Document NeNdqb45QgbnwB148JKXJwg18

\ .1 " % i I M rt *MJICT k ;* TO : . K. Richard - F csearch Censer March 6, 1S9 ARCCLOr. 'ILELirE ACCUSATIONS E. Wheeler - EVJKEZ *. H . Eorgen J. Scringate V. Sehtli: E. Olson R. Kelly J. Garrett * m Hodges ?. Park a. Keller ` E. Tucker E3EEG JSrKl USCMA EOLSO RXZL1 JGASS PHOTO PPARIv JrQ, Jr Q Risebrcugh in a recent paper "Nature", Val. 220, Esc. l'i, 15 attached 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 enzyr.es which degrade steroids upsetting Ca aetabcli'sm lead ing to reproductive weakness, presumably through thinner egg shells. (3) a toxic substance endangering nan himself; implying that the peregrine falcon is a leading indicator of things to cone. As outlined in Science ,Vol. 153* ?g. Environmental Psfens* Fun: (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 acut; or chromic (injury) to animal, plant or aquatic life'*. Wisconsin is one cf 7 states which now nave federally approved ter quality standards. According to Bern Wright, acting chief cf the Federal Water Pollution Control Administration's Water Quality Standards Branch, DE/T would fit the definition of a pollutant upon a showing that it is hai-.nful 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. Eagles', plant" life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim henzyme inducer" activity Is the real threat of ECT and PCB's and are using 7 these arguments to prove that very small amounts of chlorinated ? ? hydrocarbons are. "harmful". Monsanto is preparing to challenge certain aspect* of this problem but we arc not prepared to defend against all of the accusations. (a) Monsanto is preparing itself to identify trace ppb quantities of chlorinated fcipheryls in water samples, in concentrated collected air samples, end 3n animal tissues. Ve will knew whether ;:e have been faltsly identified and accused or net. .'We will eventually know where any pollution is taking place and the extent of the pollution. PLEAXINHTIBIFITF'S PL[AEXINHTIBIFITF1'S111 A\ PLAINTIFF'S EXHIBIT i-.-V-A3-.5L- m i2l 28 "3 ^ -j ftON 0 1 2 5 E. V.'hceler ,2- - Kareh 6 269 (b) We are not prepared to defend ourselves against the e.ccusa-. tions 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 made. Whether we can defend this route or not needs further discussion. (c) Through the Industrial 3io-Test program we are to establish the long terra allowable limits of chlorinated biphenyls fer 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 acme animals. DOT has been under attack for sene 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 safe operating limits for humans and certain' animals. Where doss this leave U3? 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 DOT and ?CB*s. We will probably wind up sharing the blame in the ppn to ppb con centration level. We can take steps to minimize pollution fren our own chlorinated biphenyl plants, v:e can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. We ca" v ?tv fr minimum exposure ?.n'm*nufacture and disposal of capacitors, transformers and heat transfer systems, and'minimize lo'sses 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 r.s cutting oils, adhesives, plastics and KCR paper. In these appli cations exposure to consumers is greater end 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. Risetrough has taken known Aroclor samples and elain3 to have evidence of enzyme and hormone change. Here there is no question of identificacin. Either his position is attacked and diccour.ced or we will eventually have to withdraw produet from end uses which . have exposure problems. Since Kisobrough1f paper in "Natura'*, Dec. 1563 has just been published, it ic timely, perhaps imperativa, th~.t this paper and its implications be discussed with certain customers. This is a rough one because it could mean less of business or. crpt/ and false claims by ?.isotrough. V.'cil prepared discussions with Inc. Bio-Test, rtonsanto biochemists, the medical end leg?.' departments must take place new. The MON 0126 ti i b G O 7 " A Z. \fhecler 3- - Karch 6, 195; aposition of DEfT manufacturers should be determined as guide. We are being accused of the sane things attributed to LOT. I have written this nemo to clarify some of the laaues. Kay I please have comments. Thanks* .. 'ns Att. W. R. Richard W r\ AC ... . _MON. 0127 h nfjVM