Document MGXkXQ1vOv6YR06Yn8nRGKvJL

October 23, 1970 Pror. a. Fred Lee Water Chemistry Laboratory The University of wt*eon*ln Madison, Wlaoonaln 53706 Dear Dr. Laei 1 never have received my oopy of your letter to Kerb 3toklnger dated August 14 which you referred to In your letter of September 23. Jack Oarrett haa received your letter of October 13 and I now do have a copy of your earlier letter and the poeltlon atatement. Aa you Indicated In your letter to Jack, there la no reason why you ahould not discuss the results of our on-going toxicity studies with Dr. Calandra and his associates. I have enclosed a copy of my letter to Herb Stoklnger with copies to you. Dr. Calandra and Dr. Mount concerning the statue of our studies and the detailed result* avsllable at this time. In connection with the position paper, I have the fol lowing commentst 1. In the second paragraph on the first page, there is a reference to pesticide formulations and the possible direct contamination of natural waters. I think you know that the polychlorinated llphenyle were never promoted aa componanta In poatlclde formulations for wide-spread dispersion on crops, orchards, eto. The fact la that tha U. S. Department of Agriculture developed recom mendations for the possible us* of the waxy type Aroelora In ptstlclda formulations for painting Interior surfaces. The USDA date indicated that hard surfaces (painted or aetalllo) sprayed with lindane or benxene hexachlorlde containing Aroclor 5460--a 60% chlorinated terphenyl, not PCB-- remained toxlo to riles, ants, roaches and sllvsr flah for as long us thrse months oomparsd to on* HONS 090752 Prof. 0. Prod Ln Ootobsr 23. 1970 Pag* Too woek'e offeotlvenese for formulations of tha peatlolda without Aroelor 5b60. Tha waxy Aroolora. 125A and 1260. may also hays andad up ln son# similar formulation*. In any ossa tha amounts ussd wars Insignificant, wa think, ln tarns of any throat to contamination or natural watars. 2. In tha saoond paragraph on page two, witter Haig's publication ln tha JAMA is mentioned. Correspondence with the author following publication confirmed tha fact that the chioraone was of such a mild nature that oven trained dermatologists would probably have missed tha evidence of the chloraone. To our knowledge, thore have been no publlahed reporta of any chloracne episode since 1952. The question can be ralaed then aa to whether the chloracne problem la of any real significance. 3. The third paragraph on page two refers to the chronic studies currently ln progress. The first sentence Implies that the two-year studies are complete. Secondly, there maybe a trend to convert completely to the metrlo system which would warrant unlta suoh as "mlcrograms per gram". I believe, however, that tha practice ln reporting doees fed to animals ln chronic studies generally la to use a "parts per million" referenoe. Perhaps this Is due to the fact that acute doeee are usually expressed ln terms of "milligram per kilogram of body weight' of the test animal. This latter point I would leave to the Judgement of Era. Stoklngor and Culandr*. Similarly, a comparison of t>xlclty of that of DPT should rest with them. 1 would add that as recently aa last month at a moating with Oarth Fltzhugh, he expreaaed the opinion that the Aroclora are much less toxic than DDT". There la no question that the comparison varies depending on what opeclea of mammals, birds, fish or possibly lnaacta one la using to make a comparison. Obviously, whether one la talking about acute or chronic toxicity la relevant. Our own opinion at Monsanto la that the general statement that PCB'a are no more end probably ioaa toxic than DDT can be supported. MONS 090753 Prof. 0. Fred Lee October 23* 1970 Page Three At the present tine, we do not think that a drinking water standard Tor the PCB'a showing up In the envir onment should be lower than that for DOT, X apologize for the delays Involved In answerlr^ your request for information and comments. Sincerely, Elmer P. Wheeler Manager, Environmental Health iiPW: Ju c.c. Dr. Joseph C. Calonilrs Dr. Donald I. Mount Mr. William it. Pspogeorge Dr. Itarbort E. Stoklnger HONS 090754