Document JNxxmKoE2vyw67E5GVMk8JpZr

V). R. Richard - Research Center March 6, 1969 ftROjZtpR WILDLIFE ACCUSAT: J.^Springate JSPHi y. Schalk WSCHA D. Olson DOLSO R. Kelly RK2IJ. J. Garrett JGARR TO E. Wheeler - ffl/HEE P. Hodges PHODG P. Park PPARK Pi. Keller J?Q E. Tucker JFQ Rlsebrough in a recent paper "Nature", Vol. 220, Dec. 14, I960, has attacked chlorinated biphenyls In three ways: (1.) 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. (5) a toxic substance endangering man himself; Implying that the peregrine falcon is a leading Indicator of things to come. As outlined in Science,Vol. l63, Pg. 5^8, 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, p3.ant or aquatic life". Wisconsin Is one of 7 states which now have federally approved water quality standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Vfate r .Quality Standards Branch, DOT would fit the definition of a pollutant upon a showing that it Is harmful to aquatic life. These people in EDF are saying we must not put stress on any living thing through a change in air or water environment. Eaglet, 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 DOT 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) Monsanto Is preparing Itself to identify trace ppb quantities of chlorinated 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 net. We will eventually know where any pollution Is taking place and the extent of the pollution. HONS 096360 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 k made. Whether we can defend this route or not needs further I discussion. ----- ' ----- ---------- (c) Through the Industrial Bio-Test program we are to establish the long term allowable limits of chlorinated biphenyls for certain birds-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 Bafe operating limits for humans and certain animals. Where doos 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. V/e 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. MONS 096361 (RevisideebnrocueghofhaesnzytmakeenandknohwornmoAnreoccloharngsaem. plHesereandthecrlaeimiss to no have 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. 3.968 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 Ind. Bio-Test, Monsanto biochemists, the medical and legal departments must take place now. The E. Wheeler -3- March G, 1969 position of Dnr manufacturers should be determined as a guide. We are being accused of the same things attributed to DDT. I have written this memo to clarify some of the Issues. May I please have comments. Thanks, ms Att. W, R. Richard HONS 096362