Document QX898L9w2eZmq3kV66Zn21Bav

DRAFT - 6/11/73 - VBP 1. How many board feet of lumber are treated with Penta in the U.S, each year? The lateat available flgurea relate to Penta treat ment during 1971. Product Utility Poles Croaaarms Fence Poet Piling Lumber Cubic Ft. 56.788.000 7,602,000 12.596.000 1,399,500 On Board Ft. 215,392,100 % of Total ** 25% 2. What la the expected lnoreaae In coat to produce "clean" Penta? The lnoreaae In coat to produce a olean Penta la eatlmated at about 4l/lb., repreaentlng an increaae of 25-30%. A algnlfleant Item which la difficult to eetlmate at thia time la the coat of handling and dlapoalng of the concentrated dioxin realdue. Ideally, dlspoaal ahould be accompllahed l?y high temperature incineration. Commercial unite capa ble of achieving the proper incineration conditione for the diapoaal of aolid waatea of thla type are not now available. 3. What la the dioxin content of the current Penta and what la the projected dioxin content of the "clean" Penta? Monsanto analyeea of aamplea of currently avail able Pentachlorophenol ehow the following chlori nated dlbenzo dioxin contents Tetrachlorodlbenzo-p-dioxln Hexachlorodlbenzo-p-dloxln Heptachlorodlbeneo-p-dioxin Ootachlorodibenzo-p-dioxin 0.2 ppm 25-65 ppm 300-500 ppm 2500-5000 ppm The projected chlorinated dlbenzo dioxin content of the modified Pentachlorophenol la aa followat Tetrachlorodlbenzo-p-dioxln Hexachlorodlbenzo-p-dloxin Heptachlorodlbenzo-p-dioxln Octachlorodibenzo-p-dioxln Non-detectable < 1 ppm < 1 ppm 1-2 ppm MONS 200018 2 A. How much capital does Monsanto have Invested In ltB penta facilities! . Monsanto's gross Investment In Pentachlorophenol facilities la approximately $5 million. 5. What can we aay about the safety aepeote of current Penta? How doea It compare to the proposed new product? There have been hundreds of millions of board feet of Penta-treated wood produced In the U.S. during the years that Monsanto has participated in this market. The manufacturer of the treatment chemicals, the wood treating Industry Itself, and the ultimate users have developed an amaslng record when one considers the hazardous properties of treatment chemicals, of which Penta la one. Our records indicate that the problems we have faced In the manufacture of Penta and the reported problems of our customers have been largely through acci dental exposure or accidental dlacharge. In all such cases the effects produced would have been tha same whether the product used had been current commercial grade or proposed "purer" grades, since these problems were principally the result of the Inherent toxicity of Penta Itself. Prom time to time there have been reported cases of chloracne In workers exposed to current commer cial Penta. In the vast majority of these oases the problem occurred In a Penta producer's plant and the Incident was traceable to a specific opera tional upset. It la possible that the proposed "purer" grades may not pose this problem. It la absolutely certain that very careful operation of current producing plants can eliminate this pro blem. If the chloracnegenlc potential of Penta la due to contaminants In the commercial grade products and la, aa Is claimed, removable through some mechanism of contaminant concentration, then this potential . will be seriously magnified In the producing plsnts through handling of concentrated contaminant realdues. It la doubtful, therefore, that the problem of chloracne can be eliminated completely from Penta producer's plants regardlese of what grade of Penta they produce without careful operation. MONS 200019 -3- The wood treating Industry end their customers. In our opinion, will not be seriously affected from s handling hazard standpoint with either grsde of Penta so long as they handle the treatment chemicals with the care they have already exhibited. Or, conversely, poor handling techniques will lead to problems with the workers In a plant regardless of the grads of Penta used because of the Inherent toxicity of Penta Itself. lhe efforts of current Pente producers and enlightened wood treaters have produced an admirable record in this Industry, Xt is our opinion that, regardless of the grade of Penta used, any relaxation of this effort will lead to trouble, Xt Is Indeed unfor tunate that the word "pure" or "purer" has been used In respect to differing grades of Penta since such words tend to lead to a relaxation in safe handling procedures, Xt la, of course, necessary to handle Penta with respect regardless of the grade used. MONS 200020