Document NepG47gYdnKXrNZQa3KNnvngw

February 23, 1973 Mr. Wilbur H. speloher Administrator, Industrial Hygiene Meetinghouse lleotrle Corporation 700 Braddoek Avenue Salt Pittsburgh, Pennsylvania Dear Wilburi . Jaok Oarrett and 1 have dlsouaaad his conversation with you ~ sometime ago concerning tha toxlolty of ohlorlnatad naphthalanaa. I thought I would confirm his oameenta to you. by this lattar. Monsanto has not had any experienco in tha memifaoture or usa of ohlorlnatad naphthalanas. our avaluation of thalr toxlolty eharaotorlstlos than la basad on numerous ravlaws of tha litaratura and frost lnvolvasMnt from time to tlaa in lnsldants whara tha ohlorlnatad blphanyla wara suspaotad of causing Industrial or anvlroisaantal problaaa, and whara subsequently, tha ohlorlnatad naphthalanaa wara found to ba tha oulprlts. I hava aneloaad Xarox eoplas of tha dlsauaalon In Patty's textbook on tha ohlorlnatad naphthalanaa. I bollava this is a good ravlaw of tha lltaratura and an objaotlva avaluation of haaards aaaoalatad with thoaa oosvounda. Obviously, this dlsousslon ralataa principally to tha Industrial hyglana aspaots of tha haaards and toxlolty. Z hava also anolossd a oopy of tha united Stataa Department of Agrlaultura Naso distributed in 1953, discussing an Incident whara tha ohlorlnatad naphthalanaa wara provan to ba a distinct anvlroraaantal problem whloh I have been told eost tha aanufaoturar of tha product oontainlng tha ohlorlnatad naphthalanaa several million# of dollars. I an sura you arc aware that the chlorinated hydrocarbons or askerel type fluids are under continuing surveillance and study by a mmber of U. S. aganoles, including tha Pood and Drug Adadnlatratlon, tha Council of Knvlronmental Quality, tha Office of Science and Technology of tha President, the National Bureau MQNS 092757 Wilbur H. Speicher 2 February 23, 1973 of Standards and several sub-agencleB of the Environmental Protection Agency. It Is no secret that a number of Indivi duals within these agencies have proposed a complete ban on the use of PCBs, including the use In transformers and capa citors. Continued use of these applications is currently allowed under restrictions based primarily on action by Monsanto to prove that the current quality PCBs manufactured in the United States could be UBed, with appropriate precautions, without serious industrial hazards and with complete protection of the environment. I can think of no other action at this time which would Intensify the efforts of a number of government agencies to effect a complete ban on the manufacture and use of askarel fluids than to change their composition by Introducing other chlorinated hydrocarbons with questionable concurrent Increase In hazards In the working environment or to our eco-system.- You are probably aware that the most Important data which has lead the government agencies to permit the continued but restricted use of polychlorinated biphenyls are the extensive animal toxicity studies which we have completed in the last two years. These Included two-year feeding studies In rats and dogs; a three-generation rat reproduction study; possible effects on poultry relating to egg production, hatchabllity and egg shell thickness; teratology and mutagenatlc studies. Along with these feeding studies have been tissue residue analysis and a major effort on developing biodegradation data. As a matter of interest, the cost of these studies to Monsanto has been something more than a half million dollars. I am certain that government agencies ( and many of the public environmental protection groups) would rightfully question a change In the askarel fluids which would Introduce the chlori nated naphthalenes. I can hot find published data indicating the possible chronic effects of chlorinated naphthalenes - If It contaminates food or feed products or Its possible effect If accidentally released to the environment. As a matter of fact, the published literature on the potential industrial hazards from Inhalation Is not as complete or current as It should be by today's standards. I know that for many years, you and your associates have established a system within your company of recommending necessary precautions In handling any materials purchased by you. The Medical Department of Monsanto has a similar program. In addition, we are In the position of essentially "banning" the production or use of any chemical where we' think the hazards or riBks make that step desirable or necessary. With the data presently at hand, we would not permit the manufacture or use of chlorinated naphthalenes intentionally nor as a significant component or by-product of any product within our company. *ONS 0 9 2 7 5 a Wilbur Bp*loh*r -3- February 83, 1973 1 don't bailor* I'r* talked to you alnoo th* last Mating or th* AZHA, ao Mjr Z tak* this opportunity to ooogratulat* you on being eleoted to honorary Maberdlp. Beat peraonal regarda. Sincerely, Ktv/alb Xncloaure SlMr P. Wheeler Manager, HnvlrooMital Health bo: P. B. Benlgnua - B2SC T. L. Ooaaage B2SL C. Paton - B2SC MONS 09i759