Document Ry2ZjKkKr8z7xvDQpg0vrEpa

1 STATE OF MICHIGAN 2 IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE 3 HOWARD HENDERSON and MATTIE HENDERSON, 4 Plaintiffs, 5 No. 83-330644 NP 6 JOSEPH .WRIGHT and MATTIE RUTH WRIGHT, 7 Plaintiffs, 8 No. 84-424230 NP (By Consolidation) 9 CHARLES D. WISE and ANN ELIZABETH WISE, 10 oi txoiii4u--ii xi ic 11 No. 84-424231 NP <By Consolidation) 12 IRA DAVIS and BERTHA DAVIS, 13 Plaintiffs, 14 ROBERT NICHOLS and 15 CAROLYN NICHOLS, 16 Plaintiffs, . 17 --v- 18 MONSANTQ COMPANY, a corporation, 19 DETROIT EDISON COMPANY, a corporation, TRANSFORMER INSPECTION 20 RETROFILL CORPORATION, and GENERAL ELECTRIC COMPANY, jointly and 21 severally,. No. 84-424232 NP (By Consolidation) No. 84-427471 NP (By Consolidation) 22 Defendants. / 23 24 THE DEPOSITION OF WILLIAM B. PAPAGEORGE 25 reported on Wednesday, May 27, 1987, at 216 North Meramec, Clayton, Missouri at or about 10:50 a.m. WATER PCB-SD0000058766 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 REPORTED BY: 25 APPEARANCES JAMES D. LEDBETTER, ESQ. 26555 Evergreen Road, 18th Floor Southfield, MI 43076 On behalf of the Plaintiffs. JOHN E.S. SCOTT, ESQ. RICHARD L. CARETTI, ESQ. 800 First National Building Detroit, MI 48226 On behalf of Monsanto Company. WILLIAM DECKER, JR., ESQ. 755 W. Big Beaver Road, Ste. 1800 Troy, MI 48084 On behalf of Transformer Inspection Retrofill Corporation. RICHARD A. DIN0N, ESQ. 900 Marquette Building Detroit, MI 48226 On behalf of General Electric Company. STANLEY R. MIKICIUK, ESQ. 30600 Telegraph Road, Ste. 3250 Birmingham, MI 48010 Dn behalf of Transformer Inspection Retrofill Corporation. LORI B. RESNICK, CSMR-3236 ****** WATER PCB-SD0000058767 1 2 WITNESS: INDEX 3 WILLIAM B. PAPAGEORGE 4 Examination by Mr. Ledbetter 5 Examination by Mr. Decker 6 EXHIBITS: 7 Deposition Exhibit 1 8 Deposition Exhibit 2 9 Deposition Exhibits 3 & 4 10 Deposition Exhibit 5 11 Deposition Exhibits 6 & 7 12 Deposition Exhibit 8 13 Deposition Exhibit 9 14 Deposition Exhibit 10 15 16 17 18 19 20 21 22 23 24 3 Page 4 222 82 83 90 92 134 141 156 220 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NortItwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058768 1 Clayton, Missouri 2 Wednesday, May 27, 1987 3 (At about 10:50 a.m.) 4 WILLIAM B. PAPAGEORGE 5 having been sworn to tell the truth, the whole 6 truth and nothing but the truth, was examined and 7 testified upon his oath as follows: 8, MR. LEDBETTER: Let the record 9 reflect that this deposition is being taken 10 pursuant to notice to all parties and will be used 11 for all purposes applicable under the Michigan 12 Court Rules. 13 EXAMINATION 14 BY MR. LEDBETTER: 15 Q Sir, would you state your full name for the 16 record, please? 17 A William B. Papageorge. 18 Q Mr. Papageorge, what's your date of birth? 19 A September 7th, 1922. 20 Q And your current home address? 21 I have a last known one here on 22 your CV on the second page. Is that correct? 23 A That's correct. 24 Q That's 321 Pebble ValleyDrive, St, Louis, 4 C & L REporuiNq CERTified Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058769 1 2A 3Q 4 5 6 7 8 9A 10 Q 11 12 A 13 Q 14 15 16 17 18 A 19 20 Q 21 22 A 23 Q 24 A Missouri, 63141, That's correct, Mr. Papageorge, my name is J.D. Ledbetter. I represent several clients in regard to some allegations of PCB exposure from certain transformers in the Detroit area. I assume you have given depositions before, correct? Yes. So, you're aware of the procedures pretty much overall? Yes. Mr. Papageorge, I've been provided a copy of your CV and I notice the date at the bottom right is 6-8-78. Is that current, other than that date perhaps? There are two additional assignments since that was prepared. Okay. Is that additions to the Monsanto experience? Yes. Okay.And what are those? Startingin 1983, I was a Director of 5 C & L REpomiNq CERiifiEd Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SouThfield, Ml 48054 (515) 827-8589 WATER PCB-SD0000058770 1 Environmental Operations for Monsanto Industrial 2 Chemicals Company. 3Q Okay. And how long did you remain in that 4 position? 1983 to what? 5A That terminated in December, 1985. 6Q Okay. And then the next correction? 7 MR. SCOTT: Addition. 8, MR. LEDBETTER: Addition, 9 correction, deletion. 10 THE WITNESS: The next assignment 11 was manager of Occupational Health for Monsanto 12 Chemical Company in the calendar year 1986. 13 BY MR. LEDBETTER: 14 Q Okay. Very well. Let me develop some of these a 15 little bit more. 16 17 A What is your current occupation? I'm self-employed. 18 Q Doing what? 19 A Consulting. 20 Q What type of consulting do you do? 21 A Matters relating to PCBs. 22 Q Do you have a company name? 23 A No. 24 Q Just in your own capacity;William Papageorge? 6 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHHeU, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058771 1A 2Q 3A 4Q 5 6A 7Q 8 9A 10 Q 11 12 13 14 A 15 16 17 18 19 20 21 Q 22 23 A 24 Q Correct. And you've been doing that since end of '86? Yes. Were you doing any consulting prior to the end of the calendar year 1986? No. Okay. So, we're talkingbasically five months or so that you've beendoing consulting business? Yes. You indicated that the type of consulting you do is relating to PCB matters. . Is it all matters concerning PCBs or is it limited to certain categories? Oh, it's general in nature. It does relate to the manufacture of PCBs, the past uses of PCBs, some of the chemistry of PCBs, some of the industrial hygiene and exposure type information, environmental matters. I believe that covers it. How many files do you currently have ongoing that you're involved with - I'm sorry? -- on a consulting basis? 7 C & L REpcwiNq CERTiFiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058772 1 2A 3Q 4A 5Q 6A 7 8Q 9 10 A 11 Q 12 A 13 Q 14 15 16 A 17 Q 18 A 19 Q 20 A 21 22 23 24 How many files do you currently have? I don't have any files. How many clients do you currently have? One. And who is that client? Smith, Helms, Muscle & Moore (phonetic). They're a a law firm in Greensboro, North Carolina. And is that working for the defendant in the case or working for the plaintiff; if you know? The defendant. Do you know who thedefendant is in that case? Monsanto Company. Okay. And as far as theconsulting business, that's the only file that you've had since -- or the only one you have currently? Correct. Have you had any others in 1987? No. So, just the one? Yes. MR. SCOTT: Counsel, don't let me mislead you. Don't assume that he has one file because he consults with this law firm. I don't 8 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SoutHHeU, Ml 48054 (515) 827-8589 WATER PCB-SD0000058773 1 want you to be misled by that. 2 MR. LEDBETTER: Okay. I 3 understand. 4 BY MR. LEDBETTER: 5Q There's just one matter that you're consulting 6 with, but it could be multiple situations, multiple 7 plaintiffs? 8A Yes. 9Q Okay. Now, in your educational background, I 10 noticed you've got a B.S. in Chemical 11 Engineering from Washington University in 1943. 12 A That's correct. 13 Q What years did you attend Washington University? 14 A 1940 to 1943; 1946 to 1947. 15 Q And both of those sessions resulted in degrees; 16 the first one the B.S. in Chemical Engineering? 17 A Yes. 18 Q And thesecond was an M.S. inChemical 19 Engineering? 20 A Yes. 21 Q Any other formaleducation other than those two? 22 A I took courses with -- at that time it was known as 23 Oklahoma A & M; I believe today it's called Oklahoma 24 State -- with the intent of working toward a 9 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqHwAy SuiTE 508 SouTHfisId, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058774 1 2Q 3 4A 5 6 7Q 8 9A 10 Q 11 A 12 Q 13 14 15 A 16 Q 17 18 19 20 A 21 Q 22 23 24 A doctorate degree. How many hours did you complete at Oklahoma A & M? I don't recall specifically. I think it's somewhere about 12 hours. And you never got to a point of doing a dissertation? No. What years did you attend Oklahoma A & M? That was during the period 1947 to 1951. And, certainly, that time period was not all regular attendance; it had to be sporadic attendance in that four-year period? Correct. Prior to first attending Washington State in 1940, were you working or have any other formal education experience above high school level or was that right out of high school? Out of highschool. And the period that you were at Washington from 1940 to 1943, did you work or just attend school? I worked in a supermarket in the early years, I 10 C & L RspoRTiNq CERTi Fied Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058775 1 2 3 4 5 6 7Q 8 9A 10 Q 11 A 12 Q 13 A 14 15 16 Q 17 A 18 Q 19 A 20 Q 21 A 22 Q 23 A 24 Q have forgotten the exact period of time. Then I was involved with a student aide program at the unversity, where I was paid by the hour for performing duties in the laboratory. I believe it was called the National Youth Administration at that time. Then after 1943, did you begin full-time employment? No. I was in themilitary. What branch? Army. What did you do in the Army? , Well, I started out in anti-aircraft artillery, spent some time with the infantry, and ended up in the Corps of Engineers. How long were you in the Army? Until 1946. Were you discharged honorably at that time? Yes. What was your highest rank? Captain. And in 1946, did you return to school full-time? Yes. And you received your M.S. in *47? 11 C & L REpoRTiNq CERtified Court Reporters 295 5 5 Northwestern HiqhwAy SuIte 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058776 1A 2Q 3A 4Q 5A 6 7Q 8A 9Q 10 A 11 12 13 Q 14 A 15 16 17 18 Q 19 A 20 Q 21 A 22 Q 23 24 A Yes. Did you work anywhere in that time period? No. After 1947, where did you begin work? With the Phillips Petroleum Company in Bartlesville, Oklahoma. Bartlesville? Bartlesville, yes. What did you do with Phillips Petroleum in 1947? I initially worked on problems associated with drilling oil wells and secondary recovery in spent oil fields. What do you mean "secondary recovery in spent?" These are techniques that are used in oil fields that cannot deliver the oil under their own natural means. And we could apply gas, water, or treated waters, to push the water to the surface. How long did you work for Phillips Petroleum? Four years. Till 1951? '51. Did you remain generally in the same job duties and responsibilities in that four-year period? No. The latter assignment involved designing of 12 C & L REpoRTiNq CERTifiEd Court Reporters 2955 5 Northwestern HiqhwAy SuiiE 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058777 1 2Q 3A 4Q 5A 6Q 7 8A 9Q 10 11 A 12 Q 13 A 14 Q 15 A 16 Q 17 A 18 Q 19 A 20 Q 21 A 22 Q 23 24 A refinery equipment. What kind of refinery equipment did you design? Tanks and distallation columns. Is that designing the equipment from scratch? Design from scratch. Did you work around the electrical industry or electrical equipment at that time period? No. Did you have any involvement with PCBs in that time period? No. / Did you ever hear of PCB in that time period? No. Then in 1951, you began working with Monsanto? Yes. In the capacity of chemical engineer? Yes. Where was the J.F. Queeny Plant? It'slocated in St. Louis, Missouri, Is that plantstill inoperation? Yes, Okay. As chemical engineer, what did you do in that time period, '51 through '55? Designing equipment for the manufacture of a 13 C & L REpoRTiNq CERTified Court Reporters 29555 Northwestern HiqHwAy SuiTE 508 SoutHHeW, Ml 48054 (51 5) 827^8589 WATER PCB-SD0000058778 1 chemical. 2Q What chemical was it? 3A Phthalic anhydride, p-h-t-h-a-l-i-c; anhydride, 4 a-n-h-y-d-r-i-d-e. 5Q Can you tell me what that is, roughly, in lay 6 terms? 7 I don't want to know the specific 8 formula. I think I already know more than I 9 need to. 10 MR. SCOTT: Didn't you take 11 chemistry? 12 MR. LEDBETTER: Just a little, 13 but not that much. 14 THE WITNESS: This is a chemical 15 that's used as a raw material in the manufacture 16 of coatings and plastic and plasticizers. 17 BY MR. LEDBETTER: 18 Q Now, as a chemical engineer, you didn't actually 19 work on the chemical itself. You designed the 20 equipment that manufactured the chemical. 21 Is that true? 22 A Designed some of the equipment that was involved 23 in the manufacture of this chemical, yes. 24 Q Okay. Did that job duty remain about the same 14 C & L RepomiNq CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058779 1 2 3A 4Q 5 6A 7 8 9 10 Q 11 12 13 A 14 Q 15 A 16 17 18 19 20 21 22 Q 23 24 A in that specific equipment, and that specific chemical in that four-year period of '51 to '55? Yes. What were the plasticizers used for; the coating plasticizers that you mentioned? We -- I didn't mean to imply that we made coatings and plasticizers. We made the phthalic anhydride that was shipped to customers who in turn made these, Okay. Do you know generally what applications or uses were intended for that particular chemical? Well, I can recall some. Okay. What are those? Paints, for example. Resins, such as those used in Fiberglas boat hulls. Plasticizers are materials added to plastics to make them pliable, soft, so they aren't brittle and breakable. Those are the general uses I recall. Do you recall whether that particular chemical was toxic? All chemicals are toxic. 15 C & L REpoRtiNq CERTifiEd Court Reporters 295 55 NoijtItwestern HiqhwAy 8 SuiTE 508 SouitrfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058780 1Q And it depends on the amount and degree, doesn't 2 it? 3 MR. SCOTT: To what? 4 MR. LEDBETTER: To be toxic. 5 MR. SCOTT: Counsel, I don't 6 understand your question. It's vague. 7 BY MR. LEDBETTER: 8Q Toxicity depends upon the amount of exposure and the 9 degree of exposure? 10 A And the creature exposed. 11 Q Okay. And that's generally an analysis of 12 toxicity, is it not? 13 MR. SCOTT: What's generally an 14 analysis of toxicity? 15 MR. LEDBETTER: My last question", 16 the degree, the amount, the length of exposure 17 and the creature to be exposed, as Mr. Papageorge 18 added. 19 THE WITNESS: Well, I'm a little 20 confused, but I'd like to suggest that the 21 effect has to be described as well, to understand 22 what is meant by toxicity. 23 24 16 C & L REpoRTiNq CEiuifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHHeW, Ml 48054 (515) 827-8589 WATER PCB-SD0000058781 1 BY MR. LEDBETTER: 2Q Okay, What do you mean by the effect? 3A Does it cause death, does it cause incapacities 4 of other kinds? 5 Does it impair functioning of the 6 creature, its ability to reproduce? 7 Many effects are possible. 8Q And the absence of those effects, would that 9 equal no toxicity? 10 A I would prefer to call it no effect. 11 Q Okay. So, in order to be toxic, you're saying 12 that it will have an effect on somebody if we 13 throw in the other factors, too, that we've 14 talked about; the length of exposure, the amount, 15 etcetera? 16 A Yes. 17 Q Okay. Generally speaking -- what was the chemical 18 again; its full name? 19 A Phthalic anhydride. 20 Q How is phthalic anhydride made? 21 A There are two processus that I'm aware of. 22 One is it starts with naphthalene, 23 which is the mothball chemical. And in the 24 presence of a catalyst and oxygen, the 17 C & L REpoRTiNq CERTified Court Reporters 295 55 Northwestern HiqtiWAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058782 1 2 3 4 5 6Q 7A 8Q 9A 10 Q 11 12 A 13 Q 14 A 15 16 17 Q 18 A 19 20 21 22 23 Q 24 naphthalene is converted into phthalic anhydride. The other process involves the use of another starting material, xylene. Under a different catalyst and different conditions, it too can be converted to phthalic anhydride. Does xylene contain PCBs? No. Doesnaphthalene contain PCBs? No. Okay. From the period 1955 forward, you began as production supervisor, also at the Queeny Plant? Yes. And what did you do as a production supervisor? I supervised the activities associated with the manufacture of two types of chemicals, as I recall, at that period of time. What are the two types of chemicals? Well, the initial assignment was involved with the manufacture of plasticizers. The second assignment involved the manufacture of a group of chemicals referred to as chlorinated nitro benzenes, Is there any distinguishing properties of the plasticizer that you manufactured in the *55 to 18 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NortIhwestern Hiqhway Suite 508 SouddiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058783 1 2 3 4A 5 6 7 8 9Q 10 11 A 12 Q 13 14 A 15 16 17 18 19 20 21 22 23 24 Q '56 period and the material that was used for plasticizers in the '51 to '55 period; the phthalic anhydride? The anhydride I referred to that I was involved with in the '51 to '55 period, is a starting material in the manufacture of the plasticizers with which I was involved with in the '55 to '56 period. Okay. So you used that same material then to manufacture the chlorinated nitro benzenes? No. To manufacture the plasticizers, Okay. And what was the plasticizers called? Did they have any particular names or categories? Yes. There were many. I don't claim to recall all of them. There's ethylphthalates, methylphthalate, butylphthalate, octylphthalate. And as I recall, there were combinations of these. And I don't remember specifically, but it's possible to have such a thing as -- I'm not too certain of this, but it is possible to have like ethylbutylphthalate. Instead of dibutyl, it's ethylbutylphthalate, Would that suggest, Mr. Papageorge, that the material 19 C & L RepoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouThfield, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058784 1 2 3A 4Q 5A 6 7 8Q 9 10 A 11 Q 12 A 13 Q 14 A 15 16 17 18 19 20 21 22 23 24 in the manufacturing process is slightly changed to go from ethyl to methyl to octyl? Yes. How is that change made? I don't know quite how to answer. Are you talking about the chemical change or the physical change? The chemical change to start. Then you end up with a physical property, don't you? Yes. Okay. Without getting too technical, I'll try. Okay. I wouldappreciate it. Phthalic anhydride in its makeups offers opportunity for alcohol to attach itself. This is where the ethyl designation comes from; the use of methyl alcohol or the use of butyl alcohol and methyl for methyl alcohol. Each of these alcohols will attach themselves to one of two places available on the phthalic anhydride molecule. As a result, the phthalic anhydride, which starts out as a solid material at room temperature, is converted then to a liquid which is in most cases colorless like 20 C & L REpoRTiNq CERTified Court Reporters 2955 5 NoRThu/ESTERN HiqhwAy SuiTE 508 SouTkfiEld, Ml 48054 (5 1 5) 827'8589 WATER PCB-SD0000058785 1 2 3Q 4A 5 6 7 8Q 9A 10 Q 11 12 13 A 14 15 16 17 18 19 20 21 22 23 24 water and looks an awful lot like a mineral oil, baby oil kind of consistency. Any odor of alcohol? It's not so much the alcohol, but each of the phthalates has its characteristic odor. It is generally perceived by most of us as being a rather pleasant odor, not necessarily obnoxious. Is the odor put in or is it a natural property? It's an inherent property of the material. Do you recall any specific safeguards in handling or utilizing these particular chemicals in their final products, in the manufacturing stage? I recall a few. I don't recall them all. Of course, alcohols are explosive, so you have to worry about the flammability aspects of it. They do have a solvent action on skin. Too much exposure can cause a reddening of the skin because the skin's natural oils are removed. The phthalic anhydride in itself is -- can be corrosive like an acid; therefore, it is not permitted to be on the skin and should not be. 21 C & L Reportinq CERTiMed Court Reporters 295 5 5 NortItwestern HiqhwAy SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058786 1 2 3 4 5 6Q 7A 8 9 10 11 12 Q 13 A 14 Q 15 16 A 17 18 Q 19 A 20 Q 21 22 23 A 24 Q When it is melted, of course, it creates problems for possible thermal burns. It's like having hot candle wax poured on your skin. Other than that, I don't recall any others. Any inhalation problems or potential problems? The inhalation of the fumes, alcohol or the molten phthalic anhydride or even of the hot plasticizer can be a respiratory irritant. And, of course, if it's overdone, it can have symptoms very much like a severe chest cold. It affects the lungs? Yes. Does it have a tendency to build up liquid in the lungs in advanced cases or more extreme exposures? I've never seen one, but I was told by medical people that it's possible -Okay. -- when it's extreme exposures. All right. Is the same thing true, as far as safety precautions and such things, for naphthalene; the same sort of risks? Naphthalene? Generally, yes. Anything distinguishing between the ones that 22 C & L REpoRTiNq CEmi fied Court Reporters 295 5 5 Northwestern HiqhwAy SuiTf 508 SouThfield, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058787 1 2A 3 4 5 6 7 8Q 9 10 A 11 Q 12 A 13 14 15 16 17 Q 18 19 A 20 21 22 23 24 you've just mentioned and naphthalene? Well, naphthalene is not acidic the way phthalic anhydride is, so it would not have the corrosive properties. But it does have the respiratory irritant properties, and also introduces a potential for headaches. Okay. Did you ever learn why it causes headaches? No. How about a problem to the skin, if any? The problem with naphthalene, again, the fine dust can be an irritant. Of course, the molten material can introduce not only the irritant, but also the burns, the thermal effects. And that goes without saying. Even if it were hot water, that would be true, correct? True. Except that these chemicals, many of them do not cool rapidly, so their ability to cause damage because of high temperatures is much more so. MR. SCOTT: Do you have a few naphthalene cases? Is that why you're making 23 C & L REpoRTiNq CERtifiEd Court Reporters 295 5 5 NoRihwESTERM HiqhwAy Suite 508 SouddiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058788 1 this inquiry? 2 Or are you headed in some 3 direction? 4 MR, LEDBETTER: Oh, yes. 5 BY MR. LEDBETTER: 6Q How about xylene? The same safety precautions, 7 roughly, similar to those in naphthalene? 8A Xylene is a liquid at room temperature. 9 In fact, it's an ingredient in 10 many gasoline blends. It, too, can cause the 11 headaches. It can cause lung and respiratory 12 effects at fairly high levels. It has a 13 de-oiling effect on skin. 14 That's all I can remember about 15 xylene. 16 Q In this period of 1951 through 1956, any involvement 17 at all in PCBs? 18 A No. 19 Q Or withPCBs? 20 A No. 21 Q 22 All right. Moving on to the next position, that was 1956 to '57, maintenance supervisor? 23 A Yes. 24 Q What did you do as a maintenance supervisor? 24 C & L REpoRTiiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy 0 SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058789 1A 2 3 4 5Q 6 7A 8Q 9A 10 Q 11 A 12 Q 13 14 A 15 16 17 18 19 20 21 Q 22 23 A 24 Q I was assigned a team of workers. This team was involved in the revision or construction of facilities, new facilities or revisions of existing facilities; the small projects. When you're talking about facilities, are you talking about Monsanto facilities? Monsanto production facilities. This is at the J.F. Queeny Plant? That is correct. Did you do any facilities outside of that plant? No. Okay. What kind of facilities were you involved in in that year period or thereabouts? Oh, for example, the replacement of a small, old pump with a modern, bigger pump; or the replacement of a leaking tank with a new tank; or the addition of a tank into a unit because the tanks there were not adequate to do the job; the replacement of steel pipe with a stainless steel pipe because of corrosion problems. Did you ever get involved in anything with electrical equipment; replacement or revision? Yes; to a limited degree. Anyinvolvement with transformers? 25 C & L REpomiNq CeRTified Court Reporters 2955 5 Northwestern HiqkwAy SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058790 1A 2Q 3 4A 5 6 7 8 9 10 11 12 13 Q 14 15 16 17 A 18 19 20 Q 21 22 23 24 No. What types of electrical equipment did you get involved in? For example, I mentioned the installation of the pump. It would have associated with it an electric motor and it would have its starting devices, whether they were a manual switch or an automatic instrument controlled from some control panel or desk somewhere. That kind of electrical involvement. Okay. And in the time period that we've talked about thus far, '51 through '57 when you were a maintenance supervisor, did you remain within basically the same department at Monsanto? No. Each of these were different departments. I'm assuming we both have the same definition of "department." Okay. In fact, I'll accept your definition of "department" as you knew it at the time; whatever that was. What department were you in as a chemical engineer? 26 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouTkfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058791 1A 2 3Q 4A 5 6Q 7 8A 9Q 10 A 11 Q 12 13 A 14 Q 15 16 A 17 Q 18 A 19 20 Q 21 A 22 Q 23 A 24 Q At that time, it was called the Plant Investigations Group. And then as a production supervisor? It was the Plasticizers Department, which was called Department 23. The terms are synonymous; Department 23 or Plasticizers Department? Yes. But a particular type of plasticizer. Okay. Phthalates plasticizers. Okay. And that was under the Department 23 title? , Correct. Okay. So, there could be Department 24 or 22 maybe; something of that sort? Oh, yes. Okay. There was also a department A-5, the Chloral Nitro Benzene Department. Okay. And that was Department 5? A-5. A-5? A dash 5. Any particular meaning to the letter or number 27 C & L REpomiNq CERTified Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058792 1 2A 3 4 5Q 6 7 8A 9 10 11 12 13 14 15 16 Q 17 18 A 19 Q 20 21 A 22 23 Q 24 designations that you know of? No. It depended on different areas of management and how they wanted to designate new departments as they were erected, Were all of those departments that you've named thus far, were they like part of a larger division at Monsanto at the Queeny plant? Well, the plant was managed by general superintendents who were given specific departments to manage, based generally on types of chemicals, but tempered an awful lot by workload so that the workload for each was about equal. That's the only subdivision that I can think of. Okay. The departments would be assigned to each of the general superintendents? Correct. How many of those were there, if you recall, in that time period? I believe at that time there were three general superintendents of manufacturing. Okay. Did you remain under one general superintendent for all of those positions, or did 28 C & L REpoRTiNq CEmifiEd Court Reporters 295 5 5 NoiuhwESTERN HiqhwAy SuitE 508 SouThtiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058793 1 2A 3Q 4A 5Q 6 7A 8Q 9 10 11 12 A 13 Q 14 15 A 16 17 18 19 Q 20 21 A 22 23 24 Q that change? That was one general superintendent. All right. Do you recall who that fellow was? Mr. McCracken; William McCracken. Okay. After you left as a general supervisor, what was your position? I'm sorry. General supervisor of which? General supervisor of maintenance, I think it was, and then you moved on to another position, I see on the CV here, it's maintenance superintendent? Yes. What were your job duties and responsibilities there as compared to maintenance supervisor? Well, this represented a promotion. All of the maintenance supervisors in the plant reported to me as the superintendent. And you would report to one of the general superintendents? The general superintendent of maintenance and engineering, who was in addition to the three manufacturing superintendents. How many maintenance supervisors were there 29 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SouTHfisld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058794 1 2A 3Q 4 5 6 7A 8Q 9 10 A 11 12 Q 13 14 A 15 16 Q 17 A 18 19 Q 20 A 21 22 23 24 reporting to you at that time period? Five or six, I don't remember exactly. Was the J.F. Queeny Plant in this time period we've covered thus far, '51 through - now we're into maybe the '57 to *59 period - were they involved at all in the manufacture of PCBs? No. Any PCB involvement up through this time period, 1959, that you had even outside of manufacturing? As maintenance superintendent, I had reporting to me, individuals who were involved with PCBs. Was that by department or group or some sort of supervisor? They were involved with the maintenance of systems that contained PCBs. What kind of systems are you referring to? I have in mind heat transfer systems, compressors, and transformers and capacitors. What does heat transfer system mean? This is a system in which a liquid is heated to high temperatures in a remote location using gas flames, open flames. The hot fluid is then pumped into an area which does not permit the use of open 30 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NomhwfSTERiv HiqhwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058795 1 2 3 4 5 6Q 7A 8Q 9 10 11 12 13 14 A 15 16 Q 17 18 19 A 20 Q 21 22 A 23 Q 24 A flames, and the heat in that fluid is used to perform some function. For example, to cook a chemical batch and when the heat is dissipated, the cool liquid is returned back to the furnace to be reheated, and it's continually cycled. Would it be similar to like a radiator? Similar to like a car radiator, yes. In this time period that you had some of these fellows reporting to you that were involved with PCBs, did you have any guidelines or directives of any sort that you referred to, to guide you as to how they should be handled or what should be done around them? The guidelines available were those supplied by the equipment manufacturer. Okay. When we're talking equipment manufacturer, the heat transfer system or the transformer or the capacitor, or whatever the case may be? Or the compressor, yes. Okay. Who were the suppliers that provided that equipment in that period of time, if you recall? I don't pretend to recall all of them, no/ How about the transformers? The transformers, I recall, General Electric as a 31 C & L REpoitthq CERTified Court Reporters 295 55 Northwestern HiqHway Suite 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058796 1 2 3Q 4 5 6 7A 8Q 9 10 11 A 12 Q 13 14 15 16 17 18 19 20 21 22 23 24 supplier, Westinghouse. I'm not certain of the others. So, your PCB involvement, as I understand it in this time period, was that that was contained in systems or components that was provided to you at Monsanto by other outside suppliers? Yes. Do you know who the PCB was made by that went into those components or pieces of equipment that were supplied to Monsanto? It was a Monsanto PCB. Okay. Were you aware of any guidelines or regulations from Monsanto regarding PCBs in that time period? MR. SCOTT: What aspect, counsel? MR. LEDBETTER: Anything to tell them how to handle it or supply it or safety regarding it. MR. SCOTT: As it would pertain to the equipment that he was involved with? MR. LEDBETTER: That's right. MR. SCOTT: All right, THE WITNESS: At that time, no. MR. LEDBETTER: Okay. 32 C & L REpoRTiNq CERiified Court Reporters 295 5 5 Northwestern HiqHwAy SuiTF 508 SoutHI'ieW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058797 1 MR. DECKER: It's been a while since 2 we've had a time indicated. Are you still in '57? 3 MR. LEDBETTER: Yes. We're still 4 in '57 through '59. 5 BY MR. LEDBETTER: 6Q In this period of time, '57 through '59, did you 7 have at your disposal company regulations or 8 directives or that sort of thing to guide you 9 into the handling of the chemicals or 10 precautions regarding chemicals such as PCBs? 11 MR. SCOTT: In what aspect, 12 counsel? 13 Again, are you talking about PCBs 14 that are contained in the transformers? The 15 question is overly broad. 16 MR. LEDBETTER: Just the area 17 that he was involved in in *57 through '59. 18 MR. SCOTT: I thought he just 19 answered that question. 20 MR. LEDBETTER: No. This is 21 regarding documents and regulations. 22 BY MR. LEDBETTER: 23 Q Are you aware of any of those that you had? 24 A Is your question limited to PCB only? 33 C & L REpoRTiNq CERTified Court Reporters 295 55 Northwestern HiqHwAy SuIte 508 SoutHI'ieM, Ml 48054 (5 1 5) 827.8589 WATER PCB-SD0000058798 1Q 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Well, no. I'm looking for where you'd go for the regulatory guidance or directives to tell you as a superintendent at that time, the precautions or safety precautions or handling precautions for the chemicals including PCBs. MR. SCOTT: That are what? That a,re in the machinery that he was maintaining? MR. LEDBETTER: That's right; that he's he's having guys report to him on in '57 through '59. MR. SCOTT: Okay. All right. THE WITNESS: When it came to the types of equipment that we discussed earlier, the transformers, capacitors, compressors, heat transfer systems, we would rely, as I said, on the manufacturer's literature. Considering other chemicals present in the plant, my team of workers would rely very heavily on the manufacturing personnel that used the equipment, for guidance regarding the use of protective equipment; proper decontamination before the maintenance personnel would start work; the permission to enter areas; the permission to use flames as in welding; or 34 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NoRThwfSTERN HiqhwAy Suite 508 SouThfield, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058799 1 2 3 4 5 6Q 7 8 9A 10 Q 11 12 13 A 14 Q 15 16 A 17 18 19 20 21 22 23 24 to disconnect power or connect power. All of that guidance came out of the manufacturing supervision. They, in turn, had available to them documents describing the hazards associated with their equipment and their chemicals, Okay. And the documents that you're referring to would have been primarily at their disposal rather than yours? Correct. And if you had questions of that sort, you would go to manufacturing superivision and ask them for whatever you needed? Thatis correct. Okay. Do you know where those documents were kept at that period of time? Well, there's twotypes, generally. One is the highly-technical document generally referred to as a Standard Manufacturing Process Manual or Document. That would generally be in the supervisor's office. There is another document available which would be referred to as the Standard Operating Instructions or Standard Operating Procedures. These documents were 35 C & L REpoRTiNq CERTifiEcI Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058800 1 2 3 4 5 6 7 8 9 10 Q 11 12 13 14 A 15 Q 16 17 A 18 19 Q 20 21 A 22 Q 23 24 designed for the use of the operating personnel; the people who pushed the buttons and turned the valves and made things happen. They, too, would have sections in them on safety and handling of chemicals and equipment. These copies would be available in the working area, generally in a room referred to as the control room', more or less the center of operations for that particular department. Would the standard operating instructions and procedures apply to you in a maintenance function in this time period that we're talking about; '51 through '59? Certainly. Okay. So, those kind of things are something that you would like to have available to you? They were available to the team involved at that particular time. Okay. Do you recall ever reviewing any documents relating to PCBs in that time period? No. Okay. Then in '59, you changed positions again - and I assume again that's a promotion -- to assistant engineering superintendent? 36 C & L REpoRTiNq CERiifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058801 1A 2Q 3A 4 5 6Q 7 8A 9 10 11 Q 12 13 14 A 15 Q 16 17 A 18 Q 19 A 20 Q 21 A 22 23 24 No, that's a lateral move. What was your job duties then? I supervised a team of engineers who were involved with primarily the design of chemical systems, producing systems. That's kind of what you did back in 1951 through ' 55? That kind of activity. The difference this time is I was responsible for the activities of many as a supervisor. And, again, at that time period, you weren't involved in designing the equipment for the production of PCBs? No. And then in 1961, you became general superintendent of warehouse inventory utilities? Is that a question? Yes. I'm sorry. Yes. What were your job duties then? I was responsible for the receiving of materials of all kinds; the shipping of products, as well as other materials; the operation of the department that distributed electricity, steam 37 C & L REpoRTiNq CERTified Court Reporters 295 55 Northwestern Hiqbwny Suite 508 SoutH field, Ml 48054 (515) 827-8589 WATER PCB-SD0000058802 1 2 3 4 5Q 6 7 8 9A 10 11 12 13 Q 14 A 15 16 17 18 19 20 Q 21 22 23 A 24 Q and air throughout the plant. In other words, anything that wasn't directly associated with manufacture or maintenance was in this group, service group. Okay. Prior to this time, as I understand it, you had been involved under one general superintendent, and now you've got a change where you are a general superintendent? No, I didn't mean to mislead you. When I was in manufacturing, I was reporting to a general superintendent of manufacturing. Okay. When I went into maintenance, I was reporting to a general superintendent of maintenance and engineering. Now I am the general superintendent of this miscellaneous activities group. Okay. So, it's notmanufacturing, it's not engineering; it's now called inventories and utilities or something of that sort? Correct, And you're one of the threesuperintendents that you 38 C & L RepoRTiNq CERTified Court Reporters . 29555 NoRihwESTEnN Hiqhway " SuitE 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058803 1 2A 3 4Q 5A 6 7 8Q 9 10 A 11 Q 12 A 13 14 15 16 17 18 19 20 21 22 23 24 Q had mentioned earlier? No. There's still three manufacturing superintendents. Okay. Very well. And we refer to them as general superintendent of maintenance and engineering and now this is the fifth one. All right. In 1961 through '64, did you have any involvement in that time period with PCBs? Yes. In what way? Two ways. One is as a user of electrical equipment in the electrical distribution activity, which involved the use of capacitors and transformers. Another is in that same unit. The distribution of compressed air involved the use of compressors which used PCB type fluids in them. The second principal use was the use of PCBs in the formulation of industrial hydraulic fluids as part of the warehousing function. Okay. I don't understand what you mean by 39 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfisld, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058804 1 2 3A 4 5 6 7 8 9 10 11 12 13 Q 14 15 16 17 18 A 19 Q 20 21 22 23 A 24 industrial hydraulic fluids being used in a warehouse function. The warehouse function which was under me, and then in turn under a supervisor, one of its activities involved the receiving of different materials; the unloading of these materials in the tanks, the pumping from those tanks into other tanks of several ingredients and blending according to some formula or formulation. That blend would then be sold as an article in commerce. And the blends that had PCBs in them were industrial hydraulic fluids. Okay. The first use that you mentioned was as a user of electrical equipment and the distribution of that equipment. I assume that's at the Monsanto Queeny plant you're talking about? Correct. So, you would be more taking the things in and distributing them somewhere in-house, rather than shipping them out to customers. Is that fair to say? I thought you were talking about distribution of electrical energy. 40 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfield, Ml 48054 (515) 827-8589 WATER PCB-SD0000058805 1Q 2 3A 4Q 5A 6 7 8 9 10 11 12 13 Q 14 A 15 Q 16 17 18 19 A 20 Q 21 22 23 A 24 Q Okay, I was talking about electrical equipment. You were talking about energy? I'm talking about energy; not the equipment. Okay. The equipment is in place and my workers would operate and make sure the equipment is distributing the electrical power that we generated in the plant and we purchased from the local utility company. It was distributed to the plant properly and safely through the transformers and capacitors installed by the maintenance people. All right. And I assume serviced by them, too? Yes. Do you recall any particular precautions in that time period, '61 through '64, regarding the handling, use, repair or disposal of PCB electrical equipment such as transformers? No. Do you recall any labels, warning labels or instruction labels being used on transformers in that time period? No. And then the second use is that of PCBs coming 41 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 NoiukwESTERN Highway Suite 508 SouThfiEid, Mi 48054 (515) 827-8589 WATER PCB-SD0000058806 1 2 3 4 5 6A 7Q 8 9 10 A 11 Q 12 A 13 14 15 16 17 Q 18 19 20 A 21 Q 22 23 A 24 Q in to you at Monsanto, at the Queeny plant in warehousing, and your folks would take it and blend it and turn it into whatever the finished product was, I assume in drums or some such thing, as an industrial hydraulic fluid? Correct. Do you recall any material data sheets or precautions or operating instructions in that regard? Yes, Of what type? They were part of the operating instructions used by the employees to prepare these products. And there was a section which referred to the safety and proper handling of all chemicals that they could have been exposed to. Were there specific parts of that operating instructions manual relating specifically to PCBs? Yes. And then there would be parts, I assume, relating to other chemicals? Yes. Do you recall any generalized types of warnings 42 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqhwsy SuiTE 508 SouThfiEld, Mi 48054 (51 5) 827-8589 WATER PCB-SD0000058807 1 2 3A 4 5 6 7 8 9 10 11 12 13 14 Q 15 16 17 A 18 19 20 Q 21 22 23 24 A or precautions in the operating manual in that particular time period, '61 through '64? Under generalized topics, certainly those materials that were flammable, there would be reference to their flammability and the avoidance of flames and sparks and the like. For those materials that were highly volatile and could cahse fume problems, there were warnings to have proper ventilation, avoid prolonged breathing, and there were references to the use of respiratory protection as appropriate. It depends on the material being handled. Do you recall any generalized instructions or safety precautions pertaining specifically to PCBs in that time period? In a general way, yes. They referred to avoid breathing of the fumes and avoid skin exposures; skin contact. Do you know if the operating instructions or precautions at that time provided any sort of safety equipment or safety devices to be used around PCBs? Certainly, they did list references to gloves 43 C & L Reportinq CERTifiEd Court Reporters 295 5 5 NoRThwESTERN HiqtiWAy Su!te 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058808 1 2Q 3 4 5 6A 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Q 21 22 23 24 and changes of clothing, respirators. Do you have any idea -- you have knowledge of those operating instructions in the *61 to '64 period. Do you have any idea how long they were in place at Monsanto prior to that? This particular -- well, it's difficult to designate exactly how long, because this particular unit was assigned to this particular part of the plant at the time I took over. So, it was a new unit with new instructions, new safety sections and the like. The operations that were consolidated in that unit had occurred at other plants on a smaller scale, with identical kinds of instructions regarding safety and handling. The best that I can recall is that similar instructions on safety and handling probably date to the middle '50's, for these industrial hydraulic fluids. When there are such operations manuals or ` operating instructions - I don't know exactly what the right name is for that document - but is it dated or numbered in some way so you know when its effective date was? 44 C & L RepoRTiiNq CEiuifiEd Court Reporters 295 55 Northwestern Hiqkwny Suite 508 SouihfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058809 It's dated. Do you recall ever seeing any of them concerning PCBs dated back to the mid 1950's. I don't recall specifically, no. Okay. We talked about what were some of the problems with some of the earlier chemicals we talked about. What were some of the similar problems with PCBs, if you recall? I would prefer to call them potential problems. Okay. With PCBs, we were cautioned by our medical experts to avoid breathing the fumes, because they could result in the symptoms I described earlier that resemble severe chest cold, congestion, discomfort, pain in breathing, fluid accumulation in the lungs. We were also cautioned against absorption through the skin, because the material can cause an irritation of the skin, and it can be quite severe depending on length of exposure and amount. And in extreme cases, there had been some evidence that the workers exposed to 45 C & L REpoRTiisq CERTiHed Court Reporters 295 5 5 Northwestern HiqhwAy 0 Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058810 1 2 3Q 4 5A 6Q 7 8 9A 10 11 12 13 14 15 16 17 18 19 20 21 Q 22 23 24 A large amounts for long times were exhibiting a skin condition referred to as chloracne. Any other precautions that you can think of relating to PCBs? No. Do you recall any guidelines being provided as to just how much of the chemical inhalation would be a problem? Yes. I was made aware of a guideline issued by a group of industrial hygienists that referred to the amount of PCBs permissible in the working environment. As I recall, there were two types of PCBs mentioned. They referred to them as Monsanto's trademark Aroclor 1254 and 1242. The Aroclor 1242 was permitted at a little higher level. As I remember, it was a milligram of the PCB for every cubic meter of air. And for the Aroclor 1254, it was a half a milligram per cubic meter of air, The industrial hygienists you referred to, is that AIHA that promulgated that particular standard or suggested guideline? No. I believe this was the government 46 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy 0 SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058811 1 2 3Q 4 5 6 7A 8 9 10 Q 11 12 13 A 14 Q 15 16 17 18 A 19 20 21 Q 22 23 A 24 Q chemists -- government industrial hygienists ACGIH. Do you recall reading anything actually published in that time period by that group or by somebody supporting their suggested limitations? I recall both the ACGIH listing and a pamphlet vfhich I think was sponsored by the American Institute of Industrial Hygienists. And how about the absorption through the skin? Any particular levels involved there or suggested levels? I have never heard of a level. Did the guidelines suggest that you should not be exposed to a lot of it on your skin, or you should not absorb a lot of it through your skin; if either of those? It referred to exposure to undue amounts and the recommendation of wearing protective gloves or washing the soiled clothing and the like. Okay. Was it suggested that you should not have skin contact at all? I have never heard it expressed that way, no. You never heard it expressed in, say, terms of 47 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 NortIhwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058812 1 2A 3 4Q 5A 6Q 7 8 9A 10 Q 11 12 13 14 A 15 Q 16 A 17 Q 18 19 20 A 21 Q 22 A 23 24 Q avoid skin contact? Yes. It was avoid skin contact, not don't have any at all. Okay. Avoid skin contact was their words? Yes. Okay. Did your job duties and responsibility change anytime in that *61 through '64 period as you've already described them to us? No. Do you recall who you were reporting to in that time period? Who was the next step above you as a general superintendent? The plant manager. Do you recall who he was? Yes. Charles Smith. Okay. And after 1964, I see here that you became general superintendent of manufacturing, but at a different plant. Yes. What plant is W.G. Krummrich? That's a Monsanto plant located at Sauget, Illinois, S-a-u-g-e-t. I was tempted to call it Sauget. I guess that's 48 C & L REpoRTiiMq CERtifiEcJ Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouTWiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058813 1 2A 3Q 4 5A 6 7Q 8A 9 10 Q 11 12 A 13 14 Q 15 A 16 17 Q 18 A 19 Q 20 A 21 Q 22 23 24 A not right. Most of us are. It's a French family name. Okay. And what did the Krummrich plant manufacture? Oh, they manufactured several hundred different chemicals. Same as those at the Queeny plant? No. There were a few that were at both, but not many. Would it be part of a different division then, as a plant goes, within Monsanto? No. It was the same division, a different group of products. And what division is that? At that time, it was called the Organic Division. Not specialty fluids yet? Those were a subgroup of the division. A subgroup of the organic chemicals? Yes. Okay. What did you do as a general superintendent of manufacturing at Krummrich plant? I was assigned about a fifth of the activities 49 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058814 1 2 3Q 4 5 6A 7Q 8 9 10 A 11 12 Q 13 A 14 15 16 17 Q 18 19 A 20 Q 21 22 23 24 at the Krummrich plant relating to manufacturing. I assume by that that there's about five general superintendents then of manufacturing, and you're one of the five? Yes. And what area -- if you could, describe generally the nature of the chemicals that you were in charge of manufacturing in that period. I had reporting to me the operation that produced phenol. Phenol? Phenol, P-h-e-n-o-1; chlorinated Phenol; one of the rubber chemicals. My memory fails me. I can't recall the other units at the moment. Was PCBs part of your responsibility in that time period? No. What group was it that was in charge of PCBs, assuming there were PCBs at that particular plant? MR. SCOTT: That's two questions, so why don't you do them one at a time. MR. LEDBETTER: Okay. Let me go to the 50 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy Sure 508 SoutHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058815 1 first one. 2 BY MR. LEDBETTER: 3Q Were PCBs manufactured at the Krummrich plant? 4A Yes. 5Q And what group was it that was responsible for 6 those? 7A It doesn't have a name. It reported to one 8 of the general superintendents of manufacturing. 9Q Do you recall who that fellow was? 10 A Paul Heisler, H-e-i-s-l-e-r. 11 Q And he was a general superintendent like 12 yourself of manufacturing? 13 A Correct. 14 Q In that '64 to '65 period, did you have any 15 involvement with PCBs, although not necessarily 16 17 A 18 Q directly under your authority? No. Do you recall any specific regulations or 19 operating instructions pertaining to the 20 manufacture, handling and safety regarding PCBs 21 at the Krummrich plant? 22 A No. 23 Q 24 Okay. And then it shows here in 1965, you became plant manager at the Anniston plant. 51 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfieid, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058816 1A 2Q 3A 4Q 5A 6 7 8 9 10 11 Q 12 13 A 14 15 16 Q 17 18 19 A 20 Q 21 22 A 23 Q 24 Yes. That was inAlabama, right? Yes. And what was manufactured at the Anniston plant? PCBs; biphenyl; hydrogenated biphenyl; PCTs, polychlorinated terphenyls; paranitro Phenol; chlorine; muriatic acid; sodium Hydroxide or a caustic soda, same thing; and a chemical pesticide or insecticide, methylparathion and ethylparathion. What were your jobduties and responsibilities as the plant manager of the Anniston plant? I suppose you could describe it as I was responsible for everything and anything at the plant. So, you'd have people reporting directly to you, including the superintendents that we talked about earlier? Yes. Was there adivision levelbetweenyourself and the superintendents or a department level? No. There wasn't like an assistant plant manager or something of that sort? 52 C & L RspoRTiNq CERTified Court Reporters 295 55 Northwestern HiqHwAy Suite 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058817 1A 2Q 3 4 5A 6Q 7 8A 9 10 Q 11 12 A 13 14 15 Q 16 17 18 19 A 20 21 22 23 24 Q No. Okay. So, the superintendents over all of the areas including manufacturing, would report directly to you as the plant manager? Yes. Who did you report to at Monsanto, if any particular person? I reported to the Director of Manufacturing of the Organic Chemicals Division. Do you recall who that was in that time period, '65 through '70? There were two of them. Initially, it was Robert Soden, S-o-d-e-n. And he was replaced by Raymond Stratmeyer, S-t-r-a-t-m-e-y-e-r. At the time that you were in the Anniston plant in that five-year period, *65 through *70, do you recall any specific involvement you had with PCBs? Well, I was responsible for the manufacturing unit. I don't know that that involved - was any different than the involvement with all the other units in the plant. Okay. On some sort of a comparison scale if 53 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SoutHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058818 1 it's possible, is there any particular one 2 product that was manufactured more than any 3 other product at the Anniston plant? 4 MR. SCOTT: Do you mean in terms 5 of volume turned out? 6 MR. LEDBETTER: Yes. Volume 7 turned out; total production. 8, THE WITNESS: I, of course, don't 9 recall the exact numbers, but as best I recall, 10 the insecticide volume was about equal to the 11 PCB volume. 12 BY MR. LEDBETTER: 13 Q Were those the two largest you believe at that 14 time period? 15 A Yes. 16 Q Do you recall any specific plant directives or 17 guidelines relating to the handling or safety in 18 the utilization of PCBs or the manufacture of 19 PCBs? 20 A Yes. 21 Q What were those? 22 A These were the documents I referred to earlier, 23 the Standard Manufacturing Process Manual and 24 the Standard Operating Instructions. 54 C & L REpoRTiiNq CERiifiEt) Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SouTlrfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058819 1Q 2 3A 4 5 6 7 8Q 9 10 A 11 12 Q 13 14 15 16 A 17 18 19 20 Q 21 22 23 A 24 Q Is that the correct title, how we can refer to it; Standard Operating Instructions? It varied slightly from time to time and from plant to plant. If it isn't Standard Operating Instructions, it might be referred to as Standard Manufacturing Procedures. But they would be very similar documents, to your understanding; just with different names? Correct. It's colloquially known as either SOPs or SMPs . You told us a little bit about the Standard Manufacturing Process Manual. That's the technical literature on the manufacture of given chemicals, correct? When the word "Process" appears on the title, that is, in essence, the Bible of the process; all the technical data and anything needed to know about the process is in that document. Are there precautionary statements in terms of handling or exposure or potential exposure in that manual? Yes. To the various chemicals? 