employer tax contributions and fringe benelits) of all employees of that facility. 9. For each year from 1985 to 1990, please specify: a. each country that received the aceioclilur which Monsanto produced, manufactured, formulated or re-f'ormulatcd; li. the quantity of acetochlor used in that country. c. the purposes lor which acetochlor is used in each of these countries. I icaith and .Safet y Questions -- acetochlor 10. ' For cadi facility identified above, and for each year from 1985 to 1990, please specify ihe quantity of acetochlor which has been released from the lauliiv, m anv form other than as a commercial product. o. 1 Meuse separately specify the quantity released to air, water, and , land. - h. For each omission identified, please specify the annual quantity of emissions that were 1) accidental or unplanned; and 2) planned or the " consequence of ordinary production operations. I 1 . j Ii vl I '! GSW 135213 STLCOPCB4035183 Knrle ii. Harbison Jr. September 4, 1991 Page (5 c. For each facility: 1. which state, federal or local government agencies regulate or monitor such releases? 2. what permits, license*? or authorizations has Monsanto obtained for such releases? d. what legal, regulatory or other official action or review has been undertaken with regard to any release of acetochlor? 1 1. Has Monsanto conducted, or caused to be conducted, any studies concerning the health and/or environmental effects of acetochlor on production workers, md users, or consumers of food? a. If so, please describe the effects studied and the dates on which the study was begun and completed. . ]. Did the study include collection of scientific data on the effects of acetochlor, or was it strictly based on the review of data collected in other studies? 2 To what slate, local, and federal government agencies has the study has been submitted, and when was it submitted? .'i If the study was published, please provide a bibliographical citation for ihe publication. legulat urv t^uesl ions acetochlor 2. Has Monsanto ever applied to KPA to register a product, containing : i n 't orh lor with the KPA under section 2 of FI FRA? If so, why and when the application submiLLcd mid what, is it.s status or outcome? Monsanto ever petitioned the FPA to established a food tolerance" audio- FIFK.A Cor acetochlor'. its residues or ns metabolites? If so, why and .'.hen-was the application submitted and what is its siatus~or outcome? STLCOPCB4035184 Knrli: 11. lljirbison Jr. September 4. 1991 Cage 7 If you have any questions concerning IhiH request or wish to meet with the Senate Agriculture Committee staff before or after Monsanto completes it, please contact Carolyn Brickey at '.202) 224 5207. Thank you for your cooperation. Sincerely. '* / I'ATKJI.'K.J. J.KAHY ' i Mian man 7 osw STLCOPCB4035185