Document QgDqwLqndJByj4N3jKnDj2m5o

. 4H seiitif TO : R. Richard - Feseerch Center March 6, 1953 AROCLOP. '..'HDLirS ACCUSATIONS E. Wheeler - EWHEE H. Bergen J. Sprln3tt* V/. Schalk D. Olson R. Kelly J. Oarrctt P. Hodges fc.?. Park Keller *Z. Tucker K32R0 JSrnl WSCHA dolso RXEIL JOARR PKODO PPARIC JFQ JFQ Risebrcugh in * recent paper "Nature", Vol. 220,. Bee.' 14, 1J5C, hcs. attacked chlorinated biphenyl* in three Kays: (1) a pollutant - widely spread by air-waterj therefore an un controllable pollutant. (2) a toxic substance - with no permissible allowable levels causing extinction of peregrins falcon by Induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing tc reproductive weakness, presumably through thinner egg shells. (J) a toxic substance endangering nan himself: Implying that the peregrine falcon is a leading Indicator of things to come. As outlined in Science,Vol. 163, Pg. 5^8, 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 atandards art at issue. "A substance shall be regarded as a pollutant if its use results in public health problem* or lr. acute or chromic (injury) to animal, plant or aquatic life". Wisconsin is one of 7 states which now `nave federally approved **ler qualify standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Water Quality Standards Branch, DE/T would fit the definition of a pollutant upon a shewing that it la harmful to aquatic life. These people in ED? are saying wt 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 la the real threat of DDT and PCB's and ara using 7 these argument a to prove that vary small amount* of chlorinated .V hydrocarbon! are. "harmful". Monsanto ia preparing to ehallenga cartain aspects of this problem but we are not prspared to defend against all of tha accusations. and tha extant of the pollution. ** * tt It f>0 003331 T 091772 PLAINTIFF'S EXHIBIT 'YVL)a*' ^ WATER PCB-SD0000042190 E. Wheeler -2- March 6, 3^9 (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 Units of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. Vo may be able to answer reproductive ability in some animals. SET 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 the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where doss this leave us? Under identification and control of exposure we will be able to identify and analyze residues as well or better than anyone in the world. W# will probably find residues other than DDT and PCB's. We win probably wind up sharing the blame in the ppm to ppb con centration level. We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. We ce" wo^k f*r minimum exposure in manufacture end disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulie users. But, we can't easily control hydraulic fluid losses in smill plant:. It will be still moro difficult to control other end uses such r.s cuVeins oils, adhesives, plasties and :::R paper. In these appli cations exposure to consumers Is greater and the disposal problem becomos complex. If chlorinated biphenyl la shown to have some long term enzyme or hormone activity in the ppa range, the appli cations with consumer exposure would eouse difficulty. Xlsebrough has taken known Aroelor samples and elalms to have evldcnee of enxyae and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw produet from and usos whieh have exposure problems. Sine* Rleebrough'* paper in "Nature", Esc. 1953 has just been published, it it timely, perhaps imperative, that this paper and its implications be dlseuesed with eerP&m customers. This is a rough ona because it eeuld neon lets of business on ezipty and false elalms by Hlsobrough. Well prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical and legal department* must take piece now. The T 091773 f>0003392 5 0078" WATER PCB-SD0000042191 Z. Wheeler 3 March 6, 1955 position of DDT manufacturers should be determined as a guide. V/e are being accused of the sane things attributed to DDT, I ha"e written this nemo to clarify some of the Issues. Kay 1 pleats have cocments. Thanks, as Att. W. R, Richard 0003393 T 091T74 5 00'/ y ' WATER PCB-SD0000042192