55 C & L RepoRTiisq CERTiFied Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHfiEld, Ml 48054 (51 5) 827'8589 WATER PCB-SD0000058820 1A 2Q 3 4 5 6A 7Q 8 9 10 11 A 12 13 14 15 Q 16 17 18 A 19 Q 20 21 22 A 23 Q 24 A Yes. Okay. Would those be mocked pretty much in the Standard Operating Instructions or Standard Manufacturing Procedures; similar wording, similar instructions? Yes. Do yourecallif there's onespecific element of PCB that made it particularly toxic or would warrant some specific instructions regarding its handling? I would not call any one element. I would suggest that the message involved the two areas we talked about earlier. This is effect on the respiratory system and the effect on skin. Say, for example, that we were just -- chlorine first is a part of polychlorinated biphenyl, right? Chlorine is part of that formula? Yes. Let's say there were just the chlorine. Would that have an effect on the respiratory system? Oh, yes. And how about the skin? It would affect the skin also. 56 C & L Report^ CERTif'iEd Court Reporters 29555 Northwestern HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058821 1Q 2 3 4 5A 6 7 8 9 10 11 Q 12 13 14 15 A 16 Q 17 18 A 19 Q 20 21 A 22 Q 23 A 24 Q If we left out the chlorine and we just had biphenyl or diphenyl, would either or both of those by themselves affect the respiratory system and the skin? I'm confused by leaving out chlorine. I didn't mean to imply earlier - in my references to chlorine, I was thinking of ohlorine as the gas itself before it's reacted to make PCBs. Does that still fit your question? Okay. I think it still fits the question. Let's say that we haven't gotten to the point yet where the chlorine gas is added to the chemical. Okay. What product do we have at that point, prior to chlorine being added? Biphenyl. Is biphenyl, prior to the chlorine being added, a potential problem to the respiratory system? Yes. By itself? Yes. The fumes would cause particular respiratory 57 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy 0 SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058822 1 2A 3Q 4 5A 6Q 7 8A 9Q 10 11 A 12 Q 13 14 A 15 Q 16 17 A 18 Q 19 20 21 A 22 Q 23 24 A problems if inhaled? Yes. And how about biphenyl on contact with the skin? Would that create a problem? No; unless it's athermal problem. Okay. You mentioned that earlier. If it's hot, then it can certainly burn you? Yes. Other than that, skin contact, to your knowledge, wouldn't be particularly toxic? No. Would the addition of chlorine make the biphenyl more toxic to the respiratory system? It's myunderstanding itwould, yes. Same question as to adding chlorine to biphenyl, and its effect to the skin; dermal effect? Yes. Okay. Perhaps wecanback up a little bit. PCB, as I understand it, stands for polychlorinated biphenyl; is that correct? Biphenyl. Biphenyl. How does that material come to be? What does it start from? How far backshould we go? 58 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqkwAy SuiTE 508 SoutHHeU, MI 48054 (51 5) 827-8589 WATER PCB-SD0000058823 1Q 2 3 4 5 6A 7Q 8A 9 10 11 Q 12 A 13 14 15 16 17 18 19 20 21 22 23 24 Q Well, let's not go back in nature. Let's say we start with a basic raw material that's going to be used to ultimately manufacture PCB. What's that basic raw material? The basic raw materials is biphenyl and chlorine. How do you make biphenyl? The procedure that I'm familiar with starts with benzene, at high temperatures and pressure, to make the biphenyl. Okay. What is benzene? That's a material that's obtained out of crude oil, petroleum fraction, or it can also be obtained out of cold tar distillation. And it consists of carbon and hydrogen. And the chemist graphically shows this when he communicates, as a six-sided hexagon-shaped diagram. Each of the corners of the hexagon represents the location of a carbon. The carbons are associated with each other, and on each carbon, there's a hydrogen. The combination at that configuration is known as benzene. Okay. And then how do we get from benzene to 59 C & L REpoRTiNq CERTified Court Reporters 29 55 5 Northwestern HiqHwAy SuiTF 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058824 1 2A 3 4 5 6 7Q 8A 9Q 10 11 A 12 Q 13 14 A 15 16 17 18 Q 19 20 21 A 22 23 Q 24 diphenyl again? The two benzenes join each other at a point-to-point; carbon-to carbon. So, we now have two benzene rings or hexagons combining to make a double hexagon or a double biphenyl; double phenyl. And hence the "bi"? Correct. Okay. Is that a heating process that it takes to get to that point; to the biphenyl? Yes. Do you recall what kind of temperatures are involved, roughly? Very roughly in the -- about 400 degrees centigrade. I recall the vessels glowing at night. They were red hot. So, it's high. When you start with benzene only, as far as its toxic effect, would it be a respiratory problem; benzene alone? It can be, but it takes fairly high volumes to irritate the respiratory system. It becomes more of an irritant to the respiratory system after you've heated it and 60 C & L RepoRTiNq CERiifiEcf Court Reporters 29555 Northwestern HiqhwAV SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058825 1 2A 3Q 4 5 6A 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 turned it into biphenyl? Yes. Once it is biphenyl, how do we get it from the biphenyl condition to the chlorinated biphenyl position? The biphenyl at room temperature is a solid. It looks very much like white candle wax. So it must be heated before it can be pumped. It's transferred into a tank, and in this tank there is normally a device for introducing chlorine gas. It's called sparging. And in the presence of a catalyst to make the reaction go faster and more efficiently - and this catalyst in this case is iron chloride - chlorine is introduced. It bubbles through the molten biphenyl, the chlorine randomly attaches itself to carbons that are present on the double phenyl group, displacing hydrogen. That displaced hydrogen combines with other chlorine to form hydrochloric gas. So, we have forming in that vessel, roughly three different chemical systems. One is the hydrochloric gas, the other is the PCBs, and the third is the tars, the 61 C & L REpomiNq CERTifj Ed Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SoirrhfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058826 1 2Q 3 4A 5Q 6 7 8A 9Q 10 11 A 12 Q 13 14 15 16 17 18 A 19 20 21 Q 22 23 A 24 Q miscellaneous unwanted residue. Okay. Would the gas be appropriately called a byproduct or a residue? They It kind ofdepends on what you'retrying to make, doesn't it, as to which one you'd call them? True. So, if you're trying to make PCBs, the other two could properly be called a byproduct or residue? Correct. We have now fromthis manufacturingprocess that you've described, we've identified three things that come from it; one is PCBs. But by the name that we've used so far, we've got chlorinated biphenyl. How do we come up with poly? The expression "poly" refers to the fact that there's more than one chlorine associated with each biphenyl. How do you tell the chlorines, how many of them are going to go to each biphenyl? I don't understand the question. You told me that chlorine is bubbled through 62 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqkwAy SuiTE 508 SoutHHeU, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058827 1 2 3A 4Q 5A 6Q 7 8 9 10 A 11 Q 12 13 A 14 Q 15 16 A 17 18 19 20 21 22 23 24 molten biphenyl and you replace the hydrogen with a chlorine. That's correct. It's at random? Correct. When it attaches, the hydrogen is displaced and, hopefully, you end up with more than one chlorine on each one; you would have then polychlorinated, correct? Correct. If you only ended up with one, it wouldn't be poly? Correct. How do you control how many chlorine molecules attach? The industrial PCB that is marketed is a mixture of the 1, 2, 3', 4, all the way up to 10, possible 10 chlorines attached to the biphenyl. In the manufacturing process, we did not control in any way by counting, if you will, the number of chlorines that are attached. By experience, we knew that after a given period of time, we could expect a certain mixture to be 63 C & L RspoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHHeIcI, Ml 48054 (51 5) 827'8589 WATER PCB-SD0000058828 1 2 3 4 5 6 7Q 8 9 10 11 A 12 Q 13 14 A 15 16 Q 17 A 18 19 20 Q 21 22 23 24 created. And we would measure the completeness of that reaction by taking a sample and determining the specific gravity of that liquid. In other words, how heavy a liquid is it with respect to water as the standard. And you have some sort of comparison scale that you evaluate the specific gravity of that product? You expect it to be whatever weight compared to water? Yes. And if you match that weight, then you know what product you have? Yes. The operator would know that he's finished; to turn off the chlorine. What happens if he goes further? He is forced, then, to go into the next type of commercial product; the higher chlorine material. Okay. Again, you said that this next step from biphenyl requires bringing the biphenyl to a molten condition. Do you know what kind of heat is involved there, approximately? 64 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NoRThwESTEnr* Hiqhwny ' SuiTE 508 SouThfiEtd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058829 1A 2 3Q 4 5 6 7 8 9A 10 11 12 13 14 15 16 17 18 19 20 Q 21 A 22 23 24 Approximately -- it's over 100 degrees centigrade. About 150 to 200 degrees centigrade. Okay, I'm still a little bit off to determine through what process we stop at, say, an Aroclor 42 percent chlorine and an Aroclor that's 54 or an Aroclor that's 60. Is that a matter of time and temperature? The temperatures are fixed. It then becomes a matter of time, confirmed by this sampling I mentioned. And when the operator reaches a given specific gravity, he knows that he now has a mixture in his reaction vessel that could give him the product that he set out to make, whether it's Aroclor 1242, or Aroclor 1254 or 1260. At that point, as I indicated, he turns off the chlorine, and he's now ready to proceed to refining this mixture to end up with the product that he set out to make. What further refinement has to be done? There are several steps involved. Initially, air is bubbled through this reaction mass to remove the gas that is still trapped. And by gas, I'm talking about 65 C & L REpoRTiMq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy ' Sure 508 SouThfield, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058830 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 ' 21 22 Q 23 24 the unreacted chlorine and the hydrogen chloride that was formed. The next step is to add something to neutralize the hydrogen chloride that the air wasn't able to displace or sweep out. Monsanto used lime to neutralize. Then the mass was heated to temperatures somewhere in the 300 degrees centigrade range with a slight vacuum pulled on the tank to suck off the vapors. The vapors are drawn up overhead and passed through an air cooler, very much like a car radiator. It's a large, industrial size unit. The vapors are condensed, they're collected in a tank, and that becomes the finished product. When the vapor stops coming off the reaction vessel, the process is finished. And the material still remaining in the pot is the residue or the tarry material that I referred to earlier. Okay. Is there any particular guideline to how much of the -- let me strike that and start over again. 66 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiiE 508 SouThfisld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058831 1 2 3 4A 5 6 7 8 9Q 10 11 A 12 13 14 Q 15 16 17 A 18 19 20 21 22 23 24 In the finished product, is there a test done to see if it's a pure, finished product or if it still has some byproduct in it? The material that is distilled and collected is agitated to get uniformity. A sample is taken and is sent to the control laboratory where the chemist then determines if it meets the specifications for that particular PCB mixture. Were there any tolerances provided that you're aware of? Yes, there were, as I recall, a full page of specifications that it must meet, and there are ranges. The chemical properties -- the lines of the chemical, so to speak, on a graph-like thing? Is that the idea? Well, at that point in time, no. It was primarily a matter of the amount of chlorine, its specific gravity, its color, its dielectric consonant, vapor pressure, I've forgotten all of the features that it must meet. So, this was a combination of chemical and physical properties. 67 C & L REpoRTiiNq CERTifiEd Court Reporters 29555 Northwestern HiqhwAy SuiiE 508 SoutHNeU, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058832 Now, the finished product that we're talking about at this particular time, is PCBs in a specific Aroclor? Correct. So, there can be a lot more different Aroclors, all indicating a different chlorine level? Correct. Do you know if there's any other impurities or byproducts in that, even though you haven't analyzed it to see if it's a certain Aroclor? Is there any way to tell what kind of impurities or byproducts are left in there? Not at that time. Okay. There was no specific test done to determine if there were some byproducts in that final Aroclor product? Correct. From your experience as a chemist, would you expect that there would be certain byproducts in the finished product? Yes. And what would those be? I don't know. 68 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 NoRihwESTERN HiqhwAy SuiTE 508 SouTkfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058833 1Q Would you expect that dibenzo Furans may be part 2 of the byproduct? 3A Possibly. 4Q No others that you can recollect? 5 MR. SCOTT: He said he doesn't know. 6 MR. LEDBETTER: He's not sure or 7 he doesn't know. 8 MR. SCOTT: The answer was: I 9 don't know. 10 Let's not change his answer. 11 BY MR. LEDBETTER: 12 Q Do you recall any analysis done on Aroclor 13 products to determine the existence of 14 byproducts? 15 A At what point in time? 16 Q After the finished product is distilled through 17 condensation, and you've got a finished product. 18 Any time along, in your experience, that an 19 analysis was done to determine the existence of 20 byproducts? 21 MR. SCOTT: You mean as a part 22 of the manufacturing process? 23 MR. LEDBETTER: Yes. 24 THE WITNESS: What year? 69 C & L RspoRTiNq CERTifiEd Court Reporters 295 5 5 NoRThwFSTERt* HiqhwAV SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058834 1 BY MR. LEDBETTER: 2Q '65 through 1970. 3A No. 4Q Do you recall there being something done 5 thereafter? 6A Yes. 7Q What was that? 8A There weresome analytical research studies 9 made - not production and control studies 10 analyses - to determine the presence of the 11 chloro dibenzo Furans in these products. 12 Q Do you recall theresults of thoseanalyses? 13 A The initial results came back to me as non- 14 detectible. 15 Q And later? 16 A I was not involved when further studies were 17 made. 18 But I understand further studies 19 were made. 20 Q Do you recall what the results of those were 21 through the information that you received? 22 A I received informationthat they found low 23 levels using more sophisticated methodologies. 24 Q Just so that we have the terms straight, what is 70 C & L REpoRTiNq CERTifiEtJ Court Reporters 2955 5 Northwestern Highway Suite 508 SoutHHeIcI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058835 1 2 3A 4 5 6 7 8 9 10 11 Q 12 A 13 Q 14 A 15 Q 16 17 A 18 Q 19 20 21 22 A 23 Q 24 the content of, say, Aroclor 1260? What is that made up of? It's made up of a mixture of biphenyls that contain chlorine. And it's predominantly in the five chlorine range, but it does contain two chlorines, three, four, six, some seven chlorine types of PCBs. Altogether, the amount of chlorine present is calculated to be 60 percent by weight of the total weight. And then what is the rest? Diphenyl? It's carbon and hydrogen. Do you recall roughly the percentages of each? No, I don't. But the carbon and hydrogen would make up the remaining 40 percent? Yes. Okay. And then would it be a correct assumption if we were talking Aroclor 1254, that it would be 54 percent chlorine and the remainder of 46 percent being hydrogen andcarbon? Correct. Do you recall of theAroclors, how many of the 1200 series Aroclors there were? 71 . * ... C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy 0 SuiTF 508 SoutHNeIc), Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058836 1A 2Q 3A 4Q 5 6 7A 8 9 10 11 12 Q 13 14 15 A 16 17 18 19 Q 20 21 22 23 24 A Yes. I think I can rundown the list. What were those? 1221, 1232, 1242, 1248, 1254, 1260, and 1268. Now, the only difference in those - if I can say the only difference - is the amount of chlorine in each; is that correct? That's correct. Well, that's a simple way to describe it. They are more complex in terms of the actual chemistry that's present in each mixture. Okay. Meaning thenumber of chlorine molecules attaching to each? Is that fair to say? It's the number and the position. It's not only three chlorines, but where are those three. There are many combinations possible, so they can be complex mixtures. Okay. Does it matter, as far as the eventual product being completed? Say, if it's desired to have Aroclor 1260, does it matter where the chlorine molecules attach and how many? I don't know. 72 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTe 508 SouThfisld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058837 1Q 2A 3 4 5 6Q 7 8A 9Q to A 11 12 13 Q 14 15 16 A 17 Q 18 A 19 20 Q 21 22 23 A 24 It's never been studied, to your knowledge? It could have been studied, but I have not. It is possible to have 60 percent by weight of chlorine and still have the wrong properties. Do you recall if there were other Aroclors other than the 1200 series? Yes. What were those? These were polychlorinatedterphenyls. And there was at least two that I recall that were blends of PCBs and PCTs. Was there any particularAroclors that were used primarily in electrical equipment such as transformers and capacitors? Yes. What were those? The Aroclor 1221,Aroclor1242, Aroclor 1248, Aroclor 1254, Aroclor 1260. In the '65 to '70 period, do you recall what the major use of Aroclors were, if there was a specific category for the majority use? To my recollection, it wasthe dielectric application. 73 C & L REpoiuiNq CERTified Court Reporters 295 5 5 Northwestern Hiqhwny Suite 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058838 1Q 2 3 4A 5 6Q 7 8 9A 10 Q 11 12 13 A 14 Q 15 A 16 Q 17 18 19 A 20 Q 21 22 23 A 24 Q Was there any particular criteria used to determine which type of Aroclor would be placed in which type of electrical equipment? There were criteria, but they were established by the customer. Okay, Whoever was buying the product would require a certain Aroclor to be provided by Monsanto? Correct. Do you remember - My understanding is PCB is synonymous with Aroclor. Is that fair to say? No. Is PCB synonymous with the Aroclor 1200 series? Yes. So, if we move out of that group, where we get to the polychlorinated terphenyls, for example, then we don't have PCBs anymore? That is correct. It's still the same properties, as far as the adverse or potential adverse reactions to PCBs and PCTs? No. How does it change? 74 C & L REpomiNq CERiifiEd Court Reporters 2955 5 Northwestern HiqHwAy SuiTE 508 SoutHHeW, Ml 48054 (5 1 5) 827*8589 WATER PCB-SD0000058839 1 2 3A 4 5 6 7 8 9 .10 11 12 13 14 15 16 17 18 19 20 21 Q 22 A 23 Q 24 We've already talked about PCBs so just talk about PCTs, if you would. The PCTs were solid materials, so the problems or the potential problems with fumes were decreased considerably. If misused, dusting problems could occur, although they did not form dust easily. So, the respiratory caution there was don't breathe dust, as distinguished from don't breathe the fumes. The effect of the dust was similar to other dusty materials in forming irritation, as distinguished from a chemical -- a corrosive-type of effect on the respiratory system. The effect on the skin was not as pronounced or even considered worthy of any special attention. It just did not give the reddening of the skin or the chloracne that the PCBs were known to have the potential for causing. Okay. Are you familiar with the term "Pyranol"? Yes. Does Pyranol suggest a specific Aroclor? C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NomhwFSTERN Hiqhwny SuiTE 508 SomhfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058840 1Q Pyranol could be a number of different 2 Aroclors? 3A Yes. 4Q Is Pyranol containing something more than 5 Aroclor, whatever the blend is? 6A It's possible. 7Q Do you have any personal knowledge as to what is 8 contained in Pyranol? 9 MR. DINON: Objection; 10 foundation as to time. 11 BY MR. LEDBETTER: 12 Q *65 to '70. 13 A Some Pyranols contained chloro benzenes; 14 trichloro or tetrachloro or a blend of the two. 15 Q And they also contained an Aroclor blend? 16 A Yes. 17 Q Do you know how much of which? 18 A I don't recall the recipes. 19 Q Okay. Do you know from early experience or 20 other knowledge attained somehow, what might have 21 been in Pyranols back in the '40's or '50's? 22 A My understanding is that the Pyranols early on 23 were still blends of PCBs with chloro benzenes. 24 Those that were blends. 76 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058841 1Q Are you implying that there were some that were 2 not blends? 3A Yes. 4Q And would that mean some are straight PCBs or 5 straight chloro benzenes or bichloro benzenes? 6A Some Pyranols were straight PCBs. 7Q And "Pyranol," that's the GE trade name? 8A Yes. 9Q Do you know what type of Pyranol was provided to 10 GE in 1941? 11 A No. 12 MR. SCOTT: What type of Pyranol 13 was provided to GE? That's GE's product, isn't it? 14 MR. LEDBETTER: It's GE's trade 15 name. 16 MR. SCOTT: Well, I understand 17 that. 18 Never mind. Go ahead. 19 MR. LEDBETTER: Well, perhaps 20 I can back up and make sure that I understand. 21 iY MR. LEDBETTER: 22 When a customer asks for, say, a 23 certain chemical to be provided by Monsanto, and 24 say it's Aroclor, if it's to be used in a 77 C & L REpontiiNq CERTified Court Reporters 295 55 Northwestern HiqHway SuiTE 508 SoutHHeIcI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058842 1 transformer application, who is it that blends 2 the chemical to be finally put into the piece of 3 electrical equipment, if it's to be used for 4 that purpose? 5 MR. DINON: Objection; 6 foundation. It's vague and overbroad. 7 What time frame are you referring 8 to? What customer, what application? 9 BY MR. LEDBETTER: 10 Q Go ahead and answer over all of those 11 objections, if you can. 12 A My answer to your question is: Monsanto can do 13 the blending and packaging and shipping or the 14 customer may do his own blending. 15 Q If it's a customer that does its own 16 blending, might I assume by that that the 17 customer would just ask you to send a certain 18 amount of Aroclor product to them? 19 MR. DINON: Same objection. 20 THE WITNESS: Yes. 21 BY MR. LEDBETTER: 22 Q Do you recall, in your experience with GE, how 23 it was done for their Pyranols? 24 MR. DINON: Same objection. 78 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouiHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058843 1 2 BY MR. LEDBETTER: THE WITNESS: Both ways. 3Q Do you recall what the term "air blowing" means? 4 Is that synonymous with the air 5 bubbling purification system that you indicated 6 earlier? 7A To me, it would be, yes. 8Q Air blowing? 9A Yes. ' 10 Q Is that a term of art? 11 A Yes. 12 Q Okay. How about HCL? Is thathydrochlorine 13 or hydrochloride? 14 A HCL is the chemical acronym for hydrogen chloride 15 gas, which when dissolved in water, makes 16 hydrochloric acid, commonly known as muriatic 17 acid. 18 Q Now, the Aroclor blend that is the final 19 product, it no longer contains the hydrochloride 20 gas, right? 21 A That is correct. 22 Q Withreheating, wouldhydrochloride gas be 23 created? 24 A At certain critical temperatures, the PCB can 79 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NortNwestern HiqkwAy ' Su'ite 508 SoutWIeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058844 1 2Q 3 4A 5Q 6A 7 8 9Q 10 A 11 Q 12 13 14 A 15 Q 16 17 A 18 19 20 21 22 23 24 degrade, forming hydrogen chloride gas. Is that a method that's used to incinerate PCB now, for example? When PCBs are incinerated, HCL is formed, yes. Any other byproduct, or any other final product? Under the ultimate conditions, the final products include not only the HCL, but H20, which is water, and C02, carbon dioxide. Any other byproduct left after that? No. In the 1965 to 1970 period, do you recall reviewing any specific studies or tests relating to the potential toxicity of PCBs? Yes. Do you recall any of those in detail or by identification? I recall discussions with the plant medical doctor, as well as Monsanto's Corporate Medical Director. The final understanding I had from these discussions - and they occurred on more than one occasion - was the cautioning by both medical professionals to avoid breathing and skin contact. 80 C & L REpoRTiNq CERTifisd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058845 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Q 18 19 20 A 21 22 23 24 And these were based on some studies that I understood had taken place in the '30's, and there were some animal studies repeated in the '50s and '60s, which confirmed that PCBs can cause skin irritation, skin damage. As I understood it, they were able to create a chloracne on some rabbits that were tested; the skin on rabbits that were tested. I was also led to believe that when the PCBs were first manufactured by Swann Chemical Company, the predecessor company to Monsanto's Anniston, Alabama plant, that the operators experienced evidence of chloracne under the conditions that existed at that time, which were difficult to determine exactly. But the belief was that there was undue exposure. Now, the tests that you're referring to done at what was then Swann Chemical Company that was done in the '30s? Yes. There were tests requested by Swann Chemical which I recall were completed for Swann Chemical before Monsanto purchased Swann Chemical, which was in the -- all this happened in the '30s; pretty close to the time that 81 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfitld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058846 1 Monsanto purchased Swann Chemical Company. 2Q 3 4A Okay. As I understand it, that purchase took place in 1935; is that correct? Yes. 5Q Swann had some studies done or at least conducted 6 on their behalf sometime prior to 1935? 7A Correct. 8Q Do you recall any particular names or title of 9 any of those studies? 10 A No, I don't. 11 MR. LEDBETTER: Let's mark this as 12 Number 1. 13 (Whereupon Deposition Exhibit 14 , Number 1 marked by reporter) 15 BY MR. LEDBETTER: 16 Q Mr. Papageorge, let me show you a study that was 17 conducted, I believe in 1936, entitled An 18 Acneform Dermatergosis by Jack Jones and 19 Herbert Alden, and I'll ask if you can identify or 20 if you've seen that study before? 21 MR. SCOTT: I gather you represent 22 that the handwritten margin inter alia and the 23 underlining are not part of the study? 24 MR. LEDBETTER: I would 82 C & L REpoirriNq CERTifiEd Court Reporters 8295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (515) 827'8589 WATER PCB-SD0000058847 1 acknowledge that, yes. 2 MR. SCOTT: Okay. 3 THE WITNESS: I have never seen 4 this document before. 5 BY MR. LEDBETTER: 6Q Sir, was Monsanto involved in the manufacture of 7 PCBs anywhere prior to 1935? 8A No. 9Q Are you aware of any companies that manufactured 10 PCBs other than Swann Chemical, prior to 11 1935? 12 A No. 13 Q So, if it's a PCB operation prior to 1935, would 14 it be a safe assumption that it's Swann Chemical? 15 A No, because I don't know who else might have been 16 making PCBs at the time. 17 Q Okay. Sir, are you aware of a study done by 18 Louis Schwartz on dermatitis from synthetic 19 20 A 21 22 23 resins and waxes? I was aware of some studies involving waxes. I don't recall the names of the authors of that report. (Whereupon Deposition Exhibit Number 2 marked by reporter) 24 83 C & L REpouTiNq CERTifiEd Court Reporters 295 55 NoRThwfsTERS HiqhwAV SuiTF 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058848 MR. LEDBETTER: Let me show you what's been marked as Exhibit Number 2, which is a study conducted by one Louis Schwartz, labeled, I believe, in 1936, and ask if you've seen that particular study? No, I have not. Okay. Again, it's not one that you're familiar vrith in your readings? That is correct. MR. SCOTT: Counsel, can you decipher the writing in the upper right-hand corner, which apparently refers to the journal where this was taken from? MR. LEDBETTER: Archives of Dermatological and - MR. SCOTT: Symposium Archives? MR. LEDBETTER: Archives of Dermatologic, and something like that. MR. DECKER: What's the date of that report, J.D.? MR. LEDBETTER: 1936. MR. SCOTT: Reported at Volume 33, page 1022, Archives of whatever it is. 84 C & L ReportInq CERTifi Ed Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SoutHtiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058849 1 BY MR. LEDBETTER: 2Q Sir, in the time that you were at Monsanto, do 3 you recall having any particular source of studies 4 and such things, independent studies, done by persons 5 evaluating the potential toxic effects of PCBs? 6A Yes. 7 (Whereupon brief pause in proceedings) 8 BY MR, LEDBETTER: gQ The last question I sought was whether in your 10 time at Monsanto, you had reviewed certain studies ii and analyses of PCB or potential toxic effects of 12 PCB. And you said that you had done that sort of 13 thing somewhere at Monsanto, correct? 14 A Yes. 15 Q And where werethose documents made available to 16 you, or how were they made available? 17 A They were available inMonsanto'scorporate 18 medical files. Copies of some of them were made 19 for my personal use. The remaining documents 20 were available to me at the Medical Director's office, 21 where I could peruse them whenever I wished to. 22 Q 23 And you did have the opportunity to use all three of those sources that you've identified to see the 24 documents? 85 C & L REpoRTiiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy * SuiTF 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058850 1A Yes. 2Q Where were the corporate medical files kept at 3 4A the time that you were aware of them? In Monsanto's general headquarters in St. Louis. 5Q Any particular division, subdivision or office; 6 anything of that sort? 7A The office of the Corporate Medical Director. 8Q You mentioned back in '65 to '70, that studies 9 or tests had been made available to you through 10 the plant medical doctor and also through the 11 Corporate Medical Director, correct? 12 MR SCOTT: No. I think you're 13 mischaracterizing his testimony. 14 What he said was that he had had 15 discussions with the Corporate Medical Director 16 and the plant doctor. 17 I don't think he referenced 18 studies that he saw between '65 and '70. I may 19 be wrong. 20 MR. LEDBETTER: Okay. Well, let's 21 let him answer that question. 22 BY MR. LEDBETTER: 23 Q Did you see studies, or did you discuss those 24 studies, in that '65 to '70 period, with the plant 86 C & L RepoRTiNq CERTified Court Reporters 295 5 5 NoRThwESTERN Hiqhwsy Suite 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058851 medical doctor and the Monsanto Corporate Medical Director? I did not see any reports. I was informed of these studies during the discussions with the two medical professionals. All right. And who was the plant medical doctor at that time, '65 through '70? , MR. SCOTT: You're talking about the Anniston plant? MR. LEDBETTER: Yes. That's right THE WITNESS: Dr. James Francis. MR. LEDBETTER: Was he a full-time plant medical doctor? No. Was he an M.D.? Yes . How often was he at the plant; the Anniston plant? Monday through Friday, daily, for two to three hours every morning, and was available by telephone for emergencies. And then who was the Monsanto Corporate Medical Director during that period of time? 87 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SourhfiEkl, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058852 1A Dr. R. Emmet Kelly. 2Q Okay. Do you know who replaced Dr. Kelly as 3 plant Medical Director? 4A Dr. Kelly was not the plant Medical Director. 5Q I'm sorry. The Corporate Medical Director. 6A Dr, George Roush, R-o-u-s-h. 7Q Is Mr. Roush still the Corporate Medical 8 Director? 9 MR. SCOTT: Dr. Roush. 10 THE WITNESS: Dr. Roush is still 11 today the Corporate Medical Director. 12 BY MR. LEDBETTER: 13 Q Okay. So, it was with Dr, Francis 14 and Dr. Kelly that you had these discussions 15 regarding the studies and tests regarding the 16 potential toxicity of PCB? 17 A Yes. 18 Q Do you recall what you were told at that time? 19 A Yes. 20 Q And what wasthat? 21 A That too much exposure to fumes can cause respiratory 22 problems; excessive exposure on the skin can 23 cause severe skin damage; or it can eventually 24 lead to chloracne, indicating high exposures over 88 C & L REpoRTiiMq CERTifi ed Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouTHfisld, Ml 48054 (5 1 5) 827'8589 WATER PCB-SD0000058853 1 2Q 3 4A 5 6 7 8 9Q 10 11 A 12 Q 13 A 14 Q 15 16 A 17 18 Q 19 20 21 22 A 23 Q 24 long periods of time. Did anybody ever attempt to put in a dosage that would be too much exposure via inhalation? The reference was made in those earlier documents we described put out by the American Congress of Governmental Industrial Hygienists and the publication put out by the American Institute of Industrial Hygienists. That was the one milligram per cubic meter and the one and-a-half milligram per cubic meter? Yes. That was for 1242 and 1254, correct? Yes. Do you recall any specific guidelines for Aroclor 1260? I was told to treat Aroclor 1260 the way we treated Aroclor 1254. I believe earlier you indicated that there was a relationship in potential toxicity as to inhalation and skin contact as chlorine was added, correct? Yes. Would it be afair assumption that at least marginally, the potential toxicity would be 89 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SUte 508 SouTtrfietd, Ml 48054 (515) 827-8589 WATER PCB-SD0000058854 1 2A 3Q 4 5 6 7A 8Q 9 10 A 11 Q 12 13 A 14 15 16 17 18 19 20 21 22 23 24 greater with 1260 than with 1254? I don't know. But you do know that the potential toxicity, at least in terms of the suggested inhalation amounts, was more strict for 1254 than it was for 1242? Yes. Bo you recall when you first read astudy regarding potential toxicity of PCBs? Early 1970. And do you recallwhat that was; the first series that you read at that time? I don't recall the title, but I believe I recall an investigator, Dr. Drinker. Dr. Drinker is the name I recall. And I also recall a reference to coatings on electrical cables. I recall the reference to both chlorinated naphthalenes and chlorinated biphenyls. MR. LEDBETTER: Would you mark that as 3, please, and this one Number 4. (Whereupon Deposition Exhibit Numbers 3 & 4 marked by reporter) 90 C & L RepoRTiNq CERTified Court Reporters 29555 Northwestern Hiqhwfty SuiTF 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058855 1 BY MR. LEDBETTER: 2Q I show you now what has been marked as Deposition 3 Exhibit Number 3 and Number 4. And first, as to 4 Number 3, I'll ask if you can identify that 5 particular study? 6A This appears to be a copy of a publication from 7 the Journal of Industrial Hygiene and Toxicology, 8 entitled The Problem of Possible Systemic Effect 9 From Certain Chlorinated Hydrocarbons. And the 10 authors are Drs. Drinker, Warren and Bennett. 11 Q Is that by chance one of the studies that you 12 recall reading sometime in 1970? 13 A It appears to be; yes, sir. 14 Q Okay. And then I'll ask the same thing as to 15 Deposition Exhibit Number 4, and ask if you can 16 identify that particular document? 17 A It's a copy of an article that appeared in the Journal 18 of Industrial Hygiene and Toxicology in February, 19 1938, Morphological Changes in the Livers of Rats 20 Resulting from Exposure to Certain Chlorinated 21 Hydrocarbons. 22 Q Is that again one of those that you recall from 23 1970, that reading in 1970? 24 A I don't recall this rat study, no. 91 C & L REpoRTiNq CERTiPied Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHHeIcI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058856 1Q Okay. Do you recall reading that one since? 2A Not clearly, no. 3Q Okay. 4 (Whereupon Deposition Exhibit 5 Number 5 marked by reporter) 6 BY MR. LEDBETTER: 7Q Sir, Ishow you another one that has been marked 8 as Deposition Exhibit Number 5, from the American 9 Journal of Hygiene, entitled Liver Lesions Caused 10 by Chlorinated Naphthalene, and ask if that may be 11 one of those that you were referring to earlier? 12 A I do notrecall thisdocument. 13 Q Okay. 14 MR. SCOTT: Counsel, are you going 15 to give these to our distinguished court reporter 16 so she can copy them and send them to us? 17 MR. LEDBETTER: Yes, I will do 18 that; of the ones he can identify. 19 MR. SCOTT: The ones that are 20 marked as exhibits, I think we're entitled to 21 have - 22 MR. LEDBETTER: Okay. 23 MR. SCOTT: -- all of those, 24 whether he's identified them or not. 92 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuSte 508 SouThfisld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058857 1 2 you. 3 4 BY MR. LEDBETTER: MR. LEDBETTER: I'll give them to MR. SCOTT: Thanks. I'll stop writing. 5Q Is chlorinated naphthalenes and that family 6 related to PCBs in any way, or chlorinated 7 biphenyls? 8A 9 I would say they are related in a very broad way, as being members of a large family of chemicals 10 referred to as chlorinated hydrocarbons. 11 Q And there's a number of chlorinated hydrocarbons, 12 are there? 13 A Hundreds. 14 Q All have the common characteristic that they are 15 chlorinated? 16 A They're chlorinated, and they have carbon and 17 hydrogen also. 18 Q Okay. And that particular portion makes up the 19 entire 100 percent of Aroclor, right; those 20 chlorinations and carbon and whatever the other 21 chemical was? Threechemicals in PCBs, right? 22 A That is correct. 23 Q So, some of the otherchlorinated hydrocarbons 24 can have additional things besides what PCB has? 93 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqHwny SuiTE 508 SouTkfiEld, Ml 48054 (5 I 5) 827-8589 WATER PCB-SD0000058858 1A 2Q 3A 4 5Q 6 7A 8Q 9 10 11 12 13 A 14 Q 15 16 17 18 19 A 20 21 22 Q 23 24 Yes. Do they all have at least what PCB has? In terms of the chemicals, but the configurations are different. Where chlorine, for example, is placed and where hydrogen is placed and that sort of thing? And the carbons to each other and so on. Qkay. Back to terminology again. We often use the term "Askarel" in referring to certain polychlorinated biphenyl mixtures. Are the two terms synonymous; PCBs and Askarels? At what point in time? Let's say after final production of an Aroclor, say, Aroclor 1260. When you have the final product in a liquid form, that's called Aroclor 1260, would you call that an Askarel also? At the time PCBs were used in electrical equipment, the electrical industry referred to those materials as Askarel. Okay. So, if I could go a step further, you've identified, for example, Aroclor is a product that goes into the fluid that goes into 94 C & L REpoRTiisq CERTifiEd Court Reporters 295 5 5 NomhwESTERN HiqkwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058859 1 2A 3Q 4A 5Q 6 7A 8Q 9 10 A 11 Q 12 A 13 Q 14 15 A 16 Q 17 18 19 A 20 Q 21 A 22 Q 23 24 electrical equipment? Yes. In some cases, it can be the entire fluid? Yes. Pyranol is one of the trade names that contains Aroclor products? Yes. And then there are other trade names that also contain Aroclor products? Yes. All of those properly would be termed Askarels? I don't know what they'd be called today. Okay. The last you knew, they could be properly termed Askarel? Yes. Okay. Is there any particular significance of the 1200 series of Askarels, other than it's just a PCB? I'm confused by the question. Okay. Significance in what manner? Why Aroclors have the -- or at least the PCB Aroclors have a 1200 series designation. Was there any particular meaning 95 C & L REpoirriNq CERTihed Court Reporters 29555 Northwestern Hiqhwsy SuiiE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058860 or designation of 1200? Yes. The 1200 referred to the biphenyl. So, any time we have the 1200 Aroclor, whatever it is, it's always going to be a chlorinated biphenyl? Correct; a mixture. Now, there were other series of Aroclors, one of which I think was 4400. Were there others that you're aware of; other series? There's a 5400 and a 60 series. Anything significant about the 44, 54 or 60 series, similar to what the 1200 means for chlorinated biphenyls? The 4400 meant that it was a blend of polychlorinated biphenyls and polychlorinated terphenyls. The 5400 series referred to the polychlorinated terphenyl mixtures. The 60 series referred to a blend of polychlorinated terphenyls and monochloro biphenyl. Any other series that you recall? There's a 2500 series. 96 C & L REpoRtiNq CERTiFied Court Reporters 295 5 5 NoRiku/ESTERM HiqhwAy SuiiE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058861 1Q 2A 3 4Q 5A 6 7 8 9 10 11 12 Q 13 14 15 A 16 Q 17 18 A 19 Q 20 21 A 22 Q 23 A 24 Q What was the 2500 series? It was also a blend of polychlorinated biphenyls and polychlorinated terphenyls. Any particular difference between those two? The difference between the 2500 series and the 4400 series is the ratio of the biphenyls to the terphenyls. In the 2500 series, it was predominantly biphenyl. In the 4400 series, it was predominantly terphenyl. Is the -- I would assume then from that, that the 2500 series is more akin to the 1200 series than would be the 4400 series to the 1200 series? That's because it has more of thebiphenyl, yes. Do you recall roughly what portion it was of those two, 25 and 44? No, I don't. But 44 had less terphenyls -- I'm sorry, more terphenyls than it had biphenyls? Correct. Were there PCBs used in thechlorinated pesticides? Not that I know of. As plant manager in Anniston from '65 to '70, did 97 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058862 1 2 3 4A 5 6 7 8 9Q 10 11 12 A 13 14 Q 15 16 17 A 18 19 20 21 22 23 24 you ever get involved in the promulgation of rules and regulations at the plant as to handling and safety of PCBs? The safety and handling of PCBs as it refers to human health were developed by the medical department. I did not promulgate any of those rules. Okay. And in what form did those promulgations of the medical department or Medical Director come to you at the plant? Are you talking about the phraseology, or the piece of paper that showed up? Yes. Not -- I don't want a chemical description of the paper, for example. Just what the paper is called and what system was used to get that word to you. I can only speak for the period in which I was familiar with. And that involved sending to the medical department, that page out of the Standard Manufacturing Process Manual or the Standard Operating Instruction Booklet; sending those pages that involved safety and handling to the medical department, and asking them to update or review and update because we were updating the 98 C & L REpORTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058863 1 2 3 4 5 6Q 7 8 9 10 A 11 Q 12 13 14 15 A 16 Q 17 18 19 20 A 21 Q 22 23 A 24 whole manual. They would make the appropriate changes and send it back to the plant. And the new version, if revised, would be incorporated in the revision that was issued. Did they then take on a different directive kind of number or some sort of thing, or did it just become part of the operating instructions; the Standard Operating Instructions? It became a part of the operating instructions. Okay. So, any time that you needed to check on the safety or handling, you could just go directly to those documents which were retained at the plant? Yes. And somewhere along the way, you or perhaps someone else, would make a decision that they may need to be updated, and they would then be sent to the Medical Director or the plant doctor? Yes. Would they be routed to first the plant doctor and then to the Medical Director? Generally, the plant doctor would review the document. And then the author of the revision 99 C & L REpoRTiNq CERiifiEd Court Reporters 029555 NoRThu/ESTERN HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058864 1 2 3 4Q 5 6 7A 8 9 10 Q 11 12 A 13 Q 14 A 15 Q 16 17 A 18 19 20 21 22 23 24 would take the plant doctor's version and send it on to the corporate medical department for their review and comment. When you say "the author," is that somebody other than the plant doctor that would author the change? I'm talking about the author of the manuals of which this safety section is a page or three or whatever is appropriate; or a section of it. Okay. So, they're big, thick manuals and part of it is safety and handling? That is correct. Do you know who the a ithor of those manuals were? It varied. Any particular group or department that would have the authorship responsibility? The process manual, the highly-technical book, was assigned to the plant technical services department, which was the engineering and scientific group. One of the engineers or chemists would be the principal author, and he would get assistance from anyone in the plant or in the corporation, in review of the sections. 100 C & L REpomiNq CERiified Court Reporters 295 5 5 Northwestern HiqHwAy Suite 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058865 1Q 2 3A 4 5 6 7 8 9Q 10 11 12 A 13 14 Q 15 16 A 17 Q 18 A 19 Q 20 21 A 22 Q 23 24 Okay. How about the standard operating practices? The standard operating practices were, wherever possible, assigned to the department foreman. Sometimes the foreman did not have the skills to prepare written documents, and it would then be assigned to the department supervisor. With these process manuals and also the SOP manuals, final approval went through corporate headquarters and the Medical Director? For that section that was relevant to the Medical Director. Okay.And the other things would go through other technical people within their relevance? Correct. Again, atheadquarters, though, for final approval? Again, it depended on the sections. Some could be done without corporate headquarter approval? Yes. Do you recall in this time period, ever having any direct contact with corporate headquarters, the Medical Director's library or some such thing, 101 C & L RepoRT'iNq CERiifiEd Court Reporters 29555 NomhwESTERN HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058866 1 2 3A 4 5Q 6 7 8 9A 10 11 Q 12 13 A 14 Q 15 16 17 A 18 19 Q 20 A 21 22 23 24 that may have relevant articles or directives regarding PCBs? I'm not aware of anybody at the plant consulting those records. Okay. So, generally, you would have your own. And if there was a difference at headquarters, you wouldn't use them; you weren't allowed to use them. Is that the idea? Oh, no. I was allowed to use them, but I relied totally on the professionals in St. Louis. Okay. And that would be the Medical Director and his staff that you've identified? Yes. How many people werea part ofthe Medical Director's staff, if you know, in the '65 to *70 period? Oh, the professionals included, in addition to the Medical Director, three individuals. And who were they? Melvin Wheeler, who was the manager of -- I have forgotten his title, but he was the individual primarily involved with toxicology; toxicology testing. And he was assisted by Dr. William Hunt, Doctor of Toxicology. 102 C & L REpoRTiNq CERTifiEcf Court Reporters 295 5 5 NortIiwestern HiqhwAy SuiTE 508 SouTkfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058867 There was a Mr. Jack Garrett, who was involved with work-place exposure and industrial hygiene matters. In addition to those four individuals, there were the typical secretaries. And in addition to that, there were part-time physicians and about four or so full-time nurses. Do you recall a Dr. Johnson who worked with Dr. Kelly? Dr. Johnson, as I recall, joined Monsanto after 1970, to the best of my knowledge. Okay. He was assistant medical director. At the time that Monsanto purchased the Swann Chemical Company, which I believe was in 1935, do you know if there came with that purchase, the patents or other technical documents relating to the manufacture of PCB? It's my understanding that yes, it did. Did you ever review the patents or that sort of technical literature at the time? Let me ask that question a little differently. You didn't do it at the time of 103 C & L REpoRTiNq CERiified Court Reporters 2955 5 Northwestern HiqhwAy Suite 508 SouTlnfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058868 1 2 3 4 5A 6 7 8Q 9 10 A 11 Q 12 13 A 14 15 16 Q 17 18 19 20 A 21 Q 22 23 A 24 Q the purchase, certainly, but at a later date, did you review documents pertaining to the technical literature that was available from Swann to Monsanto in 1935? I reviewed documents of that vintage. I don't recall whether I reviewed them all or not. Do you recall if the patent information indicated any potential adverse effects of PCB? No. Do you recall what the claims on the patent was, or claims in the patents? As I recall, these patents had to do with process; what techniques were used in the process. When Swann was purchased, do you know if the management and employees that were there were just taken over and became Monsanto employees at the time? That is my understanding. Do you know who the plant manager of Swann was at the time? No. Was Swann involved in the manufacture of other 104 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NortIhwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058869 1 2 3A 4Q 5 6 7A 8 9Q 10 11 A 12 Q 13 A 14 15 16 17 Q 18 A 19 20 21 22 23 Q 24 things in 1935, or prior thereto; other things than PCB? Yes. Do you recall again what proportion of the other things, compared to the manufacture of PCBs, Swann was involved with pre-1935? PCBs were a small part of the overall. I do not know the ratios. Do you know if there had been any other American manufacturers of PCBs? At what point in time? Post '35. I had reports given to me that whenMonsanto withdrew from some of the PCBmarket, that someone in the southwest was attempting to sell PCBs . \ Would that have been a patent infringement? No. The patents had run out long ago. I reported this to the Federal authorities. I never did get a report on whether they succeeded in determining what the source of PCBs were. Is it your understanding, from '35 through the last manufacture of PCBs by Monsanto, that they 105 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827'8589 WATER PCB-SD0000058870 were the predominant force in the market here in the United States? Yes. Do you have any knowledge as to how much of the American market was supplied by Monsanto from *35 up through, say, 1977? Which market? The American market within this country. How much PCBs was supplied to the users within this country? Of all PCBs? Of all PCBs. All applications? That's right. High 90 percent. Okay. So, out there somewhere in the world, people had come a little bit into the market and produced some in this country, other than Monsanto -- or not produced in this country, but supplied it to the country? That's my understanding. Do you recall some sort of episode bringing to your attention potential environmental effects, adverse effects of PCB, other than those that 106 C & L REpomiNq CERTified Court Reporters 295 5 5 Northwestern Hiqhwny SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058871 1 2 3 4A 5Q 6A 7 8Q 9 10 A 11 12 13 14 15 16 17 18 Q 19 20 21 A 22 Q 23 24 you were already aware of through the operating literature and the process manual that you had described to us? Again, what year? Sometime after the *65 to *70 period. Of course, after 1970, I was assigned full-time to monitor such reports. Okay. We haven't gotten into all that, but we will in a moment. I was aware of reports alleging that PCBs were involved or could have caused the migratory bird problem in the Irish Sea, and the death of young seals in the North Sea. I was aware of reports referring to the brown pelicans off the coast of California, and their inability to reproduce. This was in the early 1970 era. Okay. And that's when you became in that neighborhood, when you became manager of environmental control? Yes. You described a moment ago that your responsibility was then more involved in monitoring PCB activities, so to speak, in that 107 C & L RepoRTiNq CERTifiEd Court Reporters 29555 NoRThw/ESTERN HiqhwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058872 1 2 3A 4Q 5 6 7A 8Q 9 10 A 11 Q 12 13 A 14 Q 15 16 17 18 19 A 20 Q 21 22 A 23 24 1970 to 1972 period. Is that true? Yes. Okay. What else was your job duties and responsibilities, besides PCB, while you were manager of environmental control? PCBs was the only issue I was assigned. So, Monsanto created a special position just purely for PCBs? Correct. . Was that the first time that position had been filled? Yes. And you remained in that position until 1972? Well, let me re-ask that. You remained manager of environmental control until 1972, but it sounds like you still remained in St. Louis from *72 to '77? Yes. Was that a similarsortof job; still involved with PCBs? The responsibility forPCBs was given to me in 1970, and I retained it until February, 1976. Starting in about 1973, I was 108 C & L REpoRTiNq Ceut!fiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiiE 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058873 assigned other chemical products in addition to PCBs . So, you just broadened your responsibilities, but you still had PCBs in -- post-'76? No. Okay. I missed the date there, then. *76 was the last date in which I was involved with PCBs. Okay. But between the period of about '73 to '76, I not only had PCBs, but had additional products assigned to me. After 1976, I had a list of chemicals for which I was responsible, excluding PCBs . Okay. When you were manager of environmental control, you stayed in that position up through ' 72? Correct. Who replaced you in that position? No one. The title changed? The title changed. And you continued with PCB responsibility only for a while, and then you took up other chemicals 109 C & L RepoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqhwAy Suite 508 SourhfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058874 1 in '73 or thereabouts? 2A Correct. 3Q Still retaining PCBresponsibility? 4A Correct 5Q Did you have a staff in that first 1970 to 1972 6 period? 7A 8Q No. Was there other lateral departments responsible 9 for another individual chemical other than -PCB? 10 MR. SCOTT: Responsible in what 11 way? 12 MR. LEDBETTER: Responsible for 13 another chemical other than PCB; meaning somebody 14 lateral to him, in a similar department. 15 MR. SCOTT: Do you understand the 16 question? 17 THE WITNESS: I think I do. 18 MR. SCOTT: Okay. I don't. 19 THE WITNESS: My hesitation, 20 again, is what point in time? 21 BY MR. LEDBETTER: 22 Q We're talking 1970 to 1972. 23 A '72, There's always someone throughout the 24 corporation responsible for a product. 