Document J33zbR7DbL3v5MQqG4LGeBwje

Monsanto ........... . >ic.T.o., ; C. Paton - St. Louis - B2SC o.'! UBJtCT July 3 1973 OECD/PCBs cc W. B. Papageorge - B2NA ~c. JHN memo of June 5 TO : T.L. Gossage B2SL My comments are: 1. Amounts of PCBs (a) I am In general agreement with John that we disclose j a/p( for Newport and Sauget the amount of PCB manufactured bv PCB tvne provided our competition does the same. / " (1 would put sold ratner than manufactured^ r have not seen evidence that competition so far has disclosed this data in such detail. Our competition only have one plant each. It would be valuable competitive infor mation for them to know how we continue to split our production. Can we consolidate the production from 7 both plants? ' * (b) I am also in agreement with John that, we shnnlri-nnt. [ err< disclose exports by country but rather give an OECD ( total and a non-OECD total. 1 think U.K. and U.S. authorities would buy this, but will individual OECD countries? MOCAN has given the Canadian government our sales in Canada by PCB type for OECD use. I suspect Australia will soon seek the same information. I think we will be under pressure to divulge OECD data bn a ,ST country by country basis, but I suggest we do not break ( out the origin of the product. For non-OECD countries '** ) I think we should have a Single''total which would be \the total of Newport and Sauget exports to those- countries. I disagree with .Tnhn on divulging amounts consumed. We have no real way of knowing what is consumed in anjr-given time period by our customers. We can come close to what any customer used for capacitors and transformers but we cannot be certain if he put Aroclor 1254 into a capa citor or a transformer for example. (Itel in Brazil is a real example.) Also, do we want competition to know what the ongoing capacitor/transformer break-down is, in view of capacitor fluid competition. I agree with -John that imports and incineration matters are for~tlie goveiiiuieuL lu get exsewnere. " . 0071727 i mIN - 10 RC TOWOLDMONOQ56897 -2- 2. PCB Replacements & I agree with John. I think we should keep our Input on |44 I replacements as brief as possible^-------------------- 3. Disposal of Surplus PCBs by Incineration This is not a matter for Monsanto or other PCB producers alone. Other comments are: (a) Statistics will be sought at the beginning of 1974, 1975 and 1976. Will these be statistics for the previous year and/or an estimate for that year? This needs clarification. (b) Dlchlorobiphenyls I understand that the Swiss are prepared to allow dlchlorobiphenyls for any use. Is this official OECD policy? Was this a move sponsored by Progil to corner a market in dielectrics and other discontinued uses? Dr was the Swiss decision based on long-term feeding studies, toxicity, biodegradation, etc.? I doubt if dlchlorobiphenyls can be made free from any tri- and higher homologs - so have the Swiss set a specification for dichlorobiphenyl composition? In view of MICC/Dow discussions such a move by the Swiss would be welcomed. On the other hand, it could be used by competitors as a loop-hole to reactivate discontinued uses. How would icorporate Monsanto view such amove? In other words, /should we be discussing.the ramifications of the Swiss Amove with our UK/US OECD contacts? , Intermediates It is in our interest to get/iPCB as an intermediate "blessed" by OECD. This would cover monochlorobipnenyJL for Dow but could, of course, lead Bayer to use that route to phenyl phenols (Dow, I understand, may try to shut Bayer down on phenyl phenols which is to our advantage). On the other hand, DuPont is presumably still importing decachlorobiphenyl from Caffaro for polymer production. This is business we would like to get if it is sizable. 5. Heat Transfer Fluids/Mining Fluids nM- In view of the fp_ rpr in the U.K. over PCBs in Maendy quarry, the retention by oCD of PCBs in heat transfer and mining fluids is too much of a loop-hole, I believe. Hi particular, the 0071728 TOWOLDMONOQ56898 -3- heat transfer exemption Is a wide one; paper packaging, resins, and coatings are presumably OK for PCB use (see Page 6 of OCED Appendix) but what of Indirect food contamination? 6. Uniform Labelling/Containers, Etc. I I think Monsanto Should take the lead here so that the labels, fair drums, containers, etc. we have gone to in U.K. and U.S. should become the Industry standards. 7. Mon-OECD Countries Progll Is still selling PCB In Argentina for carbonless paper production on the grounds that non-OECD countries are not con- cemed with the PCB problem. I personally think this Is short^ sighted as Bn InMrioTvfc pnnlfl jinnw nhawga nUma+.o nnrl nardize the dielectric industrv~ as-wei:l~~a.s cast doubts on~~the nredihinty of PCB producers---It-does, however, point up the question as to why OECD countries need non-OECD statistics. Samples I note no mention of whether or not the U.K. authorities have accepted Monsanto's policy on PCB 'samples' to companies who wanted to use PCB for testing components. re*- 0tD Ai O0717Z'*