Document QJXR0deRbbR91weL0yob09mGR

>*< V.'. H. Richard - Research Center tufiioh nil 1 ><{ nci TO : March 6, 1969 AROCliOIi WILDLIFE ACCUSATIONS E. V.'noelcr - EVJHEK * _'' il. Bergen J. Sprin^ate VI. Schalk D. Olson H. Kelly J. Garrett P. Hodges P. Park R.. Keller E. Tucker RBilRG JSt'ixZ WSCHA DOLSO RKELT, JOARR PKODO PPARK JFQ JPQ Hisebrough in a recent paper "Nature", Vol . 220, Deo. l'l, 1958, has, attacked chlorinated biphenyls in three ways: (3) 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 tilings to come. As outlined in Science,Vol. 163, Pg. Environmental Defense Fund (ED?) 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, plant 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 Water Quality Standards Branch, DDf would fit the definition of a pollutant upon a showing that it is harmful to aquatic, life. Those 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 "enzyme ^.inducer]' activity is the real threat of DM' and PCB's and are using 7 tfieVe'arguments to prove that very Small amounts of chlorinated ;. . ,*> hydrocarbons arc "harmful". Monsanto is preparing to challenge certain aspects of this problem but wo are not prepared to defend against all of the accusations. (a) Monsanto is preparing itself to identify trace ppfc quantities of chlorinated biphenyls in water camples, in concentrated collected air samples, and in animal tissues, ',/e will knew whether v:e have been falsely identified end accused or net. We will eventually know where any pollution is taking place and the extent of the pollution. HONS 096509 E. Wheeler -2- March 6, 19C>9 (b) We are not prepared to defend ourselves against the accusa 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 Bio-Test program we are to establish the long term allowable limits of chlorinated biphenyls for certain blrds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyl Wo may be able to ane-vier reproductive ability in some animals DCT 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 tho mechanisms listed In (b) even though vie might establish safe operating limits for humans and certain animals. Where does this leave us? I'nrier 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't. Wc will probably wind up sharing the blame in the ppm to ppb con centration level. Wc can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, vie can continue to set up disposal and reclaim operation We ci"' work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users. But, vie 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 ECR paper. In these appli cations exposure to consumers is greater and the disposal problem bccoincis 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. Rlsebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there Is no 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 Rlsebrough1s paper in "Nature", Doc. 1923 has just been published, it is timely, perhaps imperative that tills 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 Rlsebrough. Wall prepared discussions with Ind. Bio-Test, Monsanto bioc'norilsts, the medical and legal departments must take place now. The HONS 096510 E. Wheeler -3- March 6, .1962 poiijtion of DDT manufacturers should be determined as a guide. Wo are being accused of the same things attributed to DOT. I have written this memo to clarify some of the Issues. May 1 please have comments. Thanks, ms Att. W. R. Richard MQNS 096511