110 C & L REpORTiNQ CERTified Court Reporters 295 5 5 Northwestern HiqHwAy * Sure 508 SouThfiEtd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058875 1 2 3 4 5 6 7 8 9 10 11 12 Q 13 14 15 16 17 18 19 A 20 21 Q 22 23 24 A In every case but PCBs, they, in essence, wore several hats. They might be a research person that has this responsibility, they might be a manufacturing manager, or it might be a marketing manager, it could be an engineering type; depending on the product and the applications and many other factors. PCBs were different, in that I was given the full-time assignment without having to wear another hat for at least three years. Okay. My question then is -- perhaps stated negatively, we could get to it better. In this period of 1970 to 1972, you were responsible solely for PCBs. And there was no one else that you're aware of, responsible for any individual chemical only. Is that true? Not that I know of. But that doesn't mean I know it all. Okay. All right. Do you have knowledge as to why a separate department was created for only PCBs in 1970? I have an understanding. Ill C & L REpoRTiNq CERTifkd Court Reporters 295 5 5 Northwestern HiqHwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058876 What is that understanding? PCBs involved two distinct groups within Monsanto; two separate entities in terms of management and responsibilities. One was the functional products group and the other was the plasticizers group, with a common product. And, in essence, in order to let the left hand know what the right was doing, I was appointed this assignment, to serve as a communicating link between the left hand and the right hand and the two research groups and the two marketing groups and the two manufacturing groups. Were you involved in the -- during this time, '70 to '72, were you involved in the promulgation of directives or standard operating procedures relating to the safe handling of PCBs? Yes . In what way? I was one of several individuals who reviewed proposed drafts. Of those regulations? And you would give suggestions or approvals on those proposed drafts? I would comment or .make changes where I saw 112 C & L REpomiNq CERTiFied Court Reporters 29555 NoRThwESTERtv Hiqhway SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058877 1 2Q 3 4A 5Q 6 7 8A 9Q 10 A 11 Q 12 13 14 A 15 Q 16 17 18 A 19 Q 20 21 22 A 23 24 appropriate. ' Did you attempt to stay up on the literature and research up to that date, '70 to '72? Yes. And that would assist you in making your recommendations in such things, to the operations manual, to the process manual, if that came to you? Yes. And other similar type regulations? Yes. I understand that Monsanto uses a bulletin system relating to its products. Is that true? Yes, they do havebulletins. Is bulletins separate from the process manual and the standard operating instructions that we've talked about? Yes. What is thebulletin system, used at Monsanto? What is that bulletin system, if you could describe it in broad terms? I don't know that it's used throughout Monsanto. I can only speak for some of the business groups that I happened to be working closely with. 113 C & L REpORTiNq CemifiEd Court Reporters 295 5 5 NoiuhwESTERN HiqbwAy SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058878 1Q 2 3A 4 5 6 7 8 9 10 11 12 13 Q 14 15 16 17 A 18 19 20 21 22 Q 23 24 A Certainly. With only your involvement; fair enough. In this instance, they issued these bulletins which were -- I would personally call them advertising literature promoting the products. Describing to a potential customer or a current customer the properties of the products available; the kinds of uses to which they were put or could be used, sort of futuristic; the types of packages that it was available in. That's about all I can think of at the moment. Would bulletins contain instructions for use, as opposed to you can use it as a plasticizer? Do you tell them how to use it as a plasticizer, for example? Some bulletins actually had typical recipes; so many pounds of this ingredient and X pounds of that and you heat it to a certain temperature and you get this kind of a adhesive. Some of those were available, yes. Did bulletins also contain warnings to customers as to potential adverse effects of the products? Some of them, yes. 114 C & L RepoRTiNq CERTifiEd Court Reporters 29555 Northwestern HkjHway Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058879 1Q 2 3A 4 5 6 7 8Q 9 10 11 12 A 13 14 15 16 Q 17 A 18 Q 19 20 A 21 22 Q 23 A 24 Q Is there a single department or group that would be responsible for developing product bulletins? Well, the initiative is taken by the marketing department, but they can go anywhere in the corporation for assistance, depending on the topic they wish to discuss or to include in their bulletin. Is that still, to your knowledge - at least the last you knew at Monsanto - a normal way of providing product literature; through the bulletins? That is -- I'm confused by the use of the word "normal." It is one of many ways to communicate. It was still being used, the last you knew? Yes. Are bulletins retained at some specific level or department at Monsanto? To the best of my knowledge, the corporate library keeps copies. Where is that located? At Monsanto's corporate headquarters in St. Louis. And, to your knowledge, do they keep current and 115 C & L REpoRTitMq CERiified Court Reporters 295 5 5 NoRThwESTEnrv Hiqhw/Ay SuiTE 508 SouThfUld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058880 1 2A 3Q 4 5A 6Q 7 8A 9 10 Q 11 12 13 14 A 15 16 17 18 19 20 21 22 23 24 outdated bulletins? That's my understanding. Did you ever see bulletins relating to Aroclor products? Yes. Did you ever see bulletins relating specifically to Aroclor 1260? X don't recall a bulletin specific to a particular Aroclor. , Okay. Would bulletins discuss Aroclors in general terms. Or would they, the ones that you're familiar with, cover specific Aroclor numbers? They would cover the entire Aroclor family, including not only the PCBs, but the PCTs, except for those bulletins that are specific to dielectrics. They would then include only the PCBs plus the blended materials. And the hydraulic fluids bulletins would include only the PCBs. The heat transfer bulletins, again, would refer to the heat transfer fluids by their trade names, which would limit them to PCBs. 116 C & L REpoRTiNq Cemi Fi Ed Court Reporters 295 5 5 Northwestern HiqHwy SuiTE 508 SoutHF'ieW, Ml 48054 (5 1 5) 827.8589 WATER PCB-SD0000058881 1Q 2 3 4 5A 6Q 7A 8Q 9 10 A 11 12 Q 13 14 15 16 17 18 19 20 A 21 Q 22 23 A 24 Q Okay. When we're talking dielectrics, that would cover those Aroclor compounds that you talked about earlier that was used in a dielectric application, correct? Yes. So, it would talk about that group in general? Yes. Would the bulletins talk about a specific trade name, such as Pyranol? They would refer to the word Pyranol as well as other brands or trademarks. Okay. Somewhere in thehistory here, I got a little bit confused. After you were manager of environmental control, which you indicated was 1970 through 1972, you then assumed manager of product acceptability. But from '72 to '73 only, your exclusive responsibility was PCBs. Is that a fair statement? That's a correct statement, yes. Okay. Even though the -- so, it was just a name change for that first year, '72 to *73? Roughly, yes. And from '73 to '77, you had PCBs plus other 117 C & L RepoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SoutHHeIcI, Ml 48054 (515) 827-8589 WATER PCB-SD0000058882 1 2A 3Q 4 5 6 7A 8Q 9 10 A 11 12 Q 13 14 15 A 16 Q 17 A 18 19 20 21 22 23 24 chemicals under your jurisdiction? Yes. You described earlier that sometime in the early 1970 period, I think, that you became aware of studies involving claims that there was adverse environmental impact of certain PCBs? Yes o I)o you recall which Aroclors those were primarily that were presenting the problem? The articles referenced Aroclor 1254 and Aroclor 1260. Was it -- did you come to understand why only those particular items were -- or those particular Aroclor products were mentioned? I have my understanding, yes. What is that? The references to Aroclor 1254 and 1260 indicate to me that the analyst is finding as he analyzes the materials, PCBs that are generally associated with those commercial trademarks, indicating that the higher-chlorinated types of PCBs are present in the environment, which further indicates that they are survivors in the environment, as distinguished from the lower- 118 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NoRThwESTERN HiqhwAy Sum 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058883 1 2 3 4Q 5 6 7 8 9A 10 11 Q 12 A 13 14 Q 15 16 A 17 18 Q 19 20 A 21 Q 22 23 A 24 Q chlorinated PCBs which, at that time, generally were not found, but we knew that a considerable amount had been distributed in commerce. Referring to some of the Aroclors that you mentioned earlier in the 1200 series, was there any particular Aroclor group that was manufactured in greater quantities than any other, in the 1200 series alone? As I recall, Aroclor 1242 was produced in greater quantities. And was that true from beginning to end? No. I think it peaked in about the 1960s, somewhere in there. Backing up again, back to 1935, is that when Aroclor started; in about '35? The Aroclor compounds? No. They were initially introduced in '29, became commercial in 1930. Okay. So, when Monsanto bought that group from Swann, they also bought the name Aroclor? Yes. Okay. And 1242, to your knowledge, was manufactured even back in 1929 or '30? Yes. How about 1254? 119 C & L REpoRTiNq CERiifiEd Court Reporters 29555 NoRThwESTERN HiqhwAy SuiTE 508 Southfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058884 1A 2Q 3A 4Q 5 6 7 8A 9 10 11 Q 12 13 14 A 15 Q 16 17 18 A 19 Q 20 21 A 22 23 24 Yes. How about 1260? Yes. And in the early years, was it your understanding that 1242 was manufactured - at least up through the mid-1960s or thereabouts in greater quantities than the others? No. The 1254 and 60 were the greater quantities initially. 1242 evolved through the years to become the leader in the late '60s. Was there any particular advantage -- again, we're talking in terms that these were generally used for dielectrics, correct? Yes. They had some other applications, too, but not nearly to the degree of dielectrics; is that fair? That's correct. Is there any particular advantage that 1254 and 1260 have over 1242 in a dielectric use? It's my understanding that in transformers, the 1254 and 1260 were the preferred PCBs, when blended with chloro benzenes. It's also my understanding that 120 C & L REpoRTiNq CERiifiEd Court Reporters 295 5 5 NomhwESTERN Hiqhwsy SuiTE 508 SouTWiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058885 1 2 3Q 4 5 6 7 8 9A 10 11 12 13 14 Q 15 16 A 17 Q 18 19 A 20 Q 21 22 23 24 Aroclor 1242 was the preferred PCBs in capacitors. Okay. Now, let me just try to back up on the first preference to the 1254 and 1260 being used preferably in transformers, and you added the caveat, if you will, "when blended with chloro benzenes." . Why that caveat? They are too viscous when used alone. They must be diluted with a thinner. Whereas, some companies used 1242 without the thinner, which is the chloro benzene, in transformers. Okay. Is that GE that we referred to earlier; the Pyranol? GE preferred 1254 and 1260. Okay. And that would be, again, blended generally with chloro benzenes? Correct. Do you recall any specifics of the studies, where it came to your attention that these higher Aroclors, 1254 and 1260, were being found in various places in the environment? Do you recall any specific 121 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqHu/ny Su'ite 508 SouThfield, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058886 1 2A 3Q 4 5A 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 studies? Authors, for example? This is in the early '70s, you say? Yes. We're in the 1970 through '77 period, when you were involved with PCBs. Oh. That full period? Well, the initial work was done prior to the '70s at the University of Stockholm. Shortly thereafter, there was work done by a Professor Widmark and Dr. Jensen, Soren, S-o-r-e-n, Jensen, J-e-n-s-e-n; a Dr. Robert Risebrough at the University of California, Berkley; a Dr. David Peakall at the Cornell University; a Dr. Thomas Duke at the Commercial Fisheries Laboratory at Gulf Breeze, Florida. I've forgotten the names of the investigators, but the Warf Institute (phonetic) in Madison, Wisconsin, was doing some work with the fish in the Great Lakes and found the higher- chlorinated PCBs; the laboratory at Duluth, Minnesota; at that time, it was still part of the Federal Water Pollution Control Agency - Administration. 122 C & L REpomiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouThfiEtd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058887 1 2 3Q 4 5 6A 7Q 8A 9 10 11 12 13 14 15 16 17 Q 18 19 A 20 Q 21 22 A 23 24 Q I can't recall any others at the moment. Did you or anyone at Monsanto, to your knowledge, conduct any tests or have any conducted, to attempt to verify those findings? We verified the methodology. What do you mean by that? The analytical methods used to analyze these samples. . They used at that point in time, techniques that were highly sophisticated. So we chose to verify the methodology. And once our professionals in the analytical laboratory determined that the methodology had the ability to make these distinctions, there was no reason to question the results of the findings. Was that when the gas chromatograph was used? Yes. And that was the methodology that was verified through Monsanto? It was gas chromatography verified with mass spectrometry. And that was able -- satisfied Monsanto that in 123 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy Suite 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058888 1 2 3A 4 5Q 6 7 8 9A 10 11 Q 12 13 14 15 16 17 A 18 Q 19 20 A 21 22 Q 23 A 24 Q fact you could determine that these higher Aroclors were in the environment? Yes. It isn't only the instruments, but it's the way the sample is prepared. Did anyone in this period of time at Monsanto, make a decision that it's probably not good that this is being found in the environment, and to the levels it was found? We were -- yes. We decided that this was a man made chemical that should not be out there. Now, as I understand it, you had as part of your duties and responsibilities at Monsanto in that period, sole involvement with PCBs or responsibility with PCBs. You interacted with the world community, if you would; did you not? Yes. And that included Dr. Widmark and Dr. Jensen in Sweden? I did not ever meet Dr. Jensen. I met Dr. Widmark. Okay. Andyou were actually in Sweden? Yes. And you werein Europe? 124 C & L REpoRTiNq CERiifiEd Court Reporters 295 5 5 Northwestern HiqhwAv Su'ite 508 SouTHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058889 1A Yes. 2Q And you were in Japan? 3A No. 4Q You met with Dr. Risebrough, I think? 5A Yes. 6Q At theUniversity of California,Berkley? 7A Yes. 8Q And did you playany partafter those meetings 9 ' in recommending to Monsanto that some sort of 10 additional measures had to be taken regarding 11 these Aroclors? 12 A Yes. 13 Q And what did youdo? 14 A Well, I supported the plan --or the proposal to 15 withdraw from those applications which led to 16 uncontrolled disposal into the environment or 17 exposure to the environment. 18 Q And - 19 MR. SCOTT: Wait a minute. Let's 20 see if the witness has finished his answer. 21 THE WITNESS: Yes. 22 MR. SCOTT: Okay. 23 BY MR. LEDBETTER: 24 Q What applications is that, that you supported to 125 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Sure 508 SouTtrfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058890 1 2 3A 4 5 6Q 7 8 9A 10 11 12 13 Q 14 A 15 16 17 18 Q 19 A 20 Q 21 22 23 A 24 ban or discontinue? I didn't get your word there. Discontinue the sales to those uses in which the items that contained PCBs were discharged into the environment rather rapidly and without control, Okay. What do you mean -- first, what do you mean by "rapidly;" discharging PCBs rapidly into the environment? Well, an example I can give is the application in which PCBs are used in the early versions of carbonless copy paper, where the paper once used, is pitched into the wastebasket. Okay. It can find its way into the City dump or it can find its way into a recycle plant where the chemicals are stripped off the paper and flushed into the local river. Do you recall -- That is a rapid introduction. Okay. Referring specifically to carbonless copy paper, do you recall when Aroclors were first used by Monsanto in carbonless copy paper? Monsanto didn't use PCBs in carbonless copy paper. They sold to others who incorporated it 126 C & L REpomiNq CERTified Court Reporters 2955 5 Northwestern HiqHway Suite 508 SouihfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058891 1 2Q 3A 4Q 5 6A 7Q 8 9 10 11 12 A 13 14 Q 15 16 A 17 Q 18 19 20 21 22 23 24 in their process. Do you recall when Monsanto first did that? Early 1960s is as close as I can come. And that was one of the applications that was discontinued in about 1970? Discontinued by mid-1971 -- early 1971. Of the PCBs manufactured, we've talked about the dielectric use, which is the majority. How much in percentage, would you say, of PCBs was carbonless paper between early 1960s to mid1971? Oh, I don't remember. I'd have to see the numbers again. Would it be a fair guess that it might be under one percent? If you take the full time span, yes. What are some of the other applications that were found to be one of those rapid ^ introductions of PCBs in the system? MR. SCOTT: Rapid and uncontrolled, I think wsa his testimony. MR. LEDBETTER: Yes. We're talking about both categories. The first one is just rapid. 127 C & L REpoirriNq CERfified Court Reporters 295 5 5 Northwestern Hiqhway SuiTE 508 SouTkfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058892 1 THE WITNESS: There was wide use 2 in special paints. 3 An example that comes to mind is 4 the traffic lane white and yellow paints supplied to 5 the environment. It erodes and eventually 6 ends up in the soil, or rain washoff or runoff. 7 BY MR. LEDBETTER: 8Q Again, what time period was it that 9 Monsanto began providing PCBs for the 10 application to special paints? 11 A It would have to be after World War II. I'd say 12 the early '50s. 13 Q Okay. And then ending when? 14 A We ceased selling in 1970. August 30 was the 15 last date of sale. 16 Q In that period of time, early '50s through 17 August 30th of 1970, in talking yearly 18 production of PCBs, what portion of it was 19 related to specialty paints, would you suppose? 20 A I have no idea. Most of this was sold through 21 distributors. There is no record of that. 22 Q When we were talking that the majority of PCBs 23 manufactured would have been for dielectric use, 24 would it be fair to say that the specialty 128 C & L REpoiniNq , CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058893 paints would be something less than five percent of total production? I have no idea. Any other special applications that you recall being terminated in about early 1970 or *71? Yes. The uses in industrial hydraulic fluids. How long had those been in use at Monsanto; the PCBs for that purpose? The PCB type hydraulic fluids, again, probably in the '50s. And terminated when? Started in 1970 and completed early *71. Is it a fair statement that these applications that you've indicated to me are, generally speaking, applications that were developed later in time, well after when Monsanto purchased Swann? Yes . The primary use back in that time period was what for PCBs; '35 up through, say, the early ' 50s? Dielectric. And dielectric even after the '50s, although there were additional applications, dielectric 129 C & L RspoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058894 1 2 3A 4Q 5 6A 7 8 9 10 11 Q 12 A 13 Q 14 15 16 A 17 18 19 20 21 22 23 24 still remained the majority of the product? Yes. Any other large applications of PCBs that were stopped in this early 1970 period? There's the broad usage. I'm going to refer to as plasticizer. These, as you recall, are the materials that soften the plastics to make them flexible. Many PCBs were used for that purpose. And that was stopped again in the early '70s? August, 1970, was the date of termination. Any other application that might make up any substantial PCB product that was stopped in the early '70s? The only other use that I can think of that I would consider substantial was the beginning of termination of sales to the heat transfer applications. The beginning steps were concentrating on those uses that were related to food-related processus in animal feed, or anything that could get into the food chain. And this termination was extended later to all heat 130 C & L REpoRTiNq CERTified Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058895 1 transfer uses. 2 BY MR. LEDBETTER: 3Q Okay. And these actions were taken in response 4 to the reports - and your verified reports - 5 that Aroclors were being found in the 6 environment? 7A Yes. 8Q Any other reasons other than that? 9A The termination in food uses was the additional 10 findings in some of the human food chain. 11 Q What findings are you referring to in the human 12 food chain? 13 A There was an incident that occurred in Japan 14 where oil was being distilled using a heat 15 transfer system with PCBs in it. And the oil 16 was contaminated with PCBs. That's one 17 incident. 18 Another one occurred as a result 19 of a heat transfer system used to sterilize fish 20 meal. The system leaked PCBs into the fish 21 meal, the fish meal found its way into poultry 22 feed, and eventually ended up in chickens and 23 eggs. 24 Another incident occurred, 131 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqHwAy 0 SuStf 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058896 1 2 3 4 5 6 7 8 9Q 10 11 12 13 14 15 A 16 Q 17 18 A 19 Q 20 21 22 23 24 relating again to chickens, with the heat transfer system associated with a bakery. And then the dairy incidences with silo coatings, and the presence of PCBs in milk. Those incidences relating to the human food chain led to our decision to get out of the heat transfer applications associated with food processing. Okay. If we had production figures from the 1960s running into the 1970s, after these uses that you've described for us have been discontinued and we see a corresponding drop in production of PCBs, would it be fair that the remaining production was for dielectric use? Yes. So that would give us an idea of how much total production there was for dielectrics? Yes. Was there -- I forgot to ask the other wing of that problem that Mr. Scott mentioned a moment ago. First, those things went rapidly into the environment, you've described. Then you mentioned also those 132 C & L REpoRTiNq CeiTifiEd Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058897 that could not be controlled? Correct. What do you mean by "cannot be controlled"? Well, in my mind, the hydraulic fluids is an example of a use of PCBs in what could idealistically be described as closed systems. But in the real world, they are extremely difficult to maintain because of the very high pressures involved. And the pressures on the user to keep his operations going encouraged the leakage of PCBs into the plant sewers or into the sewage system, out into the environment. We felt that it was unrealistic to expect that application to be controllable. Okay. And when you're referring to hydraulic fluids, they might very well be part of a hydraulic system which could be enclosed, but you're saying with the pressures, Monsanto really can't control whether they're going to get into the environment or not? Not only Monsanto, but our customers. Okay. So, you also considered the ability of your customers to do or not do what they should do with your product? 133 C & L RepoRTiNq CERTifiEd Court Reporters 2955 5 Northwestern HiqHwAy * Su'ite 508 SoinhfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058898 1A That was very key in our thinking, yes. 2Q Did you provide warnings to your customers 3 regarding what they should or should not do with 4 their products in this time period? 5A Yes. 6 MR. LEDBETTER: Mark these the 7 next numbers, whatever they are. 8 (Whereupon Deposition Exhibit 9 Numbers 6 & 7 marked by reporter) 10 BY MR. LEDBETTER: 11 Q I'll show you first what's been marked as 12 Deposition Exhibit Number 6, and I'll ask if you've 13 ever seen that document or facsimiles of it? 14 A I have seen copies of this before, yes. 15 Q Okay. Do you recall if that corresponds with 16 about the time period that Monsanto was becoming 17 aware of the environmental problems that were 18 reported by the various studies? 19 A Yes. 20 Q And subsequently thereto, Monsanto did in fact 21 with its customers, provide certain notifications 22 of termination of products and notified the 23 customers as to what they should do with the 24 products to ensure that they don't get in the 134 C & L RepoRTiNq CERTified Court Reporters 295 55 Northwestern HiqkwAy * Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058899 1 2A 3 4 5Q 6 7 8 9A 10 Q 11 12 A 13 14 15 Q 16 17 A 18 Q 19 20 21 22 23 A 24 environment, correct? Well, we did not tell the customer how to achieve it. We just cautioned them: Don't let it escape to the environment. Okay. I'll show you what has been marked as Number 7, and ask if you can identify that particular document; if you've seen it or a facsimile before? , I have seen Exhibit Number 7 before, yes. Okay. And what was the purpose of that particular document, if you know? This was to inform the customers on record with Monsanto of PCB products, the latest of Monsanto's understanding of the PCB situation. Okay. And that included the environmental problems, right? Yes. Were there any efforts to provide that sort of mailing to customers, regarding Monsanto's experience as to the safety and handling and working around PCBs at the Monsanto manufacturing plants prior to 1970? I'm not aware of any mailing of this type that addresses that subject. 135 C & L REpoRTiNq CeRTified Court Reporters 295 5 5 NornhwESTERN HiqhwAy Suiit 508 SourhfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058900 1Q 2 3 4 5 6A 7Q 8A 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q Were there other methods that you were aware of that Monsanto used to inform customers of the safehandling practices that have been identified in the process manuals and the Standard Operating Instructions manuals? Yes. How was that done? The primary method of communicating it was person-to-person from Monsanto's sales representatives and from the St. Louis marketing staf f. Specific medical questions were answered by the medical department representatives. Another method used was via bulletins such as we described earlier, which addressed sections in safehandling. The primary method was the person-to-person contact. There were occasions when the customers' representatives would visit a Monsanto plant or home office in which these topics were also discussed. And would the information from the Standard 136 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy 0 SuiTE 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058901 1 2 3A 4Q 5 6 7 8 9 10 A 11 12 Q 13 14 15 A 16 Q 17 18 19 A 20 21 22 Q 23 24 A Operating Practices manual be provided to the customer at that point in time? Yes. Now, when we're talking customers, we're not necessarily talking the end user of the product. We're talking, for example, in dielectric terms, the customer who's buying the fluid to be enclosed in an electrical piece of equipment. That's the customer, right? That is the normal customer, yes; Monsanto's customer. Okay. Would Monsanto attempt to pass on the information to the -- the safehandling information to the ultimate users of the product? No. Monsanto had no such list. Are you aware if Monsanto ever suggested that a warning campaign of sorts be applied by its customers to the end customers or the end users? I'm aware of such a suggestion occurring after 1970. I do not know what happened prior to that. Okay. And in what form did that suggestion to the customer take place after 1970? I know I personally have talked to 137 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058902 1 2 3 4 5 6 7 8 9 10 Q 11 A 12 Q 13 A 14 Q 15 16 A 17 Q 18 A 19 Q 20 A 21 22 Q 23 24 A representatives of Monsanto's customers along these lines. And it was finally documented in at least two documents. One was the ANSI guidelines on how to handle Askarels. And prior to that was a Monsanto booklet referring to the handling of Askarels. This booklet was revised in the '70s, and I know for sure personally we recommended they get extra copies and share with their customers. Do you recall the name or title of that booklet? This Monsanto booklet? Yes. All I remember is the word Askarel in the title. Okay. And you said it was amended or modified in some way in 1970 or thereabouts? Yes. Meaning itwas in effectsometime before 1970? Yes. Do yourecall its original effective date? I have seen copies dated in the '60s. I do not know when the very first version was published. Did Monsanto provide warnings and warning labels with its PCB products? Yes. 138 C & L REpoitriNq CERTifiEd Court Reporters 295 55 Northwestern Hiqkwfty SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058903 1Q 2A 3 4Q 5 6A 7Q 8A 9 10 11 12 Q 13 14 15 A 16 Q 17 A 18 Q 19 20 A 21 Q 22 23 24 A Do you know when that started? Asbest I can determine, it started with the Swann Chemical Company. Did you ever see any copies of warning labels that Swann had used? Yes. Do you recall what they said? Not the exact words, but it warned that it contained chlorinated hydrocarbon; avoid prolonged breathing and avoid skin contact; words to that effect. Now, you indicated that you were aware that ANSI came out with a standard on the handling of Askarels? Yes. And you wereon the committee, weren'tyou? Yes. And, in fact, you were the chairman of the committee, weren't you? Yes. And you then took the committee comments and developed, or at least in part, began developing a standard for C-107? Well, I didn't make theC-107 comments. I'm 139 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NoRThwESTERN Hiqkwny SuiiE 508 SouThfisld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058904 1 2Q 3 4 5A 6Q 7A 8 9 10 11 12 13 14 Q 15 16 A 17 Q 18 19 20 A 21 Q 22 A 23 Q 24 puzzled by your question. Okay. You, as chairman of the committee, gathered the comments and the input for the eventual development of that standard, correct? Yes. What role did you play as chairman? I called for the meetings. I appointed the two subcommittees. I assigned them to their work rooms, and then spent my time going between the groups to see that they were working and we had a target date to meet. I just kept pushing for some results. I didn't do any of the work. Okay. So you guided them along the path, so to speak? Yes. Okay. Do you recall any labels being provided by Monsanto indicating that PCBs were a potential human carcinogen? No. You never recall any labels of that sort? That's correct. Do you recall any requirements that such a label be used? 140 C & L REpoiuiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058905 1A No. 2Q Were you a part of the NIOSH committee? 3A I was part of a review committee for a NIOSH 4 Criteria Document. 5Q And that's the document that -- if I can find 6 it, I'll show it to you. 7 MR. SCOTT: Let the record 8 reflect - although you may continue with your 9 questions - that I will object to any 10 questioning of this witness or any other witness 11 with respect to any alleged human carcinogenic 12 potential of PCBs, as being irrelevant to these 13 cases. 14 MR. LEDBETTER: Let's have this 15 one marked as Number 8, I guess. 16 (Whereupon Deposition Exhibit 17 Number 8 marked by reporter) 18 BY MR. LEDBETTER: 19 Q Sir, let me show you what's been marked as 20 Deposition Exhibit Number 8, and I would ask if 21 22 A 23 24 you can identify that particular document? This is a copy of a publication of the U.S, Department of Health, Education and Welfare, put out by the National Institute of Occupational 141 C & L REpoiuiNq CERTified Court Reporters 29555 Northwestern HiqhwAy a SuiiE 508 SourhliEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058906 1 2 3 4Q 5 6A 7Q 8 9A 10 11 Q 12 13 A 14 15 Q 16 17 18 A 19 Q 20 21 A 22 Q 23 24 Safety and Health, and it's entitled Criteria for Recommended Standard.... Occupational Exposure to Polychlorinated Biphenyls (PCBs). Okay. And you were on the review committee for that recommended criteria, were you not? I was. Did you have input into what went in the recommended criteria? My input amounted to a critique of a draft that was given to the review panel. And this is the final as opposed to the draft, correct; the recommended criteria? It appears to me to be a final. I have not seen a final form. Okay. So, the only one that you saw was a draft copy of what was to eventually be the recommended criteria? Yes. Do you recall any input into the suggested labels to be used or distributed with PCBs? Not specifically, no. Okay. Do you recall having any input into developing a material safety data sheet requirement to be used in conjunction with PCB 142 ' C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqhwAy " SuiTE 508 SoiiThftEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058907 1 2A 3Q 4 5 6A 7Q 8 9 10 A 11 Q 12 13 14 A 15 Q 16 17 A 18 Q 19 20 A 21 22 23 Q 24 products? No. Are you aware that there is a requirement or a suggested criteria by the NIOSH document that that material safety data sheet be used? I don't remember. Do you know if such a material safety data sheet is used or was used at Monsanto from 1977 forward? Yes. Does that apply to -- let me drop back. When did Monsanto cease their production of PCBs? Production was ceased inJuly, 1977. Okay. And as I recall, this NIOSH Criteria Document was effective in September of '77? That's the date on the document. Okay. Did Monsantomanufacture or supply PCB products of any sort after July of 1977? They sold -- they terminated production in July of 1977, and terminated sales in September of ' 77. So, as far as material safety data sheets go, assuming there was such a requirement or 143 C & L RepoRTiNq CERtified Court Reporters 295 5 5 Northwestern HiqHway SuiTE 508 SouThtiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058908 1 2 3 4A 5 6Q 7 8A 9Q 10 11 12 A 13 Q 14 15 16 17 A 18 19 Q 20 21 22 A 23 Q 24 suggestion effective in September, 1977, it wouldn't have affected Monsanto, because they had ceased production, correct? Well, I suppose technically, yes, but we did prepare one. Okay. You prepared it for all Aroclors or certain Aroclor products? It was for PCBs. Okay. PCBs in general, as opposed to a specific type of Aroclor or specific polychlorinated product? Correct. And do you recall in what form that material safety data sheet took; whether it was a number or assumed some other sort of title other than Material Safety Data Sheet? No, just Material Safety Data Sheet; a multi page document. What is contained on that document as it relates to potential hazards, safety, handling, and that sort of thing, if you'reaware? I don't remember. Do you recall in general terms what is contained therein? 144 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058909 1 2 3 4A 5 6 7 8 9 10 Q 11 12 A 13 Q 14 A 15 Q 16 A 17 Q 18 19 20 21 22 23 24 If you'd like to, you can reference the manual. It does have a format; a grouping. Well, I remember the format. I don't recall the specific wording. It again referred to prolonged breathing and skin problems. I'd have to see a current version to refresh my memory. I haven't looked at one for years. Okay. Is such a material safety data sheet still maintained - Yes. -- for PCB products? Yes. Revised periodically? Yes. We've talked about the inhalationpotential problem with PCBs. And you'veindicated, I believe, that the levels that were suggested by the industrial hygienists - one a governmental group, one a private group - were at certain levels for 1242 and 1254. Do you recall any specific length of time that those levels were okay or any 145 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy 0 Su'ite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058910 1 2 3A 4Q 5A 6Q 7 8 9A 10 Q 11 12 A 13 14 15 16 17 18 19 20 21 22 23 24 quantitative values as to how long you could breathe them at that level? It's the 8-hour time weighted average. And that's over the course of a normal work day? Correct. Do you ever recall reading anything about short term, but greater exposures, in inhalation; the adverse effects of those? No. How does the vapor of PCB get into the atmosphere? In many ways. I can develop a scenario where liquid PCBs are spilled on a hot surface, generating a vapor. That's what happened in a die casting mill working foundry. The transfer systems, if they should develop a leak, would release a very high temperature material. And upon release, vapors can be seen coming off that spill. In order to get obvious vaporization, it requires high temperatures. At room temperatures, the vapor pressure of PCBs is so low that the limits 146 C & L RepoRTiNq CERTified Court Reporters 29555 NoRihwESTERN HiqliwAy Suite 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058911 established by these industrial hygiene groups would not be exceeded. And you can say that, irregardless of the size of the room or the ventilation of the room? The size of the room, the amount of PCBs present, the temperatures in the room and the period. If the room has been sealed for a long time, it could get saturated with PCBs. How long this could take would be variable. But it's conceivable; possible. Okay. And the higher the temperature of the PCBs, obviously, the other parts of that formula can go down? The higher the temperature, the more vapor that's going to be put in the room generally, correct? MR. DINON: I'm sorry. Did you say in general? MR. LEDBETTER: In general is what I meant to say. I think I said generally. MR. DINON: Okay. THE WITNESS: In general, the answer is yes. 147 C & L RepoRTiNq CeRTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058912 1 I would like to elaborate on that 2 answer. 3 BY MR. LEDBETTER: 4Q Sure. Feel free to do so. 5A The thought occurs to me that the amount under 6 the condition we described of a 7 closed room, the possibility of PCB vapors 8 accumulating to some detectible levels, that is 9 also influenced not by only the conditions we 10 described - size of room, amount of spill, 11 temperature, how tight it is, how long it's been 12 enclosed ~ but it's also affected by other 13 materials in the room. 14 Q Such as? 15 A Well, I'm thinking' specifically of transformers 16 fluids that have chloro benzenes in them. 17 Chloro benzenes are much more 18 volatile. They would come off first. Their 19 presence in that air space would impact on the PCBs 20 that also would be present. 21 Q What impact would they have; the chloro 22 benzenes? 23 A They are present eventually in the proportions 24 of which they are present in the original liquid, 148 C & L RepomiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy Suite 508 SouThfiEld, MI 48054 (515) 827-8589 WATER PCB-SD0000058913 1 2 3 4 5Q 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 and in proportion to their volatility. There's a mathematical relationship .that can be worked out as to how much chloro benzenes will inhibit the vaporization of PCBs, Let's say that it's roughly on a 63 to 37 percent relationship. Are you aware of how you would figure out how that much chloro benzene would affect the vaporization of PCB? MR. DINON: 63 to 37 percent of which? MR. LEDBETTER: 63 PCB, 37 chloro benzene. THE WITNESS: I'm aware of the basic mathematics that would be involved. You'd have to go to a physical chemist and his computer for him to determine it for you. But it's dependent on the temperature, the total pressure in the room, the amounts in the original liquid, and the vapor pressures of each of those. And there is an equation that can be satisfied, and an answer come out telling you how much benzene is in the air and how much PCBs 149 C & L REpoRThq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058914 1 as related to the amounts in the liquid* 2 BY MR. LEDBETTER: 3Q Does one have more odor thananother? 4A Oh, yes. 5Q Which has more odor? 6A 7Q The benzenes. Of course, also in your formula, you'd have to 8 plug in the heat, the size of the room? 9A .Well, the vapor pressure is related to the 10 temperature. 11 Q Are you aware inthisparticular circumstance, 12 that what we're talking about is allegedly 13 liquid leaking from PCB transformers? 14 A Yes. 15 Q Have you any idea of the amount of liquid that 16 we're talking about over the period of time that 17 we're talking about? 18 A In a general way. It's small amounts. Visible, 19 but not pools of it. 20 Q If that amount does leak out of transformers, you 21 know, a leakage so that it is visible running 22 down the transformers and even puddling to 23 some degree on the floor, would that suggest 24 to you that that would increase the likelihood 150 C & L REpomiNq CERTified Court Reporters 295 5 5 Northwestern HiqHwAy a Suite 508 SouTbfiEld, Ml 48054 ' (5 1 5) 827-8589 WATER PCB-SD0000058915 1 of PCBs or chloro benzenes being found in the air. 2 MR. DINON: Objection to form and 3 f oundation. 4 It's vague. Running down, pools; 5 the quantity isn't identified. The other variables 6 that he was referring to haven't been enumerated 7 or identified, to allow him to answer relevantly. 8. MR. SCOTT: Can you answer the 9 question? 10 THE WITNESS: To a matter of 11 degree. Does it suggest they would be present? 12 It does suggest that. 13 The quantities, I would have no way 14 of knowing. 15 BY MR. LEDBETTER: 16 Q Are you aware of any air samples being taken in 17 and around these particular transformers? 18 A 19 Q No. Do you have some idea of the size of the room 20 that we're talking about? 21 A 22 Q No. Do youhavean idea of the size of the 23 transformers involved? 24 A I think Ido, yes. 151 C & L REpoRTiNq CERTifkd Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SouiHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058916 1Q 2 3A 4 5Q 6 7 8A 9Q 10 11 12 A 13 Q 14 15 A 16 Q 17 A 18 Q 19 20 21 A 22 Q 23 24 And what is your understanding of the transformers? I understand that they are something like in the neighborhood of 30 to 35-gallon units. Okay. And when you're talking of 30 to 35- gallon units, you're talking about the amount of liquid in the transformers? That's my understanding. Okay. Did you come to learn that a certain amount of that had apparently leaked out of those transformers in some period of time? Yes. Okay. Do you have any idea as to how much total volume had leaked out? No. Do you know what size the room is? No. Do you know what theoperating temperature extremes might be on these particular transformers? No. If liquid -- let me withdraw that and start again. Assuming that we have an Aroclor 152 C & L RepoRTiNq CERTifiEd Court Reporters 2955 5 Northwestern HiqhwAy Sure 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058917 1 1260, and assume further that it is chloro 2 benzene that it's mixed with, would the 3 viscosity be greater than that of water? 4A Yes. 5Q And any degree as to twice as thick or -- I don't 6 know how we might measure that. Any degree that 7 you can estimate? 8A No. Icouldn't guess to it, no. 9Q It would depend also on howhot it is, wouldn't 10 it? 11 A Yes. 12 Q Assuming that that liquid does leak out of the 13 transformers at seals and/or gaskets of sorts - just 14 assume that to be true, that there is visual 15 evidence of liquid leaking from the 16 transformers - 17 MR. SCOTT: Liquid that contains 18 PCBs? Because there's no evidence that the 19 liquid that leaked from these transformers was 20 PCBs . 21 BY MR. LEDBETTER: 22 Q Just liquid leaking out of these transformers, 23 and that these transformers contained PCBs; 24 assume that to be true. 153 C & L RepoRTiNq CERTilkd Court Reporters 29555 NoRThwESTERN HiqkwAy SuiTE 508 SouddiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058918 1 Would it be a fair statement that 2 if liquid at this viscosity could leak out of 3 the transformers through the seals, that that vapor 4 would also have a tendency to come out of the 5 same area? 6 MR. DINON: Objection; 7 f oundation. 8 You've mentioned this viscosity. You 9 haven't identified the viscosity. You haven't 10 identified the temperature. You haven't 11 identified any of the factors that he indicated 12 were necessary to determine the existence or the 13 nature of the vapors. 14 MR. SCOTT: Can you answer the 15 question? 16 THE WITNESS: I can't. 17 MR. SCOTT: Fine. 18 BY MR. LEDBETTER: 19 Q Okay, Are you aware of transformers that 20 breathe? Have you ever heard that expression for 21 transformers? 22 A Yes. 23 Q Do you know what that means? 24 A I think I do, yes. 154 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy a SuiTE 508 SoutHHeW, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058919 1Q 2A 3 4 5 6 7 8 9 10 Q 11 12 13 A 14 15 16 Q 17 18 19 A 20 Q 21 22 A 23 Q 24 What does that mean to you? As temperature changes occur in a transformer, the amount of void space will fluctuate as the liquid expands and contracts. In order for that space to be filled without collapsing the unit or destroying it, it has to breathe. It has to make up for that shrinkage and loss of void space somehow. So the units do breathe. Does that suggest to you that somehow that vapor comes from the transformers, or is exhausted some way through the transformers? I don't know. There's a gas, but I don't know what it is. Some units have nitrogen blankets; some have air; some could be vapor. I don't know the system. Are you aware of any studies involving samplings of surfaces around where PCB products have vaporized and settled? No. You're aware of no wipe samples being conducted or that sort of thing? I'm not aware of wipe samples relating to PCBs, no. Well, what material are you aware of where wipe samples have been taken of vapors settling? 155 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqHway SuiTE 508 SoutHHeM, Ml 48054 (515) 827-8589 WATER PCB-SD0000058920 1A I'm aware of dioxins. That's the only wipe test 2 I'm aware of. 3 MR. LEDBETTER: Mark this as Number 4 9, I think. 5 (Whereupon Deposition Exhibit 9 6 marked by reporter) 7 BY MR. LEDBETTER: 8Q I show you what's been marked as Deposition 9 Exhibit Number 9, and ask if you can identify 10 that four-page document? 11 A I recognize this four-page document. 12 Q Okay. And that was a document prepared by you, 13 was it not? 14 A Yes; prepared at my direction. 15 Q Okay. What was the purpose for that particular 16 document? 17 A The addressee, Mr. Albert, had submitted a list 18 of questions and asked for some answers to those 19 questions. 20 Q Okay. And you attempted to provide those answers to 21 his satisfaction in that particular 22 document? 23 A Yes. 24 Q Do you recall arriving at any conclusions about 156 C & L REpoRTiNq CERTiFiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058921 1 2 3A 4 5Q 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 the potential effects or hazards of PCB in the letter that you passed on to Mr. Albert? I don't know that I arrived at any conclusions, no. Do you recall what you informed him of, as to potential hazards? MR. SCOTT: Well, the document is the best evidence of its own content, counsel. MR. LEDBETTER: Well, I'm giving him time to review the document to see if he can refresh his recollection. MR. SCOTT: That doesn't make it proper for him to testify with respect to it. Go ahead. THE WITNESS: As I indicated earlier, this was prepared at my direction. The answers to the questions were prepared by Mr. Wheeler in the medical department. I did not want to play doctor or toxicologist. I then prepared the cover letter to forward it to Mr Albert. 157 C & L REpoRTiiNq CERTified Court Reporters 29555 NonihwESTERN HiqhwAy SuiiE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058922 1 BY MR. LEDBETTER: 2Q Okay. So, you're saying the inquiry came to 3 you, but the specific answers that were provided 4 to the specific questions of Mr. Albert were 5 provided by Mr. Wheeler? 6A Correct. 7Q And that was all sent out as an entire document 8 under your signature? 9A Yes. 10 Q Do you recall in this time period that you're 11 involved in PCBs from 1970 to 1976, if you 12 were aware of any other studies listing 13 potential adverse effects of PCB? 14 A Other studies other thanwhat? 15 Q Of otherpotentialadverse effects. 16 We've talked about some of the studies 17 already, pertaining to dermatitis and chloracne 18 problems, correct? 19 A Yes. 20 Q We've talked about some studies relating to 21 potential respiratory problems, correct? 22 A Yes. 23 Q You've mentioned in passing a few minutes ago, that 24 you were aware of the Yusho incident that 158 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SoutHHeU, Ml 48054 (511) 827-8589 WATER PCB-SD0000058923 1 2A 3Q 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 occurred in Japan in 1968? Yes. Were you aware, from that study and others, of other potential harmful effects to those people from PCB? MR. SCOTT: At what period of time? MR. LEDBETTER: This is from the time period that he was involved with PCBs from 1970 through 1976, if he learned of other studies. MR. SCOTT: All right. THE WITNESS: Let me try to recall. Monsanto had under way studies with rats, dogs and chickens in 1970. And these studies were finally completed in '71. I was informed that from these studies, the following effects were noted: That the higher-chlorinated PCBs as represented by Aroclor 1254 and 1260, at the higher dose levels, which was represented by the 100 parts per million in the daily diet of the test animals, resulted in loss in weight gain of the test animal, enlarged livers with some cell deformations, and some effect on the 159 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouiHfiEld, MI 48054 (51 5) 827-8589 WATER PCB-SD0000058924 1 reproduction in terms of size of the litters in 2 the rat studies. 3 In the chicken studies, the 4 lower-chlorinated PCB as represented by Aroclor 5 1242, affected the ability of the chickens to 6 reproduce in terms of hatchability of the 7 eggs and the thinness of the eggshell. 8, And this occurred at the low levels, 9 of about -- it was below 10 parts per million. 10 I think a retest showed 3 or 4 parts per million 11 in the daily diet. 12 Those are the Monsanto studies. 13 There was later another study using rats, 14 conducted by Dr. Renata Kimbrough of the CDC, in 15 Atlanta, Georgia. And her pathologist described 16 the liver cell changes as pre-cancerous. 17 I'm aware of the dialogue that 18 took place between the pathologist. I'm aware 19 that they looked at slides from the animal tissues. 20 And in fact with the Monsanto 21 studies, we went back to the reserved frozen samples 22 and sliced some more sections to make sure that the 23 damaged part of the liver was missed. 24 To make a long story short, the 160 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqHwAy SuiTE 508 SoutNHeIcI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058925 1 conclusion was amongst the pathologists, that 2 the effects seen in the animals tested by Dr. 3 Kimbrough did show a change in cells. That 4 change was not observed in the animals tested by 5 the Industrial Biotest laboratories for Monsanto. 6 And there was an agreement in that amongst the 7 pathologists. The interpretation of the damaged 8 cells in Dr. Kimbrough's samples remains in 9 dispute, as I understand, to this day. 10 I'm also aware of a later study 11 by the National Cancer Institute, using Aroclor 12 1254. This now gets into the '80s. 13 The institute reported the 14 findings on that study, which was also a 15 lifetime study, that Aroclor 1254 did not 16 show cancerous effects. 17 I'm aware of some tests done in 18 the Gulf of Mexico by the laboratory at Gulf 19 Breeze, Florida, which established that shrimp, the 20 juvenile, the young shrimp, are extremely 21 sensitive to PCBs. They do not survive, 22 whereas the adult shrimp seem to be able to 23 withstand a fairly high dose. 24 I'm also aware that the Pautaxant, 161 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058926 1 Maryland laboratory - the wildlife laboratory 2 established earlier reports by Dr. Risebrougl} on 3 the pelicans in California attributing harm by 4 PCBs were not supported by the data. In the opinion 5 of the Pautaxant, Maryland laboratory, the DDT was 6 the cause for that affect. 7 The reports that were earlier out of 8 the North Sea and the Irish Sea - those reports 9 were finally published in, I believe, '72 10 indicated that the seals, the young seals died 11 because of malnutrition, separation from their 12 mothers. 13 The birds, as I recall, were 14 attributed to some storms and they were blown 15 off their normal paths and had nutrition 16 problems as well. 17 So, the presence of PCBs in those 18 animals was very real, but the effects were 19 attributed to other factors other than PCBs. 20 On the dog studies - going back to 21 Monsanto studies - the dogs were reported at 22 high levels of the high-chlorinated PCBs, to 23 suffer ulcers and bleeding in their digestive system. 24 I can't recall the other studies. 162 C & L REpomiNq CERTified Court Reporters 295 5 5 Northwestern HiqHwAy Sure 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058927 1 BY MR. LEDBETTER: 2Q Okay. Referring specifically to the potential 3 liver effects of polychlorinated biphenyls, your 4 studies agreed, did they not, that PCBs, at least 5 as tested, were responsible for liver lesions? 6A I'm not familiar with the lesion terminology. I 7 do know that there was an effect on the liver. 8Q You also mentioned that there was an enlargement 9 problem that could be encountered with exposure 10 to PCB, correct? 11 A Correct. 12 Q How about dysfunction of the liver in some 13 way? 14 Are you aware of any problems of 15 that sort? 16 A I was led to believe that at very high levels 17 again. 18 Dr. Kelly's the best one to answer 19 that one on the affects and how the liver produces 20 certain enzymes in order to cleanse the body of 21 22 Q 23 these materials. Have you read any studies regarding cirrhosis of the liver caused by PCBs or suspected to be 24 caused by it? 163 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (515) 827'8589 WATER PCB-SD0000058928 1A 2Q 3 4A 5Q 6 7A 8Q 9 10 11 A 12 Q 13 14 15 16 A 17 18 19 20 21 22 23 24 I have not seen any. Have you read any studies on the effect of PCBs being related to impotence in human beings? No. Have you read any studies regarding PCBs and its effect in elevated triglycerides? No. Have you readany studiesregarding the suspected relationship between PCB and a phenomenon referred to as peripheral neuropathies? No. In thisperiod of 1970, you indicated that Monsanto performed some studies. Why were those studies performed in 1970, if you know? With the reports where we later confirmed that PCBs were being found in the environment and the early allegations that they could be harmful, Monsanto wanted to establish could they or could they not harm living creatures. There was no protocol for testing for that purpose for industrial chemicals. Our medical department sought advice from regulatory agencies, which was not forthcoming. So they 164 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 NoRThwESTERN HiqhwAy SuiTE 508 SoudrfiEld, Ml 48054 (51 5) 827'8589 WATER PCB-SD0000058929 1 2 3 4 5 6 7 8 9 10 11 12 Q 13 A 14 15 16 17 18 19 20 Q 21 22 A 23 Q 24 chose to test these industrial chemicals in much the same way that food chemicals are tested; not with the intent of registering them for food use, but to use existing test protocols. In addition to testing with mammals and birds, the initial plan included testing with fish to establish aquatic toxicity. The whole purpose of that was to determine once and for all: Do these man-made chemicals create any problems with living things? Were the fish studies done at Monsanto's direction? They were attempted. They proved a failure. And by the time we decided that, our laboratory just couldn't do it properly for us, there were enough government laboratories involved. And we decided that their expertise was adequate, and any findings coming from those labs were good enough for Monsanto. Okay. The laboratory that you're referring to is IBT? Yes. Do you recall who it was that commissioned IBT to do those particular studies? 