Document QkG61m2ZzMy9n5K0VOq3Bn9XL

Mbnsanto C. Paton - St. Louis - B2SC SWMtT July 3 1973 OECD/PCBs " W. B. Papageorge - B2NA JHN memo of June 5 . TO : T.L. Oossage B2SL My comments are: 1. Amounts of PCBa (a) I am in general agreement with John that we disclose for Newport and Sauget the amount of PCB manufactured toy PCB type Pnxd3e3_ our competition does the same. (H*- (.X would put sold rather than manufactureit).--T~"have not seen evidence that competition so far has disclosed this data In such detail. Our competition only have one plant each. It would he valuable competitive Infor mation for them to know how we continue to split our production. Can we consolidate the production from 7 both plants? ~ (b) I am also In agreement with John that w shouid-not / AS& disclose exports by country but rather give an oecd | total and a non-OECD total. I think U.K. and U.S. authorities would buy this, but will individual OECD countries? MOCAN has given the Canadian government our sales In Canada by FCB type for OECD use. I suspect Australia will soon seek the same information. I think we will be under pressure to divulge OECD data on a country by country basis, but I suggest we do not break trK f out the origin of the product. For non-OECD countTINS )! ' ___ __"_______________ would he \the total of Newport and Sauget exports to those countries. (C^f I disagree with John on divulging ammmtB cnmnimed. We have no real way of knowing what Is consumed in any-given time period by our customers. We can come close to what any customer used for capacitors and transformers but we cannot be certain If he put Aroclor 1254 into a capa citor or a transformer for example. (Itel in Brazil Is a real example.) Also, do we want competition to know what the ongoing capacitor/transformer break-down is. In view of capacitor fluid competition. (d)l|I agree with John that Imports and Incineration matters (TK 11 are for the gosenuuenl to get eisewnere. IN 10 C V. ('?> HONS 029393 -2- 2. PCB Replacements I& I agree with John. I think we should keep our Input on replacements aa brief as possible.-------------------------------3. Disposal of Surplus PCBs by Incineration This Is not a matter for Monsanto or other PCB producers alone. Other comments are: (a) Statistics will be sought at the beginning of 1974, 1975 *nd 1976. Will these be statistics for the previous year and/or an estimate for that year? This needs clarification. (b) Dlchloroblphenyls , 1 understand that the Swiss are prepared to allow dlchloroblphenyls for any use. Is this official OECD policy? Was this a move sponsored by Progil to corner a market in dielectrics and other discontinued uses? Or was the Swiss decision based on long-term feeding studies, toxicity, biodegradation, etc.? I doubt If dlchloroblphenyls can be made free from any tri- and higher homologs - so have the Swiss set a specification for dichlorobiphenyl composition? In view of MICC/Dow discussions Buch a move by the Swiss would be welcomed. On the other hand. It could be used by competitors as a loop-hole to reactivate discontinued uses. How would 1 corporate Monsanto view such amove? In other words, I should we be discussing the ramifications of the Swiss Amove with our UK/US OECD contacts? Intermediates ^^ It Is In our Interest to getAPCB as sin Intermediate "blessed" by OSCE, this would cover monochlorooipnenyi ror Dow but could, of course, lead Bayer to use that route to phenyl phenols (Dow, I understand, may try to shut Bayer down on phenyl phenols which is to our advantage). On the other hand, DuPont is presumably still Importing decachlorobiphenyl from Caffaro for polymer production. This is business we would like to get If It Is sizable. 5. Heat Transfer Fluids/Mining Fluids In view of the furor in the U.K. over PCBs In Maendy quarry, the retention by OECD of PCBs In heat transfer and mining fluids Is too much of a loop-hole, I believe. In particular, the ,,ONS 029394 -3- heat transfer exemption Is a wide one; paper packaging, resins, and coatings are presumably OK for PCB use (see Jtege 5 of OCED Appendix) but what of Indirect food contamination? 6, Uniform labelllng/Contalners, Etc. I think Monsanto should take the lead here so that the labels, drums, containers, etc. we have gone to In U.K. and U.S. should become the Industry standards. 7. Non-OECD Countries Progll Is still selling PCB in Argentina for carbonless paper production on the grounds that non-OECD countries are not con cerned with the PCB problem. I personally think this Is short <; an inridant miiid annn change the climate and Jeo-^* partjlze the dielectric^Industry>rastrjLg^_af~dbuTps on~the question as to why OECD countries need'non-OECD*statistics. i> 8. Samples I note no mention of whether or not the U.K. authorities have accepted Monsanto's policy on PCB 'samples' to companies who wanted to use PCB for testing components. O&D . C. paton HONS 029395