165 C & L REpoRTirviq CERTifiEd Court Reporters 295 55 NortNwestern HiqhwAy 0 Suite 508 SourtdiEtd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058930 1A 2Q 3 4A 5Q 6 7A 8 9 10 11 12 Q 13 14 15 A 16 17 18 Q 19 20 A 21 Q 22 23 A 24 It was Monsanto, through Mr. Wheeler. And Mr. Wheeler was part of Mr. Kelly's department, right? Correct. And they were commissioned sometime in 1970, and concluded in '71? No. The studies were started in '68. There's always some preliminary work that must go on to establish feeding levels and protocols. The lifetime feeding studies were terminated in '71, which meant that they were started in '69. So, the time period in '68, as I recall, that was before there was the generalized knowledge of the problem in the environment; is that true? Well, the confirmation of it. It was an evolving situation. Monsanto started these early studies quickly. Okay. And was that after the Swedish doctors had done their work? Yes. And that, you believe was about 1968, when it was first reported? In '67. And in '67, we had also sent samples to Dr. Risebrough. And in '68, he was working in his 166 C & L REpomiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiiE 508 SouThfiEid, Ml 48054 (515) 827-8589 WATER PCB-SD0000058931 1 2 3Q 4 5A 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q 23 24 A laboratory and Mr. Wheeler was working with some preliminary animal studies. Was the test given to IBT in any way related to the results of the Risebrough studies? The connection between the pelican and its egg problems was considered when the dialogue with IBT initially took place. The intent there was to get IBT to do some studies with some wild bird species. They were looking at the Mallard duck. But by the time the protocols were established and the agreements made, the opportunity for getting wild duck eggs had passed. They're not like domestic chickens that lay eggs any time man wants them to. So, really as a substitute, it was decided to go with the standard chicken test and forego the wild duck test. So, in answer to your question: Yes. The work of Risebrough did trigger this line of thought. Okay. And eventually IBT ended up using chickens as opposed to wild game? Correct. 167 C & L REpoRTiNq CERiifiEcJ Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058932 1Q 2 3 4A 5Q 6A 7Q 8 9 10 11 12 A 13 Q 14 15 A 16 Q 17 18 19 20 21 22 23 24 And IBT's test of fish, you've indicated also ended up -- or potential test of fish, also ended up as a failure? Correct. So, no evaluation out of that? Correct. Subsequently -- well, first, who is it at IBT that was involved in these particular studies? Was it one particular area over there that the studies were given to at IBT? I don't think I understand the question. Okay. Under whose jurisdiction were these tests done at . IBT, if you know? I can give you myunderstanding. Okay. Dr. Calandra, the head of the laboratory was involved. His principal assistant, and I think he's the assistant director of the lab, Dr. Fancher, was very much involved. There was a Dr. Keplinger, who assumed the lead role when Dr. Fancher retired. And there were many other individuals throughout the organization that did the on-hands work in the laboratory. 168 C & L REpoRTiNq CeiuifiEd Court Reporters 295 5 5 Northwestern HiqhwAy 0 SuiTE 508 SouThfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058933 Do you recall a fellow by the name of James Plank (phonetic)? No. Do you recall a fellow by the name of Dennis Lindbergh (phonetic)? No. Other than its connection to IBT, has Monsanto had any connection with Dr. Fancher or Dr. Keplinger, other than at IBT; any employer or employee relationship? The only contact that I know Monsanto had was as IBT employees, as a retiree of IBT, Dr. Fancher. Okay. And the same with Dr. Calandra? He *s never been employed by Monsanto? That's true. And James Plank you don't know? I don't know. And you don't know Dennis Lindbergh? No. How about Paul Wright? Do you know Paul Wright? I know Paul. Who is Paul Wright? Paul Wright is an ex-employee of Monsanto and an ex-employee of IBT. 169 C & L RepoRTiNq CERTifiEd Court Reporters 29555 NonThwESTERiv HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058934 1Q 2 3A 4Q 5A 6Q 7 8A 9Q 10 11 A 12 Q 13 A 14 Q 15 16 17 A 18 Q 19 20 21 A 22 Q 23 24 A Do you recall when Mr. Wright began working at Monsanto? No. Do you recall when he began working at IBT? No. Do you know what time period that he worked at IBT? No. Do you know if he worked for Monsanto before and after he worked at IBT? Before and after, yes. He did so? Yes. It's myunderstanding. If I gave you the period of, say, 1971 to 1972, that Mr. Wright was at IBT, would that seem about right to you? That's about right,sure. And after he finished at IBT, he returned to Monsanto at a different post than he had previously occupied? Yes. Do you recall what kind of post that was; what position? He came in as a toxicologist reporting to Mr. 170 C & L RepoRTiNq CERiified Court Reporters 295 5 5 NoRThwesTERN HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058935 1 Wheeler in Monsanto's medical department. 2Q Was that originally, or after his stint at IBT? 3A 4Q After. Okay. Do you recall that IBT has been 5 criticized somewhat for the laboratory results 6 and the processus followed? 7 MR. SCOTT: In what situation, 8 counsel? 9 MR. LEDBETTER: Any time. 10 MR. SCOTT: Any investigation of 11 any kind? 12 MR. LEDBETTER: Any 13 investigation. 14 , MR. SCOTT: Not necessarily the 15 one that Monsanto commissioned? 16 MR. LEDBETTER: Not necessarily 17 this one. Any one. 18 MR. SCOTT: Okay. 19 If you know, you can answer. 20 THE WITNESS: I'm aware of that, 21 yes . 22 BY MR. LEDBETTER: 23 Q Okay. And you're aware that criminal 24 prosecutions came from those? 171 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SoutHfiEtd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058936 1 A Yes. 2Q And you're aware that there was a conviction? 3A Yes. 4 MR. SCOTT: Objection. You know, 5 the whole line is irrelevant, because, A, it doesn't 6 relate to any studies that Monsanto did. 7 And, B, it's totally irrelevant. 8. MR. LEDBETTER: I certainly think it 9 applies to the credibility of the studies done by IBT, 10 which is why I'm asking the questions. 11 MR. SCOTT: Oh, horse manure. 12 BY MR. LEDBETTER: 13 Q Were you aware of the conditions that allegedly 14 led to the complaints against IBT? 15 A I did not personally see them, no. 16 Q Okay. You had some knowledge of what was 17 happening at IBT that caused the grand jury to 18 indict certain members of IBT? 19 A I've heard allegations. 20 Q Did that affect -- to yourknowledge, were those 21 allegations relating to the test processus being 22 followed? 23 MR. SCOTT: Again, counsel, in 24 what respect? 172 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NortIhwestern HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058937 I think the question is vague, it's improper in form, and I object to it unless you specifically relate it to any test or any test procedure so that this witness knows what you're talking about. MR. LEDBETTER: Were you aware of what specific tests were involved in the indictment? No. Are you aware of what products were involved in the testing? Some of them. Are you aware if it was animal testing that was being done? Yes. Was it involving mice, for example -- or rats, I mean? I understand rats were mentioned. Did it ever involve chickens? I don't recall chickens. Do you recall anything about dogs or other primates? No. MR. SCOTT: Wait a minute. Did you say MR. LEDBETTER: Dogs or primates. 173 C & L REpomiNq CERTified Court Reporters 295 55 Northwestern HiqHwAy Suite 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058938 1 MR. SCOTT: Okay. Not "other 2 primates. 3 Go ahead. 4 BY MR. LEDBETTER: 5Q Do you recall if any of the tests they were 6 criticized for involved dogs or primates? 7A No, I do not. 8Q Did you ever hear of something called the Swamp 9 oyer at IBT? 10 A Only what I read in the Wall Street Journal. 11 Q Do you know somebody by the name of E. V. John, 12 J-o-h-n? 13 A Yes. 14 Q Who's Mr. John? 15 A He was a Monsanto employee working in the public 16 relations department. 17 Q Do you know what he did in public relations? 18 A I can't speak for his entire Monsanto career, 19 Q Just what you're aware of. 20 A He was assigned to work on public relations 21 matters associated with the organic division of 22 Monsanto Company in the period 1970, 1971. 23 Q So that was in the period that you were in 24 charge of PCBs, right? 174 C & L REpoRTiNq CERTiFied Court Reporters 295 55 Northwestern Hiqtrwsy SuiTE 508 SouTkfiEid, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058939 1A 2Q 3 4 5A 6Q 7A 8Q 9A 10 11 Q 12 13 A 14 Q 15 16 A 17 Q 18 19 20 A 21 22 Q 23 24 A When I was initially placed in charge, yes. Was he one of the fellows who had been involved in getting information out to the public about PCBs? Yes. Do you recall somebody by the name of Howard Minkler? Yes. Who is Mr.Minkler? A former Monsanto employee who in 1970, was the general manager of the organic division. And,again, the organic division included the manufacture of PCBs, correct? Correct. And under that division, as I recollect, came the - I think it was called special fluids? Functional products group. I'm sorry. Was there also a title called functional fluids, or is that synonymous with the one that you just mentioned? They're synonymous. Functional fluids group was the correct title, I believe. Okay. And then would that fall directly under the organic chemical division? Yes. 175 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqHwAy SuiTE 508 SourHfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058940 1Q 2 3A 4 5Q 6 7A 8Q 9 10 A 11 Q 12 13 A 14 Q 15 A 16 17 Q 18 19 A 20 Q 21 A 22 Q 23 24 Anything in between the two, as far as a step up or step down? There's a position in there, but not a group. There's an Assistant General Manager between the two. Okay. But he would be Assistant General Manager of the organic chemicals division? Correct. And then reporting to him, I assume, would be like the head of the functional fluids group? Yes. Okay. Do you recall some fellow by the name of Springate, J.E. Springate? Yes. Who is Mr. Springate? Mr. Springate was the Director of the plasticizers group. Do you know if he had any involvement, to your knowledge, with PCBs? Yes. To PCBs contained within plasticizers? Yes. Did heplay any role in the literature that was released to the public regarding -- I'm sorry, to the customers regarding the use or cautions of 176 C & L REpoRTiNq CERTifi Ed Court Reporters 295 55 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058941 1 PCBs in plasticizers? 2A He saw versions of the drafts as the document was 3 being prepared. He was aware that his group, his 4 directors of marketing were involved, and 5 supported that action. 6Q Are you familiar with Orville Hicks? 7 MR. SCOTT: Orville Hicks? 8, MR. LEDBETTER: Orville Hicks. 9 THE WITNESS: Yes, I'm familiar with 10 Mr. Hicks. 11 I've forgotten what his assignment 12 was . 13 BY MR. LEDBETTER: 14 Q Something in chemistry? 15 A I associated him with the research department. 16 Q A research chemist? 17 A Yes. 18 Q Did he do any work on PCBs that you're aware of? 19 A As best I recall, yes. But I don't recall 20 specifically what. 21 Q Would he have done some of the analyses that you 22 were talking about earlier to verify the content 23 or the purity of PCBs, for example? 24 A I do not associate Mr. Hicks with that type of 177 C & L REpoRtiNq CgRTified Court Reporters 2955 5 Northwestern Hiqhwsy * Suite 508 SoutHfisld, MI 48054 (515) 827-8589 WATER PCB-SD0000058942 1 2Q 3A 4Q 5A 6 7 8 9Q 10 11 12 13 A 14 Q 15 16 A 17 Q 18 19 A 20 Q 21 22 A 23 24 Q work, no. Do you recognize the name Cumming Paton? Yes. What was Mr. Paton's job duty or job duties? Of course, it varied through the years. He was a marketing representative of the plasticizers group in 1970. He then became the principal PCB type plasticizer spokesman. Okay. Were you aware if he had authored or at least sent through his office various communications to customers regarding PCBs or their safe use of PCBs? Yes. And your understanding is that was primarily in plasticizers? Yes. How about a fellow by the name of Pickard? Do you know a Mr. Pickard? Pickard? That you may have goneto Washington with at some time? I'm sorry. I was thinking of the wrong spelling. Sam Pickard. And what did Mr.Pickard do? 178 C & L REpoRTiiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqhway SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827.8589 WATER PCB-SD0000058943 1A Mr. Pickard is the Vice-President in charge of 2 the Monsanto Washington, D.C. office. 3Q 4 What kind of office does Monsanto have in Washington, D.C.? 5 MR. SCOTT: What do you mean, what 6 kind? 7 BY MR. LEDBETTER: 8Q What do they do there? 9A Some of it is lobbying efforts. And a good bit of 10 it addresses the registration of agricultural 11 chemicals, pesticides, weed killers and the like. 12 And also they handle the 13 registration of approved chemicals with the Food 14 and Drug Administration. 15 Q And did - 16 A And also contacts with the Environmental Protection 17 Agency, and other tax departments, and commerce and 18 so on. 19 Q Did you have the occasion with Mr. Pickard to 20 accompany him or he accompany you to meet with certain 21 legislators regarding the question of PCBs? 22 A No. Mr. Pickard and I did not go together. 23 Q Do you recall accompanying him elsewhere, other 24 than to Washington, for a subject concerning PCBs? 179 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Northwestern HiqHwAy SuiTF 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058944 1A 2 3Q 4A 5Q 6A 7 8Q 9A 10 11 Q 12 A 13 14 15 Q 16 A 17 Q 18 A 19 Q 20 21 A 22 Q 23 24 I do recall I accompanied Mr. Pickard on other matters. I don't recall any with PCBs. Do you know a Paul G. Benignus? Do I know him? Yes. What does Mr. Benignus do or what did he do? Mr. Benignus was a former Monsanto employee who was the marketing manager for dielectric fluids, Do you remember what time period that was? Gosh, almost his entire career. Up until he retired in 1972. What about Cole Webber? Who is Mr. Webber? Mr. Webber was in 1970, a manager of product acceptability, who assumed PCB responsibilities in 1976 when I was re-assigned. Did he work with you prior to 1976? On PCBs? Yes. For about three months we worked together, yes. And that was just prior to your leaving that position in 1976? ' Correct. And he succeeded you then in theposition with responsibilityof various chemicals,including PCBs, in that time period, 1976? 180 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqtrwsy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058945 That is correct. Do you know how lpng he remained in that position? No, I do not. Do you recall any information that you provided to Mr. Webber regarding PCBs, or access to information? I gave him my whole set of files; everything. You had separate individual files at that time, in 1976? MR. SCOTT: That isn't what he said. THE WITNESS: I had PCB files that I turned over to Mr. Webber. MR. LEDBETTER: Okay. Can you describe those files to me; what files you had that you turned over? As I recall, they were about four four-drawer types, about 16 drawers full of paper, containing all of the documents that I had accumulated since 1970. Did this include studies, for example? Copies of them. The originals were over in the medical department. I had summaries and abstracts and shortened versions; not the full documents. Did you have the studies, for example, as far back as 181 C & L REpoiuiNq CERTified Court Reporters 29555 Northwestern HiqhwAy Suite 508 SouTHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058946 1 2A 3Q 4 5A 6Q 7 8A 9Q 10 A 11 Q 12 13 14 15 16 A 17 18 19 20 21 22 23 24 the 1930s at that time period? There were some copies in there, yes. And did you have copies of certain bulletins regarding PCB products? Yes. Did you have copies of certain Standard Operating Practices Manuals, or portions of them? No. How about process manuals or portions of those? No. Any other category of information that you would have retained in your 16 drawers of filing at that time, from '70 through '76? We've talked about studies, we've talked about bulletins. Letters to customers, letters from customers, responses, correspondence with government agencies, government documents, copies of PCB scientific literature, research reports that related to PCBs, labels, copies of revised labels, or correspondence relating to proposed changes in labels, copies of presentations before Monsanto committees or regulatory agencies, or even a congressional committee. 182 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 NortItwestfrn Hiqhwav SuiiE 508 SouTlnfield, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058947 1Q 2 3A 4Q 5A 6 7 8 9Q 10 A 11 Q 12 13 14 15 16 A 17 Q 18 19 A 20 21 Q 22 A 23 Q 24 Did you appear before any congressional committees regarding the subject of PCBs? Yes. Which ones? I don't recall its exact name. It was a subcommittee that I recall was associated somehow with Merchant Marine chaired by Congressman Stubbs of Massachusetts. Any others that you .recall? Not congressional. On your C.V., we had only gotten up to '72 through '76. . You remained in the same position, although without responsibility with PCB, as I recall, up through '77? That is correct. And then in '77, you took a similar titled job, but at a different location? No. What happened is that Monsanto reorganized and formed a new unit. And that's where the Intermediates comes in? The Chemical Intermediates Company. And you did not have involvement with PCBs in that time period? 183 C & L REpoRTiiviq CERTified Court Reporters 295 55 NoRThwESTERN HiqkwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827*8589 WATER PCB-SD0000058948 1A 2Q 3 4 5A 6Q 7 8 9A 10 Q 11 12 A 13 Q 14 A 15 Q 16 17 18 19 20 21 22 23 24 That is correct. Were you periodically called upon to provide service to Mr. Webber or advice to Mr. Webber or others at Monsanto regarding PCBs? Not often, but I was available, yes. Did you have occasion to involve yourself in litigation through either providing support services or being deposed or trial testimony? Yes. Do you recall approximately how many times you appeared at trial? In all or just '77? From forward; 1977 forward. '77 forward -- Relating to PCBs; not anything else you may have been. MR. SCOTT: To today? 'MR. LEDBETTER: To today. MR. SCOTT: This is one. MR. LEDBETTER: Well, this isn't a trial yet, but this is one. MR. SCOTT: That's right. THE WITNESS: I'm going to guess somewhat here. Since '77, I've been involved with litigation matters about eight times. 184 C & L REpoRTiNq CERTified Court Reporters 295 5 5 NoRThwFSTERrs HiqhwAy Suite 508 SouTkfiEld, Ml 48054 (5 1 5) 827'8589 WATER PCB-SD0000058949 1 BY MR. LEDBETTER: 2Q Okay. Now when we're talking eight times, is 3 this at trial actually, or is it depositions, or 4 just any litigation matter? 5A One trial and seven depositions. This is an 6 estimate. I don't have a score sheet. 7Q Okay. The trial that you appeared at, do you 8 recall where that was? 9A It was up in Michigan. 10 Q And that's Bad Axe, Michigan? 11 A Yes. 12 Q And that was regarding silos or something, wasn't 13 it; the plasticizers on the inside of the silos? 14 A Yes. 15 Q The Aroclor involved there was a different 16 Aroclor than 1260 and the 1^00 series, correct? 17 A It was a 1200. 18 Q Was it a 1200 series? 19 A Yes. 20 Q Okay. What were the seven depositions, if you 21 recall those; what they were involved with, 22 roughly? 23 A I'll try to remember them. 24 Depositions involved with the Michigan 185 C & L REpoRTiNq CERTifiEd Court Reporters 29555 Notuhu/ESTERN HiqhwAy SuiTE 508 SouThfisld, MI 48054 (51 5) 827-8589 WATER PCB-SD0000058950 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q case we just talked about. I'm having trouble with my dates. A deposition in South Carolina involving contaminated waterways from a capacitor plant. A deposition relating to the Bloomington, Indiana landfill and sewage treatment being contaminated with PCBs from a capacitor plant. A deposition regarding the replacement of transformers in an office building in which the owner was seeking financial relief. There was a deposition regarding some transformer manufacturer in Texas, who had dumped PCBs in his property. A State agency was seeking remedial cleanup action and he was seeking financial reimbursement. Last week I had a deposition in a case in Texas, in which many individuals are claiming health effects due to the exposure to PCBs at the work place. I don't recall any more, but -Do you recall another one in Michigan, regarding 186 C & L REpoRTiiNq Cert! fiecJ Court Reporters 295 5 5 Northwestern HiqHwAy " SuiTf 508 SouThfkld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058951 1 2A 3Q 4 5A 6Q 7A 8Q 9 10 A 11 12 Q 13 | A 14 15 16 17 Q 18 19 A 20 21 22 23 24 PCBs in some sort of dental compound? Yes. But that was before 1977. Okay. You think that that position occurred sometime before '77? I think it did. Okay. But like I said, I'm having trouble with my dates. Do you recall any involvement with any case in California regarding PCBs? No, I've never been involved. There was a case in Colorado. Do you recall what that one was about? I take that back. I was prepared to appear and I was told to go home. So, I never did participate in that one. I don't know what happened. Okay. Do you recall the type of product involved there? It was PCBs. I don't recall the source. But it seems to me that PCBs somehow were found on a farm, and the owner of the farm claimed some harm to his property. I don't know if it was heat transferred PCBs or dielectric. Scrap PCBs 187 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqhway Suite 508 SoutHfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058952 1 2Q 3 4 5 6A 7Q 8A 9 10 11 Q 12 13 14 A 15 16 17 18 19 20 Q 21 A 22 23 24 is all I remember. And then prior to 1977, other than the dental case, do you recall any other PCB cases that you were involved in with either a trial or a deposition? Yes. What werethose? Well, there weretwo that went totrial. One I will refer to as the mink case in New Hampshire. That was the claim about the mink somehow losing its mink or something of that sort? The poor things dying or some such thing? The allegation was that as a result of ingesting PCBs in their diet, the mink had tw6 problems. One, they could not reproduce normally; they failed to reproduce. Secondly, their pelts were inferior. The second trial? The second trial was a trial brought in the State of Tennessee, involving transformer liquid of a new transformer on route from a GE plant to a customer. It developed a leak. The driver of 188 C & L REpomiNq CERTifiEd Court Reporters 29555 NoRThwESTERt* HiqhwAy Suite 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058953 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Q 15 16 A 17 18 Q 19 A 20 21 Q 22 23 A 24 the transfer vehicle was pulled aside by the Highway Patrol. They talked to the dispatcher and the dispatcher advised them to just drain the whole unit. And he did, on the shoulder of the road onto the farm land. And as a result, we had a farmer claiming health effects for his family and damage to his farm value, contaminating a cattle pond and contaminating his herd. In addition to that, there was an individual who was on the same roadway heading in the opposite direction, claiming that with his window down, he was splashed with the material and suffered harmful health effects. Do you recall what time period that that first alleged exposure occurred? I believe it was in '74, and the trial was '75; something like that. Did you give a deposition also in that case? It was a very short deposition and then we went to the courtroom that same day. All right. Any other depositions in that pre1977 period? We tallked about the two trials. Yes. Both trials had depositions involved in them. 189 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern Hiqhway Suite 508 SouThfiEld, Ml 48054 (51 5) 827'8589 WATER PCB-SD0000058954 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q 23 A 24 Q Then there was a North Carolina chicken case; Holly Farms Chickens. This had to do with breeding hens not laying eggs, and the eggs that were laid wouldn't hatch - it effected the whole operation - as a result of contaminated poultry f eed. There Was a similar situation that occurred in New York State in the Catskill area; PCBs in poultry feed affecting flocks. In Indiana, there was another dairy case with silo coatings affecting cattle herds. In Montana, there was a case of a leaking transformer in a packing house, - beef and pork packing - where the transformer oil got into the sewage system from which waste from the packing operation are collected and salvaged and placed in animal feed; you know, the fat and the blood, along with PCBs. That was in Montana. Did I mention a case in -- yes, I did. The Catskills? South Carolina. South Carolina? I have North Carolina, Holly 190 C & L RepoRTiNq CeRiifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuIte 508 SoutHHeW, Ml 48054 (5) 5) 827-8589 WATER PCB-SD0000058955 1 Farms. 2A Yes. Oh, yeah. The Waukekan Harbor-Outboard Marine, 3 This was the use of PCB hydraulic 4 fluids at Outboard Marine. 5 MR. SCOTT: Hole on one moment. 6 (Off the record) 7 BY MR. LEDBETTER: 8Q We were talking a moment ago, Mr. Papageorge, 9 about the number of depositions you had given 10 pre-1977, and the last one you've discussed with us 11 was the Waukekan. 12 Is there another one after that, or 13 another one in that time period that you can recall? 14 A I can recall one more, but I don't recall which 15 time period it falls into. 16 This relates to PCBs in New 17 Bedford, Massachusetts Harbor. 18 Q That was reported, as I recall, in some of the 19 popular literature? 20 A I believe I saw some press clippings, yes. 21 This related to PCBs in capacitors. 22 Q Was there a manufacturing facility of capacitors 23 near there? 24 A Two of them. 191 C & L REpoRTiNq CeRiifiEd Court Reporters 0295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfield, Ml 48054 (515) 827-8589 WATER PCB-SD0000058956 1Q 2A 3Q 4 5 6A 7 8Q 9 10 11 12 13 A 14 Q 15 A 16 Q 17 18 A 19 20 Q 21 22 A 23 Q 24 Do you recall who those were? The Aerovox Company and Cornell-Dubilier. Okay. Any other depositions or trial testimonies that you can recall; other than those you've mentioned to us? I think I've covered them all. I don't recall any other ones. We've talked about a number of records and documents relating to PCBs. Was there a record-retention policy, or is there now, if you know, for documents at Monsanto? Yes. Is it a formalized document? Yes. Do you recall what the retention policy is as to those items relating to PCBs? Well, PCBs are not mentioned in the formal program. My policy was to keep everything forever. Do you know if that's been followed since you've left your office there in 1977? I do not know. Have you been involved with PCBs, other than this trial testimony and depositions, since 1977, 192 C & L REpoRTiNq CERTified Court Reporters 2955 5 NoRThwESTERN HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (5 1 5) 827*8589 WATER PCB-SD0000058957 1 2A 3Q 4 5A 6Q 7 8A 9Q 10 11 A 12 Q 13 14 15 A 16 17 18 Q 19 20 A 21 22 23 Q 24 in your job assignments at Monsanto? Yes. Okay, Maybe we could get back to that real quick, I'm sorry. I misled you. Not in my job assignment. Your involvement has been something collateral to your jobs? Correct. Can you describe what that involvement has been, other than depositions and trials? That's it. Okay. In conjunction with thiscase, didyou review any documentsrelating to this case prior to appearing here today? I was shown a group of documents that I was informed had been involved in this case in some manner. Do you know what kind of documents those were or what they concerned? I just can't distinguish one set of documents from another anymore. I really don't remember. Do you recall if it was some compilation of facts, for example, or if it was a deposition or 193 C & L REpoRTiNq CeRTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouThfiEld, MI 48054 (51 5) 827*8589 WATER PCB-SD0000058958 1 that sort of thing? 2A No. It was, as I recall, a sample of a letter sent 3 to customers. 4Q Do you recall the time period, the vintage of that 5 letter, sent to customers? 6A It was in February, 1970; very much like the one 7 that was submitted as an exhibit here earlier. 8Q This one here is dated February 18th, 1970. But 9 there's a similar letter that went out as 10 a mass mailing on February 7th, 1970? 11 MR. SCOTT: No, no, no, no. 12 THE WITNESS: February, 1970. 13 BY MR. LEDBETTER: 14 Q Okay. I'm sorry. In February, 1970, that kind of 15 letter went out to customers? 16 A Yes. 17 MR. SCOTT: That's the letter I 18 think he's talking about. 19 THE WITNESS: Yes. 20 BY MR. LEDBETTER: 21 Q Do you recall a specific letter to a specific 22 customer that you reviewed in this case? 23 A No. 24 Q Anything else in documents that you reviewed, that 194 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqhway SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058959 1 2A 3Q 4 5A 6Q 7 8A 9Q 10 A 11 Q 12 13 A 14 Q 15 A 16 Q 17 18 19 A 20 Q 21 A 22 23 24 you recall? I just can *t recall. How about photographs? Have you ever seen any photographs relating to this case? No. Never saw any photos of the transformers, for example? No. Or thetransformer room? No. Did you ever read any depositions or summaries of depositions? No. Or excerpts ofdepositions? No. Did you read any analyses, lab analyses of transformer fluid and/or tissue samples, blood samples, or anything like that? No. Did you discuss those with anyone? Mr. Caretti indicated that -- let methink a bit now. I'm getting my cases confused again. I remember a reference to some analyses that questioned as to whether the right 195 C & L RepoRTiiNq CERTifiEd Court Reporters 295 55 Northwestern HiqHwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058960 1 2Q 3 4A 5 6 7 8 9Q 10 11 A 12 Q 13 14 A 15 Q 16 17 A 18 Q 19 20 A 21 Q 22 23 A 24 Q chemical was analyzed. Do you remember anything more about whether the right chemical was analyzed? As it was described to me, the chemical was listed as PBB. And through the B, the center B, a C was written over it, creating some question as to which chemical was analyzed. That's all I recall of that discussion. All right. Were you sent any documents relating to this case? No. None actually delivered to your hands or your possession? That is correct. Those documents you have reviewed has only been while they're in the possession of someone else? Yes. ' Has that someone else primarily been Monsanto's attorneys? Yes. Did you review documents in the hands of anyone at Monsanto relating to this case? Not a Monsanto employee. Okay. In 1977, you became environmental 196 C & L RspoRTiNq CERTified Court Reporters 295 55 NoiukwEsTERN HiqhwAy SuiTE 508 SouihliEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058961 1 2A 3Q 4 5A 6 7 8 9 10 11 12 13 14 15 16 17 Q 18 A 19 20 21 Q 22 23 A 24 Q operations Director, correct? Right. What was your job duties as environmental director? I had reporting to me a staff of professionals, and we covered the three general areas. One was involved with plant emissions, solid waste, and the water affluent issues. The other was the work place health issue; industrial hygiene kinds of matters. And the third was the product acceptability function. This had to do with Monsanto products after they left the plant gate on route and in use. Making sure they get there safe, so to speak? Get there safe. And we communicated to the customers all we knew about it, and how they should be handled and so on. Was that involvement with PCB in that time period? No. Somebody else had responsibilities relating to 197 C & L RspoRTiNq CERTified Court Reporters 29555 Northwestern HiqhwAy Suite 508 SoutHHeU, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058962 1 2A 3Q 4 5A 6 7 8Q 9 10 A 11 Q 12 A 13 Q 14 A 15 16 17 Q 18 19 20 A 21 Q 22 23 24 PCBs from '77, forward besides Mr. Webber? Oh, yes. It changed several times. Do you recall who it was that succeeded Mr. Webber? I believe the activities were assumed by Mr. David Wood. But I was not close to that, so that's an impression I have. Do you recall when Mr. Wood may have assumed those responsibilities? When? From Mr. Webber. No, I don't. Any others succeeding Mr. Wood that you recall? Mr. Wood was followed by Dr. John Craddock, C-r-a-d-d-o-c-k, who currently has that assignment. And his assignment, much like your former assignment, was in charge of PCBs and other chemicals, too? No. As I understand it, it's exclusively PCBs. Did the records retention policy that we talked about, have a specific document name? That multi-page document that pertains to records retention, does it have a name or a number? 198 C & L REpoittiNq CERTifiEd Court Reporters 2955 5 Northwestern HiqbwAy SuiTE 508 SoutHHeU, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058963 1A 2 3 4 5 6 7 8 9 10 11 12 Q 13 14 15 16 17 18 19 20 21 22 23 24 It had a title. It was a booklet issued to all employees, with the policy described and guidelines, what documents should be addressed and the retention time appropriate for each, under many sub sections. I don't recall the title of the document, but I know it had the words record retention program in it, and I know it had the word Monsanto in it. Now, the best I can recall at the moment is Monsanto's Record Retention Program. Do you recall if at any time while you were at Monsanto, the PCB literature may have been incorporated in a computer? MR. SCOTT: Objection, counsel. I think you're getting into a privileged area and I'm going to instruct the witness not to answer the question. MR. LEDBETTER: You think my question relating to whether it's put on a computer is privileged? MR. SCOTT: Yes. The attorney- client privilege may be within that, and I'm going to instruct the witness not to answer, 199 C & L REpoRTiNq CeRTifiEd Court Reporters 295 55 Northwestern Hiqhwny Suite 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058964 1 You can ask me the question if 2 you want, and if it isn't a matter of privilege, 3 then I'll give you an answer. And I'll make it 4 sworn. 5 MR. LEDBETTER: Can I do special 6 interrogatories to you in that regard? 7 MR. SCOTT: If you want to, yes. 8 But I'm going to instruct this witness not to 9 answer until I've had an opportunity to discuss 10 it with our client. 11 MR. LEDBETTER: Okay, And if it 12 is something that's discoverable, then maybe 13 special interrogatories can satisfy my inquiry. 14 MR. SCOTT: Fine. 15 Can you give me the question back, 16 Lori, or not? 17 THE REPORTER: Yes. 18 (Whereupon previous question read back) 19 MR. SCOTT: We can debate it later 20 and I'll make an inquiry for you and determine 21 whether or not I'm going to assert a privilege. 22 MR. LEDBETTER: Okay. And then, 23 of course, I'm going to - 24 MR. SCOTT: If I assert a 200 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058965 1 privilege, I'll give you enough information to 2 argue your question. 3 MR. LEDBETTER: Fair enough. And 4 we can do some sort of an evidentiary hearing if 5 we need to, 6 MR. SCOTT: You can give me a 7 special interrogatory if you want. 8 MR. LEDBETTER: Okay. 9 BY MR. LEDBETTER: 10 Q At the time that you were aware of all the 11 literature in your office, was there an indexing 12 system that you kept? 13 A Do you mean was there a log kept on a separate 14 piece of paper somewhere? 15 Q Something that would lead you to whichever file drawer 16 it was in. You've got 16 file drawers. What's in 17 which. 18 A Very crude. Just open the file drawer and look 19 at the files and see what might fit. 20 Q And I remember I put it back here in 1972 or 21 something? 22 A And actually it evolved, and I became very dependent on 23 the secretaries to retrieve documents for me. 24 Q Do you have any knowledge if at a later time, an 201 C & L RepoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058966 1 2 3A 4Q 5 6 7A 8Q 9 10 A 11 Q 12 13 A 14 15 16 Q 17 18 19 A 20 Q 21 22 23 24 A indexing system was ever established for the PCB documents in your office? I do not have any knowledge. How about at the Monsanto Medical Director's office? Are you aware of any indexing system used over there? I do not know. You've never made reference to documents at headquarter's office of the Medical Director? Yes. Did you use an index system to locate the documents you're looking for? I would ask the secretaries to retrieve them for me. I do not know where they -- how they located them. Okay. You don't know if there was some sort of catalogue or index or a table of contents of some sort? I don't know. All right. Have you personally had any involvement with computer retrieval of information since 1977 -- No. 202 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouihfiEld, Ml 48054 (51 5) 827.8589 WATER PCB-SD0000058967 1Q -- relating to PCBs? 2A 3Q 4 No. Okay, ' MR. SCOTT: He may be able to 5 answer your first question then. 6 I'll talk with him after the 7 deposition and then maybe we can answer your 8 question on the record. 9 MR. LEDBETTER: Okay. And then 10 just get it all taken care of. 11 BY MR. LEDBETTER: 12 Q Is the library kept at the Medical Director's 13 office referred to as the Environmental Health 14 Library? 15 A 16 Q I do not know how it's referred to. Have you ever heard that expression; Monsanto's 17 Environmental Health Library? 18 A No. 19 Q Have you ever heard of a program referred to as 20 Monsanto's Six Point Program as it relates to 21 PCBs? 22 A Yes. 23 Q What is the Six Point Program? 24 A This program was approved by the corporate 203 C & L REpoRTiiMq CeRTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy Sure 508 SouiHfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058968 1 2 3 4 5 6 7 8 9 10 Q 11 A 12 Q 13 14 A 15 16 17 18 19 20 21 Q 22 A 23 24 administration committee in early 1970, and it had six elements to it. I'll try to recall them. One had to do with continuing the toxicology testing of PCBs. Another element had to do with the continue to refine the analytical methodology. The third element: Withdraw from those applications that were difficult to control and led to easy escape to the environment. That's number four? These are not in any specific order. Control the escaping of PCBs in the environment was the fourth one? By limiting the marketing to those applications. Continue to communicate to customers and the regulatory agencies any new developments Monsanto became aware of. What was the sixth point? It escapes me at the moment. ' I can't recall the sixth item. Was there something about, for example, disposal? Oh, yes. Look for a technology that would assist in the disposal of waste materials. And coupled with that was the control of our operations 204 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy SuiiF 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058969 1 2 3 4Q 5 6 7A 8Q 9 10 A 11 12 13 14 15 Q 16 17 18 A 19 Q 20 21 A 22 Q 23 24 A in such a way that losses down the sewer and up the vent stacks would be controlled to some acceptable level. All right. Do you recall sometime in the early '70s, that the recommended disposal practices of PCBs changed at Monsanto? Yes. What was the change, and what approximately was the time period of that change? I mentioned early 1970. It was sometime in the summer of 1970 that we were recommending that the preferred disposal of liquid scrap material, unusable, would be by incineration under the right conditions. And incineration was what we touched on earlier; about it being at the right temperature to turn the PCB product into essentially two gases? Really three. There was hydrochlorideand thenthere was carbon dioxide? And water. And water. And that had to be done at the right temperature? Yes. 205 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SoutHHeW, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058970 1Q 2 3A 4 5Q 6A 7 8 9 10 Q 11 12 13 A 14 Q 15 A 16 17 18 19 20 21 Q 22 23 24 A Was Monsanto doing that at that time period; the summer of 1970? No, but we had demonstrated by the summer of 1970 that it was doable. Was it Monsanto that demonstrated it? No. It was the John Zink Company of Tulsa, Oklahoma, that was in the petroleum furnace business designing high temperature furnaces, that demonstrated they could design a unit to handle PCBs. Okay. And then that would fully complete the environmental process so that it's just diposed of harmlessly? Yes. When did Monsanto start doing that? The unit was installed in 1971, and placed in service about the summer of '71. The material for disposal was collected starting in 1970. So we had an inventory of material that had been accumulating for about a year before we started destroying it. Is it fair that as early as 1969, Monsanto undertook a program as part of that Six Point Program, to develop a process for incineration? Oh, yes. 206 C & L RepomiNq CERTifiEd Court Reporters 295 5 5 Northwestern Hiqkway SuiTE 508 SouTkfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058971 1Q 2 3A 4Q 5A 6Q 7A 8Q 9 10 A 11 12 13 Q 14 15 16 A 17 Q 18 19 A 20 Q 21 22 23 A 24 And eventually it was put into use in 1971, in one location? Yes. And eventually multiple locations? No. Just one? Just one byMonsanto. Okay.Customers used their own individual facilities, do you recall? One customer installed their own unit. Some customers used commercial units that were becoming available in 71, '72. Did Monsanto provide recommendations or communications to its customers to notify them to return the spent fluids to Monsanto for disposal? Yes. Was that started again in the 1970 period where the collection began? Yes. Were customers told why Monsanto wanted the material to be returned to Monsanto rather than them disposing of it themselves? Yes. We had told them to not dispose them in such a way that it gets in the environment. 207 C & L RepoRTiNq CeRTifiEd Court Reporters 0295 5 5 Northwestern HiqhwAy SuiTE 508 SouTkfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058972 1 2 3 4 5 6 7Q 8 9A 10 Q 11 12 A 13 Q 14 15 16 A 17 Q 18 A 19 Q 20 21 A 22 Q 23 24 A And in response to their question, what's the best way, we said we now know we can incinerate. You can send your material to us at a given location for a given fee, and we will do it for you. What was the recommended disposal practice prior to the incineration? Authorized landfills. In containers, drums, and that sort of thing, in a landfill? Yes. Were there studies conducted by Monsanto particularly relating to replacement chemicals for dielectrics? Yes. When were those started? The early work started in about 1969. And this is all about that same time period that this environmental thing came to light, right? Yes. Was it found that there were suitable replacements for dielectric use? Monsanto did not succeed in finding a suitable 208 C & L REpomiNq CERiifiEd Court Reporters 295 55 Northwestern HiqhwA> SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827'8589 WATER PCB-SD0000058973 1 2 3Q 4 5 6A 7 8 9 10 11 12 Q 13 14 15 16 A 17 Q 18 19 A 20 Q 21 22 A 23 Q 24 A replacement. So, they abandoned the market eventually. Does that mean transformers didn't get any fluid anymore and capacitors didn't get fluid anymore? The alternative materials, as I understand it, did not have the fire resistance that the PCB fluids had. So, the trade-off had to take place. And Monsanto's attempt to find a fire resistant fluid which was also a good dielectric was unsuccessful. Okay. And that would include that group of dielectrics that you described for me; 1242, 1254, 1260? You couldn't find a suitable replacement for those? That is right. As I understand it, the dielectric fluid production ceased in 1977? Yes. Prior to that time, did the Aroclor 1260 cease production? Yes. And when was that? 1970. 209 C & L REpORTiNq CERTifitd Court Reporters 295 55 Northwestern Hiqhway Sure 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058974 1Q 2 3A 4 5 6 7 8 9Q 10 11 12 13 14 15 A 16 Q 17 18 A 19 Q 20 21 22 23 A 24 Q Okay. Why was Aroclor 1260 stopped before the others? It represented the highest chlorinated liquid, and there was a very easy replacement in the 1254. And the customers were very willing to make that replacement. It apparently made no difference in their final product. Do you recall in terms of production, say, in the five years between 1965 and 1970 that you were at the Krummrich plant, in terms of production, how the amount of PCB compared - I'm sorry, Aroclor 1260 compared to Aroclor 1254 or 1242? It was the smallest Of the three. So, it was less of a problem to replace, I presume? Yes. Was there any conclusions, to your knowledge, reached that since 1260 seemed to be a greater burden on the environment, that that would be the reason for ceasing production in 1971? In 1970, yes. That was the reason. Okay. And 1254, you've indicated to us earlier, 210 C & L RspoRTiNq CERTifiEd Court Reporters 295 5 5 NortNwestern Hiqhwsy SuiTE 508 SouThfiEld, Ml 48054 (5 1 5) 827-8589 WATER PCB-SD0000058975 1 was slightly less chlorinated, but still found in 2 the environment, but less of a long-lasting 3 effect than 1260? 4A Relatively speaking, yes. 5Q Okay. Do you know if liquid transformers have 6 been manufactured since 1977? 7A I am told so, yes. 8Q And no longer containing PCB products of any kind? 9A That's correct. 10 Q Do you know what they've been replaced with? 11 MR. SCOTT: Isn't this a question 12 for GE? 13 MR. LEDBETTER: Well, I guess it is, 14 kind of. 15 MR. SCOTT: Why don't you ask him 16 questions about his area and let Dick's witness 17 answer the other questions. 18 BY MR. LEDBETTER: 19 Q Do you know what they've been replaced with? 20 MR. DINON: Foundation. 21 THE WITNESS: I believe I do, yes. 22 BY MR. LEDBETTER: 23 Q 24 A Okay. And what were they? Some were replaced with mineral oil and 211 C & L REpoRTiNq CeRTifiEd Court Reporters 295 5 5 NoRThwESTERN Hiqhway Sure 508 SourhfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058976 1 2 3 4 5 6Q 7 8A 9 10 11 12 13 14 Q 15 A 16 17 18 Q 19 20 21 A 22 Q 23 24 A installed in a different kind of environment. Some were replaced by so-called dry units. Some are replaced by silicone fluids. And in Monsanto's opinion, none of those were suitable prior to 1977 as replacements? They were not, in Monsanto's viewpoint, a like for like kind of replacement. The installation of these units is different from what they would have been if they had been PCB units. Sprinkler systems had to be designed, different vaults -Size also? Size. Or they had to forego fire resistance, pay high insurance premiums, put in firewalls. The conditions are different. Okay. Did you do studies -- not you personally, but Monsanto do studies in this '65 through '77 period, on biodegradability of PCBs? Yes. And what studies specifically were those, if you recall? They were two active programs. One in our 212 C & L RepoRTiNq CenTified Court Reporters 295 5 5 Northwestern HiqHwAy SuiiE 508 SouThfidd, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058977 1 2 3 4 5 6 7 8 9Q 10 A 11 12 13 14 15 16 17 18 Q 19 20 21 A 22 23 24 facility in Wales, United Kingdom. The other in the St, Louis Research Center. They involved the exposure of PCBs to bacteria and the determination of what effect these bacteria had under conditions of air flow and concentration. The intent was to determine if any of the PCBs were destroyed by these bacteria. And the findings? The findings are that the lower-chlorinated biphenyls seemed to degrade fairly rapidly. Not as fast as sugar water, but faster than many chemicals. The higher-chlorinated biphenyls resist degradation. And the indication is that they would last for many years in the environment. And the higher-chlorinated levels, that's 1254 and 1260 and one other you had mentioned earlier on? ' There are components in those commercial mixtures that reflect the higher. That is, the 5 chlorine, 6 chlorine, 7 chlorine, and higher, are very resistant. And they are key components in the 213 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqbwAy SuiTF 508 SouTHfisId, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058978 1 2Q 3 4A 5 6 7Q 8A 9 10 11 Q 12 13 14 A 15 Q 16 17 18 19 20 21 22 23 24 Aroclor 1254 and 1260. Do you recall who it was or what group in St. Louis did the studies involving degradibility? It was a group under the direction of Dr. Keller through Dr. Scott Tucker. And I remember a Dr. Vic Saeger being one of the researchers. S-a-e-g-e-r? S-a-e-g-e-r. And then I believe there's a Dr. Emery who was involved as well, in the early stages of these studies. E-m-e-r-y. To your knowledge, was that study confined to the biodegradability question only, done by Dr. Keller through Dr. Tucker and Dr. Saeger? Yes. I just have a couple more questions for you and then we're all done; at least I'm all done. Mr. Papageorge, do you recall if the Standard Operating Practices Manual had a warning something to this effect, regarding chlorine gas, saying: If you are caught without a gas mask and large amounts of chlorine gas are liberated, hold your breath and go cross-wind until you're out of range of the gas. Once out of the area, obtain emergency gas mask and return to the 214 C & L REpoRTiNq CERTified Court Reporters 2955 5 Northwestern HiqhwAy SuiTE 508 SouThliEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058979 1 2A 3Q 4 5 6A 7Q 8 9A 10 Q 11 12 13 14 15 16 17 A 18 Q 19 20 21 22 23 A 24 Q area to correct the problem? Yes. And thechlorine gas was used as a part of the reproduction of PCBs -- I'm sorry, the production of PCBs, correct? Yes. Is chlorine orchlorine gas anaccelerator of toxic effects of the biphenyls? I'm not accustomed to that kind of terminology. I'm just trying to describe in summary form, the effect that we discussed earlier as to how biphenyls are potentially toxic, and then how they're potentially toxic after chlorine is added, It increases the toxicity, in general? Yes. Okay. Do you recall if theStandard Operating Practices Manual may have included a section relating to Aroclors which stated: "Other hazards of the material: This material causes eye, skin and mucous membrane irritation"? (Nodding affirmatively.) Do you recall when you first read aStandard 215 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHway * SuiTE 508 SouddiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058980 1 Operator's Instructions or Procedures Manual 2 of this type? 3 MR. SCOTT: You've got jumbled up 4 about three questions. 5 What's your question to the 6 witness? 7 MR. LEDBETTER: When he first read 8 a Standard Operating Procedures Manual of this 9 type . 10 MR. SCOTT: Of what type? 11 MR. LEDBETTER: That contains these 12 particular warnings. 13 MR. SCOTT: Well, you haven't even 14 established that they did contain the last 15 warning that you just read. 16 MR. LEDBETTER: I think he just 17 answered that. 18 THE REPORTER: He nodded his head 19 af firmatively. 20 MR. SCOTT: Oh, all right. I'm sorry. 21 BY MR. LEDBETTER: 22 Q Let's go back to your response. You've got to 23 give me a yes or no response to the last 24 question. 216 C & L REpoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy Suite 508 Sou4ifiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058981 1 2 3 4 5 6A 7Q 8 9 10 11 A 12 13 14 Q 15 16 17 18 A 19 Q 20 21 22 23 24 A And that was: Do you recall if the Standard Operating Practices Manual contained a section that said under Other Hazards: "This material causes eye, skin and mucous membrane irritation"? I do. And when was the first time that you remember reading a Standard Operating Practices Manual pertaining to PCBs that contained such a statement? About 19 -- well, let me look here and refresh my memory. I was going to say 1962, *63. Okay. And I believe from our discussions earlier, that you thought these Standard Operating Practices Manuals may have gone back into the '50s? Yes. Okay. Also, do you recall a statement in the Standard Operating Practices Manual pertaining to PCBs, which indicated under other hazards: 'This material can cause dermatitis, systemic poisoning from the fumes, yellow atrophy of the liver"? I remember. Yes, I do. 217 C & L REpoRTiisq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058982 Okay. Do you know what is meant by systemic poisoning from the fumes? As a layman, that tells me that it's going to poison my system. I'd better not get exposed to it. Okay. And what is yellow atrophy of the liver? I understand that that's a deposit or a buildup of fatty material in the liver. Is that an explanation for the larger size livers that have been shown in the studies? That is one explanation that I have seen. Also under other hazards relating to the Aroclors : "There are skin, mucous membranes and eye hazards encountered in the handling of this material ." Do you recall that? Yes . Then under the storage and handling, do you recall the section that says : "Protect the skin, lungs and eyes by wearing approved protective clothing, respirator and goggles. People who handle this material at elevated temperatures should have medical supervision and the air should be sampled to ensure compliance with MAC"? 218 C & L REpoRTiNq CeRTi Fi Ed Court Reporters 295 5 5 NortItwestern HiqhwAy SuiTE 508 SoutMIeIcI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058983 1A 2Q 3A 4Q 5 6 7A 8 9 10 Q 11 12 A 13 14 Q 15 16 17 A 18 Q 19 20 21 22 23 24 Yes. What is MAC? Maximum allowableconcentration. Okay. And that was a little different standard than that suggested by the industrial hygienist, which was a threshold value, right? Well, it meant the same thing. As far as Monsanto was concerned, that was the maximum allowable. Do you have an understanding as to what is meant by elevated temperatures? The intent there was to avoid -- it's other than room temperature; or ambient temperatures. Okay. And then in those situations, one should have medical supervision and the air should be sampled periodically? Yes. And then under Aroclors, do you recall a section that said : "Aroclors is manufactured in Department 246,or non-flammable liquids, which may vary greatly in viscosity in room temperature. Contact with skin should be avoided. In case of spills on the body, wash the affected area with soap and water. Inhalation of Aroclor and 219 C & L REpomiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy SuiTF 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058984 1 Montar fumes should be avoided as they are highly 2 toxic. Protect the skin, lungs and eyes by 3 wearing protective clothing, respirator and 4 goggles. If spilled on clothing, change to clean 5 clothes"? 6 MR. SCOTT: Counsel, you're now 7 reading from a document. 8 I request that you let the witness 9 take a look at it. 10 MR. LEDBETTER: Sure. 11 MR. SCOTT: Let's mark it and make 12 it an exhibit. 13 (Whereupon Deposition Exhibit 10 14 marked by reporter) 15 BY MR. LEDBETTER: 16 Q 17 Here's the part that I was reading from, (indicating) ' MR. SCOTT: Let the record 18 indicate that we've had marked as Deposition 19 Exhibit 10, what appear to be portions from a 20 deposition of Mr. William B. - oh, no, testimony 21 given by Mr. Papageorge in Bad Axe, Michigan; 22 excuse me. Selected excerpts of testimony. 23 MR. LEDBETTER: Okay. 24 220 C & L REpoRTiNq CERTifiEd Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouTkfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058985 1 BY MR. LEDBETTER: 2Q First, Mr. Papageorge, would you take a look at 3 that and just see if, to the best of your 4 recollection, that rings a bell as to your trial 5 testimony in Bad Axe, or a portion thereof? 6 MR. SCOTT: A very small portion 7 thereof. 8 THE WITNESS: It appears to be an 9 excerpt of my testimony, as best I can tell. 10 MR. LEDBETTER: I've only got two 11 more paragraphs, and we're done. 12 BY MR. LEDBETTER: 13 Q Then do you recall a section in the Standard 14 Operating Practices Manual that indicates: 15 "The operating instructions are the property of 16 Monsanto Industrial Chemical Companies, and the 17 recipient is responsible for its safekeeping 18 and contains confidential information of 19 Monsanto"? 20 A 21 Q 22 23 24 Yes. And under, again, other hazards -- I think we've talked about that. As to the safehandling of the material, do you recall the section; "A clean change of clothes is furnished daily to 221 C & L REpomiNq CERTiFied Court Reporters 295 5 5 NoRihwESTERN HiqkwAy Suiie 508 SouthfiEtd, MI 48054 (51 5) 827-8589 WATER PCB-SD0000058986 1 each employee and time is allotted at the end of 2 each shift for bathing. In addition, one should 3 wash his hands and face before eating"? 4A Yes. 5Q And those were all recommended criteria for those 6 working in and around PCBs? 7A Yes. 8 MR. LEDBETTER: I've got no other 9 questions. 10 Thank you. 11 MR. DECKER: I just have one I'd 12 like to clear up. It will take two seconds. 13 14 BY MR. DECKER: EXAMINATION 15 Q Mr. Papageorge, my name isBill Decker. I 16 introduced myself earlier, but that was quite a 17 while ago. 18 I represent Transformer Inspection 19 Retrofill who's involved in this case regarding 20 repairs of the subject transformers. 21 Just as a precedent, my knowledge 22 of chemistry, etcetera, compared to Mr. Ledbetter 23 is probably something like Einstein to Poindexter, 24 because I really have nothing. 222 C & L REpomiNq CERTified Court Reporters 0295 5 5 Northwestern Highway SuiTE 508 SouThfiEld, Mi 48054 (515) 827-8589 WATER PCB-SD0000058987 1 2 3A 4Q 5 6 7 8 9 10 11 A 12 Q 13 14 15 16 17 18 A 19 Q 20 21 22 23 24 A So, I hope you'll help me in this area to clear something up. I'll try. You had testified earlier somethingconcerning the likelihood that PCB vapors would be present if there was evidence of PCB running down the side of a transformer and then collecting to some degree on the ground. Is that a fair recollection of what you said? Yes, it is. We also mentioned that in order todefine what kind of concentration we can estimate to have in this room, there are other factors, such as the size of the room, the heat, the ventilation presence, etcetera. That's also correct? That is correct. Okay. Would it be a fair assumption to say that without having those measurements, including the heat involved in the room, would there be any way of determining the concentration of PCB vapors in such a room? At the time the - 223 C & L REpoRTiNq CeRTified Court Reporters 295 5 5 Northwestern HiqHwAy SuiTE 508 SouihField, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058988 1Q 2A 3Q 4 5 6 7 8 9 10 A 11 12 13 14 15 16 Q 17 A 18 19 20 21 Q 22 23 24 Alleged exposure occurred. At the time, yes, there are ways to do this. Okay. I will get to that in one second. At room temperature, if the PCB material had collected on the floor, are the molecules light enough that they would ascend? Or would they stay close to the floor? Or are there other factors involved in order to make that determination? In every liquid, there are always some molecules that are going to escape. The energy with which they escape varies from liquid to liquid. PCBs would lose very few molecules compared to the benzenes that we talked about earlier. Okay. With today's very sensitive instruments, the few that do escape would be detected. Then it becomes a matter of: Are there enough to cause harm? Okay. We had discussed earlier the amounts that Monsanto had -- or the parameters that we were working with before ; the one milligram and one and-a-half milligram, depending on which Aroclor we 224 C & L REpoRTiNq CERTifiEd Court Reporters 295 55 Northwestern HiqhwAy Suite 508 SoutHHeUI, Ml 48054 (51 5) 827-8589 WATER PCB-SD0000058989 1 2A 3Q 4 5 6A 7Q 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 were working with? That is correct. Okay. Would those instruments, those very sensitive instruments, be able to make that determination? Easily. Yes. Okay. MR. DECKER: Okay. I have no further questions. MR. SCOTT: Okay. Let me ask him one question off the record. (Off the record) MR. SCOTT: I'm not going to let him answer the question. You can submit a special interrogatory to me if you want, and we'll deal with it. MR. LEDBETTER: Okay. (At about 5:05 p.m. - whereupon deposition concluded) 225 C & L RepoRTiNq CERTified Court Reporters 295 5 5 Northwestern HiqhwAy 8 Su'ite 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058990 1 CERTIFICATE OF DEPOSITION REPORTER 2 STATE OF MICHIGAN) 3 COUNTY OF ST,, LOUIS) 4 I, Lori B. Resnick, Notary Public in and 5 for the County of Wayne, State of Michigan, do hereby 6 certify that the foregoing deposition of WILLIAM B. 7 PAPAGEORGE, was taken before me at the time and place 8 hereinbefore set forth, and that said witness was duly 9 sworn by me to tell the truth, the whole truth and 10 nothing but the truth, and thereupon was examined and 11 testified as in the foregoing deposition appears; 12 That this deposition was taken and 13 thereafter transcribed by me and that it is a true 14 and full report of my original stenomask notes. 15 IN WITNESS WHEREOF, I have hereunto 16 set my hand this day of June, 1987. 17 R 18 LORI B. RESNICK, CSMR 3236 19 Notary Public, Wayne County, MI Acting in 20 My Commission expires: 12/29/87 21 22 23 24 226 C & L RepoRTiNq Cert!lied Court Reporters 295 5 5 NoiuhvvESTERN HiqhwAy SuiTE 508 SouThfiEld, Ml 48054 (515) 827-8589 WATER PCB-SD0000058991 03/ P tJQ^~ Q-^- v*A2'. r ^- 33: (022 mC AX ACXEFOR.M DERMATERCOSIS JACK \V. JONES. M.D. ,\ x o HERBERT S. ALDEX, M.D. ATLANTA. I, A. It is only within comparatively recent times that the dermatologist lias interested himself in dermatoses associated with or caused by the daily work. W ith the advent of a more clearly defined appraisal of the words eczema and dermatitis and the more general use of the patch test, der matologists have necessarily inquired more and more deeply into the innumerable chemical contacts that occur in the day by day lives of their patients. As well as being conversant with dermatology, the der matologist must have a working knowledge of the manufacture and content of the many new and old compounds that are handled and applied by large numbers of persons. Hence, more and more derma tologists are becoming industrially minded, and it is dawning on them that the solution of some of their industrial difficulties may aid them in a clearer conception of the dermatoses that are encountered in their every-day practice. Dermatergosvs of the aciieform t\pe occurring in persons working with chemicals have been repeatedly reported in Kumpe and discussed as industrial "ehior-acne." : This term "chlor-aj <." was rir-t Used by Herxheimer ; in 18l)'~) to describe an eruption o posed of comedones and small sebaceous pustules that occurred on ' ami' and face' of workers manufacturing chlorine gas electml :;iil\. ti'ing carbi.n electrodes. It was natural to assume that the ch uc was the caii'atiie agent. Hettman hqd observed in March It?'1/ two patient- whose -kin' were diffusely pigmented, dark, rough and dry. in whom were oh-er\ed small tenacious comedones associated with numerous 'iital! follicular abscesses Subsequently he reported twenty-one additional case' with similar symptoms in workmen who were engaged m cleaning out an acid tower used in the manufacture of hydrochloric acid. A: no time did these men come in contact with free chlorine, but numerous loose Read at the Fifty-Eighth Annual Meetine m the American Derniaioi'-aicat Association. Inc.. White Sulphur Sprme>. W. Va., May 19.?.- 1. White. Prosser: The Dermaierc'es. ed. 4. New V-rk. Paid P. H'Mer. Inc.. 1934. 2. Herxheimer: Munched, med. Wchn-chr. 46:27s5. IS'111 3. P.ettman : Deutsche nted. Wehuschr. 27:437. 1901. i-F 25 _ .5 S> e( a1 i EPOSITION EXHIBIT L-t. WATER_PCB-SD0000058992 L. iaily *rds derthe - of lerund and ma- hem hem heir '-vinyf - <f in *n itive kill' ed ilar with : an time m ise jical eher. I I I i l \ JOS BS-A LDES--AC S El'O RM DERM At ERCOsIS 10'J derivatives of cual tar were present. Herxheimer later absolved the chlorine lint considered the trouble to lie due to various chlorbenzene*'. From time to time other reports ot the occurrence ot "chlor-acne" have been made in the European journals, each author continuing the error ot Herxheimer in assuming that the cause ot the condition was chlorine. Some ot these reports hat e been indefinite as to the chemical conditions under which the men worked, except that they were exposed to chlorine yas. However, some authors have suspected various chlor benzene derivatives, such as hc.xa-chlorbeuzene. hexa-chlorethylene. para-uitiobenzene. perchlornaphthalene i "perna" 1 and probably others.' Chlorinated naphthalene was first indicted by Waiter ' in 1(|KS as a cait-e ot acnetorm eruptions of the skin, the condition beintj called Pcniakrankltcil. His observations were confirmed by Koelsch 1 and recently by Telektv The latter reported an exhaustive study of a lartje number of cases occurring in workers eturaued in the manufacture of perchloruaphthalene. in which the workers were excised to fumes of the molten mass and also to the sublimated dusts, [n approximately one-half of the workers exposed there developed comedones of a particularly heavy and tenacious t\pe with resultant -ebaceoiis ab-ces>es. containing heavy velluw pus ami serum. Considerable improvement resulted when the chlorine content of the mass was decreased from 30 per cent to S per cent, ami Tcleky believed that the disease was due directly to the halogen content of the -ub-tance. He mentioned the similarity of the di-ea-e to ViA/i/ii- 'tar acne i but carried the analogy mi further. Individual predisposition appeared to alter receptivity. Some authors have leaned to the view t' die acnetorm eruption is due to direct external contact with the ch icais notably Bcttman. Hallopeau. Jacm.et. Funiou/e. Tcleky and Kwl'ch'i. ( fthers . Leh mann. Herxheimer. Jacoln. Roth and Kobe-: '* considered it to be a 4. Occupation and Health: Encyclopedia llciere. Path*-y ai'd S* cad Welfare. International l.ahour Office. F***i*-n. World P--.we F* umlut: n. I'i25. I.r* cluircs .54 and 285. 5. Wauer. cited in Occupation ami Health. Knoclopcdfa -f H>ierc. P.vbol- wy and Social Welfare. International t.ah*-nr idirke. l!*-t* n. W- rlil Peace Founda tion. 1925. brochure 34. ri. Koclscli. F.. in L'llmann. K. : i Vpeulieini. M. u:d Kdle, .1 H. Injuries to the Skin. Leipzig. Le*.*p*sld \V*--. l'ijn. \..|, 2. p. 3".! 7. Teleky: Klin. Wchn.-chr. 6:845 i April 30*: ''*7 i Mae 7i 1*J7. 7:314 * Jan. 29 i 1928. ' 8. Flettman: Hallopeau: Jaoiuct: Funiotizc: Tcleky. iiid Koel-ch. cited lit Occupation and Health: Encyclopedia of Hysper.e. Pat:i"!"cy ,ii*i| Social Wel fare. International Labour Office. Boston. W..rld Peace F iindatton. p/JJ. brochure 285. 9 Lehmann: Herxheimer: Jacobi: Roth, and K.-U-rt. cite*I in Occupation and Health: F.ncyclopedia of Hystiene. Patholosiy and S* cinl Welfare. Inter- nati* nal l.abour Otfice. Ro-ton. World Peace Founilapoii, 1*>25. brochure 285. WATER PCB-SD0000058993 1024 ARCHIVES OF DERMATOLOGY ASD Y PH I LOLOt.Y dermatitis due to the absorption of chemical compounds by the linn's or gastro-intestinal tract, with elimination bv wav of the K-haceotts glands. The majority of writers on the subject, particularly Prosser \\ hite.1 have seemed to feel that chlorine as such has little to do with the formation of the comedones and cysts, and they have repeatedly referred to tar and products of the distillation of tar as the prime causative factors. Prosser White rebuked authors for using the term "chlor-acne" at all and expressed the belief that the process is one of the manifold cutaneous reactions produced by tar and its derivatives. Recently we have had the opportunity to study, with the full coopera tion of tlie manufacturers, an outbreak of acne form eruption occurring in a group of workers engaged in the manufacture of chlorinated, tit-phenyl. This study has brought out some points in the production of this unusual dermatosis that we feel are important in solving its exact cause. The following case is typically illustrative of the disease as it occurred in the men working in this plant. KtrtJRT OF A CASE History.--O. D.. a .Vegro aged 2b, began work in the distillation of chlorinated di-phenyl m April 1 oJO and worked regularly mud the latter part at the year Idjj. About May ot 1'hk'. he iinticed the appearar.ee *>i hlackheads on his face. neck, arms and lees. Thv-e areas itched -lightly. In a -hurt time Slackheadbesan to appear on the chest, hack and loner part of the abdomen, an>und the' navel and on the -crottim and peni. Many -o' the-e blackheads -welled and became infected, discharging thick pus. The areas healed with difficulty and mien left scars. The condition seemed to he progre-'ive until N'ovem1'. - lojj. When seen in Deceniher 1 **.!.? the patient complained of lassitude, lo-. appetite and loss of lihtdo and -,nd that hi- cuuneous condition -ernied to '. mpming. Physiotil E.riiiiiimiii'Mi.--On examination lie -ectr.cd In go,.,| o.-' . -u health Hi- complaint of lassitude was not borne "tit by anything more than :-ual tempera ment of the Negro toward work. On the forehead, ex'ending w::' n the hair ime. and on the cheeks, chin, nose and neck were tumier-ti- -mall, very black, tctiac-on- comedones, their distribution best described a? being "peppered" witlr.n the skin. Many ;.f the comedones surmounted tirni -hothke c'-t>. which in - ire areas Contained viscid yellow pus. The pustular elements were more :v.ttccah'.e on the neck. Similar shotlike comedones and cysts had appeared "it the -h"tiMcr. midportion of the hack and chest, w ilh an occasional large c>-t. A peculiar peppering the skin with tenacious carbon-col--red comedones amcircnt around the umbilicus and lower portion of the ahdomcn. The -cr- tum and petti, vtere involved in a similar process, the former being given more t" the formation of cysts. The -inter surfaces - nanterior thigh. -ii..---l similar but fewer comedones. The whole eruptionwas acnetorm hut differed fr-iu acne particularly in the lack ->i a seborrheic appearance of the -kin and in -he peculiarly deep black of the comedones as well as the general peppered il-tr-biui.m in areas not usually involved in acne vulgaris. A general pin-teal c\umn:at'--n had revealed nothin? --f importance. I uu> vith Ally itue crm : ot ve>. erariiu: attrd tion xact is it atcd > ear i hi? cads ! the I .1 ;*craline. emit? the '-me ah!e !cr'. i!iar irent n*ni$ iti*m Miilar ;rnm the niti^n lation # i i 4 i * i j J()S'E.'\-.ILUES-- 1C S'EI-< 'KM UERM.I I ERoDilS 1025 Tiyntmciii.-- He was instructed to scrub his -km thoroughly before and after his hours of work, to wear fresh clothing each da> during work and to u-e a lotion made up .is follows' zinc -ulfaie 4 t on., pota--mm -ulfurata 4 (,m. and distilled water to make 125 cc. On recommendation lie later reported for weekly doses of roentgen radiation according to the usual manner of treating acne vulgaris. ,1/fcom/co/uv E.iiiininiiliiiii.--A portion oi the -kin of the chest was removed fir microscopic study i tig. i>. The chief feature of the sections was noted m the hair follicle- and sebaceous glands, in which there were cystic dilatation. .MUMimr/'V i*f the A \ uift- M/jf ,tmi 1 rctif ntetit iu-..s i.vteeu t ti.vt j of . feurr* of fintfti hi * il*0 ACtf RiM1H Whit.' :n > s WlutV\ htU- nv ti W Into F W hit- s v m U hnj'i V cm '1! ' V I-' \. wm 'M ' :P : ' It r : 11 *. F 1'2 : lJ St U htu hitU tu'f \\ liltN. WTM U 1111 \- irro T"VtIi.n.. < "-httrrhl-f VIOI> { dt-n- j Tv[h/ Kniftion \ hT\i|miue*uMre y\j-iurtlilv--t*tlltk'* loll* \\ munths AV-rillf" * nrrh* c AVrue- try /I'itfim- rt-uit 'Itiu* *: j :rw rvt I j Il|uiHtlr-rettUt*i--lfv>?ts iann*l *; j j hPiifiiTrem*f/*Vm'tm* j--l<o1ne: ' *. immih> ThrnuKhout Ht 111<*i11Its Ao r.iy 1 roiti-rln-*: aI-nui -Dyw-tk* <mi (uif *! i-r< nrrh. ;rn:nJ1 r!irjtktu:--,ii.*r-'imr*-*-r`iyo-tnitn-***: ^ -nrrh c j i rvtfvi hi.HiiiH *i;i:- ! v\ . in ;i i) i v<t' \v- r;ic- h vv -h.ll' ;if *, '.II .*-JMm111ian1. throughout in muuth^ iJ ' month* I / *. month* < wm- |, v.t*. mi all Thriimrlinut w r;tk*- atr--r< -1 * ':/ *n1111111 11r v * 111. r- { r :J T'IiF* *i : Ctl* *.f * ..rrh- F- \v. 'if \v mev-l nrrh* ...... or:.,:.. j V. rv I- u . . / :HJ. f -i - /. J hr/>fciM.{ j..... 1 'ir-".')ii.ot 'i-rn- f:*'wrtt. .v-.f.'.It:,*V!W* //. l rs pn*c-rumiil'nt rrfnfiMtcfrm-anpntiyfno:oNon*ttnruciin-iuoirnc: None None rinrucmKiuoinr-: Nonu None Hth'r:;nii*cyNonRf !ni--r;Mij*t^y-tioN<nVonNon111tiic* :u>Mi* riti'V ;*f-. no- Ttn- I- r. port. *1 ;n tsi;I. destruction of the hair, marked tinmiiiTg '.md -itr- ; h. i d\ eiutltelium : die follicle- and a heavy plug of keratinized muic-rai ':"ch nartl; tilled the *>-t:c cavity. In some areas there w.t- a -tipcrricial plug .a die -nriace "I'come: others -liowed the surface open and the ping deeply -hunted There wa> no purulent cMidate. There were a zone f moderately deii-c imvtue ti--ne -urroumlmg the enlarged follicles, -light edema and inriltrnti- -n '> !> mph. c> te- but no leukoci tcs. Slight edematous changes were m ted m the '-cca-ional -chavcgland- present, but ti'ev were -trikingly lew. The >wcat gland- were "..final. . * .jmCt--.. * WATER PCB-SD0000058995 10J6 ARCHIIES OF DERMATOLOGY AX n sYFMlLOLOGV Fig. 1.--Section of skin from the chest, shewing hUtoluicic chances in the formation of an acnetorm eruption. WATER PCB-SD0000058996 t JOXES-ALDEX-ACXEh'ORM DERMA! ERGO>IS 10.7 Of the twentv-four men working in the manufacture of chlorinated di-phenTTiriTfTtrTThe perTixTtTOm the late summer of trrOCToTifrT 1733. twenty-three were reported to have had an acnetorm eruption on the face and body. Of the twenty-three, sixteen were examined. 1 hese men presented eruptions of acneform character similar in type and dis I4 tribution to that in the case referred to but varying in severity i table i. In many patients numerous -mall sebaceous abscesses developed, par ticularly around the collora line, which exuded heavy, tenacious pus. '4 4 4 Fiif. 2.--Characteristic appearance and !<>caii>>n "t an acnef"rm eruption. I and the remaining ulcers were indolent, leaving in their wake much scarring. In two of the cases particularly, main large abscesses developed on the neck and back. Until very recent times di-phenyl and chlorinated di-phenyl were only laboratorv curiosities, and their commercial manufacture was unknown. In the experimental stage of manufacture the apparatus was necessarily crude, and experimenters and workers were exposed for long periods to fumes and dusts containing much chlorine, both free and combined. In the early experiments, as well a.- in the early manufacture in large 1028 ARCHIfES OF DERMATOLOGY ASU tY I'H I L(>LoGY quantities, the di-phenyl was made by hen tins' benzene derived from crude coal tar. W hen heated in a suitable medium benzene becomes cli-phenyl (C,.H,,,). This substance is then chlorinated at various saturation points, by exposing it under suitable conditions to tree chlorine gas. Distillation of the resulting chlorinated di-phenyl l" results in a purified commercial product 'tig. 3>. The commercial benzene always has a small quantitv of impurities, but some of the cruder commercial benzenes contain relatively large quantities of these impurities, such as xylene, toluene and paraffin. On the heating of the r Fie. 3.--Chart illustrating the process m manufacture f chl> r:uit. 1 di-phcm!. cruder benzenes, the toluenes and xtleiiea. when pre-eiit m large quan tities. may produce the chemical substance -tyrcne. u Inch has the formula C,, H-. CH: CH.. Styrene when chlorinated ' it being imcparahle from the di-phenyl) is an unstable compound ir ppmg its chlorine atoms very readily. It is probable that "titer complex hydro carbons may be formed from these impurities, which mt chlorination become quite as unstable as the styrene. t >ne of the~c compounds may he chiorethvl benzene t C.: H- CH-Cl-CH;i. 10. Chlorinated di-pheml consists "f a mixture "t <ti-piuti> 1 chlorinated at various saturation points: imna-chlorn-di-plieiwl ' C HCI.. -Lb c! i vie. WATER_PCB-SD0000058998 H' f m l at to al he .sc the A :iv 1. lanthe epa- its Iro- ition may id at JO.X ES-.1LDEX-. 1C XEl'OR.U PERM J l ER(,Oifo 10J9 In the e\|)erimentnl stage and in the early manufacture of chlorinated di-pheml. the men working were exposed tor long period* to these chlorinated products. As the demand tor the hui-hed product increased, quantitative manufacture mas speeded up rapid)) . and open 'till* ami heating units were of necessity Used until better equipment could he designed and made. But -ince no physical trouble had developed in the workers previou>l> there was no apparent hazard connected with manufacture. On or about March 1**33 the electrical properties of the chlorinated di-pheml produced in the plant the workmen of which were deepened. About one month later an acneform eruption was observed mi the faces and arms of several of the workers, which became progres- 'ivelv worse, gradually becoming apparent among all the workers engaged in the process at that time. Although one of the men had had a slight acneform eruption on hi= face itt January, little thought wa> given to it until the eruption appeared in the others, fu the slimmer of BM2. m.\ or eight mouths previous to the genera! outbreak of the Condition owing to a difference in price, the crude benzene was pur chased from another source, and it was not until the purchase of this particular benzene was discontinued, in October 19.33. that the finished product came up to the standard. During the period from March 1"33 until October l'Ma. the eruption continued among the men. and it was present as ahead) described '.\heti the men were examined in December of the same rear. The appearance of the eruption coinciA mill) with the production of a pour grade of chlorinated di-pheml - led to indicate a relation* -hip. < 'ii due chemical investigation -tyr- e was assumed to he the offending substance causing the low grade the finished product, It seems that it may he readily a."Uinc- iiat our problem as to the calmative agent* of the acneform erupta" wa* connected with the chlorinated products of the impurities present m the crude benzene. However, with the exception of -t) rene. these products are imt known. The problem hence becomes difficult of exact solution, and iteces- 'ttrv to resort to a reasonable deductive lnpoihc'is. The exact conditions tinder which the men contracted their eruption cannot be satisfactorily duplicated experimentally 'iuce prolonged mild contact seems to be a deciding factor Repeated patch te-t- made oil numerous persons with the riuished product, chlorinated li-plicrii) I. and the foreign substance' styrene, 'tyrene di-chioride and chiorethyl- hen/.ene. have not resulted in an acneform eruption except in one instance. Repeated patch tests made with chloreth) Iheii/eue m the same area produced on the third attempt an erythematous follicular eruption, which persisted only a few days hut which wa* Iw no meum i) pica!. WATER_PCB-SD0000058999 1030 ARCH IT ES OF DERMATOLOGY AXD a YPHILOLOGY We could not duplicate this in other instances. Since styrene, chlorinated styrene, chiorethylbenzene. xylene, toluene and their probable products are tor the most part lipid solvents, they will produce death and denudation of the epithelium, and one always obtains a chemical burn m response to a patch test made with the -tyrene and styrene di-chloride. Small quantities mixed lou-ely with an inert powder or dissolved in ether produce a mild erythematous reaction but no acnetorin eruption. Patch tests made with the finished product, chlori nated di-phenyl, at no time produced am erythema or evidence ot irritation; hence the chlorinated di-phenyl can he absolutely absolved as an irritatintr agent. In looking over the consecutive history ot the development ot the eruption, we found it apparent that the men were in some degree exposed to the chlorinated impurities in the benzene for some time before the eruption actually appeared, and that to duplicate the conditions we should have to make repeated patch tests daily for long periods in the same person. a procedure which is not feasible. As a group, the workers in the dusts and vapors, which were presumably saturated with chlorinated hydrocarbons, were not cleanly. making 1 ittle effort to 1bathe after work, and sweating and rubbing enhanced the liability t<o deposition of the substances on the skin. ThToreticnlly. the chlorinated hydrocarbons, presumably styrene di-chloride and chiorethylbenzene. deposited on the skin gather around the hair follicles and sebaceous glands and are gradually rubbed in. Being lipid solvents, they dissolve -ebum and in the reacti'-1'. which is modified by the heat of the body and the water present, gn --rt hydro chloric acid, which cause' death or irritation of the cells. This in turn causes an excess of cell growth. inflammation. sebaceous | Aggir.g and an acnetorin eruption 'rig. 4i. This process repeated mer a long period may result in -evere 'ebaceous infection, sebaceous ah-ce-s and scarring. One would naturally expect this process to occur in the seborrheic areas as well as where clothing might rub the particles into the skin. Also one would expect the process to enhance an already existing acne vulgaris. This occurred in cases 1 and 0 i table 1 i. the cases in which there was the worst involvement with -ebaceous ab-ccsses. In the beginning an attempt at prevention of the condition was made by being especially careful that all men engaged in the manu facture of chlorinated di-phenyl should have a thorough bath after working hours and that they should wear freshly laundered clothing before starting work. They were also instructed to apply night and morning veterinary white lotion to the attected parts. Some of the patients having the most numerous cysts and follicular infections were instructed to report for roentgen treatment administered in the manner usually employed in treating acne vulgaris. Following the WATER PCB-SD0000059000 ( , ( rene, their >duce ms a e ami nvder nt no hlnrice of solved f the . were ne tor plicate ly tor e. e prelennly. libbing skin, tyrene in uind ed in. I is l,_ .11 m turn ng ami a long 'S and in the e> into II ready l i. the -cesses. >n was manti!i after clothing ght and nine ot i fections 1 in the ving the I JOS'ES-.lLDEX--.iC.XEFi U<M DERM. ITERGEiSIX I0JI change in the tvpe of benzene used and the einpliivnient of enclosed distilling apparatus and ventilation fans, there was noted a gradual improvement in the acneform eruption. Those patients recei\nicr roent gen radiation improved much more rapidly, hut it cannot lie -aid that this form of treatment gave unusual results. The rinai treatment, of course, was removal of the patient from the offending chlorinated hydrocarbons, and then cleanliness and relief from any infection. All the men showing evidence of cutaneous disease. >o tar as is known, are greatlv improved, or the condition has entirely cleared except for an occasional comedo and a few scars. L f When one recalls the cases reported by the l .ttropcan investigators, it is altogether plausible that the chemical process outlined here occurred in most instances. The slow lilieratioii of-chlorine m the presence of a lipid solvent (usually chlorinated hydrocarbons > "as present in most cases. It is doubtful whether the disease is influenced by the '[tiantity of chlorine present; it is apparently more due to the formation of unstable chlorinated hydrocarbons as well as to the liability of the workers to close contact without a thorough cleansing m the -kin and a change from saturated clothing. It is also probable that the disease has little to do with tar itself Inn more with the products tunned by the 1032 ARCHIVEa OF DER.\(ATOLO(JY AXD *YPMU>Uh,Y chlorination of tar. Hence, the disease cannot be culled "chl<>r-acne" or "tar acne." That it is not caused by internal absorption is evident when one considers the following tacts: First, acute intoxications by chlorine rarely occur, since suffocation and death by pulmonary cdetna ensue even in the presence ot relativelv -mall quantities ot chlorine gas tn the air. Second, when invested, chlorine and the chlorinated hydro carbons are so rapidly oxidized and chlorine hi readily combines with sodium that opportunity for acne-like eruptions, such as occur m bromine intoxication, is nut possible. In retrospect, we are intrigued by the hypothesis that these theoreti cal considerations may have some relation to acne vulgaris. The past quarter of a century has seen an enormous increase in the use of coal for heating homes as well as in industry. The smoke stacks of the cities have belched an ever increasing stream of coal -moke---moke heavily laden with carbonaceous products containing numerous hydro carbons. It is well known that coal smoke contains hydrochloric acid. Is it not possible that at least some ot" the acne vulgaris may have a part uf its origin in the constant contacts with the chlorinated hydro carbons of coal smoke? Sl'M MARY We bate recorded herein observations concerning an industrial dermatosis of an acneform type. The type of eruption and the cau-ame factors are analogous to those in the previously reported cases -pokcn of in the European literature tts instances of "chlor-acne." tar acne or f\ruaki\niUii'it. Although exact duplication : the conditions under which the workers acquired the dermato-i- itin<>t he accomplished by experimental means, reasonable deduction- t- to the cause of the difficulty can be made. The eruption occurred luring the manufacture of chlorinated di-phenyl from benzene. The rmatusts occurred at a time when the benzene Used contained excc'-ive quantities ot toluene, xylene and paraffin as impurities. The heating and chlorination of these impurities probably resuited ill the production "f -tyrene di-chlorde and chlorethylbenzene. which, we believe, on contact with the -kin produced the acneform eruption by the -low liberation byIroghioric acid and nut by internal absorption of any chemical. While many chlorinated hydrocarbons, as brought out by I'p--er White, are lipid uhstances producing death or irritation of the ceil- In the liberation of chlorine, this is nut true in all instances, -ince the hui-hed product, chlorinated di-phenyl, did not. either experimentally ..r Actually, produce any cutaneous or sebaceous irritation. Irritation apparently depends on the ease with which chlorine atoms are released 'Tom the hydro carbon ba.-e. We believe that these dermato-e-; -liouid be labeled acneform dermatergoses resulting from certain un-table chlorinated 4 cue or evident .nils In edema iite ca# hydro* o> with >n>mine heuretihe past use ot hicks ot --siHoke liydrorie acid, have a I hvdrn- ldustrial uwuh e "kelt <it e or - under uplished c "t tl-.e m nurture red at a t>'luetic. it these cltl'iride die *kin 'dll' ric !e many ire lipid ration nf pr. 'duct. . produce depends e hydroled acnetlorinated y jnXE.i-XLDEX--.U.X LEO KM I'EKM.I I EKUDsi > |njj hydrocarbons and -hmild not he spoken ot as "chlor-acne or tar acne. The siicrsestion has been made that some ot the acne vnlsjarU ot the -km may he the result ot the -ante type of irritation from -not or coal oimke ABSTRACT OF DISCUSSION- Dr, Oliver S. OrM'UV. Chicago: [ should like to add an experience ( '-ad three months aeo that o of intere-t m this connection. [ think that hr, hue- paper i- eNtraordinanly intcrc'tmvz and valuable, and the small er- up .,t ca-e* I am come to report may add to hi> troubles rather than <"l\e any of the prohlcnis. About three months ailo in Michigan. I -aw a patient, through the c ur't>; of Dr. Milton <V Butler, who presented an extraordinary aettefornt eruption. Tin- patient was IS years old and had been observed hy Dr. Butler. The eruption in these various ca.es consisted of acnctorin pustule* and comedones of variable size and depth, with scars, me of which were keloidal. The eruption occurred i on the face and neck, particularly over the posterior portion, and extended well up into the -calp. The trunk, arms, thtchs and less were also involved. Two .,f the patients presented on the hack of the neck deep perifollicular pustular leions, with keloidal >cars. uclt as are -een in Kaposi's dermatitis papillaris capilhtii. Both deep and superficial atrophic wars, -ucli as are seen in deep lesions lvavu: acne, were present m -ther portions ..f the neck, face and trunk. The onin"l"i;c nere |>rominem :n ill areas, including the less. They were of variable -i/.e, and many were larse and deep. The aee of the affected patients varied i>..in IX to 5u year', the .'"imcer ones Hems more severely atfected. The condit'oii a< apparently produced by Contact with an uisredieut in a fungicide pr. .'-ice': by a chemical company f r destroy ms I'.msi in lumher. The particular chcitnc .'. u this I'uus'Cide that apparently was responsible for the eruption was - dunn vt--i- cT?lor.oriho.| Hun Iphvnate. 'which i* i yellow powder. Only those wlm came " ii'.act -\ nil it had the eruption. Thoe w lv ' ttidlcd the other insrediv::t i the uns'.c.de and did not come -u contact ' this particular chemical had dimculty . A* there were apparently no vh e. hr-mme or tar radical' in 'lie formula, it : difticult to ietvrmme the .u - factor m the production ,.f ;i-1.- Ivstotis and al-o whether :he eruption n,i- >cd by !..cal action by contact 'T through ahsorpttoti and internal erfects Th.e ts n. wa- ,..( concerned in any way with acne, and no patient in win m the erupt- deiel. ped had had acne previously. Dr. Marion- B. hi l/p.kr'.fr. N'cw York I think that Dr. Jones has c ntrihuted a study that will he very mterc'iiiur wiieu continued 1 itad an opportunity of seeins a group of patient' with acne of .eternal "ren about a year and a halt ago. The patients were ail employed in i :act-ry makuis radio o inlen.'er'. > Pitch tar and a type of wax habvvax. a cn.l- riuated naphthalene' were vised u; these condensers. The act'.e which developed -..is :-kc that described by Dr. .l-iics and also included comedones --n the 'ess. i- :.i<i that which Dr Orm.hv :-a. mentioned. I saw six patients from this uv -mail : w: ry. They were dl in the age of puberty or the early twenties, and tl-e group ;e,eluded per-oii- ..f both sexes. I believe the most important point in tin- -tudy i- the possible '-o|n>cctioii between acneiorm ilermato.es distinctly due extcfal irritant' and true acne vulgaris. It is iiuerestmc' that many derivatives f tar are closely allied to the cstr'vjetiic hormone. that certain component# .f :ar are -tit e-tr--etetiic and acnejetuc and that the estrogenic hormone nui.t perhaps he incriminated in the produc tion ..f acne vulgaris. There can he no r|..uht th.at acne - itcii due to stimulation or 10J4 ARCHlfES OF DERMATOLOGY ASD xYPHILOLOGY irritation of the pilosebaceous apparatus and that hormonal as well as external inriucnees can produce this stimulation. In the patient suffering from acne, who has. of course, come. in contact with the estrogenic hormone during intra-uterine life and then has had no further contact with this hormone lor the clo-ely related testicular hormone i until he or she begins to form his or her .sun hormones. one can readily conceive the pathogenesis of acne vulgaris as being based on an excessive stimulation of the hair follicles, a stimulation produced hv the sudden new formation of the hormones at puberty. It is as though the follicles, after being sensitised to the hormones during fetal contact and then passing through a period of freedom from contact, react excessively to the new and massive contacts with the products of the gonads at puberty. I have discussed this subject in great detail elsewhere. Dr. H. <i. [rune, Minneapolis: I wish to comment on "lie point and to compliment Dr. Jones "n an excellent piece of work and his presentation of it. There was a difference between hi< situation and that which Dr. Tunnaclirf and [ encountered i Arch. Df.rmay. & Syph. 33:JOr> [Feh| 19jn>. In his case the manufacturers called mi the medical profession to help solve the prohlem. Our study was undertaken where lay people were in charge. It -hows clearly the need of medical advice in the production of various chemical preparations. Dr. Jack W. Jones. Atlanta. Oa.: I am very grateful for the discussion. I did not have time to go into the various preventive measures attempted in con trolling the outbreak or the treatment. In most of the cases the condition has finally cleared up. Regarding Dr. Sulzberger's di<cu"i"u. we -tutlied this otithreak and the literature rather caretully for a year and a halt or two years, and we are con vinced that the etiology m tin- particular group can he a-crihed to external irritation and not p. any internal Complications. Our idea i that the unstable chlorinated In dr. carh. ii- give ..rf chlorine very easily. wherea- the chlorine that is fixed in the benzene ring i- comparatively -table. When tlie-e un-taMe chlorinated hydrocarbons come into contact with the -kin and enter the - Hides, they are broken down -lowly, giving n chlorine to f..rm hydrochl.T ::d. U'e feel that this is the primary can-e -.f the tr> uhle. ( l . ^ | I , ` . | SI I | I i I i V WATER PCB-SD0000059004 June, loif, Dermatitis from Synthetic Resins and Waxes' LOUIS SCHWARTZ, M.D., F.A.P.H.A. Senior Surgeon, U. S. Public Health Service, Nrw York, N. Y. DERMATITIS in the manufacture . For making plastics, such as telephone re of natural resins and from their ceivers, pipe stems, push buttons, ear phones use has been reported by numerous obacirgtiafirciahloldteeersth, bottle plates, caps, buttons, Inksi ornaments, bracelets servers,1 but dermatitis in the manu earrings. facture of synthetic resins and from For making varnishes, flexible coating, their use has not been frequently re floor finishes. ported 2 or studied. The principal synthetic resins manu factured in the United States are: For making cements, wall boards, gears, dishes, water containers, insulators, rubber compounds, and numerous other objects and for electrical insulations on condensers and 1. Phenol-formaldehyde resins, sold under wires. various trade names, such as Bakelite, Durite, Durez, Resinox, Indur, etc. 2. Urea-formaldehyde resins, sold under The most important of the resins, from a standpoint of volume used and trade names such as Beetle, Plaskon, Unite skin hazards, are the phenol-formalde 3. Coumaron resin, made from coal tar hyde, the urea-formaldehyde and the residue coumaron resins. 4. Ester gums, which are natural resins, such as Rosin, Dammar and Copal, in which the acid of the resin has been combined and PHENOL-FORMALDEHYDE RESINS neutralized with glycerol These are made in two principal 5. The glyptal resins, which are a com bination of glycerol and an organic acid, such as phthalic and malleic acids varieties: 1. The cast resin, which is finished in the 6. The vinyl resins, which are vinyl esters, ethers or halides combined with phenol, formaldehyde and hexamethylenetetramine 7. Furfural resins, obtained from combining factory 2. The molding resin, molding companies and molding process which is sold to completed in the . furfural with phenol (furfural obtained from corn cobs by treating with H.-,S04 and frac tional distillation) Phenol or cresol, formaldehvde and ammonia are mixed in proper propor 8. Chlorinated resins, obtained by chlo tions in a kettle and heated a sufficient rinating various oils and balsams 9. Chlorinated waxes, obtained by chlo rinating mineral oils, paraffin, naphthalene, di-phenyl, etc. length of time and to the proper temperature.3 They combine and are drawn out of the kettle in the form of a syrup. This is run into pans and These resins are used for many allowed to cool, when it solidifies. purposes: This is known as " first stage resin," or " alpha resin." The pans are then Read before the Industrial Hygiene Section of the American Public Health Association at the Sixty-fourth Annual Meeting in Milwaukee, Wis., October S, 1935. ~ heated, the resin re-melted and poured into suitable molds. These are placed in large, mineral oil filled carriers and [586] Vol. 26 placed into c: j,re heated ami beta and gam pleted cast n - After being the resin is u0,1, and was!., and dried, am carved or lath-, obiect is desirt ; ' During the tlons, formaldt air of the root, of it, unless an is employed. bo are sensit develop derm: and arms, a; parts where t. the belt line, t md the wrist The oil use dissolves out phenol and fo over and ove considerable c stances. On analyzed after contained 2 f and formaldeh this oil have t: it and at time acne and dern and other pa soaked cloth ir. titis due to tl phenol and th in the oil. Tf is usually a on which thert and pustules ( The girls resin, with sc develop derm arms from th Strong soap s hands are cc factories, the hydrate after neutralize the June, 193k Vel.26 Dermatitis 587 sms y. :ciephone re' ejr phones, ;ons, inks, bracelets, coatings, i.-ds. gears, rubber 1 and and i'-' resins, ,Jsed and ' "rnaldeind the ^.vs ; "incipal ; in th# old to in the . v and . rnpor'dent ~ope1 i are m of and lies. -in/' > 'hen red ; placed into curing ovens, where they are heated and go through the so-called beta and gamma stages into the com pleted cast resin. After being taken out of the oven, the resin is taken out of the molds and ], and washed with soap and water *ad dried, and it is then ready to be carved or lathed or bored into whatever object is desired. During the course of these opera tions, formaldehyde is given off and the air of the room is strong with the odor of it, unless adequate forced ventilation h employed. Workers in the rooms who are sensitive to formaldehyde may develop dermatitis of the face, neck, and arms, as well as of the covered parts where there is friction, such as the belt line, the ankle at the shoe top, and the wrist at the cuff line. The oil used in the curing process dissolves out of the resin some of the phenol and formaldehyde and, if used over and over again, it can contain considerable quantities of these sub stances. One sample which was analyzed after it came out of the ovens contained 2 per cent each of phenol and formaldehyde. The men handling this oil have their clothes splashed with h and at times suffer not only from oil acne and dermatitis of the legs, thighs, and other parts touched by the oilS'teked clothing, but also from derma titis due to the irritating action of the phenol and the formaldehyde contained TM the oil. The eruption in these cases is usually a diffuse erythematdus base n which there are scattered the papules and pustules of an oil folliculitis. The girls washing the oil off the tySin, with soap and water, may also develop dermatitis of the hands and arms from the oil and also from the strong soap solution with which their kands are constantly wet. In many factories, the oil is treated wdth sodium hydrate after each baking in order to neutralize the phenol and formaldehyde it may contain, but if this is not care fully. done, dermatitis may result from too much alkali. The skin hazards to the users of these cast resins are practically nil, be cause when they are finished no phenol or formaldehyde are given' off from them. The molding resin is made up in numerous qualities, containing different proportions of phenol and formalde hyde and ammonia. It is carried to the alpha stage or beta stage, and then is ground, heated, and mixed with ground wood, zinc stearate, soap, dyes, and hexamethylenetetramine in a mix mill. From this mill it is discharged on to conveyors, where it is air cooled. While cooling, it forms lumps which are ground in mills to proper sizes fit for molding. The workers engaged in mixing, grinding, and packing the mold ing resin are all exposed to the dust of the irritating chemicals it contains, as well as to the formaldehyde which it gives off, the odor of which permeates the rooms. Dermatitis is a frequent occurrence in this occupation, especially if the rooms are not properly ventilated to draw off dust, and if the machines and jobs where there is dust are not properly protected by suction hoods. In a factory employing about 400 workers, where no great care was taken to allay and prevent dust, 27 cases of dermatitis occurred in 8 months. Patch tests performed on 10 cases with various resins, hexa, 4 per cent solution of formaldehyde, and 2 per cent solution of phenol, showed that hypersensitivity to hexamethylenetetramine and to formaldehyde was the cause of 80 per cent of the occupational dermatitis in this plant. Hypersensitivity to phenol was also found, but in lesser degree than to formaldehyde and hexa. The actual cause of dermatitis from exposure to hexa and formaldehyde is the same. They both finally decompose in the presence of warmth and moisture 588 American Journal of Public Health ^une,}^ ;YoL26 V, into formic acid, which is the real skin irritant. Dermatitis from the dust of the mold ing resins usually occurs at the points of friction with the clothing--the wrist, the belt line, the shoe tops and the collar line. It may, however, occur on the covered parts when the dust penetrates the clothing. The skin around the eyelids may also be af fected. The eruption consists, usually, of scattered papules and vesicles on an erythematous base. It gets well if the worker stays away from work, and returns again if he re sumes work. In this factory, the dermatitis was more prevalent in the winter because the workers did not take showers in cold weather after their shift, whereas in the summer they were more likely to do so. UREA-FORMALDEHYDE RESINS These are made by mixing urea and formaldehyde in a kettle. No heat is required, the reaction generating its own heat. A syrupy liquid results. This is mixed with bleached sulphite pulp, under heat and pressure, and dried in tray dryers. It is then mixed in a ball mill with pigments, zinc stearate, and a small amount of hexamethylenetetramine, about j-2 per cent. It is then screened, and is ready for shipment. Minute amounts (frac tions of 1 per cent) of other ingredients are added to different brands. The manufacture of the ureaformaldehyde resins on a commercial scale is more recent than that of the phenol-formaldehyde resins, hence the two factories studied had more modern machinery and safety appliances than the phenol-formaldehyde resin fac tories. There were adequate ventila tion facilities and good facilities for dust prevention. As a result, among 190 employees over a period of over 2 years, there had occurred only 4 cases of dermatitis. They were all due to hypersensitivity to formaldehyde Two chemists in the experimental laboratory of these plants were hy^er. sensitive to formaldehyde and suffered with dermatitis when exposed to it One of them exposed his forearm hj my presence to the mouth of an opeD bottle of formalin and almost j^. mediately an erythema developed on the exposed skin. In a molding plant in Ohio employe about 300 workers, where phenok formaldehyde and urea-formaldehvde resins are used, 26 cases of dermatitis occurred in the first 10 months of 1934 and in a molding plant in Pennsyl-' vania half of the workers developed dermatitis in thfe hot months of 1935, The process of molding is practically the same for all the resins. The powder is placed in a " pill machine " and pressed into proper shapes for the molds. The pills are then placed into the molds where they are subjected to heat and pressure which shapes and hardens them. During the molding process gases are given off from the molds and the odor of formaldehyde is strong in the room and irritates the nose and throat and eyes of those unaccustomed to it. There is an excess of powder in the molds which flows out during the mold ing process and is only partially " cured." This is called the " flash." When the molds are opened the flash is cleaned off the molds and filed off the molded object. Patch tests with the resins with which they worked were performed in the winter on 2 active cases of derma titis, and 10 workers who had recovered from dermatitis, gave only 2 positive reactions, 1 to the phenol-formaldehyde and 1 to the urea-formaldehyde resin. The examination and history of the 1C cases who had dermatitis but were free of it when the patch tests were made, showed that 2 had dermatophytosis and 1 probably had ptyriasis rosea, ll * " js probable that ;. . j 0f the 26 cases 1 . 'not of industrial j * , The same pi j August, 1935. 1 j ' titia had occurred \ 9 months before, t ' yyho had dermat: 1 ` yyere patched wf i of ea-formai .: ! formaldehyde re.-. * fcexamethylenetetr 1 1 no reactions afte: f the. 7 patches a; positive reaction.- : the resins, and <- j positive reactiontetramine. Two of the 4 < reaction had erup patches were appl of dermatophvtoeczema which dan The weather was during the period and this may ha reactions, because ported in 1934, 1> periods of hot wt July, and August There can be considerable pera titis in this plan: origin. That hexamet) major causative f; fact that most of workers handling hyde resin, which than does the urn Hexa, which wa the rubber indus! and caused dernr almost entirely accelerators. It i phenol-formaldern order to furnish of formaldehyde a to go through the . completion. WATER PCB-SD0000059007 - r.afXt tMf y"e, 1936 nnaldehyde. 'experimental "ere hyper* and suffered Josed to it. forearm in t an open almost im-veloped on J employing re phenolrmaldehyde dermatitis hs of 1934, i Pennsyl- d eve! oped of 1935. practically .'he powder ine " and y the 5 into id to <VCS and molding from the .aldehyde hates the of those er in the he moldpartially "flask." he flash filed off Yol.2(> Dermatitis 589 is probable that a considerable number of the 26 cases reported in 1934 were not of industrial origin. The same plant was visited in August, 1935. Twelve cases of derma titis had occurred since the first visit 9 months before. This time 9 workers who had dermatitis during this period were patched with suspected samples of urea-formaldehyde and phenolformaldehyde resins, as well as with hexamethylenetetramine. Four showed no reactions after 24 hours to any of the 7 patches applied. Five showed positive reactions to one or more of the resins, and of these 5, 3 showed positive reactions to hexamethylene tetramine. Two of the 4 cases who showed no reaction had eruptions at the time the patches were applied. One was a case of dermatophytosis and the other an eczema which dated back to childhood. The weather was cold (less than 70) during the period the patches were on, and this may have a bearing on the reactions, because, of the 26 cases re ported in 1934, 18 had occurred during periods of hot weather in May, June, July, and August. There can be little doubt that a considerable percentage of the dermahtis in this plant was of occupational origin. That hexamethylenetetramine is a major causative factor, is shown by the fact that most of the cases occurred in "'others handling the phenol-formalde hyde resin, which contains more of it than does the urea-formaldehvde resin. Hexa, which was extensively used in fhe rubber industry as an accelerator and caused dermatitis, has now been almost entirely displaced by other accelerators. It is necessary in certain phenol-formaldehyde molding resins in tder to furnish the necessary amount f formaldehyde and ammonia required to go through the gamma stage--or to completion. In the urea-formaldehvde resin, hexa acts as a stabilizer to prevent the resin from hardening before it is molded. The ventilating and dust prevention conditions in the molding plants were poor. There were no suction hoods over the molding machines. The suc tion hood over the " pill machine " was out of order. There was only window ventilation in the workrooms, and wash-ups or showers after work were not compulsory. With proper dust allaying facilities, such as forced venti lation, suction hoods, wet sweeping of floors after each shift, compulsory show'ers, protective clothing and oint ments, the incidence of dermatitis in this plant could be decreased. Dermatitis may occur in users of molded phenol-formaldehyde and ureaformaldehyde resin wares if the hexa is not all combined. Theoretically, it is all combined in the completed resin, but practically (as in some imperfectly cured pieces or pieces in which there was too much hexa in the molding compound to be completely taken up), there may be a sufficient amount re maining to cause dermatitis in hyper sensitive people. The same thing may be true of the phenol, if not com pletely combined. Dermatitis has been reported as due to contact with finished resin products, such as dermatitis of the ear from telephone receivers, and of the hands from varnishes. In order to show that a dermatitis may have been caused by' contact with a resin, it must be established that: 1. The dermatitis followed contact with the resin 2. That portion of the skin which came in contact with the resin was first affected 3. A powdered portion of the suspected resin placed on the clear skin near the eruption in the form of a patch test, gives a positive reaction if left on 24-96 hours To determine the actual chemical in the resin which caused the dermatitis, WATER_PCB-SD0000059008 I .f gi r;' r = r;-i~ ' ' l%:Wr- WT-w<a'-l" i; rty&^z--nfym-. =* <;. irC iH'tl* fz "j* t-. '-r..: $11 i# & uvAVs ri r* 6'r*vi JpSt's'i isfli `*19 "1 I iteisiSji l'i^S?P 1**0 .H ; -Pll Eli-8 HM; %))$* :Tfe 590 American Journal of Public Health June, iqj6 the nature and chemical composition removed and the remaining oil js of the resin must be determined, and pumped to a neutralizing tank and patch tests performed on the patient! treated with caustic soda to destroy with each of the chemicals composing- the remaining acid. The oil is then the resin in order to determine to which washed with water to remove the of them the patient is hypersensitive. soluble matter, and it is allowed again The patches of the chemicals should to settle and the water is removed. be in such dilutions as will not cause The oil is now distilled and the reaction on the normal skin if allowed solvent naphtha is distilled off and the to remain on for 24 hours. naphthalene is removed by live steam. A 2 per cent aqueous solution of After this, there remains a heavy oil phenol can remain on the normal skin boiling at 320-330 C., which is re in the form of a patch test, for 24 hours moved from the resin. without causing a reaction. A 4 per cent solution of formalde COUMARON RESINS hyde can remain on the normal skin, in There are no skin hazards, outside the form of a patch test, for 24 hours of acid and alkali burns, in these opera without causing a reaction. tions, because they are totally en Powdered hexamethylenetetramine closed. No skin lesions were found may remain on the normal skin, in the in a large plant and the medical form of a patch test, for 24 hours records for a number of years showed without causing a reaction. no cases of dermatitis. Powdered coumaron resin may re Dermatitis has occurred from cou main on the normal skin, in the form maron resin in varnish which was used of a patch test, for 24 hours without on heddle frames in a cotton mill. The causing a reaction. skin on the forearms of the weavers Coumaron resin is used in varnishes, was struck continuously by the moving adhesives, rubber, paint, chewing gum, heddle frames and some developed lacquers, paper and fabric sizing, print dermatitis. Patch tests showed that ing inks, and waterproofing. thev were sensitive to chlorinated It is made from the crude coal tar ceresin and coumaron resin in the distillate, which comes off between varnish. The varnish grades of cou ISO0 and 200 C. maron resin, especially the darker This distillate is re-distilled to re resins, may contain sulphuric acids re move impurities such as benzol, toluol, sulting from the sulphuric acid treat zylol, naphthalene and tar acids--and ments, if they are not carefully pre a sharply fractionated naphtha is pared, and it is these acids that cause obtained. The naphtha is dried in dermatitis. lead-lined or stone-ware receptacles by treatment with HL.S04, in the propor SYNTHETIC WAXES tion of 3 to S parts per 1,000. After The principal synthetic waxes manu standing a while, the acid is drawn factured in this country are chloro off and fresh HuSQ, is added slowly naphthalenes and the chloro diphenyls. and agitated until 3 to S per cent of They are both used for practically the acid is added. The kettle is kept cold same purposes--as electric insulators during the reaction with brine-cooled on condensers, as insulators on electric refrigeration. wires, in paints, varnishes, and lacquers, After the reaction takes place, the and as oil in transformers. mixture is allowed to stand until the The chlorinated naphthalenes are tar and sludge settle. They are then made by passing chlorine through , naphthalene and hydrogen atoms pj more of the he'replaced, form to pef chloro naf 0f the hydrogen at chlorine, the fur .The niore chloric the material. . jn making chijs first neces-a diphenyl, tured by passing molten lead, at a 800 F., where . combine to form ! hydrogen being s- Diphenyl is a substance. This cylinders and through, replacin. or more of the h replaced, forming dj chloro diphen; diphenyl, C12CIj. is a by-product . chloro diphenyls solid, up to the Nonochloro diunder the trade used as an inst electric wires ar. also as a de-luste In the manui diphenyls, the w a benzol hazard made, as well as inhalation of the The workers e the diphenyl, es the operation wh is being re-distih ties, are affected dition of the si in workers expos chloro naphthale fumes of these on the face penetrate the c! like lesions to - WATER PCB-SD0000059009  U.. :> Dermatitis 5b L jrCCUUtme and replacing of the parti. the shoulders, and the belt-line, cvccytm itoms with chlorine. One and even on the penis. The lesions on c nxr of the hydrogen atoms can the skin resemble acne. Thev begin ;e rfccuecci. forming, money diT tri, up as small, pale, elevated pinnies, many ;t>r chloro naphthalene, in which & having no i_>jx?nings in them. Thev de i - re hvdrogen atoms are replaced with velop into hard cyst-iike elevations .dame, the formula being C^CU. under the skin, some of which go ,1c mote chlorine,. the more solid is on to suppuration, forming boils. Some re 'material. of the lesions also occur tit the mouth .*, making chlorinated diphenyls, it of the follicles and resemble the -.rst necessary ter manufacture comedones and pustules of acne vul utnrryl. CjjHto. This is manutac- garis. .wd i>v passing benzol, CaHe, through In addition to these skin lesions, warn lead, at a temperature of about symptoms of systemic jtoisoning have 09''' F.. where 2 molecules of benzol occurred among workers inhaling these mniiic to form 1 molecule of diphenyl, fumes. Those working with the chloro yinx'en being set.free. diphenyls have complained of digestive- A.nhenvl Is a solidf crystalline-like disturbances, burning of the eyes, im '.no.ttir.e. This is melted in dosed potence and hematuria. The latter w finders and chlorine is bubbled symptom developed among a number nrnijyh. replacing the- hydrogen. One of men making amino diphenvl. which r :iore of the hydrogen .atoms can be is used in the manufacture of a rubber -Placed, forminganon chloro diphenyl, antioxidant. Cases of death from yellow dnir, diphenyl.' up to deca'chloro atrophv of the liver have been re .-(^t.vI. rlsClH)< Hydrochloric acid ported among workers exposed to the- -iv-product of this reaction. The fumes of the chloro naphthalenes.- v.'-m .-iiphenvls are. liquid ' or semi- Patch tests performed with Halowax -f` to the hexa chloro diphenyl.' and with the chloro diphenyls have V'Vhloro diphenyl, ,CiaHGl;i, sold yielded! negative results. The skin vUr 'He trade name- of' Arachlor, is lesions probably result from the- m insulator fdr automobile mechanical plugging up of the follicles '.ires and' iri' condensers,-, arid - of the skin with the-waxes as the fumes 1 '-i <Je-lucferer of rayon.'.. manufacture', of1 the chloro the workers'are^'exposed to 'A"4 tiHxard whbn * thb Jdiphfenyl is "** >'x '-ell ns to at'hhzard lfrom dhe-,f 'the firnies. of di^henyi.' solidify on the skin * The chlorine present. in '. the waxes may have anirritating effect on the plugged- follicles and ' cause' suppuration. PREVENTION ' " 'u'/ers engaged !itv'chlorihatihg ' especially- that' part' of "* "t-m whnre'th'e crudd1 Afachlnr --.v r i /'itiillnddto remove impuri ' hiv-pid with ansacnedike1 com - f 'hi' -kill,- This also i occurs ' "`ptW'd lo thfe-fumes of the' l.'Tho protection of the workers from the irritatine chemicals that compose the resins and waxes from the resins and waxes themselves. To dd this, the process should be totally en closed.' If this is not possible, hoods wilh suction exhaust' should ' be so placed over open processes that'dust and fumes urn pulled away from the worker and out o the room: " ` "'d-nt4tBfipst or'Halowax:; The< ' ')*<' (.ofrtpouuds cause' acne. ' f rr" iirtrt' neckk andd may *. *!'(hltHbssandn caasecacne*to dA'tWppoftMhfe covered 1 *11 have' recently seen the wife and : child" of' a ' worker who had developed comedones and ptisfille* from ' contact with hit)-work' clothhs which 'were-saturated with hftkiwax and -which hk wot accustomed to- wear at-hbme. L. S.~ s ft *' -wmu f! Mall WSBm S727/ sr m THE JOURNAL OF INDUSTRIAL HYGIENE m iLa AND TOXICOLOGY Volume 19 SEPTEMBER, 1937 Number 7 THE PROBLEM OF POSSIBLE SYSTEMIC EFFECTS FROM CERTAIN CHLORINATED HYDROCARBONS* a 4 'X Cecil K. Drinker, Madeleine Field Warren and Granville A. Bennett Department of Physiology, Hot card School of Public Health and Department of Pathology, Harvard Medical School, Button, Matt, THE use of chlorinated naphtha rapidly and thoroughly as possible, f f lenes and compounds of allied In brief these eases were ns follows: pharmacological possibilities is Patient 1. Male, age 21, The previous extremely wide, and will; the steady medical history of this man was in no way growth of the use of electricity is cer significant except for the fact that he had tain to expand much farther. For years it has been known that many of these compounds cause a troublesome sene, and there is n large literature an attack of jaundice about 6 weeks prior to his fata! illness. Late in December, 1936, he became badly constipated and had much abdominal pain and distention. When ad mitted to the hospital he was slightly jaun upon this phase of the subject. Our diced and was evidently very ill. He was 1 investigations have not been concerned somewhat anemic and his skin, particularly with chloracne but with the possibility 1 of systemic effects following ingestion or inhalation of sueh products. In the upon the arms, face, chest and back, showed many pust ulcs. He died after a brief period in the hospital, and at autopsy was found to spring of 1936, tin; 11 a Iowax Corpora tion, ft division of the Bakelhe Cor poration, called our attention to three fatal cases of jaundice in workmen using chlorinated naphthalenes and chlorinated diphenyl, and requested that the subject he investigated as * Received for publication June 30, 1937. t Tne Halowax Company makes many products besides chlorinated naphthalenes, and it has rumt- to our knowledge that all of these products are indiscriminately called "halowaves" by purchasers and users, and arc lumped together as possible causers of acne and even of systemic disease. Since "IihIowox" is merely a trade designation, care should be taken to describe compounds by their rhcmienl names and thuB avoid condemnations w hich are both troublesome and misleading. 283 .! 9t3e WATER PCB-SD0000059011 ^ 284 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Stpl. 1# l'ui- at, : have a cirrhosis of the liver with acute yel low atrophy superimposed upon it. This man had been exposed to low concentrations of vapors arising from a mixture of tetra and pentaehlorn&phthalenes, together with approximately 10 per cent of a refined chlo rinated diphenyl. While both he and others engaged in the same work had chloracne, there were no other disturbances of health in fellow workmen, nor was there any pre cipitating cause for the acute, yellow atro phy such as treatment with arsphenamine or exposure to dangerous concentrations of carbon tetrachloride. Patient i. This was a young man who died in February, 1936, after an acute illness characterized bj jaundice. He had been exposed to fumes arising from a mixture of penta and hexachlornaphthalenes. There is no record of chloracne. The patient worked with a large number of other people of whom but otic (Pntient 3), a close friend, had significant illness. F'at-ient S. Another young man employed with Patient 2. lie became jaundiced in March, 1936, nnd died after an illness of 2 weeks. A careful autopsy resulted in a diagnosis of acute yellow atrophy of the livet Here again no history could be ob tained as to a precipitating cause, and there was no record of preceding attacks of jaundice. In addition to thf.se throe very re cent fatalities, we have learned of four oilier possible eases, none of them fatal. Ail of these have had jaundice and the entire group consists of iso lated individuals who have been picked out of large groups having the same, exposure. In but one instance, Pa tient 1, is there record of antecedent disturbance of health, and the general health, of fellow workers has been good. Such cases have not been reported in the medical literature and only occa sionally can one find reference to sys temic effects of any sort. For exam ple, Courtois-Suffh (1934) reports cm work dope by Tournine and his asso ciates (1934) w ho examined 00 workers who had been exposed to tricolor* 1 A mix!u;i 0 * 1 naphthalene. Of these 13 were found naplith: to have mild digestive complaint 2. A mix; i, r m anorexia, nausea and vertigo, Courtois-Suffit remarks finally, sorption is certainly possible and **, f 'hiurnap!-: i,. 3. .\ mix'urc . a ( 'hi- -n.a oh! have for proof of it some of the dig*1 tive and genera! complaints whick Ti nddif ion, -i .l !ii I3i wen ' f( ,iii i have been due. to it. But they apP6** ^beulaiu-.Mi-le. to be of little consequence consider? the mildness of the digestive troubl and the absence, of respiratory ph*", A t) r j i1 of 1 ) i the sub!;itual" , i i aiVpo,.,foil! h- \, . nomeua," In Touraine's cases the exposure to a triehlornaphthalene, whereas d* ; aUtO|,sir 1 Th, i;r. Ulill.N ft.,., ') ' i 11 Lr '') .) hay ;i ,,;1 thr L-l-i h--. America;i cases of acute yellow atrofhf: were exposed to compounds of higl^ 1 hose iv.i'<4\ 111t 1 ,. - 'er,. (.v }lHr . chlorination. Our own experime0**j indicate that triehlornaphthalene.' & quire enormous dosage, far bey^ anything encountered in industry, : order to produce liver damage. T* eky (1927) reported a number of AlUopsv i!: Mrikiim h">eril m j a,'Ut e vc 'lr-T , Mlgu,,sfjv ' 1 1 I : I . . - - ' rhi'lr th, ,* ( of chloracne in persons exposed W or m,j. / chlorinated naphthalenes with a dA* them an- a: :i! . rine content ranging from 14 to 53 J aLnj>ji v , ,f -, r cent. He found chlorine cor,tent that the the less lower W* j the s^'Jj K t At hluii; tie 11( MJ;, ,, a a. i -F:.! v _, p. Mittelstfidt (1935) examined a nuk fa,,1 that 1 111 ` ! of cases of chloracne due to tricksy ^ naphthalene and reported a number* J vague general complaints but noih^S in the nature of serious disease, garding his animal experimentation, Lehmann (1919) reported that inals fed chlorinated naphthalenes^ fused to eat after a time and whether poisoned by inhalation ot feeding, at death showed ``peili*pl lesions in the liver. Flinn and (1936) gave subcutaneous injection*' enormous doses of chlorinated B*i thalenes dissolved in paraffin oil f||| rabbits. The compounds used as follows: 01 ucut, vdhn ' i hi men w . Ifkii.' wi-(. . thalen.-s 1 'll* \ h* Uleiii. sarim A'- I f > ^`Sinning o! I hi - I,;.- bn,. av . 11 j: i * ' iteralure l II M 1! , thtse sub-U anr, - . h ' i ! 1 I ! i J: ' of 1;!, !l!id Jarviu p.h'.t, ' (>r even s;,,,. uh'"H human 1 ,, m " i hr) , |, i, lhui the i|i.,,ri,. WATER PCB-SD0000059012 rvt 19, KI-TKCTS OF rilLOUlNATKO HVI)RO('AIlHONS 285 A mixture of tri ami tetruchlornuphthulene. 2. A mixture of tetra ami pentachlornaplithalone. 3, A mixture of pent a and hexachlornapht halene. In addition, sublimates from (2) and (3) were collected in oil and injected subcutaneously. None of the animals receiving (1) or the sublimate from (2) died, and even after 2 months W ere quite normal when autopsied. The first death in the ani mals receiving (3' occurred on the 121 h day and the last died on the 2bih day. Those receiving the sublimate from (3t were even more severely affected. Autopsy in these animals revealed striking changes in the liver, not, as described, entirely I'haraeteiislic of acute yellow atrophy but sufiieiently suggestive to cans,' the authors to eondude that `'eeriam chlorinated naph thalenes or i: 111 >u ri t it - - contained in them are capable of producing yellow atrophy of the liver in tin rabbit." At the beginning of their paper, Flinn and Jarvik (l'.idfy. mention the fad that tie r, have oem, three eu-e> of acute yell,iv, atrophy of the lb or in men working v ith chlorinated naph thalenes imt g:\ e no d< i ails in regard to them. These ease.-- are undoubtedly the same as those described in the beginning of this paper. due may summarum the meagre literature upon systemic effects from these substances as follows: ]. With the exception of the men tion of acute yellow atrophy hv Flinn and Jarvik (193bi there are no reports or even suggestions of serious effects upon hitman beings. 2. There is evidence 'Teieky, 1P27) that the degree of chlorination is sig nificant in relation to tlm production of acne. In the work of Flinn and Jarvik (103(1) the compounds produc ing serious liver injury were the most highly chlorinated of those, tested, though the chlorine coni cuts as given by analysis vary surprisingly little. 3. There are no published figures upon the amounts of various chlorin ated naphthalenes in the air which will produce injury of any sort, and while tin' work of fs'hmann (1019) am! of Fliim and Jarvik (193b) point to the liver its a possible sit, of injury this indication rests upon Mich extreme dosage as to fail to apply directly to human exposure. Kxpkiumkntai. Work In appraising the possible toxicity of any substance met in industry it is first necessary to determine the prin cipal route of absorption. In the ease of the compounds under considerai ion there can be no doubt that inhalation is their chief means of entering the b,,d>. They tire used hot in a great vat'ir-U o! operations ami volatilize in \ aried degree. They ate olden applied in solution in such volatile solvents a.< urban tel raeldoride and toluene. The amounts reaching the air under such circumstances are hardly detectable. it will however be shown that, carbon tetrachloride adds to the toxieily of tiie chlorinated naphthalenes ami allied compound', and if there is possibility oi inhuiing these compounds in other parts of the factory then inhalation of carbon tetrachloride adds a decide,! hazard. I'nder sm-h circumstances solvents such as toluene should be Used. Observation in a number of plantcauses US to feel that ,'Vell though WATER --aMW^r*8 ------^m^m- f^ i t Ih 2S .ioi'kxaj, or i,\i11 si'iuAi. hycikxi: and toxicology [,S'rpl. t9Si h vol. 19. f| workmen may be extremely dirty and lion. Tlie-y thri\e- upon a diet ver? ? I careless, comparatively Intli- ol tln-M similar to man, and in the case of thee* I'. waxes is eaten. They are teunciope i hle>ri11ated compounds it is peissiM1 substance s, insoluble in water, and if they net on the hands they stick there that diet may be very significantFinally, their normal e-liaracte'ristics and are not 1 rniisfctTed to the food Skin absorption is the third possible have- been de-se-ribed so well as to matt1 the- detee-tion of abnormalities both memos of entering the body, li m:i.\ e.e-cur but at best must be slight wle ii compared to the- steady inhalation of i-!|sy ami certain. Mrtliod of (fjinsm i. The- in)mlati<m experiments were' onrried out in K>nf finely e 1 i\'ide-e 1 or rtis'iiie male-rial in large air-tight wooden boxes, t-'lieu t !n air. capable oi bolding ten ml cages. >1Zl /' I'u, I. I 'l'oiit \ ic'.\ im,l ii.ii,m i ml ef i n i li.,\c.- h ith niI cages m |ilacc amt <|nuts ip--o Inhalation experiments an- then the ii.isl iinpoi'lant sonfecsot iiilurmation, but- to them \vi have add'-d a eerl-am tn.imber o! eibsi-i'val ions npou ingest ion and s| i bent a i iei n is injection of tarioue< ilil pout tils'. /lihchil-o/i ExjH rum /<i-s Alumni*. While Pits h.'IVi Ihi-ii employed 1 lirougliou1. Thc\ permit the i;sc of a larg" number ol urnmab it- a reiat iv t-lv small inhalal mu i.p! al!a- 22" x 22" x 14", in two tiers of fixe cage-, each. \\ hen t in - experiment w.-ts not ill progress tin- doots were npf'ilCG wide and tin- cages kept in place n'igure It. At the center oi one end oi each box tiie inflow end air was ini reduced through a pipe 7 im-hes in dianicbT tiguie 2'. hath box was equipped with an individual variable-speed elrcfie blowet which, blew the air tlivollgp si i et a! I eel - ii 7-ti teli ) ipc i n !i ,-r. futet- eiihirin.'p i mgmg, WATER PCB-SD0000059014 m7 ( TV 'SC finmt. l-Fties i make - I Kith alalion in four , each es, size i - hi live * 11111'111 w as l | c i l ] )l1 ] 11 `11 I IM ] ilai'i' I , ,i rarli I >\ i:il niilucoii 11diameter tmiuipllfMI -peed elocair 11 inmil!i iu'liirc <-i:WT- . '\ I III.(TSOI ( III.OMNATKII il Yblim wniioxs IJ.S7 inp tlic end of the box. An orifici meter was plarcil ill tlic pipe line, and tin' flow of air in cubic (n ( | m t minute chlorinated diphenyl were placed ill the boltoi11 ol each Mask and melted in the elect r'1' heater. Fresh samples wop' could 111' adjusted and lead ofl directly from a ndil n ut inn nin e. A vane deflector placed at the entrance of the pipe into the box was adjusted to as sure a uniform distribution of the stream ol air to the two tiers o| capes. used every other day, but it was often found iiecissan to add 20 gm. of new material even after one run since so much had sublimed. Whatever I he case, the collected sublimate was At flit* opposite end of the boy the outflow end the air from each box was exhausted through a 7-ineh pipe fitted with a damper and eomieeied to a large central exhaust fan (figure T. About -1 inches from tin entraneeof t.Jie 7-inch pipe into tlic Im>x, the fumes of the substaiire.' listed were ml in duced into the inflow inp air. Spe cially designed pyrex pla-- ilasks (figure 4), 7;,1 inches loop and with a diameter ol li im-hes. were used to held the heated waxes. The-e Ilasks were made with a side arm and tide that extended In tlm 1)1*1 1111:1. The top of the flash un- guumd. and into this fitted a short tube j .'. inches ill Jrnpth. This ~h> r! lube was inserted into a large mhhm -1 * p | n i lhal filled tightly into a hole m ,rn< m t j,,- 7-ie.eh pij on t be under side , tigui'e 2 n The Mask in turn w a- iTu-ed n an elect; ie iieatcr made In rover it completely below the side arm and1 ground gin-.- top. Kldibci lulling connected the side ai'iii with a compressed air resetvoir and a gentle .stream of air blown through the mein d wax kept it in I'm lb", (ric tieaO-r for in.'iieliiining I'liloriuai cil ei, i, j)*,(.;)11 s- ;,t a const an t t chi l>ii\-i!UD ie phe r a|. iiilluw eml of lies. motion and assured uniform heating. Into eacli (lash wa- inserted a lung mcm always removed from the upper par1 ol liie flask and a clean top used each centigrade thennonu iin which \\akept in p!a,-i and could be read at any time above the i-ioeh pipe through wliicli it juissed 'fisruri 7b. Approximately MO pm, of pulverized chlorinated naplithaleiies or 20 gin. m day. No sample was over used for more than two runs. The flask phis the contents was care fully weighed at the beginning of the run and a! the end, and the loss in weight used to calculate the average WATER PCB-SD0000059015 Ai 2S8 JOURNAL OK INDUSTRIAL HYG1KNK AND TOXICOLOGY [.Sept. 1M" flowmeter Tradings. The figures ob tained were not absolute because of slight variations in the air flowing through tlii' boxes and because of deposition of material on the ther mometers and on the inside surfaces ot the box, but they cheeked well with direct determinations through atr samples. Approximately 1 hour was allowed for the wax in the flasks to melt and come to a constant temperature. At that time the box doors were tightly closed, air bubbled through the Husks, and the blowers 1 timed on. This was the beginning of the exposure periodBy means of rheostats on tin- funs sum dampers in the out How pipes, the amount of air tio.\ing through the boxes wa~ adjusted and an attempt was mad' to keep the lour hexes as uniform a- possibh usually between Kid am! ]7d e.f.m. In tlie first group of e.\|H'nne?i)ts ha' following substance' wen tested: 1. .V mixture of Lrichloniuphthaleues plus a truce of tetrachlornaplhalene. Chlorine content J9.9 per cent. 2. A mixture of penta am! hesueiilornaph! halcnes. Chlorine content 02.ti per cent. 11. A mixture of 90 per. cent petnu and hexaeliiornaplithaietwy plus 10 per cent refined chlorin ated diphenyl. Chlorine con tent Odd) per cent. 4. Chlorinated dipheuvl. Chlorine cooti-nt (id.O per cent. The compounds were selected as rep resent ing a certain range in clilorination and aXo i weauso of their industrial nnj>ortanci . ]u each instance SO ani mals w ell- exposed, it' rats being placed in c:H) cage. Tie v were fed. Purina IS, no. 7 jSS^Dog Cho'v sat .>4r\ KS. milk cue. ' This fir't gr||: begun on JC> * tposUl'e to MC if':ehlt>rnaphti>at |p6th. Tia ex-, ' Compound' 1 L.lSth On r;c five animat' \ C Sure from g-m. killed aide' 2 15th. in order ' f'ftCoKiirru-.N.' M e - f j-frichloro aii k S'. tetrach: j;,-,, and O x:. ib penta me! j Manes p;UB Borina`-d die; a-iod would b affect" i 1. pPP 3 w -->rposure cm 1 B?r nxamintit io.. The average S-u hours -l-.-ily fack mond."g -a set, and bet p.rn. tic ' ^ghed, etc 1: rmity of exi-' gifted cm a r... fvyfsf, s.,^ >x , WATER PCB-SD0000059016 r 7\ | EFFECTS OF CHLORINATED HYDROCARBONS f T'1! Chow supplemented by lettuce, wax concentrations were somewhat .^s, milk and cod livev oil. higher at the inflow end of the boxes. r 111is first group of experiments was Preliminary runs showed that once ^un on July 1, 1936 and the last properly adjusted, wax concentrations ypfBure to number 2 (penta and liexa- in the air remained very uniform from ^tornuphthalenes) was on November day to day, but to insure absolute ffih- The exposure to the other three safety readings of temperature, air ppmpounds ceased upon November flow', etc. were made every night be jgth. On October 15th representa tween' 10:00 and 12:00 p.m. as well tive animals were taken out of expo- as on starting and stopping. At dif wn from groups 1, 2, and 4 and were ferent times during the course of the |21ed after 2 months on Deeember experiment tests for free chloride were jjth, in order to see whether this clear made but were uniformly negative and TABLE 1 QgjfDITlONB MAINTAINED IN INHALATION EXPERIMENT FROM JlTLT I TO NOVEMBER 16 AND 18 MATKA1AL CBLO* BINV rsuv. CONTENT Triohlornaphtbaleuea plus traces of tstraehlornaphthalene...................... % 49.9 c. 150-16C AV. COHCKNTHATTOM OF AIB IN UOX ;CU. *n. 1.31 High 2.80 Low 0 10 TOTAL SI* FOSL'KE AV. DlAILT ilPCSURA hc*rt hovr* 1896 16 penta and hexachlornaphthaiene*.... 62.6 160-170 J 16 High 2.19 1864 16 r penta and hexachloruaphtha- Low 0.51 If*plus 10% chlorinated diphenyl. 63 0 166-175 1.37 High 3.17 1896 16 Low 0 64 C&oriuated diphenyl............................. Co 0 165-175 0.57 High. 1 19 Low 0 23 1896 1C period would bring about recovery in the affected livers. Animals from poup 3 were similarly removed from exposure on October 4th and killed {or examination on December 4th. The average length of exposure was 10 hours daily for 6 days a week. Each morning at about 9:00 exposure eased, and between this time and 4:00 p.m. the rats were cleaned, fed, weighed, etc. In order to secure uni formity of exposure the cages were shifted on a regular schedule, since showed that under the temperatures used no decomposition occurred. Tabic 1 shows the temperatures at which the various substances were held, the average concentrations per cubic meter of air, and the average exposures from July 1 to November 16 and 18. The concetUntiion of ahthalerm and chlorinated <,>.{ air of workrooms.--Table 1 shows that animals have been exposed to varied concentrations of the substances under 111111 MM WATER PCB-SD0000059017 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sefit. 290 test. The concent rath' may he regarded as fa tive of industrial exp. r. i, mployod /" ta. to in question is passed over heated pi***" nurn in an electrically heated ([part* tube and the effluent gas scrubbed in a column of glass beads moistened witb the initiation of inhalation experi sodium carbonate containing a trace of ments a number of estimates of chlo rinated hydrocarbons in the air of dif ferent factories were made and the sodium sulfite. The beads are then washed down and the chloride deter* ol. 19, no. ?| i ; somewhat ease r n- TebbeusV but ' :.>1 devices are the In both eases *o:. V;'- tinated hydm< we St &cid and sub-i or Sodium earbonaV In our ease eon ''> suction apt to be very Tv leas xban 1 mgi... : quently the am w actually formed m t 80 small that it < either gmvimotrn-i Tor this reasi u v. use the j-ph< som -t: is sensitive : i r< vi NOT DRAW WTO SCALE sa 0.1 nigm. per It is douijtii should exceed 1 h conversion of v.i-pound to byd:: ; subsequent aT.'r.v unless the vel< low. Another ;' is that the mmh a Fl0. 5. Dimensioned sketch , KflJSTAWCC FURNACE quaear. 7MMUG1P*1 aorr NicHeoMEwifB pia|t t0 platinum foil wickia/5 fc" * rs57* ooo/" is.i.4 isi ,t o.cc-c5-4 cm. of combustion tube and absorption apparatus concentrations chosen for inhalation experiments depended cm these exami nations. The technic of analysis am! the apparatus employed were the work of Frederick R, Milihiser and William F. Hemperly. The method and apparatus used fur determining concentrations of chlorin ated hj'drururbons in air were adapted from well-known procedures The air . . .. oa gilf mined nephelometrieally as chlTocribdbeo. iis (1937) has recently & i scribed a method and apparatus whi Jf should be equally satisfactory for ths work. In figure f> we show a dime' 5; siormd sketch of the combustion t0& . a;i<] ab.sor])1inn apparatus as used bf ^ us in botJi our laboratory and ms. The absorption tube ^..| j- teiy chlorinateu determined In:. distinguish betve |. tswe.sbut detern.m. the results nm '. puted in terms m ' .. At the prore-.. 'v l.fonnation as i<> vn I'Hnated naphtha'''-different plea a;: vfegtanccs .he repeated m.-v< r.. ' j;4he amount' hiv|. those used in ; u: taust lx- reiiu-n.. The (-r-mliusl'i- r-|vjr;--tlis s-,,u.ivte. d t-> <>'D ' W Wiltauu ., equipment i;.f .^tiou pump with a WATER PCB-SD0000059018 tM. 19, no. 7] EFFECTS OF CHLORINATED HYDKOCAKBONR 291 somewhat easier to wash down than is Teblx-na's bill the essentials of the two devices are the same.* In both cases conversion of the chlo rinated hydrocarbons to hydrochloric acid and subsequent absorption as sodium carbonate should be complete. In our case concentrations in air are apt to be very low--the objective is less than 1 mgrn. per cu. m. Conse quently the amount of silver chloride actually formed in the final reaction is so small that it can not be determined either gravimetrieallv or by titration. For this reason we have been forced to use the nephelometric procedure which is sensitive to concentrations as low as 0.1 me.ni. per cu. m. of air. It- is doubtful if the sampling rate should exceed 1 liter per minute as conversion of the chlorinated com pound to hydrochloric acid and its subsequent absorption are not efficient unless the velocity of the gas stream is low. Another precaution to be noted is that the method is not selective -- any chlorinated substance will bo determined. Furthermore it docs not distinguish between solid particles and gases but determines them all alike* and the results must, of course, be com puted in terms of total chlorine. At the present time we possess in formation as to the amounts of chlo rinated naphthalenes in the air of 30 different plants, and in a number of instances the measurements bate been repeated several times. Frequently the amounts have been greater than those used in our experiments, but it must be remembered that the rats * The combustion and absorption appa ratus suited to field sampling is now made bv Willson Products, Inc.. Heading, Fa. The equipment includes flowmeter and suction pump with a carrying case. have been exposed for 10 hours to an atmosphere constantly impregnated with the substance under test, whereas human exposure is usually a variable, quantity, intense for a short time and then negligible. It is our opinion at the present time that the concentra tions of chlorinated hydrocarbons used in our experiments would be dangerous for workers in the case of compounds above trichlornaphthalene in chlorina tion. Fortunately it is easy to venti late processes of manufacture which require these substances and to reduce air contamination practically to the vanishing point. Such treatment of the problem at once removes both the possibility of systemic poisoning and the annoyances that arise from cases of acne. Results of Iuh'ilali.ju Experiments. 1. Animals exposed to a mixture of tnchlornaphthalcnc's plus small amounts of tetruchiornapthalcne. Living animals were apparently en tirely normal. Autopsies performed near the end of exposure seemed to show slight, swelling nf the liver, and mieioscopie examination occasionally showed swollen ami by pergranulnr liver cells. The changes wi re, however, never more than slight. 2. Animals exposed to a mixture of pent.a and hexachlurnuphthalenes. No abnormalities were observed in the living animals. Itats were killed and autopsied every ti weeks. In the first animals sacrificed liver changes were observed. These were swelling of cells, slight granulation and hyalinization. In September and October these conditions were somewhat more ad vanced, and in November the process became siationaiy. There were highly 292 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [AYp/. 19S7 granular cells, liyalinc inclusions and mitotic figures, but no more than 2 months previously. 3. Animals exposed to a mixture of 90 per cent penta and hcxachlor- naphthalenes plus 10 per cent refined chlorinated diphenyl. No abnormali ties were seen in the living animals. After G weeks the livers showed changes similar to those in the animals exposed to penta and hexachlornnph- thalencs. These advanced in grade during August and September and then became stationary. 4. Animals exposed to chlorinated diphenyl. No abnormalities were seen in the living rats. After 6 weeks' ex posure there was slight liver damage which advanced during the next 2 months. The changes consisted in slight to moderate swelling of the liver cells, an increased granularity and many mitotic figures. IJyalinization was always present as a result of inhalation of chlorinated diphenyl. Summary of the first inhalation ex- perirncnl.--In these experiments care ful observation of appearance, body weight, activity, blood, and urine showed no abnormalities of any sort. Yet after G necks' expo- " the. compounds with chloric trichlornaphthalene enuoca. '. - grees of liver damage, and no changes whatsoever in other organs. There was no acute yellow atrophy or any thing suggesting it except that a slight degree of liver damage was always present and was quite clear in the liver sections examined microscopically. This damage hud no detectable i fleet on the health of the animals. They held their weight, ate and behaved norma!!}', being in e\ cry respect similar to the many people vho have been exposed to these compounds without illness of any sort. The functional appraisal of the liver damage caused by certain chlorinated naphthalenes and by chlorinated di phenyl.--There are no tests of liver function useful in such minor degrees of liver damage as were produced in these experiments. Indeed the ani mals resist'd the injury so perfectly as to display no abnormalities except .upon histological examination of the liver. The situation was perhaps similar to that met in industry, where, barring acne, the health of work'-rs in the.-e compounds has been good with the exception of the fact that in iso lated instances jaundice has occurred which upon at least throe occasions has gone cm to acute yellow atrophy. During recent years this disease has been seen following administration of carbon tetrachloride, arspbrneiniue and cineopheti. In the case of carbon tetrachloride it is known that a low calcium diet and alcohol favor the pro duction of liver damage. For the acute yellow atrophy that occasionally complicates use of the other two drugs no cause can be assigned. One cannot produce acute yellow atrophy with arspbenamine, but somehow or other this now and th.cn does happen to pa tients under antisyphilitic treatment. It occurred to us that something of the same sort might be involved in this problem. The human eases have been sea tiered and few. They have been isolated instances out of large groups of healthy employees who have had equal degrees of exposure It was our idea that perhaps many of tln-s-e people got liver changes such as existed m our rats, changes not recognizable through f & : i ; & b i I * <>oi. is, no. r; any moan? nth - ; nation. If, r; ' such change-, -i disturbance, a-v not a viy which any of < r. this relatively w over to acu'e ; A Knowing t; had liver ' . slight c .vi-*' n 1 we decided v ' - subs; a news g . Struct if U:. vb.lv alcohol w'! matim, Inal i u chloridi tin- f '; per kilogram v f normal v bit" r:.* , to 0.7.') no. 0.75 cc. of ' " I ; Tills mKiv tube ;.v the n " main and v. i! h ' following lab b .v Rati fed 0.7* teira In'.ir:-:"' s' 1. le-nic. r chtornoniUI' iv . 10 ifi.T) 10 rv 2. Pen in vb at 9:30 a.m.. b 0 .!: i \... 30:30 ; - 1 (ill ;! Nov. V 1 'bed \rv i nie.i > 11:3m .. . i dev! N: v. 1 J;t , , (ii"u N'.v tv liitii ivb " r,. 90 thalnn f ci'i !> ; ' Fed at 1C*.00 i )' I f WATER PCB-SD0000059020 lepl. 19S7 f )OUt the liver jrinoted ted di ll liver degrees need in ue anierfectly except of the icrhaps where, kers in d with in isocurred : as ions ophy. ise has lion of uunine carbon / 'O- . die k in ally drugs annot with other to pauueut. ing of m this : been been ;roups e had as our leopie in our rough m sol. 19, no. 71 EFFECTS OF CHLORINATED HYDROCARBONS 293 any means other than autopsy exami nation. If, upon the substratum of such changes, they got ;m acute liver disturbance, acute catarrhal jaundice, not a very common disease but one which any of us may experience, would this relatively innocuous disease go over to acute yellorv atrophy? Knowing that our inhalation rats had liver changes, but changes too slight to cause recognizable symptoms, we decided to test their resistance to substances known to cause liver de struction. Carbon tetrachloride and alcohol were selected. Having infor mation that 1.0 cc. of carbon tetra 1 died Nov. 10th between 5:00 and 10:30 p.m. 6 died Nov. 11th between 4:30 and 10:30 p.m. 1 died Nov, 11th between 4:30 p.m. and 9:00 a.m. Nov. 12th. 2 died Nov 12th about 1:00 a.m. 1 died Nov. 13th between 5:00 and 10:00 p.m. 4. Chlorinated diphenyl. Fed at 10:00 a.m., Nov. 10,1936. 10 rat-s. 1 killed Nov. 10th at 10:30 p.m. (almost dead). 2 died Nov. 11th between 4:30 and 10:30 p.m. 1 died Nov, 12th before 8:30 a.m. (stiff). 1 died Nov. 13th between 9:30 and 11.00 a.m. 1 died Nov. 16th between 10:15 p.m. chloride plus 1.0 cc. of ethyl alcohol per kilogram would kill 14 per cent of normal white rats, we reduced the dose to 0.75 cc. carbon tetrachloride and Nov. 15th and 9:00 ft.m. Nov. 16th (stiff). Controls: Fed at 9:30 a.m., Nov. 12, 1936. 10 rats. 1 killed Nov. 13th for normal liver. 0.75 cc. of ethyl alcohol. This mixture was given by stomach tube to the following groups of ani mals and with the results found in the following tabulation. This tabulation summarizes into the facts that : 1. No normal rats were killed by carbon tetrachloride and ethyl alcohol. 2. No trichlornaphthalone exposed fiats fed 0.76 cc. pc* l.gm each of carbon tetrachloride and ethyl alcohol by stomach tube1 2 3 rats were killed, and this fimLing agrees with our inability to find lesions of moment in the livers of the animals that inhaled this substance. 1. Trichlornaphthahnc plus trace of tetrachlornaphthalcne. Fed at 9:00 a.m., Nov. 10,1936. 10 rats. No deaths. 2. Penla and he.xachlornaphlhalenes, Fed at 9:30 a.m., Nov. 10, 193o. 10 rats. 3 died Nov. 11th between 4:30 and 10:30 p.m. ] died Nov. 12th at 3:20 p.m. 1 died Nov. 12th at 4:30 p.m. 1 died Nov. 13th between 9:30 and 11:30 a.m. 1 died Nov. 15tb between night of Nov. 14th and 12:30 p.m. Nov. 15th. 2 died Nov. 16th between 10:15 p.m. Nov. 15th and 9:00 a.m. Nov. 16th (stiff). 3. 90 per cent penta and hciuchlornaphthalencs and 10 per cent chlorinated diphenyl. Fed at 10:00 a.m., Nov. 10, 1930. 10 rats. 3 The penta anil hoxachlorinated naphthalene, the mixture of these with 10 per cent chlorinated diphenyl, and finally the la* u ' i alone seem to have promr . ons lowering the resistance to ...; ..gent capable of producing serious liver disease. 4. The sole lesion produced by this test of liver function was acute yellow atrophy usually accompanied by jaundice. This test of liver function was ac complished with a substance which itself is an organic chloride and curi ously enough it is the only substance we were able to find that was effective. - WATER PCB-SD0000059021 294 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY (Scpf. 1 lml, lg In animals with the minor degree of liver injury which has been described we were unable to produce acute yellow atrophy or any variety of liver effect with ansphonainine, cineophen, butyl chloride, ethylene (hloride and tetrachloret hylene, but carbon tetrachlo ride was uniformly effective in dis closing the existence of liver damage. Recovery from livtr damage fallowing removal from exposure.--Animals ex posed to triehlornapbthnlonos plus traces of tctrachlomaphthalenc being practically normal on removal from exposure need no consideration. In the case of tho pmita and hexaehlor- signs of liver injury will be many months in returning to normal. The effect of high concentrations of tnchlornaphthalenes with traces of letrachlurnaphlhalcnc,--The first group of inhalation experiments showed that this material in concentrations averag ing 1.31 rngm. per cu. m. of air was relatively innocuous, judged both by direct observation and bv the carbon tetrachloride test. This is an in teresting fact since such compound? cause acne, though less potently than substances of higher chlorinationIn order to explore the matter further one of the inhalation boxeswasarrangod -A Other.- t|.> fats were one may i,.m oblornnfii,! i.-b _ as tl, , . IS they an- , Upon t),e jl, batuji, an e, 77,- P> >-tn -ItiCl'e ,. i ., ficc ,j, ,,,, .,.,. but if, ;|. Ported m> v. : 'Onhl r liOt . TAI!Lie 2 Comm ions M.tm a/.nkd nemv; Inhaiation or Hutu ('o.versriuTioxs or TkH'IH.OIVV A 1'HTII Al.EN'E- J'M'S TrTllACHLOR VAI'HTHALENE MATF.RIAL AV. f'O.STES rixATION or AIR IN POX 1 TOTAt. ! AV. BAlt-t rng. cu. TrirhlornnpLUmlf'i'f-s plus tuicr-s of : 137-200 1 10 07 totraol lnmapiit halono l High lC.-t'.t Low A.7S Sour, j *"" 1232 j 16 naphthalene, rats after 2 months' re moval from exposure still showed swollen liver cells, increased granu larity, hyalinization and mitotic fig ures. The condition was not advanced as. compared with rats killed at the time of removal from exposure but on the other hand 2 months were insuffi cient for recov< ry. The same findings were true of the mixture of penta am! hexaehlorinnted naphthalene*- and chlorinated diphenyl and for chlorinated diphenyl alone. Apparently the ehunginduced in the liver cell-- by these substances are exceedingly persistent and ore- must expect that, an individual showing any so that fumes from four glass contain ers were delivered to the air line instca-i of one. This resulted in the conditions shown in table 2. The animals sub jected to these conditions showed do clinical effects of any sort. After 1 month the liver cells were slightly swollen mid over-granular and then were occasional mitotic figures. Tltf-^ change's were similar to the ear1} effects o1' more highly chlorinated compound.-, and progressed urJ> slightly during the third and lourtt months. When rats in this eondihea were given carbon tetrachloride 3"-'alcohol, in sons- instances their livershowed massive central necrosis ans ovi-. i. ' atropi,;US- of ; On J),,, suliicc;.., ftiarizi.- * ; . bi.il:: di Sb-"' I iUm i,., i(T hue) lili-.-i ! and s , ^po-ure. lilted fat; v i j- ; ^ith ammni. - WATER PCB-SD0000059022 JY lSp<. 1M7 be many .mal. ic.entmtions of traces of tetrafirst group of showed that nlions averagn. of air was igcd both by >y the carbon is is an in to compounds jotcntly than chlorination, latter further t was arranged 4 & I f TlONS OP tVTAL j AV. DAH.T ^ tour j Aourt /*2 16 <& lass containr!ini instead ic conditions mitnals sub showed no rt. After 1 ere slightly r and there ires. These t the early chlorinated essed only niui fourth is condition blonde and their livera mcrosis and tti. 19, no. 7} EFFECTS OF CHLORINATED HYDROCARBONS 295 ja others this did not develop. Fifty rats were used in this experiment and one may conclude that, while the trichlomaphtIndents are in no degree as toxic as those of higher chlorination they arc not entirely free from effects upon the liver if high enough concen trations are inhaled over long periods. The effects of high concentrations of penta and hexuchlorriaphthalencs.-- There can be no doubt as to the dam age done the liver by these compounds but in the concentrations so far re ported no symptoms were caused that could be recognised clinically and nothing approaching acute yellow the liver after 35 days of freedom from inhalation. It is thus evident that penta and hexachlomaphthalenes are markedly toxic compounds and that recovery from their effects is extremely slow. The effects of penta and hexachlornaphthalenes, the mixture of these with ]0 per cent chlorinated diphenyl, and of chlorinated diphenyl alone, when inhaled in low concentrations through an 8-hour day instead of a lG-hour day as in the first experiment.--Since steady human exposure t.o any of the compounds tested would invariably be for 8 hours rather than 16-hour periods, a further TABLE 3 Conditions Maintained dciuno Inhai atio.v of IIioh Concentrations of Penta and Hexachloknamithalenes TOTAL ; AV. DAILV KXPOftARE IXROSUftL Pent-fi slid hexophlornuphthulunrs e. j j rany 137 Hifj j S 88 ! High 14.0 i 1 Low 5.75 knur* j Aivurt 008 | 16 i i atrophy occurred except through the use of the carbon tetrachloride test. On December 1, 1936, SO ruts were subjected to the conditions sum marized in table 3. This expr-rment was terminated on January 21. All of the animals lost weight and appetite and deaths began after 8 days of expo sure. Fifty-live- rats died, most of them heavily jaundiced, 8 were killed for microscopic examination, 9 were killed by the carbon tetrachloride test and 8 lived through the period of exposure. The livers of the animals killed for examination showed marked fatty degeneration, centra! in type with necrosis of liver ceils. Surviving animals showed pronounced changes in inhalation experiment was arranged under the conditions shown in table 4 which are quite comparable to those in table 1 except for the. shorter inhala tion periods. F.ighty rats were used for eaeli of the three compounds tested. None at any time showed the slightest evidence of illness. Microscopic ex amination la-ginning after 6 weeks' exposure showed swollen liver cells, excess granulation, hyaline inclusions and occasional mitotic figures. These changes did not progress and were very similar to those in the animals exposed for 16 hours under the conditions sot forth in iabie 1. The carbon tetra chloride test was uniformly fatal to them and one must conclude that con- to WATER 296 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY [Sp<. ti$' centrat-ions of those compounds such as were employed cause a certain de gree of liver damage even if inhaled for but 8 hours daily. This injury is resisted successfully by the rats just as was the 10-hour injury but it is none the less there and destroys, the ability of the animal to resist the carbon tetrachloride test. Summary of inhalation experiments. The findings that have been described briefly will be amplified upon the pathological side in a further paper by Dr. G. A. Bennett. What has been given is, however, sufficient to indi men never inhale enough of any of these substances to get acute yellow atrophy. They may, however, acquire a substratum of liver damage upn which acute yellow atrophy may de velop. Experience in a number of plants has shown how easy it is ,0 reduce concentrations of those com pounds practically to the vanishing point, and every effort should be made to attain such conditions. Gross Fee,ding Experiments The various compounds used v/cre ground as finely as possible and mixed with a standard balanced ration ior TABLE 4 Conditions Maintained during Inhalation or Low Concentrations of Three Compounds during 8-Hour Instead of ltj-IIoua Periods material TEMP. AV. CONCENTRATION OF MK IN TtOI TOTAL EXPOSURE tAxVr. oDAtfI'*-' c. Penta and hexachlornaphthalenes.......... 149-193 90% penta and hexachlornaphthalenee plus 10% chlorinated djphenvl............ 150-197 Chlorinated diphenyl.................................... 103-174 in. 1.44 1.66 0.93 range High 2 58 Low 0 42 High 3.30 Low 0.56 High 3.23 Low 0.03 hov?* 920 % 912 920 . s s cate that compounds more highly chlorinated than trichlornaphthalene are capable of causing liver injury when inhaled steadily in quite low concentrations. It is an extraordinary thing that even the most searching examination fails to show injury in any otiier region. It is not easy to grade the toxicity of the different compounds tested, hut the chlorinated diphenyl is certainly capable of doing harm in very low concentrations and is probably the most dangerous. Industrial experi ence combined with these experiments make it appear probable that work the white rat. The food was placed in a single container, at which the It* animals in a cage had an equal chance, the amount of the compounds added being reduced as the number of rat* lessened during the feeding periodThe experiments were designed to give an idea as to the possible toxicity ol the compounds selected and, if toxicity was observed, some idea as to the site or sites of damage. The experiments, were successful m both respects, and indeed one may anticipate that future appraisals of tb possible toxicity of chlorinated hydro- ol. 19, n-i. r; i carbon;' nmy feeding and do ; rate apparntu- . sary for inn d.,-, essential n tn the idem it \ by Dot 11 Out do, , different Seem to -mus-c sn fur ns ever wav 1 !- Trichi',r< tetrochlnni,- on l!;i! q. outil Nov, ning 3 gm., f ;: to (1)0 fo.id and thi- througho L:. animals w- r, "hleh died ;-.n ' loss, of w I. ! wasting hd - , death \vn- ; .. spirato.ry turn to the >: ; Hi-tobv;.-;.. slight chaeg, . of gn-nt sic .::! Tctra o> i Feeding 1-^-, dosait,. -. All the ani.u:.. worn uith, - , 29, IlCLi. At anton---- Dgu-d'y -h, i. a*T-e(..j q ,r dig, iiypergr., sio/is f; j 111 filer,.- in - ;-. ;! ' "'as a tion...r-i, Penh: r-. ' Feeding b,'.-dosage be*m- -wf-t-jAf.iv- /- . -a. WATER PCB-SD0000059024 K>1. IB, no. 7] EFFECTS' OF CHLORINATED HYDROCARBON'S 297 carbons may often be mnde by simple feeding and do not require the elabo rate apparatus and the expense neces sary for inhalation experiments. The essential reason for this opinion resides i>. the identity of the lesions produced bv both methods, and the fact that the different compounds so far studied seem to arrange* themselves identically so far as toxicity is concerned which ever way they arc administered. Trkhlornaphthnlcne plus traces of tetrachlorunphthalrnc.--Feeding began on .May -3, 1930 and continued until November 2, 193d. In the begin ning 3 gm. of this mixture were added m tiie food for 10 rats each day, and this concentration was maintained throughout the experiment. All the animals were killed except the last wliieh died on Nov. 2. There was no los.- of weight and no appearance of wasting illness of any sort . The single death was due to some variety of re spiratory infection which had no rela tion to the material inhaled. Histological examination showed slight changes in the liver but nothing of great signifieanec. Tara and pcntachkrnaphlhaknes.-- Feeding began on June 29, 1936. A Uusa.ge of (.'.a gm. daily was employed. All the animals sickened gradually and w-rc either killed or died !>v August 29, 1930. At autopsy both grossly* and histo logically the liver was the single organ affected. The liver colls shoved swell ing. hypergranulation, hyaline inclu sions and vaeuolation. Here and there necrotic cells were found. There was a tremendous accumulation of fat. Pcnia ar.i hrxackloruaphthalcncs.Feeding began May 4, 1936, a 3 gm. dosage being used. By June 6, nine rats had died. The last one was obvi ously* ill and was killed for autopsy examination. All animals lost weight from the beginning and were ill. At autopsy the liver alone was affected, the lesions observed being similar to those that have been described for fi'tra and pentuchlornaphthalcnes but worse. 00 per cent panto and hcxachlnriMphthalencs and 10 per cent chlorinated diphmyl.--Feeding began May 4, 1936 on a 3 gm. dosage. On May 16th feeding was stopped but all tlm animals went on to death, the last dying on June 8th. An autopsy tin* liver lesions were extremely severe and of the usual type. Or: account of the high toxicity of tin 3 gm. dosage, four ruts were given a 0.5 gnu dose every oilier day. Feed ing began June 21, 1936 and the ia-t animal was killed Sept. 1 It Si. There were no deaths hut all the animals lost weight. At autopsy the liver as usual was the single organ affected, the lesions being characteristic and ex tensive ('him ilulled diphenyl. Feeding be gan May* 4. 1936 on a 3 gm. dosage and va- discontinued on May 10f.lt. Seven of the 10 rats were dead by* May* 12aL. The tlm*" remaining rats gained in weight but were sacrificed for autopsy purposes on July* 8th. The liver changes began at onee, There were no changes in other organs. A second group of 10 rats was fed a much smallci dose-0.5 gm. every other day. Feeding began May 20, 1936. The first rat died on May* 29th and four more before June 24th. The remaining were sacrificed. Those rats that, died showed losses in weight, while those sacrificed had recovered 298 JOURNAL OR INDUSTRIAL ilVGILNK AND TOXICOLOGY I Sept, l-7 their initial loss in weight, and were gaining. The liver lesions were similar to those found in rats fed penta and hoxachlornaphthalcnes plus 10 per cent chlorinated diphenyl hut not so marked. Summary of gross fading c.rptnnirv(s.--Of the various materials fed rats in large doses triehlornaphthalene plus trace.- of tctraehlornapht halene was quite innocuous. Totra and pentaehlornaphlhnlrne showed definite liver damage. Penta and hexaehlornaphthalenes caused a similar grade of injury. The addition of chlorinated diphenyl to penta and hexaeblornaphthaleries increased the toxicity. Chlo rinated diphenyl alone produced liver lesions but in the dosage used was less effective than when mixed with highly chlorinated naphthalenes. In no ease did the compounds: used produce acute yellow atrophy hut the lesions ob served indicate thi- might Ire possible if one found a dosage which could net for the proper period of time. Feeding Precise Doses by Sbrnmch Tube The compounds employed were sus pended in gum acacia. In figuring the dosage the total .amount a man of 50 kg. would inhale in an 8-hour day assuming an air concentration of 20 mgm. per cu. m. ua.> first calculated and reduced to milligrams per kilo gram. The rats and rabbits received this dos<- (.(ieh day. The compounds used weie those employed in the gross feeding experiments and the results were essentially similar (hough the lesions were less severe. Snbeutmi- ons Injection s The same gum acacia suspt iision-' were injected .subcutaneously Into rat-- and rabbits, the dosage being calcu lated on the basis of 4 mgm. per cu. mof air. Again similar results were obtained. In all sue!; experiments there must of necessity he differences in the degree of effect hut invariably the liver was the sole organ affected and the lesions were those already described many times. Disctssiox These experiments leave no doubt as to 1 he possibility of systemic effects from the. chlorinated naphthalenes and chlorinated diphenyl. As in the case of the effects upon the skill, the degree of chlorination seems to determine the systemic toxicity, and it is a striking thing that when triehlornaphthalene is icached systemic effects are never marked and are produced with the greatest difficulty. It. is most remark able. too, that a'l the compounds tested attack the liver and the liver alone. During the past few months we have determined the organically combined chloride in the livers of ani mals very severely poisoned by Jieiita and hexachlornaphthal nes but have found no increase over normal figures, though the livers, as determined histo logically, were very severely affected. At the present time we are conducting inhalation experiments on a chlorin ated diphenyl containing 55 per cent of chlorine instead of 04 per cent a? in tho case of the experiments- reported in this (taper and on a compound with a chlorine content between tri and letrachlornaphthaleric. Wc are also determining tin- degree (o which the di*'< 10.jy inerc::- or decrease toxicity, this being suggested by similar work upon cc.' Imih (etno. hiuride. Jr the basis of tics; experiments m M. 19, no. 7; \ JMC ! rn r- and on many field different compound- rooms, it appear" tainly cashy a 11: '1''1' -. that the air In-eat lw-. more than 0.5 mgniof these compoune naphthalene, In tie- compound concent r:are permissible. *' many pxavnbvo i m- plants that such, cu been greatly 1 20 years, and w e 'r fact that our ).' been inexorably < human exposure Time and cnivl'm change tho'-e opto: " but todav >.r are safe, Impregnate arrangemem - m T ' hydrocarbon ar- lifeguard. Comp- " lead u'tracthy1 :-.v ; LornTois-Srn : 1^' profpi--sieve p- tal#!K- V 11934 b APA.f x\v> Mi profrssi--. jrt; ses de-ivi-. fed. 337. p 8unn, p. }! . certain e;sb,r liver. Ir... S5, 118 il'.i:;,, 3*11 Lehvwx, K. ! Arfipi;,:- u,-,| r-ei, LOo.-on r M fc.X- J2SKH1EBE. gg| WATER_PCB-SD0000059026 >t. 19S7 Ml . n. .. ere ments cnees riably ectod ready loubt filM't.S s ami case cgreo c I he iking 'IK is lever (he mrkunds liver mths ( 'y `1* have ires, ist oted. ting )rin- Cdlt t as rted -vith and also the 'it.V, ork m eol. IS, no. 7] EFFECTS OF CHLORINATED HYDROCARBONS 299 and on many field determinations of different- compounds in the air of work rooms, it appears sate and it is cer tainly easily attained, to ventilate so that the air breathed does not contain more than 0.5 mgm. per cm in. of any of these ' compounds above trichlornaphthalene. In the case of the latter compound concentrations of 10.0 mgm. are permissible. Wo know from many examinations in many different plants that such concentrations have been greatly exceeded during the past 20 years, and we arc conscious of the fact that our rat exposures have been inexorably constant whereas human exposure is never so ordered. Time and careful observation may change these opinions as to standards, but- today we are convinced they are safe. Impregnating tanks and other arrangements utilizing the chlorinated hydrocarbons are easy to hood ami to safeguard. Compared with benzene, lead tetraethyl and many other com pounds, these substances are very little toxic and operations employing them can easily be safeguarded. It may bo argued that where possible tricblornaphthaiene should be used, but this compound will cause acne and if employed very carelessly might do more. Furthermore, higher chlorina tion is often essential for highly prac tical reasons. The solution consists in thoroughly adequate ventilation plus good housekeeping around all wax containers. A final word of caution bears upon the use of carbon tetrachloride as a wax solvent. Obviously this compound adds readily to the toxicity of the highly chlorinai '- u. carbon tetrachloride is u. m should be excellent, but in um opinion it would be better to dispense with car bon tetrachloride and depend on other solvents, especially upon those con taining no chlorine. BIBLIOGRAPHY Covutois-Scsfit: fiit'idc sur I'intoxication profes-donnelle par !;> triclderonnpb- talene. Aon. de Bird, legale, 422 (1931). Abstr. of paper by Tockaixk, A., and Mnet!!F.l, B.: Dermatoses professieaseMes par la nnplitalinc et ses derives. Prat. mfd. franc,-., 335 (1934). ` Funs, F. B., and Jarvis, N E.: Art-ion of certain chlorinated naphthalene- on the liver. Proc. Soc. Kxptr. Bit.l. A Med., So. 118 (193fi) ' Lehmann, K. B.: Furzes Leiirbuch der Albeits- und Grverlj, ''-vsiem-. 8. Jiir- zel, Leipzig, 1919 (p. 251). M'.jtklstaot, O.i Gewerbcsehiidigungen dureh llaftax (Triehlornaphthalin). Inaua. diss-rt., .lena. 19,'15. TniiiiKNs. II. IV: Portable combust inn ap paratus for field (Icterniinations of eh.'oii.'iatvd hydrocarbons. Tins J., 19. 204 (1937). Tei.ekv, I,.: Die Pernakranklieit (C'hlorft-iie'.. hiin. Wrhiisehr., 6, 897 (1927). TOCKAINT., A., .SOI.ENTE. M E.NETHER. B., and Anwr.v : Oinquantc-quatre eas do dermntites par trichhiriiiiapbudirie. Hull. Son. deunnt. et syp],., 1,1, 2(15 (1 93-i). Hits VP '/iiSw# nasast, cf. '.-j,.. T??rhA-:.Sr&i: I ; f-' WATER PCB-SD0000059027 DEPOSITION EXHIBIT CYNTHIA U. WBCHMANN Carol L Davij Reporting Service Houston. Texas AT Tt~ Exhibit No. ./*? TTFT r, < <TSA^ fifoy aQJbr*-L~<L3L<_cL, 0~ J- THE JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY Volume 20 FliBRUAKY, MOItriiOUMIU At. CIIANCKS IN Till; uvf.ius of rath ItKSUn iNO. FROM KXI'OaUKK TO C KHTAIN OHI.OIUNATFO IIYDKOCAIUION8* A C K.Chanvili.e Bennett, h ii. Drinks, and Madeleine Field Warden De^erlmanl of f`aiholofy, fior+ord Htditni School, the iMpmrtmont </ Hatword School of Public lloohh, BooUm, Umoo+ckuooiU H LOR IN ATK I) hydrocarlHws, to determine what systemic effects, C particularly chlorinated naph thalenes and rhlonnatcd di if any, would result from the adminis tration of a number of these com- phenyl, have lawn need extensivjeHlynimta to experimental animals. in certain induslm-s. Their use in the The known findings in the three manufacture ami prvparation of many fatal rases of jaundice, together with type* of electrical equipment in eon- a review of the jiertinent literature stanlly inrrrs*tug Although it is have already been reported (1). known that suinc of Ihcsc comfWHffids The present paper describee the earn* arm*, only recently has the pathological changes observed in nil possibility of mom wnous systemic that had been exposed to various affects been recognised. chlorinated naphthalene compounds During the spring of 103ft we were and to chlorinated diphenyl. informed of the occurrence of three fatal caws of jaumhre in workmen Matkriajub and Metbom using rl!I n oml cl naphthalrmw ami diluni.itii I H|do-nyl At the request Of the manufacturers of these com pounds, we undertook an investigation Wl* Raceivsd for puMirslum Heplamber 8, This ii tit* second of thrrs nsiiers read at ijruipucium <>n <-hlmatea hyilrorarhomo given st lh Harvard Krlttiol of Putlifl BsallV ll.loM, June 30. IU37 Tbs third papar will appear shortly. A detailed deeenption of the ap paratus and technic employed by the authors in this investigation has bees published (1). White rate, main tained on a diet of Tunna Dog Chow, supplemented by lettuce, eggs, milk, and cod liver oil, were used throughout the experiments. IMW wKBgfflBm TBWntBlWwWS WATER PCB-SD0000059028 98 JOURNAL Or INDUHTRIAl, HYOIENK AND TOXICOLOGY M Pi, ne 9 The chlorinated hydrocarbons tested were the following: Compound A. A mill lire of In* and letrarhlomaphllialenc*.* Chlorine content 49.4 per rent. Compound B. A mixture of tctra- and |>enlachloni*pbtha- lenea. Chlorine content 66.4 l>cr cent. Compound C. A mixture of tcLra-aml pentachlomaphthaIcne* plus cTn7irmkT<l'Tiipliiyl. t >hinnn rnnlrnl 41 6 per rvnt 1 ( Compound l>. A mixture of \ pcnta- end hciarhlomaphtha- ^ r^ lenm. Chlorine content 62 6 j**r cent. __ I ('oiii|Nmml Iv A mixture of --\ j**nta- and hexarhlomaphtha- \ Icnce Chlorine content 62 6 lMr cent. Compound F. A mixture of 90 |ht cent pFimP and iiru> cldoroaphtFalcne*, plus 10 per cent chlorinated diphnivL Chlorine content 63 |*f cent L Compound (L (.li. f ^ idicnvl ^Biloriuc..fQatcnLit5 0 Q ierent. _ Tliemr'"prcp*ration* were selected because of their relative importance in industry. It shnuld l*c noted that they also represent a wide range of chlorination. All of the above material* were administered orally ip-varyMi^Tloeea. <"ompoundif1 A, IJtF,/am^fj^wcrc aeh-ctrd for the inhalation^experiment*. * Ttui c<ih|miuimI rxiiltinnl only small tmuunU nf 0(rrlilM>t|>blfitltnM In tin* iitpfr it will thrrdfur* Im rfltmtl U* m f Thu ciini|>ound niniiitsl of a miilur* of riinpnundi It iml G but in aiililion runlairurl two plafUnifn vbirk tuv 1>mb roMukrad to b* uarrt * ilhoul Umm Mkmli U rblunar rooU-ot of thu rum* poakd oU be betwaea Ual of oompouada buiD Inhalation Experiments We were moot interested in the rvwult* of the inhalation ex|tfnmenl* because they more nearly eimulate the type of exposure to which the workmen are subjected (l). 'Hie in halation experiment* were carried out in air-tight wooden compartment* through which air, containing the volatilised tQ^pflundUung--tested, wa* driven by eleetrical__hloitpr*. With this apparatus we were able to teal simultaneously the effect of four compound*. Kighty rat* were ex ported to each compound The melhoiht for determining the tiady air concentration (rngm*. |*rr cu. m) of the chlorinated Itydrocarlmn being used, am well as the rate of airflow have l>ccn described (I). Compound A (trirhlomaphthaleoee) wa* adininiMtcrcd by inbalalion to two group* of animal*. In the first of these cx|M`riinent*, the rat* were ex(Kiecd to low air concentration* (aver age 1 31 mgina. per cu. m ) 16 hour* tiady for 134 dayH. In the accond ei|>rriment the concentration wa* increased to an average of 10.97 mgiiin. )>or cu. m This 16 hour daily ex|Hwture was conlinuctl for 102 days. Com|Niund L> (hexa- and penlachlornaphthalene*) wa* adininiHlered to three group* of rats. In the first ex|ieriinent the ex|K>nure consisted of 16 hour* daily for 134 days, with an average air concentration of I 10 ingnm. pcrcu. m. In a second experi ment the average air eonccntrniion wa* I 44 nigniM ftcr cu m 'Hum *kn Diamtamed 8 hours daily for 143 days. In the final experiment, the average air concentration wa* incrrsmil to 8 H8 ingyna per cu m ami expoeure, 16 hours daily, wa* con tinued over a period of 52 days fak. 19991 CHLORINATED HYDROCARBONS 99 Compound F (hex*- and pent*- Carbon Mrockionda and alaokal shlomaphtbaJenee 90 pier cent plus odminia/roium fa experi ehlorinated diphenyl 10 |*r cent) wa* mental anifftoi* admimstered in low concentration* to two group* of rat*. In the first Seemingly the ineidenoe of acute experiment an average air concentra yellow atrophy in worker* exposed to tion of 1.37 ingm*. per cu. in. wa* chlorinated naphthalenes and chlo maintained 16 hour* daily" for 134 rinated diphenyl u very low. TFi* dajrsT "Ib~the second experiment. air single fact i* of eome imjmrtance io average-'air concentrat ion of 1.66 that it auggeat* that certain indi mgmr per cu^ m. wa* inhaled 8 vidual* may he more eueceptible to fcours dady" for 143 day* (he compound* or that in these in Com|K)und ( (chlorinated diphenyl) stance* the liver damage may have war'adminialrreil to two group* of animal* in low concentration*. An Iwen intensified by some other agent. With this in mind, group* of animal* average concentration of 0.57 mania, that had been exposed for varying gwr cu in wa* employed. 16 houia f*riod* of lime to certain chlorinated daily for 134 dsya-in Ihw first ap*r->. naphthalene cotnjRHjnda and chlorin maot. In the second experiment (em ated diphenyl were milieequently ploying an average air concentration given a aoblethal done* of carbon of 0.93 fugma per cIT nTT tins animals .tetrachloride and ethyl alcohol by wars expoMod 8 bourn daily for 143 stomach till* (0 75 cr of each per dgya kgm ). This dtmage did not result in a single death among the 16 control Feeding experimente All compound* tented were employed la the fading etjs'nmcnU. A animal* and the degree of liver damage produced wa* quite constant and never very great. Administration of carbon tetrachloride and alcohol to rat* swighed amount of finely ground material wa* mixed with rat food. This mixture wa* placed daily in one expOM.'d to the more highly chlorin ated naphthalene compound* and chlorinated diphenyl caused extensive food container to supply tlun rat* in liver damage and proved widely fatal. a given rage. 11m* each animal had Therefore, the use of rarlwy tetra aa equal ppsrlninly to ingeet the chloride and alcohol ha* Iwrn employed sowpound supplied As the number regularly on representative group* of af rat* pier rage wa* reduced, the rat* (rum each inhalation experiment. doage supplied wa* proportionately dacreaaeil Mont rompHiunda were Examination of iieeuee Mpphed m luric' mo.I Nioall amount*. Huppleiiunury |*Tinienl* were mfcicted on a smaller mmdtef of lets by feeding several of thn comgewnad* in amali kuown amount* by Animal* were aon6eed for patho logical examination after varying peri od* of exposure. Complete autopsies sen* performed Liver weight* were recorded. In representative animal* sasaaaab tub* or by injecting them BBbufapioualy aa euspenaiona in gum * On* cubio taiimUr nf eArboa tslra- cblonda pit* 1 0 fo ethyl alcohol par kilo gram whaa xdmiaixUrtd orally io aoranal whiu raia eataaaa a 14 par aaoi mortality n\ WATER PCB-SD0000059029 100 JOMItNAh OK INDIWTIUAL IIYOIKNK AND TOXICXllAXlY [sal. to. mo. t from esrlt ei|M>nmcnt, all organa subjected to thawi conditions showad nn'ptmK the rcntril nervous system no ill effect*. Autu|siiea were |*ir- were rMnuiied /mcrueropicaJIy. The formed on group* of 3 to R animals liver* of all animals were stmlioil after 37, 72, 105 and 134 days' micrtisroptcatty. Tissues were fixed ei|KMure. There were no significant in Zenker's fluid, 10 |>er cent formalde abnormalities in liver weights * Mao- hyde solution, ainl absolute alcohol. roscopically the majority of the liven 'Hie roulmc para/fin lions were ajiprared normal allhough an occa stained with ixsin methylene blue. sional one waa paler than normal. Other slam* employed were hematoxy Karely alight mottling was ofmerved. lin and rosin, phuNphotungstir arid Microscopically, the liver cells often hematoxylin (Mallory), Fool's modifi appeared slightly enlarged, more gran cation of fhel.wdiowwky's stain (rrticu- ular than normal, and orcasionally him), Herd's earmine Main, and Iron they were vacuolated. These slight reaetion with frrrtwyaimh* of |Mfa.H- abnormalities and the presence of a ' 1 mum (Mallory). In addition, fron-n rare mitutie figure suggested that very sections from eertam liver s|irctMiciis slight injury to the liver cells had were Mamed with scarlet red, l.ugol's occurred There was no dcinnti- solution, and methyl violet. strnhle increase iu the alsive changes ItfcMUf.TH after the hrxl e|siNiirc period (37 dnyn). Occasional liven of rats ex- CumpouwtA. Tnchlomaphihaltnrt (a) b'jf>o$ure by nhatatton to Utw fimcrttinuwu* (mwroyc / St mgmo jtrr rv m ) It! hour* Judy. - The HO rats Itoned for the total jieriod showed * I'tlriintiima pertaining Iv the weights of liver* in theer and anharquenl nmmab are hawed un ilala in II II. Ilonaldaoa** ........ 11m- Mat." 2nd ed The Wietar luatitutf. Philadelphia. IW4 (p. 2tt) Hi .atk I Kii; I and 2 Camera lucnla ((rawing* (>>IMS tile |M<rtal tfraa >( the livrra of leo rale that acre fed larg* do*** f a imiture Vetra- and |*rnlachbrniih Ihah-uc* ami chlorinated tli> I h chang** illustrated in figure I occurred within tt data alter e|o*ur* wa* begun One lioulil note the marked accumulations id h> aline globule* in the cell cytoplasm, and the marked smelling of liver cell* In cleaned number* of mitotic figure* wer* also prevent Similar rliange* are apparent in figura 2 hu h wan made In.m (he liver of a rat en*nl 125 day* I legeiteration in the renitai |Mrtlolia of the liver lohulea it ai* pre*eot Ki<> .1 aNIi I Thear drawing* illuatral* the marked a* ellmg and latlv v*<u<diali.m of liver tell* oh*erved in all rat* that were fed amall ih<e* of tclra- and |*entaehlor' naphthalene* The change* shown in hg* ure 3 were prewenl after 211 dava* eapoaure, those in figure 4 after 4H dava* e|*iire Note ilia mitotir figures in figure .'I 111* eooi|ound rea|Minailde for th* chanana eon* Uioad av chlorinated dipbeoyl Otbarwiaa it m aimilar to the compound rnaponaibl# for th* leaoma illualrated in figurea I and 2 ion 5 (NU it <`arm-ra luetda drawing* of the |Hirtal area* of the liver* of two rata fel moderate aiaed daily do*e* of a niiitur* of ieota and hesarldornaphthalcnn* for 14 anil 2v daya respectively In the first ot the** ligurea on* note* * filing of liver mil* with narrowing and distortion of th* sinu soid* The liver cell* ehow an innreaand granularitv tit* cytoplasm with a massing of haaophilie granule* near th* nuclei There i* aUo an tuna of fat in amall and medium aired vacuole*. Thi* w*a morr Itnoniiicot hi th* central portion* of Iht iver (<>))** An inereaaad apacmg Ihslaecn liver e||* and hetaeen liver Call* and aioiooodal endolhelinm I* pre*ent After daya' Minrr <lig SJ the alorv* change* are greatly increased Numerous large intercellular Apace* containing serous precipitate, strands of hhrin end leucocyte# liail devehi|red between liver celt* Tnaaa apace* wee* hounded by distorted liv#f cella He* also plate III, fig I Camara lucida drawing* X 3M L .3* WATER_PCB-SD0000059030 HI2 MU l<\AI. IH |\|M>*T|<IAI in ;i.\l A\lllO\UuHm;\ |,,,f HI, n.. 9 lilt tlihlllf* f'haMgf (Sff fiC <1, II j \IJ nlher nrgin>> ufte hoMmtl * Itirilirr that llir li\rr H--tie injury hml Imth \rv r*hgh< wa- olilMitirtl Immm llie rmlmit fetm- ihlureh inh| ii--I Of |0 ml-* I#*r III ilay- in llif ulimr in:im r ami linn fill 0 7f *r |h-i kgm null of iiiiImmi trip iielili if i*|i' :<! rfhlt nil iifml 1*5 '1(1(11(11 I) ll*e, iikiii' <li <i ,\l imloji-y Mini iin ini tiiM<i|'le xmiitlllll toll (here Wl- lllllr >i mk i uiIhim <d In.r ini'ux great* i (li.tfi that jiro'lm e*| lit i)i- -.tim d-e *| i :<i Iiii t*i i ;i lil*irnle mill uhih>l ill timti.al i nfit I * l ini' (See |\ , Itg- I iukI 2, ami jdale \ , ti|( I I *1 he |n*,c> ol K miifiiui- cv|iii'*'il li t rn hh>rna)hl hah ne- fnr IO.'i I.v~ mid tiiOi|>-ii'il uIlM ii 2 nmnlh rm\n\ |m Mi.il |ii\\*il no delinitr |i:illiilingual hang* I hi' i' fur* lii-r ex idem that llii' i oft11HfitiiiI t- niily -lightly t*\n I h*-4- hmlmg- n pfi - nt n mmLol * III II 111 id tiff I \|M Mil" (- (< Htll 'li'llllll Hill ll.lllgl- 11 Mill I HI "tgltll l-llll I ifliltl I tit llvtl lM% enidra-d In I hf |M'r>i*lfiil hf|*>ilif ItsKHi- le-nlhng f 11 fin fNjHf-Mn' In I hi' fniii|HmiiiU of higher <`lilntiimiinn. <1*1 /vs/MMUf* In/ inho/n/iun fa fitfjh (* nimht'tt (ln.'t," tuyin* fu r ru m ) /.' hour* i/ni/v In I hi** fkjtenmeid, the ritnieni rat nm of 1 rn him impht lui- le in- uh- approximately eight (tinea that pr*\ mmi'Iv employed l.xfHi-nrv hk- Hiiiiuiifil fur 102 tiny- Tin ,r*0 iuiiiiimI- -iihjiM-1nl |n till- him rill IH- lltin ;|i|N irt l iiHlnuil f 11 mi|i- >! II lit IT rat- were 'in-rifieed alter expi< -*iif |< noth n( III, IS, fill, 72 mill lo*2 l.i\- \lu-( >( llif lm i> ni pale \<l|m\ m nilttr uihI -lightly molded I In i Hu-, liHin vcr, n>* -igmfii iiiit iiilNilioli m IfM-r weight Mfeln- -I'l i| Mi I \molli:ti lull tin eilleit f*W ollril II \ i t I`II- With -lightly IIHteii-eil grmiuhiiiiy mid \ in itnliniltun of tin* ry *|<I.I-||| t Vea-mind degeftrnil lllg ami iegi-nfiatnig erll*. were oh-i-rve*!. 'lh*- i hang* -, whit It wen* lightly in* *i mat hoi iii ihf eenlntl jHirtinli if the !l\rl IiiImiIi-, Well* p|r-elll llfltT the lir-t liamth nf I*\|MI-Iiri' Tliry i*i vri m I |. I ` %Ml I I.IVI'I < !* N ng - I*--lilt t ig I 9 i*nr || 1..I1MIIH'I III (-M <1 lie Id"* 11. Ii|i 1 l..i I* ( Mii*l r 11I *1 hi * ! < :*> 11 lie >!.< !*.**!(- I> ligni'- I Mnl : |l|> "-I tlllllli' <1 till (If?* *!'*** *1 itfi* (i..I'.iitf' *1 (I1**!IIIMiid I,Mi ln\- 1 11 < Iv | I. in 'IjiI> I"'.* -* .1 gin in f lit tif 1 I l,i hung' - *!# *d 1 iMa 1-l i-l if llglll ( 111.I* I 111 ' -Hlllltlg "I ll * 1 I 'ill' in> i' 1 .< rfi .iniit.H/11 ' Ilf 1 l.,dj*,-ni and III i* 11 * :*!* |>(''l"tiMi`'l i*|i"-i|i` I11M* V ll-tl (I I-'I> ol ill* fMiiJ>/(l of II* Hint I I. I. l ull ||' Vi H'inll"ii "( '.' < II-I' linl 1 * ft. I ig*ih ,1 1 - m .(11 mg from ,1 -, r tton "III,. Il > I "| l< I I I ' *1 I- M't'H II > !' I I..M uf t nf !>>" "t tf . hh,t MHfdif >! / - (. |i* *t.i\> N* -filling *i * "ii-lint t t'lllig' - Hill idi-iiviit III tut* -* (Hill'll ll"fi"ii.il fit- tin -ligt.llv "lli-n ii ltd min | gt ii miliiiif \ id fix- ill" |iIm*IH \ f lire Hill'd Ii ligllll i- nl.M ii i <| 11 > 1 HMollMf H'l tl'ilx* t|..- ,'|, l\|l (l \||l f'lNI ll|l|l I llllllgi n '.I.MU'il f'dfiiM ll'g III! Il'il'lllll-I fill I'.n "f H lit I - IIII i.( |M lit , Mill) {> \:n Ill'll Ii.I I'll! Ii*- ll< ' Hf>- *lli|-lr.it *1 II' it""' dll'* dHM- lll ' I ig*11. | I (" I.HI'g' - % I'd nll't (.'.(tug Itn- |'i I'tii uf i"H Hi d gin il nit '!"> |i< r In ml-. Ixf h |miI'I <( (* d,\- I lu ll 1 I < * M- Ml'- <"i|t l< 'IK >>ll' 11 Hi"l * . 11* I l I li<l< I- mI-" In-' I "Mi ni"! gi ' III |" 1.1 l I 11 d * II- I Ml gi ii'l'I. H'dm -)<h< - ;ii "liMiud l S Id.l. \ I l.g. I ......I .* I. -- 111111 ltd Iml lU'llnr 1 I'ling' hi* 'dt-tistd Ht I In llviitt I 1 *1 (. d ->' illi 1 !'- - '( (lii- )i< |'u i ii I ii .11 Iv" llg .'ll I '1. . . \jH.-l|l' I ilglllt-fl it III' I I H I l II.. I|*'l III) . I.tllg' * (I'll *Hi*.l "(lit inl.'il.i I <-i. ..I !.. 1 "in Him I I' ll- | lllll ltll'1 t" Ml. Ill'll IH* I ill I 11 tl nil* h i \"l* tl.* -H. Him* id ll.. livu nil' ill* III! (I : .III V HI Ill'll Hit I'||I M*id |H * * ttr>/ | lm' Hliml" H "I III iillli* glidilllri* nilliili till- f|>* ( tJ1 oh-t 11 f'l ligii'.- 111 f> In- t a in* 1 1 Im kIh iIukhiik* * t'ti WATER_PCB-SD0000059031 1 > | Jot H\AI. < |\l| .VIMIAI 11% <111 \l. AM> To\l OliM;> I ton fmt in* r*/ | niff* longfr \ll r |M2 |it> l In- liirr f||' lOTf Ota.If ItMIlk'lilv MOl)rn Mini 11 it i n ' I lur^*- Mini I it \minlr' SiiiiiII iiyulmr ln<|*l< ls hi I In- ' i ll < ytnjiln.'in \\ M' iittit-Milinllv tiltM*r\rtl M11nlir tiKMr*--, nil lmii|(li IICMT imiiimt- him, H' rt' inrn n-4*il in iihm'Imt N* >ifii <ur/il i Iimiik' -' fun I ifriiiri tl in tin l\i-r Ii'IhiIi '. (arlioii liliiii'Mornlf uinl rl|i\t n I - ti'lml rh' MillitUiHli'f'il IV 'ItMIlilfll IiiIm- lu !i rnl- krpl mni'-i Ifif't* i oimIi- I!** \l aiil'|~y I ln-n livif-t urn* In iiMHli ralrlv i-h|jtr^-ii 'I lt*v . win* yt-ilnw III nlor Mini lln- limjaifilv Tin**f ifu-nt \\rn- itiolll'-'l mi-m- 'injur ||ltilni|< Heir Mirml'li* In nllf lllllllllll lllf iiIwm l-,| |lf| fai'l' ||- no Kit'ith-r limn llml mtii nlli-r 1 lt* nihiiiiii-trnlioti n| u 'Minim i|n-t* of iiiiImiii l liiu iilnriil'- mill nlmliol In ii"rnml i toil ml ml' i'lii' lnr> ol 1 aiiiMinl' 'liowi .1 iiirri-ii'i-il Cm 11 y !'K<ii<rMin<n in tin* *-rnirnJ |Hri*in> **f tin- IoIhiIi-' hiiIi 'tiuiil iu mlir Im i In I In* 4 ri niuinniK iiiiiitml' nuni'io* t ini nil m-t rti'i' fnnl tM'inifl In tin* iim-l iiimknl **f lln ^1 Iti# 2, V), I In1 i t iilml oiif Imlf in Iho IIiiiiIh of noli |i\i*r Inluilf w> imrnlii' mot in fit niMMinti iirni' ln or nmrf iitljni**n( loltnlf liil mu If iitonf ilt*ni*in*ml ion I IfinorrliiiKt* iiimI f>li ii-im* Imifttrylir mlillrnlioii luol iMinrml in lln*Hf nfirttiir nn-if Tin* Ir-t ilttiiMLgf'l In rr ivll* nl lln* |*ri|*fn*ry of tin* ImImiIi-' >)iovu'tl liniif iiiiiiiIh rt of nitlotir fiKnrt*', iimIhiiIiiik inatlf mini rt-u# in rulivf mlivily If I bif Nliif of llif IU rat' |f| | r it lilnriiH|iliiliitif ih*h in Iti't's of II him. jar 'lit\ |M*r IU mlt rn* n rilif**il nl Mirying of 1 in if flttin M |o |Ilt lay*' 'lln* Irntli in) tIi.-iI <.| n ii*'|iirniory ioft*t tnm nflnr Is2 ilnv-* f\|Ht'Hii* TIii*m* hm mi 'itmiln ant nliiiorioiilily in lln* \o-ights of llo* In it-* of linw itmionU .\flff 2 iimiii In' i ^iMt'iirt*, him m-M-tijm- i*unm- lllllllMlI lf lllf ll\f*r'> 'IlMIAfll >llj(lll 'W.lliiMf of livfr nl)** Tin- mi m i itin| Min Mil l.y nun ii'fil viiriMilim- I Mill o| lllf Vln|ilu'IO I It If lo lllf in i mi on fal ion of nfiMoMMitily law 1*1. \ l I III In.' I,.' \ \ m .1 I m r i liioiKfn it-niilliMK 111tilt t Im* nilmillMlMtl lull. It\ fl'tillllK IIM.I IMllatllltima trl a Mlltllirt- III (HlllM nml fit i> Il<'rn|lil lt*K in - f*f, ) anl liltr tltaala if ll|>|u IM I III!*, > aft- >11 Mr** I MI I III llut <lm<MHKt I ttfiifa- i It n iliaMlMtf tnmif 11 tin m M-rlion l*ni*-il il li 1*1 \ II lit wt|lln> It* mIIii i i Imiinrt ll iltiiifM- alllilt- |irt-at*iH t` lai^r mi<l -nmll Milt trt Miilur -I'rtt i t, llilt-l |>M U*tl tn l*lo t*-l hilt iNfliialli*-* l lii al N|lIT]t I itltlltlilt'll n,<.- |*l <i l|(l(alt'. Mum. NMtl M-ttOtai II ||. I-Mln Suit* tlu- altiiijtlx u|| I lott'tl lu'llluiaM - <>( lli*' i|tai I't nrnl llu iiihiimi'I III lill ti llu mi- a | tilt M imiilll Im ill i lia Him imI mmm < til lit* f< <ln>|f >( luitfi- IniK iliw* lot U lima Simtlitr lull lt-i inarkftl a liaiiti-a M'aiilltal fu>ui llu* I I line ll aliiall it.aaM* iiVa l a | fMul *l alaVa lata* l>0 -) Mil t 75 ilaia* a ijxiaiin1 In MalaalalM'M (> ItMt t-iMia-flilrallMlIM ( lltta laffltaralMtu. itaalltt'tl ltva*r a(iafi*a-t*, a-a.ta- lahHR at-Mular aat-lloiK. N aa-U"lllali'M, aiul It i alitai sal i"M Mart* M|t|tamtl (Ilf :n III.' t. IM* I* Till- talM't >'<< i|ala" i`liii|i'a K-illliMK tfuaia a- la* alilua Manila | tl t |tlal`tt I I alt- ll I ll-t I a Ifai Ml llll'aa* ll||IMI't I IKUli' I KM HlMalf flialll Ilia- llVl'f t*l a tal la<l iaiMa* ilaill laia fai imiI\ li Ini* MmLi'il NHilliiaii ol lit .Mail tafiai rt-ua Mt ialiva* a> tivil\ tot'a|t|*ai*ii( I iriim* fi illiialiMlit tlaf 'llallK, llial hiii mo I >imll iiiimIimi*! Im (Iu- tfa'lmn a>f hiiiiII tliMit a<| lltia \aitt* llu* >* lta iaia |\ iitiMit't hi* ImwImu* tin liiamna tat liwf al'llaa rial- tal Hna ' a | > *!' ! lot I'M ( t aa \.ai aiaailat a laitli(|r - a aa a |iti-lau*->f Im lit** w<lmittfalialntii ! lltti i-aaiia|*iiii*l Im iiilialalfiii Mu-lluHlt iIik ti) Tilt* rttl Ifilai a lata It lh- IrnaiiiK ant aata<la taa>l la*t*ii i-i|nm*'i| ! lua ratiii i tilralioiiN Im a |t>mI a*l |II7 ala | a In. | I'aiiu'ta lata i.ln tlraaoin a HR hi.v 2 lo li I niu-ri lua tala <lraaiiin< A .I'* IlKi Jol H\AI. OK |\|)| STMIAI IIU.IIAI AMl ToMOI|Ih:\ I mtiotinl- nf Cut Thr-r rhmitfr- in - mi'itl -lltfhllv XXJlh rH|Hi'Hli- IS*' |fitI** II, ln> I niiil 2 ) Tlnri' wrfi Iiii mi liilri Miml i liMliK1'' Ml tin* ll\ *1 lh-i hii-i* iIm* rffr.-l- rr-ullutK from lur(ti* ihw- uf lrn hlornuihihnlntr- "l lr -llfclll , llil- rnnipnllll't Wll' (lul fi ll III -mall unioillil- ( iiifi/iMiim/ //. `fthtt- un>t /* rifitt Ilf /-.'rjMivifi tn/fiffuui I Inllult w | il* v* I iMily ill fmliliK \|m riiiii-ni' ( (ii* daily fiMni rufion li>r III ial- mil mm <1 0 .r> gi" <>t 11 t~ :iitiifMiidiil \)| ;nmu:il- fi ll ill mu) xllhrr ln l hi xxi'lr ';ii nlirril lv ill* -\ix 1 liirl liny I In' hxn- wi ll- |miIi* wlloxx in mini, (rmhlr, ;iimI i h i 'it 'ii mill I y -huxxnl mo<- tliutf Un i* vxrrr iii.OKi.ilinml wiiiu- linn- in xx right'* lilt iiinin-iopM r\iiitnii.ilmil lln* -mm* rhmigr- "**r* xili-rxr| in ;ill ml-, 'I In -*- mn-i-lnl if iihm|< r;i'r ( limrkril -xxrlhlig ami ti.Hinlinj' of lli*` Itxn i'll- lln- -iini'ool- wi fe iniirki-illy urn mu -! I In majority of til'- Ion nil- ion I :i n * I lurgr ntniilNT- of -mull fnl \ in uolr- l lii- hinting xx;t- Mto-| inmi.i-<l iiinl hr-l nh-rrxnt ill fid' niiml fHirtioii- nl ltd' lolmh - In III! Uni nhi fill ri ll- ifn-rr xxn- |iro|M|. unit na--ng of hu-oj.liilii graimli-in ar thr inn In Hmu'IoimI n-nnfir rrll- urr nl.-irvi'll Mu..in figure- xxrir |*ir-ntl in iinmit-nl imiitUr-, MnliriitiMK lM`i t'li'i n I nl irgnirfiil tx * nr* tmlt 'I In- mil io-ro|iM' Imngr- ir-iiittug from iIm' fi-nhng of tnrii- Mini |m iiI;m lilorii:i|ilillmli nr- mi- illii-lmini ill Jilnli- I, hgtirx - ;i Mini I Tlii'V nrr i|io-i- of ililTn-*' fully iiilill mi mu mnl hilly ilt'Ki-in-riiliou CtlinfHtUltil T.fffl- ll inf /'m/tllflllll- niljihlfulh tf.\ fJ n * l hh>> />Mli >r Ihjthf ttifl A.`i/miiir fnttnuj Imting (.1 Km iIih-1 daily |H-r Id niH xxu- ii.olnnnil uitli Inil on- f dm mfi'i- iiiption for hfO ilnv- Iiii ini- xxnr - n.-ii|i'il S x i n ml- rii' sjnTjfn <`*( ai xixryiug j*rrxud- of 17 In 121 lay-. Tltii'i' ml- xlii'il Him r\jn-.irr jM-rxod-* of 122 In I-10 iluy- In nil miininI- t In* lixrr- xxi'fi*mlmgr.l Ml lo*Hl |M*r I'l'hl). TTn* iixniigi* xxnghl mrmi-r xxus 71 |H'rmit Vlmy xxrrr al-o jrnthlr. ttalr. yi'lloxx in roloi . mnl-onu'xx liul mol I Ini f'h""iiihjru-f ii|tir i'villlih]itiUll7 run-* mil rliilligr- xx on' i ill.m n| IVsn'1 n-nlly i-x n y 11x i f roll xxn- sxxolli'ii mnl lomnl'-il TIhii i>lo|.la-in ronliiMM-il linn* IiiiiiiIh'I-- o| liviillln' I.Qiln'Tlnw xxi'lr nirillal ol o\al ill -fiii|H* Mini ximi.l in -in- Iioim iiltonl hall thr -iff ol n ml IiIimmI oi|mimI- fo twin* lln' -ur ol lln- inn Ini- ol u Iim-i rrll iSn- hg- I Mini 2, |lalr f I fit intnuT m- iii-lmnr-, many -mull hyiilim* hodlr- Iiinl forming ill<*' * ,,i td.'lT ina--r- ii- Imgr oi lm|(n limn it norimtl H.vn l\ I l> I 1% ) >lltl-l..i(IN|ll| 1% lll.l-l ft.l M>ri I < M< lit <<l lln Ilti'l il.linntf' | i(.n In. i III I- l|..i|- lo M 7,r. it |Mf li/Mi < I. 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In lore no.lor Iho-o . on.lilioii' apponr-<| IMM noil t l<ln<lfiiol til*' o\|*o'|fo (MTiotl (hll ilnV't liopro'inialni' miitmiN Moco 'tonliml in Kronin *f J lo IS minnal'aftoi mitviok o\|w*'iiro |m-m*m1' it' <|.'i mIm*I III lit** o\pol inionl> oimpin mg Iro hlornaplilhnl' iiO'. 'I Jo-io Mir. no 'iiemlnanl nltornlioii' in Inor M< htlil' M;o i`0' opn nIt\ llo- major ity of llo* In it' Mon lighl >oIIom in ooloi ami 'lightly 11 n > I li I V11 *-r II it* initial i\|nt'iiir )*< i mil of .17 ilny-* tlion- Mit' mnli-mo of 'linht injury t ri.Air \ I n. | \ |.l*>1 *ittl *kt*t|l. l.'lt bIimw- mu Hiunll ill n* .if li*-* r.-M o. .i-tiltnl uri. of ||i- liv.l |o(.i|l.*M fim ml till'f Imiii < Vpo-. <1 til t>. |W .'.IIM'lllrHlK.IIM I In. M.t in.pl.lIimI* m*- (or l.l I I*\ h follow tlotlgtol.Ootlil. I. 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M"ti.l. i*i. \ i i: \ oBliMlWiiBiif8 ^m nnm WATER PCB-SD0000059034 If IIH JOI lt\Al HI IMH.aIIIHI. ||\(ill\| ,\ \ l> Tll\ M 111 I H.\ Jo./ fit. III. f ll' *T l i II- ulili It t| -Unlltli ami mule Ktnmilai lliatt * 'I I * > I | >l;i' IM *1 iM <iiv|uit.i) ifll- lute lam* . I *imaII :t* IivuImh' ilmit- iii- uimI IImt* ;in it i \ri-- * >l Ini hi I In- fin hi *l liny t a* Hnlt-- I I*k li. |>litli- III All mu in-* itjni- al>nnrnmlilit - im n n-fil -li^lilly t|inm lli* -imml |h-iimI CI7 In 72 ilnv -) l*nt no -ij*nilh ant imImimi-i- wa- l-l- t*-) Im-Iui-i-ii i|i- 72ml ami I It 11 It day *l t\|H*-l||l- 'I*Im Im r- nf mi- \|mc*-iI lot lUfi lav- iiml lin n n-iiMm-il lium rH|n-urf l*r a |h-im**I u| 2 nintli- -lilt -Imui'il itllul.ii *1111111*1- -null.ii' to tliti-i- ol< Min-il lit tin* Irt'KinnniK of tin* m*n\ * r\ |t-ii*tii In a li-w of tIn* >|M' inn-n- Ili**v ii11|m-ir*I -liKlilly lr-- marknl, llnll* tiling tli.il -tilin' r**|MII l*i(*I tdki ll jtlin i' In mi in-lam ** mt- tln ir t \ iili-m nl im rt a-t'*l damagf t 'ailMin 1*1 r;n Iiluinit ami t llivl alrn- I...I a*lnnni-tt r**t| to nit- **x|mi-i*I hi I In .il>*.\ i mannri' lot I I I *in\ - **! Iti|>ld\ latal. It out o| ID lilt- dying milnii lit* hr-i It tlay- ti uillun 72 ti**nr- \t ai|toji-\ 1 In- I:* i f* *l llte-r lal- n*if \< ll*i*i iiimI mnltlrd alnl liny mu* iiuita-**! in w-g!il tit* In II | >* i * ui | \| i* m-t **| in* lAaniina* I (tin -li*tt| iil*-j*iia*l > nlial iifcm- -i- -mnlai In tlial oli-t n. .1 m till ly iiMilf \*ll*n atioj'liy of man (-* tin- I ami 2, Jiltitf \ lit Tim ffnlial om- tialf or luoilnitl- of no Ii lm*r lolmlf -lionttl i oinjilflf Im-r * *11 m-t ro-i- nml i|i jt`'i'rt ui mu | tilTn-if\l ia\ u-al mmi ot t ry I limi-yli*- Inn! * iffor i ill mnl muiirtoM- |*ol \ morpliono*l*ai' nml mononmlfiir Ifm-inyli** Innl m\ mlfil tin* iiftmtif iirfn- In tin- mi mm |MTi|Nirlni zom - nlnr** tin* lm*i * ( IN nen* If.-.- marki-tIK ilmnugiil, I In if **ere large mnnlH*i- of mitolu* fignir- (fin 2, |ln1- VII) fill A'jfhitiurf // itihithtltuti lit Inir tutu i tifmltotm (tlfiauyi I nujtn* fur i i< m j M Aiiur.i \inimm 1- lu-ri* -tilijfflftl to tlif-f lomlilion- for I III ilav- (irou|i- of iiinnmi- -innliffil iifirr 12. 77, IIM, I Ml, nml I III day/ e\|Hi-nif -Imneil h\ I*r * Imngc- llml were e--flit tally liki' tlm-f -t*fi lit lilt- f\|M*-fi| Iti limir- daily Tin* tail Inin li-trat liloride nml nlfnlinl lc-1 n;i- nniformly lalul ami jMntliiffil ln*-r * limigf- 11 mi 1 m-ri* nlfiitiinl to lIn-i* alirmly tit -i tiU il ami illn-tialfil (fiK- I ami 2, |d;itf \ 111 ( I In/ t ithitlttl tint fa htf/h t tiilt i till nf tnu (tin null X XX Htf/tit.', i* i tu hi | /(.' Amos ilitiltf IViitn- nml in-\.-n lilornnfilitltiili-nr- \*ln n inlntmi-tt-ift| in tin- fom* nlrntion |iio*r| Inuldy to\u l.i^lity nmmnl- wire I'l All V I I i. I H....................... A*n iIm Itv.t .( ti r.il * >!- it !* |Mutil- ***l ltf.i * lil.Il.nl* n - l*i *l* fct ilniM *>f IIK- ,|.,il . (mi I*. .I.o - I I,. In* . . *11- ho *.<* ..II. 11 iiihI mill In <|t * * n* l**l**l* *1 I lif o >11.11.(111.11 iIm Ii*.i .fit Milumii* In I |M/t|* |ill|IHlnl|nllt l|H. il will. -- IlH t lit* It It ( Im o* ** m- f * i*l* * ( <**wt In *1 (nil* m K.-rnl |.tt> It* h.MiIimII I** llti * tittii** - iihiiii o.u- * *il OHiM.I Hint irri'KH I ir nil* o lluUr -(...* * - iio- no -* ui tl.ri>iin. .ui (In- Itsi-i l.ilitilr- Sin I* -|*i* -- * m* I ii lit N Hf.-lllllwl -M f.lll- J.Ol I|I|1.||. -It.III.I- ( Mil III mill IM M-l'MI.ll || II* <11 1 lr riif-f H|ll. .*- 111 --.(ill IIM t Hlltl Ilf .IfIff H.M.l l. Will 11 ||f l.t .lllill III loll <>( I III- till.' I H Jill III* IfIt an.I iii.hIh till I I., .* I I.I- |i|>.<liimii-r<.||iitit| jilt ** I.I ii .M>||.||0 .1 w ill. tin it It*.* litf nn- .l.iio <>l - I 1 '(* - I III HI I III I III ll >.( * l. It* It I till ll|(. |H .i.ttM f.l Ii* ill* -lllill MIH|*.<Hll.l H'llllllO |-fl O <f III W illlti-lflll IllHIIIK'l III till- I In' l mI It* Im I . I IIIif Ii nil* * nl i ii 11* iIimI |ll III >1 - Hll.l Ilf*|I IiImI III! |it"I till If tlfa (! .W 1'I.VH : \ I WATER PCB-SD0000059035 11*2 Jnri'NA!. (iK IMH STHIAI. A\l TO\M (U.<H;V |rut m, *0 `If H 'l, all of u Iim Ii )<>| weighl iiimI Mat-* mooted from e|HiMtre lia- appetite Kour died |v 1 Ik* end of I Ilfs) month, Sfi Hlllilli f2 .IhV- Mmn| t wit'H llir thud ami fiftli urrk ron* timo'il to ilir, Ho- longest Miri iv al liiiM* of I lie-r were markedly jaimdind bring ;i.r day* Muro-ropi, ehainiiift- I lie remainder won* Mirrdired for lam o| tin* I * \ rr- *f these omiooiIn I nit Imlogti ill examination or Mir- rri*-alrt| on et idem *- of rrrovrry eimdad to tlo- rlfvtt-s of enrhon Irf rni liloralr and nleolml Only H iimimiN -ur\ i\nl I In* 5>2 <lity <**jioMire Tin1 majority of h\rr- were modrr- Adnmn-trnlinn of rartam irtm lilorolr nml alroliol again pro ted fatal to uiumitU ex|*osed io (hr altove iminm-r The liter- of m li iiiiimhiIm alrly or markedly enlarged They -hotted III*' elmrarhll-tie imivMVe were all yrllou uml in addition llir ma nm-m-is prr\iou-ly de-mla-d nml illiin- jority wi n- tmiikediy mottled Oi oi- ! nihil -mindly they win- gmmilnr ami llirir rot -nrlnee- -howed mmol*' -pines wlmli heeame morr prominent uftrr hi) tCifMtHHn hy futility \\ la-n f**il m do-e- of kim daily hi a group of 10 IlMilloti Alter nil K liny rXjM-orr, III!' liter *rll- Wi'ir loarkrilly -uoll< H ml-, jm oIii- ami lirxio Mormi|ilillotl< oi-- prodma-d maikrd rrllulur nml ami moderate fatly degeneration \\n- -itm-hiral ehiingrs mi the liver in a pr-- ol Tin- wa- nm-t mntkvd to litr iioiral arm- nil (mill'll all -hot! penoil of time Ml fal- ton) w iglii and appeared ill from tin* of ill* ll\er lohnle- weir alTerled ) I'lMliMig llir longest -nrM\|ll llllM* I ll*' r\t* ill of Im r injury rapidly no ren-ed '* that uflrr dtt day-' rxjMe -ore, maiknl -inn I oral a- will aeetlidar i hungr- were apparent Tin* w.i- .Id day- Mllmngh ill** liter edge- wrie liluol and rounded, I lien* were no -ignihranl weight i arm- lion-. 'S he liter- Were (nahlr, yellow mil ro-i ojiir n|i|M'aram were tdenli- ami nml|led MIt ro-*o|Mi ldly (hey al to lliii-i to Ih' d< -< rile d m lul led large do-e-. of jM-iiiu- mill lii-\aliloro.i|>lil lialrnr- (fig-. I uml 2, plate -howed marked -welling and tni noh*niMili of the i t IU Their Wn- a)-** i oinplrle dfgeneral Ion of -raltered \ I' .ili'l m fat- Ini -iioil.ir do-r- ol i <11- t I,, .i-lon.d loil<<fl< ligure- were | r I I lit | lila- arnl Im\- IdoriMphtha .-*! \ | l-rr |ig I. pl.Hr II) S*llt- lt m - phi- Ul p r ni Ul<>nnaisl al*lr -lam- n sah<l \<-i\ marked fatty liylti<\l (-o' hg I plate III ami tu: l . ..i-* MU deg* n< ration Oo.ei<iii;il < *11- roti.o .l -lijd of lf< ular a*kl- ft \n V \\ | I', | \ |.m |niMil |<lna<>llili ogr.i|>lt * r> iIIu-KhIikx O*' "Mth.l <1 .1. 4-i. -i* ' I li<* *-idM*g lorn *- * ; I * k* < I '* *. I i %0 i * .< . i ` . ' , i |>i Wn I.. i, kiih.ki ia iiki io. ri|ha >1 |.n si'.iel* !' o.ll*iM'ti iih l,, |lf l*..*a> |<> Mel )n o- 21hl.Mm|<tilli*h-*e f.i i;tl il>< I la miMil .le-l ilh< le.ur- mIO r llir ham- lM<r*tioli f lelrat hloralr Similar di'gir, - n| iiri i*'Ki< ffMillel fr*a i)m a.lmno-(*att-<M of **" *< hlernlr ,i. I ) Il-t.i. la- I. !.) U-*m < l i . ai<i'> I loi.u wt^*)*` t. I Ilf , il.t .atAU-l .U|*wtd >f lo O taa <1 < 1*1 **f Mial< <i li|'l<rl<\ I 1 y it, 2 A IiimIh i !,** phitlonn* ro(tfnf*k 22A ( tlir liver iMuahaled m I lie la*v ligare KT/'f WATER PCB-SD0000059036 IM JOrilNAl OK INIH'SIMIAI. \i; A\I> TU\h oloin (,,,/ #r/, | nph.hr hyaline tin hi-inti- In im|i|||mmi iluv tit it group of I min) tin* nlarve I linn* i y***l*< hange- there were de-iTilted liter change- occurred Icmpi t.tin.emu- viimii|t -ued intereethilar -pine- I l.ro.ighont ,fig- I ii i it I 2 d.e hver- (x-i* \ I ami tig I, plate III) TIm-m* -pan- i-rr ii-mally nmilar or oval in -hu|M', although rapidly alitl to a Ic-m r degree (-i*c lig 5, plate ll| (`itnifHHiml F / Vn/n umt /tr/ilfhtmnnfthttinh in .* many of diem ramified Iretvvreu **11-4 Frftuiiiirr Inf /ni/mg |-en|nig ill in tin- Imr .oliimu* or Ireiweeii liver 1*11-4 mill tlo* -ii.umii.IiiI -ii*l>tIm'Imimi lo-cs of | gut daily for hi ml- wa.ronliinied w id. I Mil oiif 4 day inter in Mull a any a- lo -ugge-l llml they ruption. All 10 rat.- iuol dad or find r pre-ented gmally <lilnl-il hile cap.l- Ina ii -ttenfieed l#y do- lift > lf I fi day lnri* or < hIoiIk iiIi (lig I, plate III) They iomImmm'iI -emu- pr.-eipitnle, a The-e hver-werc friable and yellow i-h, ami exhibited imMlentle lo mniked f w -trand- of Mum, Hiol on a-ionailv nml I ling One nomial vn.- jaundiced a li M vie- Kaielv itiir ol- Ilf I lie ft itoilonl- tl.nl wen -aellficed, * rv nl one nl two degei.eraf log In i r nil- within I he-e -pare- In -nine of three -IniWed < nlnrge.m ol of tin* I.n-I CIO lo III pet . ei.l 1, die remaining Ihe tool** markedly damaged hvei-, r. if lil.il or|Mi-< le- w re nl-o pre-eni *1 In' above ion m-i i|iir i linage- H|i- l.vei- were normal in -in tin mum- -ropii I'Minmialimi (lie livei- ol ihIn i \|m-rd lor 2 urk- -(.owed marketl |Kilt..l lili-lit M ill to tlio-i* ol(-if\nl Ml m ll.ilni i liange- d.t.l ap|M'ared lo In- flu' lin t- of ral - -ul'jeeted |o high degenerative m nalort \ld.otigl. die ronn-litlaf ion- of (til- lolM|MM|||'l I * V liver .-.11 itijuiy - -4ntn vvlat greater iiiiial.il ion om'IIiimI- (tig- I mnl 2, I<hi11- \ I) Tin v were nNo -miliar lo lit (lie eenlrti) |M*ltlon- of die liver loln.le-, no |Nti'lion of die liver wa>* I In' ehangr- llial reMilled flout I Ikhiding of another (MOla- llllii Im n.ii hloiiiaphthnleiie oio|hiiiinl (hg- .i paled 'Iln liver.ell- -hovved vary ing tlegree- ol -Wellmg, inerea-ed giam.lailty ami v a. Mol./.at Ion of tin- ami li, |>1:11 - I i ami from tin- feeding i ytopla-m Katlv n.pirv wa- null- I a mivfnre "I |m mIii- and hemn hlor* naphthalene f'Ml |M-r null nml liluil- inteil Itv a to..--mg of lMi-..|lidli giamile- and -nndl ohI -IdiimiI -lim- oainl diphenyl (l<) |H-r i nit l \\ lii'ii tin- |Mi-|iaralmii ol penta- amt Intel near the i. II mn lei The pe ripheral |Ni|||o|- o| -hi I. cell- were hevin hlotnaphthalene- vim fnl in a. idophthe ami v ae.mlaled Small -mailer nmoiinl- (tl ft gin every -n mnlVI irieindal -pare- were pn-enl In tween VI \Tl. V III 11>. ) v mIi "* Kim mKinii * *( ||\.I ) tl ml It.) >1 multio ( ** , |Miiln .ml *** tlr|>l*tt**!*i**miI In', Ii1*ii tinO'.l <li|.lit mi I oi a Kin ili.'t* |h i lilinlil.'i | In- ml **! vit i l l*ti i.\ tlm n nto r lllillMK II *4 t A 'Mt|Miri-l>M >( llie Ion ( tin- ml illi llnmr *! rut* -m nil. i ) iln r in.) ati'il I tin I llic lit ft t linu*en laid |rit((r -r-i-i| oti-xln i*til \ nl tn million*! ra Iimii ( tin' i iim|>iiMil liml lii'i ii IniiiiiinO tl I tin- -IniitM iiiilv llti' nmtki <| i Intuiv in tlw lliii no tote* litre I lit '|in> n hki ll|i>(M' |hi > iMli-lt ltlil-11 iiO it ilitf* | ml J ,>I| \|l NO * el t l|0*(e Mint till M'lHHMHMlt Ill'll II --tie I - i i *ln | H -nil I tie I o et i el In m)ii>w iiiiiih >1 Ini I v ill ge inml n m I I*. ` V l**li< . |mi*i I |ilnilhmiIi i etf I H|ili v J ..A from n.M-ilier nm-n mi Hie liver tlliMtmteil in tin* n) *\ i Iikiio- mi mm n\Aun iMM sntiAi am> tommm<h;\ m *, *. # li\*r * M' ihhI Im Iuimi iIm- i'iiImmiii'* of llU'l tIK nnd I hi* -lim-oNl/il intloiImIhiiii (-* lig 5, plulr I) TIii'ni* wt*r* inlrrprHril In Im* tin* rmly "higt-< Mi IIm* fiifiiutliMii til lurgr M11 1 It i lit r h|mm (hg It, plait* I) wltnh xtih"t lOtitlly tin rl<pi*i| uml uliuli wrrr Ithntlial In | lie '|*;iri`H ili -i rtlH i| lit I lit* hingoHig '^' iimi Afirr fotigi-r tlit- Ii\f 11 IK '.(inwi-ii \fiy markfil "twlJmg mid ln> iidtllralmn Oi l U'llHMlI tltgtlHTllllHg Hlltl irgriMTitl iiig * t il' u i ff nli-i i \ i-d ('intifmiinnl /" !ttl fur t t til /*< n/ii- ntul //< Jm him tnif/hlhith tn m tint! lit fh r lit I Vi/nf|i|,|/,i| Iftftht niff ft! > hi/jK>\un hi/ itihillultit/i lldim lalinii i vjif niMfiil wi-rr tam'd tint on l wt ieinu|f> nf mt'' Tin* lii't of iltrxr Kri'M|i> til MO 11111111:11" writ* r\|Mt"ftl In lm\ t niii flit rulinll-t (ii\TMgi- I 1(7 mgni> |H-r in mi I Hi itunr" daily Inr l.ll tl.U" Till* "fflllltl glotlp, ||I"0 tnn|)ri-fd itf Kll ml", wii" f\|n"fd In h.rt t Kill fill III! Inti" (iiMl'iigr I tit* tiiiftii- i'll rn I H ltmr" tlady b<r III day" Nti i* \ dfli f *f illitf"" \\,i" iMiiiil in tin- hung mtnn:tl" mi fitlu r group In i`:n Ii f\|H'iiiiit-nl ri |rf"fiii alivi |*inii|t" nl aiiiniiil" win "in rilii < d aflfr t \|>n"iirf jiiTiml" i tirri "|N>n<liiiK In tlin-f U"t-d III tn\\ rniii f lit rat l*H iiifin Ini inn < K|H'rititi'iil> with In* Itlur* nn|ilitliiili-iif" and |mmi!h- him! Iti'Mi- tfdnrilMfdit ImlffM-A Sint i* I lit re wen* IHi n*)<iglliznhl<* IiITi-m in in (lie iiiniMint nr 1 \ |*< nf Imr * haug<* nit"*1!\ftl lifter "iinilnr A|M)'*iri (teriiitl" III I In-"** tun group" if Till", lilt* "M-enlld grolip <l \|m-*fd M LiMir" tliiilvj uill tml Ih- dt-HU-wd Min n#"t n|nenl(y tfn* lixi r-* m-ri- ll"lndlv ligld yellnw Vflrr prn- hing'd r\jtMMire, lb-abonrinalif v inure mark'd mid m ninny indituM** Miolihtig wih Tlierr mt` mm ifiy Mgnihrant iilti-rnlMiii" in the wtiglil," nf li\er> altIhmikIi the iiiajnrilV wen* "hghily "Wnllt-n |ii\ringi* nf per t i nt iiu n-it-t in wt-igld > Miiru^ii|iniilly (lie h\*r" "Imwid I*ni"liiiit rlmugt" after H7 days nf e\|Httire f fiese IlliTfiix-d "ninewliut during (tie net-mid (mtumI <d l.r day* fxiitfiT fXitM-Mii-f |trn*|nil liliJe it any tin rea-M* in In it duiniig*' Tlie <! -ervetl (ml linlnKifiil t-lmnyi-" t nu-i"ted nf "nelliiiK iiud ruillidiniC nf liM*r eelU a* t **ii*14itit<I l.y n di timie uiereH.-f in (fie | r< all lit i*'l ll e nf tin* i Vtn|>(|iHUllf tfranulfs llyidnif drn|*tet" in the alteifd eyttt|ilfiHin wen* n fmt."|*it limit ft-iiluie (ft :|r |)IhIi* III) Mitnlie fixnrt" were jire-enl in nhnurnmlly lniK<* munhiTs In nn in e;i"iniin] liver, nt ih the i-H"** with similar rx|Mi"tire In IhiIIi |M*nlii' uml heMieldnnm|ililIiii* h net nlnne and refinetl t hlnrinnled ih|ilifliyt, there Wat a liimketl <lt-|Hi."i( nf finely * In I* let I Kiaiiulnf mill reffill life yi IkfW nl y f| hrntvn |tljf- nnnl 'Ihi- win* |tn"fiii within li\er and Knjilh-i IU l.aK*r uiuniinl" were Imind in the tiiitia) |Hirlinii" nf the lixer Inlitilf" If failed In ."tain in a manner <hmmleii"in nf either llfiiin-'iderill nl hein<ilt|."i in Tin* livt-rt nf rat" reinnveil fmni eX|Mi"iire fm 2 nmnlli" alter an ex (in sure |N*rmd #f Wit d;y> were similar In llms- nf iiiiiinitl" >mrilnti| at tin* eiltl nf 105 tiny"' e\|Mi"iire There Wls, liiittiUI, tin exnleliee nf any lln reii-t- in the |uilhnh*|(l< al fhiiinies The iidimiiM i itf mu nl ihIm*ii iiiia- ehlnrnli* and ah #*hnl wit" aliuti"! nnl- fnrinlv lafitl Mm im"<m|im exmiiutN- I Inn ttf ||\*l' Itl then' fat- re\ eiileil marked enhtr|(ineni lM|i|*ruxuiialely M.. i*M| chlorinated hydrocarbon 117 9 par cent). Burh Hvera ware y**Uo the lees markedly damaged llvw, md mottled Affairt there wu eilao- such spaces contained serous precipi #re and widespread liver tiemmU oo tate, strands of fibrin, and mall esfaroecopic euniiaatiuD (see 6e. I number* of leucocytes. In rata sur red 2, pUte VII). viving I to 36 days, these spaces were much larger and often had attained (b) Srpotur* by feeding.--When fed the aise of a normal liver lobule (see Ii Utr* doeea (3 gm. daily for 10 rata) figs. 1 and 2, plate VU1). In these thfc ooropound proved to be very more severely damaged specimens, taxle. All auimaU appeared ill and extensive hemorrhage had occurred fioadlng of the compound wm stopped (fig. 2, plate VUE). In eecliooe rfler 12 days. Dwpilo this the reia stained with P.T.A If. these spaces renUnued to die, the laat dying on the were seen to be bounded by flattened iftth day. 8ubne<)urnt microaropio liver cells which showed sharp cell asuuninatiou revealed that the liver borders. Liver cells between such cfoangT* bad continued to progreea spare** were distorted, swollen, and elter feeding wu stopped. Macro- allowed marked fatty degeneration. eaopirally, the majority of the livera In many of these livers there was a were enlarged, the largest showing an light increase in connective Maeue taoreaae in weight of 11 per cent; between the remaining cords of liver fifes average Increase was approxi cells and around recognisable portal mately 40 per cent. All livers were areas. Proliferative changes were ysUow, friable, and many of them were occasionally observed in the bile ducts. markedly mottled. Bulmequent mirro- This was indicated by increased num eoplc examination indicated tlial ber* of ducts in certain areas and by much nf the mottling was due to mitotic figures in the bile duct epi fcsmorrhage into spaces within the thelial cells. No recognisable dilata Over tissue In addition, the external tion of medium aland or large bile tad ml mirfacen of the hvent np|eared ducts was present In many sections lightly pitted or granular. The micro- the architecture of the liver was so eopic changes observed in the liven completely altered that it was difficult 4 the animals autofiMied after 10 to to recognise the portal areas. In all 14 days' ei|Kteure ennsiated of moder ate to marked swelling of liver cells aaeompanied by marked fatty vacuUsalion. Occasional liver cells showed additional signs of injury such as nuclear degeneration and polyonrvliiii.il' I. ni I. ii> < ytic invasion. Bratiert-d t in-nlar .r uval ebape*| mtrrellular spaces (fig I, plate HI) like those previously d<**rril>ed in experimdIs where pent a- and hexachloraapbthaienes were employed (figs I sections there was evidence of fatty and hyaline degeneration of the re maining liver cella. Blight polymor phonuclear leucocytic infiltration was present This was somewhat more marked In the periportal areas. Feeding of this mixture of pent*and hexachlornaphthalenea and chlo rinated diphenyl in smaller doses (0 6 gm. every second day for 4 rats) resulted in liver damage that devel oped lees rapidly. The rats were sd 2, plate VI) were observed. In sacrificed after exposure periods of WATER_PCB-SD0000059038 UK JOHHNAI. OK INDUHTIllAl. HVOIKNK AND T0XU0I.CM5V M W, a* 21, 34, 58, and HI day* Their liver* the toxic chlorinated naphthaiena were yellow, increased in *ie and ronipoutide (fig*, f and 2, plain VII), showed slight mottling Mn-rosr.npi* The miern*enpie change* resulting rally, lhr ilm*f Abnommlily ultM'rvrd from ex|maure to tow concentration of was (narked fatty vacuoliaation of liver chlorumted diphenyl alone were simi cell*. No intercellular space* like lar to those resulting from inhalation lhoar dritcriticd alnjve were present. of |>enta- and Itcxarhloniaphlhalcnea, plus 10 per rent chlorinated diphenyl. ^ Ctmpoumi O. ChlormiUril Ihphfnyt^ The moat conspicuous change wai (a) Exposure by mAo/o/ion. Kx|*>wirr by inhalation method* to low concentration* of rliloriimlHl diphenyl was earned out on two grou|is of animals, each comprised of HO rata, in a manner identical to that de scribed lit the foregoing sections, In 1 the first group a 16 hour daily ox|*>surr, with an average conrentration of 0 57 ingm* per ru, m , was employed. hyaline degeneration (fig. (I, plate til) aiiYiougn swelling of liver cell*, in creased prominence of cytoplasmic gfMUilcw and merraeed vaeuulixation were present. Mitutin figuwsi ween present in mereawd iiiimiIst* No imcru*co|nc evidence of rccovcry~"wi* found m the liver* of rat* cxismcd for 105 day* and then removed from rx|wKiire for a period of 2 month*. The second group of animals was eximM'd H hour* daily to an average concentration of 0.93 login* |icrcu in Neither gniup of rata appeared ill Krproentalive animal* were sacrificed in groupa of 3 to 21 rata, after varying iwnoda of ri|KMurr. Ill thr first ek|M*ninent, the animals were sneritiretl after 37, 72, 105, and 134 day* of cx|>o*urc, in llie accond ekperimenl after 42, 77, 98, 119, and 143 day*. The liver* were pale or slightly yellow and aoitiewhaT"'*nuittN. There were no constant variation* in the weight* of the liver* The microscopic find' mga in the (wo grou|M imhealfd that the different expoauren had rrmilled in the name degree of liver injury, '('he pigmental ion of the liver and huoffi r eilli wa^ somewhat greater m animal?* rx|MMcd H hour* daily. In both experimental groii|m the carlion tetrachloride and alcohol tost wim highly fatal and led to the name exten sive ecnTral necrosis of "liver liwuf (h) Eiftoiurc b\f fffiUuq When fed in large daily do*** (3 gin. for gro(i(w of 10 r*(.sj, chlorinated diphenyl proved lughly toxic Feeding wai discontinued after 0 day* Neven rata died within the find 8 day*. The 3 remaining rat* giimt'd in weight after the feeding wa* stopjied and were finally sacrificed. The last animal wu nacnficed 63 day* after hiding waa la-gun The majority of liver* showed a moderate increase in weight Micro scopically there m a* evidem e that liver injury bad occurred within the first few daya The cell* were *wo||cn, at time* sufficiently to olwiirc tin* sinu soids. The cytoplasm of the liver cell* wxn acidophdie in staining ipiality and contained hiiihII vacuoles. Small conin-Htaineil hyaline grunuh-H and glohuh-H were present Mitotic hgure* were numerous (my fig 4, plate ill) 1'hcre was little inllaininalory cell infiltration and no structural change* that wan olmrrvcd in rata cxnms-d to were obaerved. r*, in*\ atLOMINATtD HYDROCARBONS 110 When Hiiiallcr done* (0 6 gn. every Sttorift ilay) il tin.-? eom|ound wer* tdimnudered to HI rata, thc7ir*t 3raUi aonirnxl after 9 day* Two addi tional death* occurred after 12 day* aod two more by the end of thr fifth *ek. The remaining amrnal* were wrifierd 1**1 wren the 4Utii and lbs lOOth day The liver* were enlarged, the average increase in hver weight bring 33 per cent. They were pale *d flightly mottled. '1'he most oul- fUnduig mirroMcnpir abnormality wan the presenee of large number* of varying mud mi nlopluhc hyulmcj(lob- *l* in thr cytoplasm (*rC iig 5, plate 111) Thi-x- hyaline globules, all hough hrgor am) iijuic Jimm-mun, apjs-ared faWiliml to those encountered m the kvm of rats f-x|>o*ed to other i-hlori- trilii diphenyl preparation* 'I'hu iwr rell* were markedly swollsn and bowed tally vacuolization There wauTiliwi incrdociTfcgcm'rative activ- t^r. No Htnirlural change* were ol>- awvad m any of the fivers. Discussion Published report* coiirermd with lb* possible systemic r/Tts-ts nf rfilori- alad naphthalenes have l*<'h few in MlplwrN l^'hmann (3) ,n 1919 regaeUd tliat animnlH cxiHew'd to chhri- B&Ud naplilliAlcnes by udraUtom or Ifvding relusi-il to cut mul Id death Aflwed "(srnfiar" IcsJotm m the liver la 1U.IA, Hum ami Jarvik (4) fcjNirtcd Um nwtills ohw-rved following thr dally *ulu iltUUe.MH |HU > linllH IlltO 30 rabbit* <l (30 login ) ft eertam chlormat-d naphthalene MMptMinds iJisridvc,| m jtarailin oil TV* rmbhits receiving a mixture of In- (d Uirtchlornaphlhalcm.** lived ainl vbis aacnfieed, after a 2 montlui' exposure, no patliologicaJ diangm attnbuiahle Ut the compound injected were dcinonalrahle. 1'he miiturea of tetra- and jientarhlomaphlhaJeoee and of pent*- and brsachlomaphtbaJeDea l>mve*l highly fatal and degrneratioo of liver (issue was observed From their finding* Kliun and Jarvik concludcnl that certain chlorinated naph thalene* or impuntir* contained in them are ca;>able of pniducing yelkiw atrophy of the fiver in the rabbit. H is noteworthy, in the light of the present experiments, that the com* |M>und of lowest chlorinalkm (a mix ture of tri- and (ctra^-hlomaphthalem**) had nu apjwrent effect on the well ts-mg of the animal* and did not produce demonstrable rhangee in the hvnr although injected daily for a jwrHMl of 2 montlis. 1'he present ezjirritnenta demonMtrate that chlorinated naphthalene rompiu/aJn and chlorinated diphenyl are capable of producing marked liver <Unuig*_in. the white__ral__Fithoul demoimtrahle micruoaipir rhangvw aDpearuig m the other organa, Further more, the characterisliea of the fiver lesion* result mg from comparable amounts 08 any given compouniT are the same, regardless of the method of admimatratum (inhalation, feeding, or An attempt ha* I wen made through out this study to grade the toxicity of each of the several compounds tested in acrordam-o with the everity of the liver damage pmduced. Although some of llowe rompourubi af^>eared to produce aiiuilar degrees of fiver injury, the toxicity of each compound wvmflJ directly related to it* degree of chlorin ation Jims, a mixture of trichlor- naphthalenes (cblorioe content 49 4 _ MB' 130 JOURNAL OF INDUSTRIAL IIYCIKNE AND TOXICOLOUY \*ot *>, r*, (Mil CHLORINATED HYDROCARBONS 121 per cent) proved to be the lesst toxic lion and fatty degeneration (figs, . v ; of eny of the compound* tinted, wherry# chlorinated diphenyl (rMurine content 06.0 per cent) wee highly toxic, Mand 4, plate I). feeding of trlra- ent.Lj>entafhlpe-~ Vtf naphthalene 111 combination with .jj* even in very low concentration#. chlorinated diphenyl 'resulted In pro- 'j "TriehiomapbtlieJenee, when com nounced liver changes. Tlicai liven pered to other nephthelene coni|iounde had increased in weight (average 71 of higher degreen of chlorination, were per cent). Microscopic examination relatively innocuous. Kven after pro revealed a peculiar type of hyaline longed feeding of large amounts of degeneration involving prarliraJly thin materiel, the rets showed no every liver cell (see figs I and 2, plats evidence of ill health. After 2 months' I). This type of cell degeneration exposure, microscopic examination of was morf marked and occurred earlier the livers revealed only slight to idler eTpoeflre to preparation* con moderate degrees of fatly infiltration taining chlorinated diphenyl than to and degeneration of liver cells (plate II, 6g. I and 2). These changes were therrnore, it was roost marked in the alight when compared to those result livers of animals exposed to refined ing from short exposures to compounds chlorinated diphenyl (figs. 4, 6, and 6, of higher chlorination. Kxpoeure by plate III). inhalation to low concentrations of Comparable exposure of rats to Iricliiomaphliudenes produced liver penta- and liexachlornapblhalenes cell alterations that were never more (Compound I)), |>enta- and hexacltlor- < than minimal (see fig. 3, plate II). naphtlialenes (Compound K), and ^ Much animals witheUiod additional penta- and bexachlomaphthalenes (00 ) - liver injury from rarlxm tetrachloride per cent) plus chlorinated diphenyl and alcohol in a manner indiMlinguieh- (10 per cent) ((\m|ouiui K), resulted |f ahle from that of the normal animal. in liver changes having few detectable Somewhat greater liver injury re differences. fhc mor)>hological ` sulted from inhalation when the air change* were slightly greater in the concentration of this compound was increased more than eight times that used in the previous experiment but livers of rats exposed to the last named compound. In these instances ijlji Sthe hyalin degeneration of the cell - agaio the liver changes were slight cytoplasm was more marked. A)- compared to those produced by com- though rata ududing low^cOnccntra- paraUr exposure U> Use more highly n< t) and V otT demonsxnJtde spu of ill bnJi\ TW nurture of uua- and pnna- hus'ratlcoj^^namjumtiuo uf linearTressa J ehlomapblhaletiee employed in these experiments appeared to be consider ably more toxic than was the mixture of IrichlomaphthaJenee. Animals fed ^vfJrd'mafked hver ceU injury ^ plate II, and fig. 3, plate III). 'Hicse Irtuons were nt ill demonstrable j after a 2 moiillis' recovery period. : small doses of the former of these further evidence that liver damage'j preparations fell ill and died or were had resulted from inhalation in low sacrificed by the 63rd day. Their ronceitlralionH of these compounds ' | livers allowed extensive fatty infiltra- was obtained from tbs carbon tetre- * chloride and alcohol teat. Buch teats essentially unchanged after a 2 th vm almost uniformly fatal and recovery period In these mulled In widespread liver normals small sublathal doses of carbon Urtiw (figs. I and 2, plate VII). These chloride and alcohol uniformly pro three compounds proved to be very duced extensive liver necrosis and was toxic and resulted in a most unusual highly fatal to them (figs. 1 and 2, type of liver change when administered plate VII). Chlorinated diphenyl fed b large amounts by feeding (see fig. In email doses produced similar but I, plate III, fig. I, plate VI, and figs. more marked liver injury (see fig. 6t I and 2, plate VIII). Identical plate III). in large doses this eom- changes were observed following iiiba- pound was highly fatal. Tlie over hiion in high concentrations of com changes in animats dying after short pound D (see tig. 2, plate VI). In exposure were inconspicuous and xacb livers the moot conspicuous consisted "mainly of swelling of cellp feature was the presence of large and active regeneration--4ecc fig. 4, bterrellular *j>are*. Kxamiiiation of plate III). However, animals rw routine sections, supplemented by moved from ex)wsure before being serially 'xlauied preparations indi fatally poisoned, aubsequeotly-devel cated that Uum spaces tied resulted op! hyaliiiynjcg&hj^Tf^^lJvcjt^ from dilatation of bile canaiiculi. cells similar to that produced by pro Tbs reason for such dilatation was not longed administration of small doses apparent There was no correspond of this compound. ing dilatation of the large and amalt Thus the results of the present UU ducts at the periphery of the liver study, as well as certain field studies hbulee and no inspissated bile was that have been made (1) suggest that ever oleerved. The organically cotn- the solution of the Industrial baaard kbsd chloride in the livers of these involved is dependent largely on a rats was no greater than that olstcrved reduction of the air concentration of b the normal animal. Although scri- these compounds to a level that will aoa Uver damage results front ex|tosure not produce liver damage. Tbs pres to high concentrations of theeo compsunda, the resulting changes are t unusual and do not resemble ent experiments indicate Dial lower aft HJUiseiilflriions must be obtained Ln ITTe caM uf til* toore Tughly chlori m of acute yellow atrophy on nated naphthalene compounds and totoscopic examination. Of the various ehlonnaled hydro naphthalenes"if a safe environment for whose tested, ehlonnaled diubcnyl workmen to to be assured Because p*S evidence of Iremg the must toxic. umislfnd hyinhalation in y iuw fotii i tii tkiiih (avrrass U~&7 of the pronounced toxic effect of small dosee of carbon tetrachloride on the livers of animals already Injured by *ta in mgum per iiT)"liver^cell ' exposure to chlorinated naphthalenes " were very pronounced after and chlorinated diphenyl, ita i :Tfct exposure period The most solvent for these compounds would change was uio l7yahni*ation_ appear to be very hazardous. eeli cytoplasm (see fig 6, plate Although this Investigation was Bush cellular alterations were designed to determine what systemic r uWmSKSBmBmmMBKSSISm iiw|wh|HR li--M HDh I-- ail WATER PCB-SD0000059040 122 JOURNAL OF INDUSTRIAL HYGIENE AND TOXICOLOGY M. 90, no. 9 effects, if any, would | produced in lieing used (H). The fact that liver experimental animal* by a group of eeff changes were stiff present after * chlorinated hydrnearlNinM, lhr patho 2 month period during winch the ani logical changes produced have lieen of mals were removed from cxjxvmr to Much a nature a* to juatify further the more highly chlorinated coin* ronimrnt KxjNMmre of rata to highly jsmnd* is further evidence that this chlonnstcd naphthalene nmipoiiDih type of injury i* jrerxiMtenl and only ami rhloruiatiil diphenyl results in a slowly recovered from. type of liver injury differing conmderabiy from the liver lesion* resulting from carbon tetrachloride (5, 0) and chloroform {Humming (7). The changes resulting from exiwnure tq the compoutula employed in tlusHtiidy The adiniinstratiuii in high concen trations of two <-oin|MMiiid* of inter mediate degrees of ehionnatioii rw* milted in marked structural changes in addition to marked degenerative changes in liver cell* The most involve alljjiortionH of the liver lobule 'flue im true despite the fact that the Initial morphological changes arc more con*picuouM change was the occurrence of progressively enlarging intercellular apace*. These were interpreted as pronounei'd in the liver celt* <ican*Hl markedly dilated bile eanaliruli We the hepatic veinH. The change* nl>- ure unaware of such changes having nerved are degenerative nature, Tile mu i i4tt*T degenerative changes were cloudy swelling, fatty infiltration been jirrvmusly dewnliod. From the above it ia apparent that exjiosure to highly chlorinated naph and~Tatty degeneration anil finally^ thalenes and chlorinated diphenyl not the complete dtHintegralion f the cell. _ only results in liver changes having llegeneration characterised by the marked differences from those caused aen'timilatlUllil bl targe amount* oL. by other well known toxic agents, hut idophuic hyaline material was also _ also that the characteristics of the irtjafTVRT TKT5 lealure wan much liver change* produced can be mark Jjmdrc marked urine fivers of animate ||VipuHna~loTlie cooupouitda containing ' chlorinated diphenyl. it i* of interest that widrapivad degenerative change* of all liver rcll* can exist for several month* without producing any evi dence of ill health in the animal* or without rausing important Hlruclural edly altered qwanfilalively and quali tatively by varying Hie degree of exjtosun*. For tliivie reasons one would *eem justified in Miggeatutg tluit detail'd studies on animal* in which the typi** of liver injury observed in these cx|M*rimenl* had been produced might further our uiiderstandmg of changes in their livers. Such finding* liver cell function. suggest that the alteration* take place slowly and that fii^aratirred-iiiwipolie Kummahy cell* are efficiently removed and .re placed by new cells which also become injured There waa no otmervnhlc nibrpfiological evidence to indicate thgCthc regenCTKtlng Iti'Pfr 'crTC^Iiad I Studies coiicernmg the effect ii|mmi while ruin uf a griMip of clJonnsled naphthaline cmnjsiuml* ami chlorinated diphenyl are ref*irtvJ. This invcMigiit ion was undertaken acquired an increased o. because of the recent occurrence of the.injurious effects of the compound 3 fatal cases of jaundice ui turn work* ** , inti CHLORINATED IIYDR OCA It HONS 123 hg Id industrial plants when* these eocapounds were lieing used. The eompminds tested were selected as rrprenentative of a certain Tange of chlorination and la-cause of their relative industrial imjMirtartee. 2 Four of the conijamnds tested were administered hy inhalation. The air concentration and exjiosure periods were varied AJ1 com|Kmn<i* were latxd hy fciding in large and small amounts. In addition three of them were tested on smnll numlicr* of tuiiBuds by aula'iitaneous injection*. The affects of any given comjHumd did not ap|ear to lc influenced liy the aetTiod iTadministration However, marked quantitative and qualitative difference*! in the effects of each of mvrral romjMMiml* resulted from vary ing the air concentration* in inhalation experiments and the dosage employed b feeding ei|a runciit* 3 Macroscopic. and microscopic examination of the tissue* of rats axpumd to these coiii|Miund* indicated that the injurious effects are mani fested solely in the liver Hlood examination during life revealed no Dgnihrant abnormalities. 4 The liver changes resulting from exjKisure to the chlorinated hydrocarlione employed have been described and illustrated. As indicated by their ability to injure liver tissue the toxicity of these compounds increases with increasing degrees of chlorination. Thus a mixture of trichlomaphthalence is relatively innocuous in low concentrations and when compared with compounds of higher chlorina tion, its toxic properties even in higher concentrations are relatively slight. tieChloruiatrd diphenyl appears to the most injuriouM compound of all those tc*lcd 6 Administration of small Htibiethal doses of carbon tetrachloride and ethyl alcohol to rata whose livers have alrcmfy lccii injured by the__eoin- {M)hnd*~uhdcr consideration is highly fatal and pruduciw massive necrosis of the liver. ti The significance of tfiis study in relation to the industrial problem involved is discussed. 7. It is suggested that the types of liver injury observed id this study might lie employed in experiments designed to study liver cell funcUoo. bibliography I Diot'C*. C K . WtiMN. M K . AMO IImnmxtt, t< A ; Tli* proOIrm of pue iltl# tytloraie Roct* from cartaia J ,eblorinaUal lydroc*rloo Tais 16, 28U (IWJ7) )1S. l.iHioN. PH: Feraootl toinmu&ilinn I Lssmamh, K : Kurtc* l^hrbucb dor Arta-il und tlrwi-rlwhygioo* B. Hkr- r-l liw >, 2AI) 4 Fit**, fi . N K : Actios ut ctrUia tlil'itvotlol bt|tblhftlu* oo ihft hvrr Prwr Hoo. Kip Biol sod Mrd . U, I IS <IW) 4 0*XDHH, tl II . tilOVB, R C , OlllTif- Mnu.to*. H K . E I> , TsowrsoM, M J , WikU, II 8. ano Lamaon, P. D ; Bludie# os lbs palholugicsl hiU>iugx of oRporiwsstai earboe tstrarhlond* poisuoisc Bull Johas Hop kins Hoop , 99. M (1928). i. CiMiaoN, O R, amb Kamo*amatos, W A Et'arbon teUacblorida elrrhoui io rwUlioo to lim rgMraUos. J. Pslb. and Bart . 49. t (1938). 7. Wmm, G. II, amp Braftar, J. A : C'hloruforrp powooing Uv*r oocroans and repair Bull. John* Hopkiao llusp . 90, 778 (1909). 8. MavNippp. W. A . A *\ody of tba ac quired raaistaoca of tba fiiad tuaua crlli morphologically allprad kbroogb proceapos of repnr. J. Pham, and tap Tbarap , H, US (I9) a r^'v4:rc^': i S/>V/^7 Tl SEE 0 a-Uvj-g^ J-*-4JL *-"&-j* /w'-o 'TruZ-0 '\jULS^*~ a'~' <r j(j ^ e > A MI MOAN JJl JOURNAL of HYGIENI Volume 27, 1^38 January, March, May Board of Editors i oco oaar>.. xso * R. W. HEGNER R. R. HYDE E. V. McCOLLUM R. PEARL L. J. REED M. FROBISHER, JR,, Managing Editor C. V. Chapin E. C. Faust J. G. Fitzgerald Simon Flexner F. P. Gay . C. A. Kofoid J. A. Kolmer with the assistance of R. F. Meyer Matthias Nicoll G. W. McCoy W. H. Park M. J. Rosenau Willem Rudolfs F. F. Russell J. F, Siler Harry Steenbock C. W. Stiles E. R. Stitt L. R. Thompson C.-E. A. Winslow Hans Zinsser Published by the School of Hygiene and Public Health of The Johns Hopkins University. Supported from the DeLamar Fund, The Johns Hopkins University. 13i111 . I ' .v'VS- .. X' WATER_PCB-SD0000059042 ' the nilki due t ions ified rized ified pnsid in ) QOO n.' vihg ilk is ,'j LIVER LESIONS CAUSED BY CHLORINATED NAPI1T1IA. LENE1 BT FREDERICK B. FLINN AND NORMAN E. JAHVJK (Received for publication July 21, 1937) In this country nine cases of yellow atrophy of the liver have oc curred in shops in which chlorinated naphthalenes are being used to impregnate wire and other electrical equipment. The total number of employees exposed in the three plants was approximately 250. The fact that three of these cases have occurred, in each of three dif ferent plants, all widely separated and under different management but using the same type of material, indicates the possibility of a com mon etiological factor. The average time of exposure varied from 4 to 6 months. . Yellow atrophy of the liver is a rare disease. Osier (1) reported three cases among 28,000 patients examined. The records of 5,000 autopsies at the Presbyterian Hospital in New York, show three acute cases and fifteen sub-acute cases Up to 1913, Umber (2), in Ger many, had not seen a single case among 84 autopsies performed. In 1920, he reported two cases in 200 autopsies, and in 1921, eleven in 149 autopsies. Seyfarth (3), also of Germany, had had only one case up to 1915; but between 1915 and 1921 he found twenty-nine cases of yellow atrophy. The increase in the number in Germany appeared during the World War, at which time the use of chlorinated naphthalenes also increased. The majority of the cases, however, occurred in women during the middle or latter half of pregnancy, and no record of exposure to chlorinated naphthalenes in these cases has been reported. We have been unable to find reports in the literature of any case of yellow atrophy occurring among the workers exposed to chlorinated naphthalenes either in this country or Europe. The hazard com monly recognized has been a cutaneous one, the lesion being in the * From the Institute of Public Health, Columbia University, New York, N. Y. We want to thank Dr. William C. Von Glahn for his assistance in studying the pathology of the animals autopsied. 19 WATER 20 FREDERICK 11. FLINN AND NORMAN JAUV1K form of an acne comedon. One hundred and two cases of dermatitis were found among 124 workers in Pennsylvania and a few mild cases in another plant. These cutaneous lesions have been reported by Wauer (4), Koelseh (5) and Teleky (6) under the name of "Perna Disease" which had resulted from exposure to a perehlornaphthalene. Perna wax is, in general, a mixture of chlorination products of naph thalene. It is yellow to dark brown in color, soluble in fats, contains 44 to 45 per cent of chlorine and sublimes at 130 C. Teleky showed that the cause of cutaneous injuries was definitely due to the easily .volatile chlorine compounds contained in "Perna" to the extent of only 5 per cent. Lehmann (7) experimented with animals and found that this chemical produced lesions of the liver which resembled acute yellow atrophy. Observers in Prance and Germany agree that in spite of the claim of individual susceptibility, 50 per cent of the workers showed cutaneous lesions. The failure to find reports of any cases of atrophy among indus trial workers exposed to chlorinated naphthalene may be explained by the history of similar industrial diseases. The medical profes sion at the beginning did not recognize the connection of the patho logic condition with an industrial exposure. Frequently, correct diagnoses are not made when the first cases make their appearance. In this instance the first cases in each locality were diagnosed as ca tarrhal jaundice in spite of the fact that catarrhal jaundice is rarely fatal. Post mortem examination which revealed the correct nature of the disease was not made until the second or third case appeared. In the factory to which we were called to determine the etiological agent we found three types of chlorinated naphthalenes in use. They are sold under the name of halowaxes,and, in this paper, will be des ignated as compounds A, B, and C. Compound C was introduced into the factory at the beginning of the 6-month period during which three cases occurred. Compound A is a mixture of tri- and tetrachlornaphthalene. Compound B is a mixture of tetra- and pentachlornaphthalene and may contain some trichlornaphthalene. Compound C is a mixture of penta- and hexa-chlornaphthalene which is plasticized with a rela tively small percentage of asphalt. A boils between 600 and 650 F.; B boils between 615 and 655 F.; C boils between 680 and 730 F. We determined the chlorine content and the melting point of each of these materials. The sublimate given off by B at 192 C. and that given off by C at 172 C. were collected and analyzed. - ' - LIVER LESIONS CAUSED I1Y CHLORINATED NAPHTHALENE Compound Chlorine percentage A .............................................. 47.9 B .................................................. 49.8 C .................................................. 47.9 B sublimate ............................ 35.3 C sublimate .............................. 53.1 Melting point 89 - 90 C. 117.5-122 C. 123 -132 C. 87 -- 89 C. 117 --123 C. 21 While the circumstantial evidence pointed to the chlorinated naphthalenes as the etiological agent, we included in our study other materials that were being used in the plant during the period in which the disease developed. These substances were found not to produce the liver lesions. We therefore concentrated on the naphthalenes and used them in amounts that would be certain to produce results if they were at all toxic. In the preliminary pari of the study we were not interested in determining the minimum toxic dose. The first symptoms noted by the affected employee were a "run down" condition and jaundice. As the jaundice increased there ap peared an increase in general malaise, anorexia, attacks of dizziness, loss of weight and a tendency to vomit. Severe abdominal pains across the upper quadrant were noticed. The blood picture was nor mal except for a low blood sugar which in several cases was around 68 mgm. per 100 cc. A typical gross autopsy finding showed an extensive necrosis, fibrosis and regeneration of the liver, acute enterocolitis with edema, fibrosis of the pancreas, acute pancreatitis, jaundice, ascites, edema of lower extremities, and subpleural hemorrhages. EXPERIMENTAL It has been our experience that the rabbit is the best laboratory animal for the study of liver lesions. Rabbits weighing approxi mately 2 kilos were, used in the study. We also included a few rats and guinea pigs in these experiments, which brought the total num ber of animals used up to two hundred. Dose. Fortunately for our investigation the State Division of Occupational Hygiene of Massachusetts had made a test of the air in the plant we were investigating when the last case appeared. Their findings are as follows: Rolling Department, 1 to 2 mgm. of wax per cubic meter of air; Soldering Department, 1 to 2 mgm. of wax per cubic meter of air; Impregnating Department, 11 to 20 mgm. of wax per cubic meter of air. ' *'* Our observations in* this plant and laboratory' experiments made - h WATER_PCB-SD0000059044 22 FKKDKIUCK 11. FI.INN AN1) NOUMAN JAItVIK us feel that even 20 mgm. of wax per cubic meter of air in some lo calities may be low. The ehlornaphthalene crystallizes readily out of the air within very short distances from the tank in which it is being heated. For this reason we felt that it was very difficult to determine the exact concentration to which a man might be exposed. Taking into consideration that a man breathes from 4.5 to 5 cubic meters of air during his working hours, we selected 120 mgm. as the dose a man might possibly inhale in a day's work. There were no available data at that time to aid us in determining the dose which might have caused liver lesions in man. We wish to emphasize that this arbitrary dose of 120 mgm. was selected only as a starting point for our work. 4 The naphthalene was dissolved in paraffin oil heated up to the point where the ehlornaphthalene went into solution. We have de termined from other work that the oil does not produce pathologic changes which would interfere in this work. For the reasons stated we chose the method of subcutaneous injection rather than the in halation method for exposure because we felt we could, in this way, control the intake absolutely. We were further urged to use the subcutaneous method because of our experience with tri-cresyl-phosphate, which causes the so-called "ginger paralysis" in man. It was found that when the rat, guinea pig, cat, dog, and monkey were fed tri-cresyl-phosphate paralysis did not occur; but if they were given subcutaneous injections the lesion appeared. On the other hand, calves, rabbits or chickens became paralyzed when fed (the chemical) by mouth. The subcutaneous method was effective in all the species. The work of Lehmann (7) indicated that the liver was injured whether the animal inhaled ehlornaphthalene or-was fed the compound. Our own experimental work confirmed this. We have found in our studies that the rabbit frequently requires the same dose as man to produce similar results. The toxic dose of a substance per kilo of body weight is frequently many times higher for the rat than for the rabbit. We found that 120 mgm. of the chlorinated naphthalene killed the rabbit too quickly to produce the final picture of acute atrophy of the liver. The dose was reduced to 30 mgm. Our observation showed that even this smaller dose was too large to produce the final picture of atrophy in rabbits. These doses brought out very definitely the toxicity of the material, at least for rabbits, which was the main object of this preliminary study. One hundred per cent fatality occurred in the groups of animals re ceiving chlorinated naphthalenes B and C, and sublimate from C. I.ivr.ll l.KHIU.NS CAUSED HV CIU.OHINATKD N ACHTH ALEX'E 23 On the other hand, no fatalities occurred in the groups receiving the compound A and sublimate B. Our procedure was as follows: groups of five rabbits were used for each compound. They received daily injections until they died or were sacrificed. Then the work was repeated with the same num ber of animals. Aside from loss of weight, we were unable to detect any symptoms among the injected rabbits in the groups receiving compounds B and C and sublimate C. The control rabbits receiving paraffin oil, compound A and sublimate from B, gained weight. The blood picture showed no change in the red, white, or differential count. During the experiments the rabbits were fed the usual diet of water, hay, oats, and cabbage or lettuce. Our results can be summarized as follows: ehlornaphthalene: A. All animals receiving either 120 or 30 mgm. daily remained alive until they were killed for post mortem examination at the end of two months. B. The first death occurred in the group receiving 120 mgm. at the end of 12 days. The same holds true for the group re ceiving 30 mgm. None survived beyond 15 days. C. The group receiving 120 mgm. daily were all dead by the end of 15 days. The first death occurred at the end of 9 days. In the group receiving 30 mgm. the first rabbit died in 32 days. The last of the group died on the twenty-sixth day. B Sublimate. No deaths occurred in the groups receiving 120 mgm. or 30 mgm. They were sacrificed for autopsy at the end of 2 months. C Sublimate. This group received 30 mgm. daily. The first rab bit died at the end of the ninth day and the last one on the . fourteenth day. We are giving two typical autopsy findings on the rabbits which received daily doses of 30 mgm. of compound C. Rabbits receiving compound B, C or C sublimate showed very much the same picture-- perhaps in some cases not so far advanced. Each liver showed the yellow areas and necrosis. Rabbit no. 533. Dosage 25 injections of 30 mgin. of Compound C. Died on the twenty-fifth day. Liver: Dark red with many opaque yellow areas; capsule smooth; cuts without resistance; cut surface smooth. In many parts of the organ there are yellow, opaque areas with dull surface, which involves groups of lobules. In between, the liver parenchyma is red in places and the lobulation is clearly 'w"*visibleT*1ih"other*place*lobulation innnot be seen, the parenchyma|*> WATER_PCB-SD0000059045 24 FREDERICK B. FLINN AND NORMAN JARVIK parently disappeared and the stroma is collapsed; these portions are greyish red. The gall bladder is distended. Lungs: Mnny dark, red areas in all lobes. Cut surface moist; in the peritoneal cavity a moderate excess of bloody fluid is seen. The presence of bloody or yellow fluid in the peritoneal cavity was a common finding in our rabbits. It was observed in human cases. Histological finding*: Heart: A very few phagocytes containing yellow pig ment are found near arterioles. Lung: Capillary congestion and edema. Spleen; Some post mortem autolysis; phagocytes containing pigment in pulp. Adrenal: Normal. Kidney: In epithelial cells of the convoluted tubules there is a finely granular, yellow pigment. Liver: Presents a striking change. Beneath the cap sule on one ^f the sections is a wide zone of necrosis in which portal areas are surrounded by a single row of well preserved cells, or none at all. In other places in the section efferent veins are surrounded by wide zones in which liver cells have undergone necrosis. There are numerous other places where liver cells have completely disappeared and only the collapsed stroma remains. In many places calcification of the stroma is well advanced and larger masses of calcium are frequently seen. Multinucleated giant cells of huge dimensions are often clus tered about the masses of calcium or are found in the areas of collapsed stroma. Liver cells remain but regular normal architecture is not retained. Bounded groups of liver cells are numerous, or only narrow bands of these cells surround portal areas. The liver cells also present a peculiar arrangement in many places. A double column of the cells will open leaving a considerable apace surrounded by the cells. The space contains granular precipitate or large plugs of bile. One gets the impression that these spaces may be hugely distended bile canaliculi, because in some instances they contain bile. Necrosis of individual liver cells is also seen. Cirrhosis negative. Iron, stain: Heart: Pigment stains red. Lung: No pigment. Spleen: Pig ment does not stain well, perhaps because of autolysis. Some granules faintly blue, others yellow-red. Kidney: Pigment in moderate amount; red in eolor. Liver: Pigment red. . ' Babbit no. 534. Daily dose of 30 mgm. of C tor 21 days. Heart: Bight ventricle dilated and filled with blood; otherwise normal. Lungs: Pink, air- eontaining and normal. Spleen: Soft, congested, but not enlarged. Pancreas: Appears larger than usual, otherwise normal. Liver: Capsule smooth and trans parent except where there are large areas of yellow discoloration with irregular outlines. On section the yellow areas extend into the liver substance for a few mm., but almost everywhere are near, or in contact with, the surface. Where these yellow areas of necrosis are moat discrete they seem to be in the portal areas. Elsewhere the portal areas are yellowish gray, the efferent vein regions red-and the intervening parenchyma reddish brown. The lobulation, except in the necrotic yellow zone, is distinct and regular; no gross cirrhosis. It presents a very startling picture. Adrenals, kidney and stomach appear normal. Histological findings: Heart: Negative. Lung: Negative except for one small cah-ifled mass, probably a thrombus. Spleen: Malpighian bodies large; sinuses wide and full of blood; few phagocytes with pigment. Kidney: Normal.^ Liver: Extensive necrosis involving all liver cells of lobule or leaving a narrow zone about the portal areas. Barely, the necrosis is more focal. Where liver LIVER LESIONS CAL'SED 11V CHLORINATED NAPHTHALENE 25 cells remain they often have compact, blue-staining areas in the cytoplasm. In this section, as in rabbit no. 533, there are wide spaces bordered by liver cells and at times containing large plugs of bile. It can be clearly seen that these spaces are distended bile canaliculi. Calcification is present in many of the areas of necrosis, stroma as well as liver cells. Large foreign body giant cells are found about the calcium. Some of the liver cells contain large droplets of fat, but total amount of fat is not great. Many liver cells contain bile. Cir rhosis negative; no proliferation of bile ducts. Iron stain: Heart: No pigment. Lung: No pigment. Spleen: Small amount of blue pigment. Liver: Pigment red. Kidney: Very small amount of fine,'red- staining pigment in epithelial cells of convoluted tubules. - For the purpose of determining the effects of smaller amounts of chlorinated naphthalenes we fed guinea pigs 5 mgm. per kilo of com pound B for from 2 to 5 months. The pigs showed no clinical symp toms before death. The autopsies presented very much the same type of lesions as in the rabbits which had been receiving the large close by injection. The liver surfaces were pebbled, and yellow areas beneath the capsule and deeper into the organ and areas of necrosis involving entire lobules were common. A group of rabbits was injected with 2 mgm. of compound B per kilo of body weight. After a period of time sores began to appear in the skin. Histological section of these sores showed them to be areas of multiple, small necroses. As they only occurred in the ehlornaphthalene animals we feel that this condition is due to the exposure. The rabbits were killed after 7 months and autopsied. The pic ture of the liver showed the same type of necroses and yellow areas. Our findings indicate that this small exposure does affect the liver of the rabbit although in these cases it will take a longer period of time to produce the lesions obtained by shorter exposure to the larger amount. Discussion From the facts presented one arrives at the conclusion that cer tain of the commercial, chlorinated naphthalenes are toxic if they are absorbed by the body. This conclusion is warranted by the follow ing facts: (1) there was 100 per cent fatality among the animals re ceiving injections of compounds B and C and sublimate C; (2) the livers of the animals receiving the injections showed the early stages of acute atrophy of the liver; (3) in spite of the rarity of this disease there occurred three human cases of yellow atrophy of the liver in - each of three widely separated plants, all using the same .type of ma-.. terial. .- ... *f WATER PCB-SD0000059046 Whether the toxic material is the chlorinated naphthalene itself, or some impurity contained in the commercial product, is the subject of further study. However, one may take into consideration the following facts. Several addition compounds of naphthalene are known. They are probably the intermediate product of naphthalene, such as penta- and hexachlornaphthalene. One would expect the chlorine addition products of naphthalene to be relatively unstable. As a matter of fact, the simplest one, naphthalene dichloride, slowly evolves HC1 at temperatures as low as 40 to 50 C., giving the rela tively stable monochlornaphthalene, a true chlorine substitution prod uct The higher chlorine addition products, and the compounds containing^ both the substituted and added chlorine which may be present as impurities, are more stable than naphthalene dichloride but, under certain conditions, they will give up IICl to form true chlorine substitution products. This is only a working hypothesis. However, the observation can be explained by assuming the presence of a trace of these relatively unstable addition products, which may be absorbed by the skin and there give off HC1 but which, upon suitable heating, would be partly or completely destroyed so that the vapors would be relatively less toxic. This may be the explanation in the case of compound B. In the case of compound C one must conclude either that the toxic im purities, if any are present, are not destroyed by simple heating or that this particular polychlornaphthalene is toxic per se. It is rec ognized that batches of chemically pure naphthalene will chlorinate in different ways at times. SUMMARY - 1. A 100 per cent fatality occurred when rabbits were injected subcutaneously with chlorinated naphthalenes B and C and the fumes of C. Guinea pigs fed by mouth gave the same result. 2. The liver lesions are those found in the early stages of yellow atrophy of. the liver. After a longer exposure, small doses will cause lesions similar to those produced by the larger doses. 3. The cases of yellow atrophy of the liver among the employees using these chlorinated naphthalenes are probably due to an exposure to some chlorinated naphthalene. . Bibliooraphy 1. Boyd, ML 1931. The Pathology of Internal Diseases. .. phia, 322, 323. Lea and 1'cbiger, Philadel- **sf*~j*. 1 11L VK LESIONS CAUSED BY CULOItlN ATKLJ NAPHTHALENE 27 2. Umber, F. 1922. Akute und subakute Leberatrophic. Klin. Wchnschr., 1, 1585. 3. Seyfarth, C. 1921. Zur pathologischen Anatomie der akuten gelben Leberatrophie. Deutsche mod. Wchnschr., 47, 1222. 4. WAUER. 1918. Gewerbliclie Erkrankungen durch gechlorte Kohlenwasserstoffo (Pernakrnnkhcit). Zentralblntt f. Gewerbehyg., 6, 100. 5. Koelsch, F. 1926. Gewerbliche Hautkrankheiten durch Teerabkommlinge (Teerfar- ben). In Oppenheim, M., Bille, J. H., und Ullman, K.: Die . Schadigungen der H&ut durch Beruf und gewerbliche Arbeit. Leopold Voss, Leipzig, 5, 327. ' 6. Teleky, L. 1927. Die Pernakrankheit (Chloraene). Klin. Wchnschr., <>, 897. Die Pcrnakrankheit (Chloraene). Ibid., 6, 845. 7. Lehmann, K. B. 1919. Kurzes Lelirbuch der Arbeits-und Gewerbehygiene. S. Hirzel, Leipzig, 251. . .. ... ' , _ WATER PCB-SD0000059047 Monsanto COMPANY -- 600 N. Lindbergh Boulevard St. Louis. Missouri 63166 (314) OXford 4-1000 ' -- _____------------------- ORGANIC CHEMICALS CM! _ . March 3, 1969 On February 24, the San Francisco Chronicle carried a major fe ature about "a menancing new pollutant" found in the San Francisco Bay area. The article was based on marine life re search carried out by Dr. Robert Risebrough of the University of California. It stated that residues of polychlorinated biphenyl (PCB) were killing certain marine birds and posed a long-term threat to humans. This story has caused considerable comment on the West Coast and its claims may be repeated elsewhere. As you know, Monsanto manufactures polychlorinated biphenyl and markets it unde r our Aroclor trade name. We, the refore, would like to present some additional facts. . The work done by Dr. Risebrough dates back to earlier re search by other scientists to analyze the amount of pesticides in wildlife, soil and water. The initial pesticide research was extremely difficult since any search to detect materials in the parts-perbillion range also brings out other "interferring" substances. . 1130 I WATER PCB-SD0000059048 Several years ago, two Swedish scientists at Stockholm University's Institution of Analytical Chemistry, Professor Gunnar Widmark and Soren Jensen, reported they had identified the other substances which were appearing during analysis of chlorinated pesticide resi dues. They said some of the materials were polychlorinated biphenyls or PCB. The amount reported was in the parts-per-billion range, or less. Since PCB's are not "broadcast" or spread around the land as are pesticides, the scientists theorized that the source must be the`` industrial wastes of PCB users. Dr. Risebrough's more recent work reports the identification of PCB, along with DDT and DDE pesticides, in the tissues of birds and fish on the West Coast. The conclusionsof these scientists are puzzling from several aspects. Polychlorinated biphenyls are stable chemical compounds which are essentially insoluble in water. Their use does not make them easily released into the natural environment. A principal market for PCB is in electrical applications where they are used as insulating fluids for transforme rs and capacitors. In this use, the chemical is completely sealed in metal containers. Another market is for heat transfer applications where the PCB fluid functions in a closed system. PCB's are also used in several "plastic type" applications. Here the chemical is incorporated into the polymer as an integral part of the solid mate rial. This applies whether the polymer is used as an adhesive, an elastome r or a surface coating. The Swedish and American scientists also imply that polychlorinated biphenyls are "highly toxic" chemicals. This is simply not true. The toxicity of any material, whether it be chemicals, drugs, natural plants or even foods, is relative. Compared to the thousands of industrial chemicals and home products, PCB's are not toxic unless they are mishandled or misused. During more than thirty years of U.S. production and use, cases of any toxic effect have been extremely rare -- and then only where the simple precautions recommended for use were not followed. 1131 WATER PCB-SD0000059049 -3- To our knowledge, polychlorinated biphenyls are not sprayed or dusted on crops, woodlands or any other areas, as are pesticides. It is, therefore, not only puzzling, but extremely difficult to con ceive how commercially produced PCB can show up in wildlife as DDT and other pesticides appear to be. This raises the question whether the substance identified in the Swedish work, and now in California, is actually PCB -- .or whether they are materials which,, due to the metabolism of other materials in the marine environment, appears to be PCB. Unfortunately, even though techniques for analyzing tissue samples have become quite precise, the ability to analyze the possible impact of naturally occurring substances in the food cycle of living organisms has not made comparable advances. Monsanto has a research program to confirm the identity of the compounds reported to be PCB by the Swedish and California scientists. We also cooperate, on a regular basis, with federal, state and university laboratories in their analysis of chlorinated hydrocarbon residues. Additionally, Monsanto will continue to exercise the highest degree of control in its manufacturing, shipping and storage of PCB --as we do with all products. In the functional fluids market, we have carried out a program for several years for the reclamation of used PCB's to avoid disposal of these valuable materials. The source of the marine life residue identified as PCB is not yet known. It will take extensive research, on a worldwide basis, to confirm or deny the initial scientific conclusions. We will keep you advised of our own research and are available to answer questions as they may arise. Very truly yours, /ecd Elmer P. Wheeler Manager Environmental Health 1 132 WATER PCB-SD0000059050 Monsanto Mo'fi-I anto Company 800 N. Llndbargh Boulevard St. Louis. Missouri 63166 Phone: (314) 684-1000 .6MAMK CHEMICALS OMSICH February 18, 1970 Dear Sir: Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (PCBs) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the parts per million and parts per billion categories. ' It is claimed that the PCBs found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. Products which are sold by Monsanto under the trade names of Arocloi 1254 and 1260 do contain chlorinated biphenyls. In addition to Arocloi 1254 and 1260, Monsanto sells certain functional fluids containing Aroclor. 1254. These include Pydraul 625, Pydraul AC, Pydraul AC - Winter Grade, Pydraul 540, Therminof FR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Arocloi 1254 and 1260 and formulated products containing 1254, we wish to alert you to the potential problem of environ mental contamination as referred to in the newspaper and magazine arti cles. We would like to point out the following additional facts: 1. Products such as Pydraul 90,135, 230, 312, A-200, F-9, 150, and 60, Turbinol 153 and Therminolw FR-1 and FR-2 are not formulated with Aroclor 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not been found in the environment and appe ar to pre sent no potential problem to the environment. (S3 1 139 WATER PCB-SD0000059051 We have developed, and are now testing, new formulations to replace the Aroclor1254 and 1260 components in our Pydrauf products. The new products appear to be equal in performance and to have similar physical properties. ' . We feel that all possible care should be taken in the application, processing and effluent disposal of these products to prevent them becoming environ mental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969, regarding water pollution standards set by each state ' in the Union. It is attached. This article reflects that good manufacturing practice in the future may require that no product used by any company ' should find their way into waterways. We realize that you have marketed or may now market transformers and other electrical equipment containing dielectric fluids which include Aroclor 1254 and 1260. Although the se fluids are sealed into such equip ment it is recognized that occasionally the fluid may be lost through leaks resulting from equipment misuse or equipment repair necessitating replace ment of the fluid. Since the dielectric fluid contained in this equipment is only an incidental part of the over-all unit manufactured by you, we are not notifying the purchasers of such equipment of the potential environmental contamination problem described in this letter. We do recommend, however, that you notify such equipment users of this problem. Sincerely yours, lb Attachment Donald A. Olson Director of Sales Functional Fluids Group 1 140 WATER PCB-SD0000059052 .-J criteria for a recommended standard occupational exposure to r^fcV' - 1i i < I* I S07/JT/ POLYCHLORINATED BIPHENYLS (PCBs U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE Public Health Service Matinnof tm Serter for D7s-3S$e Control ...,,r* l !l:aUU WATER PCB-SD0000059053 ( c SPECIALTY & PROCCSS CHEMICALS DMydH MONSANTO INDUSTRIAL CHEMICALS CO. BOO N. Llndbargh Boultvard St. Lcui*. Missouri 63168 Phone: OH) 684-1000 March 18, 1975 Mi*. Dan A. Albert Staff Supervisor . Personnel Relations Westinghouse Electric Corporation Highway 58 Vest South Boston, Virginia 24592 . Dear Mr. Alberti Attached are responses to the questions listed in your letter dated February 3* 1975. In addition to the industrial hygiene practices described In our responses to your questions, I cannot overemphasize the need to properly control the use and handling of Inerteens to prevent their escape into the environment. Also, in discussing this information with your employees, I strongly recommend that the perspective gained from over 4-0 years of experience in which no human harm has resulted, ` be emphasized. In summary, the proper handling of Inerteens should pose no environmental or human health problems, permitting society's continued use of a very valuable material. I hope the above information is useful to you. If I can be of further service please let me know. Sincerely, / V,.- WBPipd W. B. Papageorge Manager, Product Acceptability Specialty & Process Chemicals 1 unit ol Monsanto Company 1626 WATER_PCB-SD0000059054 1. Question: Does Inerteen have permanent effects on the human body? If so, what type of permanent damage and how long a period of.time does it take for this to develop? If not, explain why, if possible. The polychlorinated biphenyls in Inerteen can have permanent effects on the human body. The length of time or period of exposure necessary to develop symptoms depends on the degree or amount of exposure. In general, a single exposure for a few minutes to atmospheric concentrations that cause irritation to the eyes and/or respiratory tract would not be expected to cause either the skin eruptions or demonstrable liver injury. The problem arises from repeated and prolonged exposure to atmospheric concentrations In excess of the accepted Threshold Limit Levels or repeated and prolonged skin contact. The polychlorinated biphenyls have not been recognized as skin irritants" in the same sense that caustic materials or many organic chemicals are irritants. Because of their "solvent" action in removing the natural fats and oils from the skin leading to drying and chapping, repeated and prolonged skin contact should be avoided. When the polychlorinated biphenyls are mixed with other chlori nated hydrocarbons, the mixture may be classified as a skin irritant. The potential toxic effects in humans from excessive exposure to polychlorinated biphenyls include injury to the liver and chloracne. In animals, the liver effect is demonstrated by increased liver weights and injury to cellular tissue. Although chloracne is difficult to evaluate in animals, in humans, this takes the form of comedones (large blackheads with typical acne pustules) and may be an external sympton of over exposure pre ceding serious liver injury. ' Animal data and human experience indicate that the toxic effects are similar whether exposure results from ingestion, inhalation of vapors, or absorption of the liquid material through the un broken skin. (See AIHA Hygienic Guide Series - "ChlorodiphenyIs" attached.) 2. Question: Several hourly employees have mentioned recently that many chemicals such as Inerteen cause sterilization . after prolonged use. Is this true? There is no evidence that polychlorinated biphenyls cause sterilization" in humans. 1627 WATER PCB-SD0000059055 ( 3. Question: Since Inerteen affects birds and other animals, 1 if there is no real effect to human beings, how do ' you explain it to employees in such a way that they will understand why it can kill a bird and not a human? ' . . There is a potential real effect to humans - including death - as discussed in the answer to Question 1. Due to differences in metabolism of food (and food contami nants) in birds and humans (and particularly the difference in the reproduction process in birds and mammals - including humans), birds are particularly sensitive to many chlorinated hydrocarbons including polychlorinated biphenyls. . 4. Question: If an employee spills Inerteen on his clothing and later takes the clothing home to be washed with other clothes, will this have any effect on him or his family and should he carry his clothes home to be washed? . There should not be any effect on an employee or his family from home laundering of work clothing. If washed with other clothing, there may be residual odor of the chlorinated hydrocarbons in the clothing. . " / 5. Question: Employees carry Inerteen home on the soles of their " shoes and complain quite a bit about the effect Inerteen has on wearing out of their shoes. Is this a serious problem? Will Inerteen in the soles and leather of shoes, over a long period of time, have an effect on the feet and skin since the shoe is the. only protective equipment we wear on our feet and the Inerteen penetrates through the leather. .. There should not be polychlorinated biphenyl on the floor for workmen to contaminate their shoes to carry home. The plasti cizer or solvent action will destroy or shorten the life of the shoes. More importantly, the wearing of contaminated shoes could lead to absorption of the liquid through the soles ' of the feet as through any other unbroken skin surface. 6. . Question: There is one employee in our plant who had no pro blem whatsoever with Inerteen years ago. After six years of using, now when he works in Inerteen (which is a part of his job) he develops a swelling on the inner bicep of his left arm, only in one location. Could this be from Inerteen or not? It goes away as soon as he gets out of the Inerteen. It is similar to the swelling after taking an injection. :w 1628 WATER PCB-SD0000059056 ( We do not believe there can be any association between "a swelling on the inner bicep" of the arm and exposure to polychlorinated biphenyls. Question: Are there hand cleaning solvent materials that we should be using when working in Inerteen to coat our skin before working in it and to wash it off after we finish working in it? Please give your recommendation. Our employees working in Inerteen are not able to use gloves since it is an assembly area. Even if they could, the Inerteen would destroy the protective glove. ' We assume the question refers to the use of "Barrier Creams" rather than a "hand cleaning solvent". There are a number of barrier creams available to protect workers against water insoluble solvents. Probably the most effective include silicone ''to provide an impenetrable shield". A problem with such creams is that they may offer a false sense of security. Proper use includes a discipline which requires liberal appli cation at the beginning of a work shift and after each washing of the hands during the work day. 1629 WATER PCB-SD0000059057 WILLIIAM B. PAPAGEORGE TESTIMONY BAD AXE, MICHIGAN MAY 1984 WATER PCB-SD0000059058 ]. -ftsiMt; &/0 SYp? ^iC, MR. CUBITT: I have no further questions. THE COURT: Mr. Jungerheld? MR. JUNGERHELD: Nothing further with Dr. Willett. THE COURT: Mr. Davidson? MR. DAVIDSON: Nothing further, Your Honor. THE COURT: You may step down, sir. 8 Do you have Exhibit 421 and 422? These have been marked. 9 Go ahead. 10 MR. JUNGERHELD: Your Honor, we'd like to 11 call Mr. William.Papageorge, please. 12 THE COURT: Very well. 13 Raise your right'hand, sir. 14 WILLIAM B. PAPAGEORGE, 15 called at about 2:44 P.M. by the Defendant Monsanto, 16 sworn by the Bailiff, testified: 17 THE COURT: Take the stand, sir. 18 MR. JUNGERHELD: Your Honor, I don't anticipate using any more overhead transparencies, 20 would you like me to remove those sheets? 21 THE COURT: If you don't mind. 22 DIRECT EXAMINATION 23 BY 24 MR. JUNGERHELD: Would you give us your name, please, sir? Volume 36 -160- WATER PCB-SD0000059059 1 Q. And what's the date of those instructions'? 2 THE COURT: Are you offering that exhibit? 3 MR. WOODWORTH: Yes, Your Honor. 4 THE COURT: What's the number on that? 5 MR. WOODWORTH: The number is 153. I'd move 6 for its admission. 7 THE COURT: Any objection, Mr. Jungerheld? 8 MR. JUNGERHELD: None, Your Honor. 9 THE COURT: Mr. Davidson? 10 MR. DAVIDSON: None, Your Honor. Thank you. 11 THE COURT: One fifty-eight is admitted without 12 objection. 13 . ' MR. WOODWORTH: Thank you, Your Honor. 14 THE WITNESS: That date is July, 1964. BY MR. WOODWORTH: 16 Q. And that has a stamp on it confidential. Is that to keep 17 the information within the company? 18 A. 19 Q. Yes. And would you read, please, then, what we have - first of 20 all on the very first page we have a title. Operating 21 22 A. 23 Q. 24 25 A. Instructions as to Aroclor, is that right? That is right. Okay. And then subsequent to that we get into an area called Chlorine Gas, is that correct? True. But it's under a broader heading. Volume 37 Page 140 WATER PCB-SD0000059060 Okay. And go ahead and tell us what the broader heading... The heading is - this is the safety and housekeeping section of the operating instructions. Okay. And the first item referred to under that safety and housekeeping section is the Chlorine gas you refer to. And Mr. Papageorge, what was the chlorine gas used for? It was used to provide the chlorine that is present in the finished product. That's what you bubbled through the benzine biphenyl or the biphenyl after it was made from benzine? Correct. And so you had chlorine gas on hand on the premises for this process? Yes . And how was it stored. Was it liquid, under pressure, or how? Obviously it was gas, because it says chlorine gas. In 1964, the chlorine was generated at another unit as a gas and was transferred into the Aroclor unit and used directly. Chlorine gas itself is fairly toxic, is it not? Oh, yes. And what, in fact, does it state for the very first causes and action to prevent as to chlorine gas? What's the one I have marked there with a little red pen? Volume 37 Page 141 WATER PCB-SD0000059061 It reads: Chlorine gas is a very toxic, corrosive gas. Leaks are high pressure, can occur to liberate it. Okay. We're still on chlorine gas - does this next page refer to chlorine gas yet? No. The next page skips from number one item chlorine gas, to number five item, fires. Okay. It's another section of that safety and housekeeping portion. And the next page is back on chlorine gas? The next page appears to be a continuation of a reference to chlorine gas. So I don't know what preceded that. Mr. Papageorge, I'm going to ask you to read - and this is under safety and housekeeping as to chlorine gas and as to biphenyls, the next topic under it. And if you'd just read those three paragraphs, please. Well, the first paragraph is under chlorine gas, and it reads: "If you are caught without a gas mask and large amounts of chlorine gas are liberated, hold your breath and go cross wind until you're out of range of the gas. Once out of the area, obtain an emergency gas mask and return to the area and correct the problem." Second paragraph: Volume 37 Page 142 WATER PCB-SD0000059062 2 3 6 7 8 9 Q10 11 A. 12 Q. 13 A. 1* ' Q. 15 16 A. 17 ; 0. 18 19 A. 20 21 . l! 22 ; 23 24 ; ij ij 25 A victim of chlorine gas fumes must be removed as quickly as possible from the gaseous area. Place patient on his back with head and back elevated. Milk may be used in mild cases as a relief from throat irritation. If the patient has stopped breathing, start artificial respiration immediately." Third paragraph: And if I might interrupt for just a moment. The third paragraph now refers to biphenyls, is that correct? Biphenyl?. Biphenyls? Correct. And that's the product that was made by the uniting of the benzine? That is correct. And what's the safety and housekeeping recommendation or instruction regarding biphenyl? It reads : "Biphenyl is a flammable material which will burn. Burning should not be done in the presence of biphenyl or biphenyl vapors. The melting point is 68.7 degrees centigrade, flash point 106 centigrade, the fire point 124 centigrade. And the auto ignition temperature is 268 degrees centigrade. Inhalation 139 Volume 37 Page 143 WATER PCB-SD0000059063 I I T of biphenyl fumes is not recommended since it can cause a drug effect on the person." 3 0 Thank you. And the next - as we go down this list, we come 4 c to a subparagraph H referring to crude Aroclors. 5 A. Yes . I 6 Q. Then if you would just read the last sentence under crude Aroclors under paragraph 6H on page 6, please. I 8 A. The last sentence reads: 1 9' "Prior to air blowing, the material has HCL fumes 10 1 entrained in it, which are- irritating to the skin or mucous membranes." Thank you. Now we finished that one for 1964, July 1964, 1 is that correct? I H A. That's all I can see at the moment. J != C- And then we go on to another set, and this is WGK Operations 16 Manual I imagine that's for the Krummrich plant? 17 A. That is correct. 18 Q. And it's kind of hard to read, but if you could bend around, I just the first paragraph of what's there of the first 22 I 23 24 25 paragraph, please. Well, it's the - it seems like the last piece of a sentence which I can only read, comma, but "There is an explosion hazard if chlorine is mixed with a strong-reducing agent, such as hydrogen or hydrocarbons at high temperatures." 140 i Volume 37 Page 144 WATER PCB-SD0000059064 Okay. And the next paragraph there, perhaps that's the one I had marked. "Under other hazards, this material causes eye, skin, and mucous membrane irritation." Thank you. It doesn't say what that material is, though. Okay. What's this - is that monochlorobiphenyl? Yes . Okay. A.nd that's one of the biphenyls, is it not? It has one chlorine ring.? . That is correct. What's the other hazards under that? This material can cause dermatitis, systemic poisoning from the fumes, and yellow atrophy of the liver. There are skin, mucous membranes, and eye hazards encountered in handling this material. Can you tell us what is meant, or what you understand is meant by the term "yellow atrophy of the liver? I have an impression that it means the liver is damaged and has an abnormal appearance as a result. And the paragraph under storage and handling for the monochlorobiphenyl. Storage and handling: "Protect the skin, lungs and eyes by wearing approved, protective clothing, respirator and Volume 37 Page 145 WATER PCB-SD0000059065 I Iv I 1 I l T i r i i ! . t 1 goggles. Feople who handle this material at 2 elevated temperatures should have medical 3 supervision and the air should be sampled to insure compliance with MAC." 5 0. 6 A. 7 What's MAC? I don't recall at the moment. I just don't remember. "There are no special storage restrictions K 8 3 !G Q. 1! under normal conditions except store in a ventilated area." Thank you. Now we move to another set of operating instructions. And these are dated October,, L974 , is that 12 '.3 A. 14 Q- right? That is right. And department 246 still operator, still operator would be the person who runs the distiller for Aroclors? 16 A. Yes . 7 ft And department 246, where is that located? 13 A. This is at the WG Krummrichplant in Saugat, Illinois. ia 0 Okay. If you'd read just the introductory paragraph on 20 this under what's called Aroclors, please. 21 A. "Aroclors as manufactured in the Department 246 22 are non-flammable liquids which may vary greatly 23 in viscosity and room temperature. Contact with 24 skin should be avoided. In case of spills on the 25 body, wash the effected area with soap and water. Volume 37 Page 146 WATER PCB-SD0000059066 ( ! 2 3 6 Q. 7 S A. 9 10 Q. 11 . A. '2 Q. '.3 14 A. 15 16 17 18 19 20 21 22 23 Q. 24 25 : Inhalation of Aroclor and Montar fumes should be avoided as they are highly toxic. Protect the skin, lungs and eyes by wearing protective clothing respirator and goggles. If spilled on clothing, change to clean clothes." Thank you. Next is another set of instructions, as to 246, again out of the Krummrich plant, is that correct? It looks like 246 , and an additional marking of some kind that's hard to read. Okay. And this is dated March, 1974, correct? That is correct. And would you read that paragraph, the - what one operating instructions are for. "These operating instructions are the property of Monsanto Industrial Chemicals Company and the recipient is responsible for its safe keeping. It contains confidential information of Monsanto Industrial Chemicals Company, which must not be reproduced, revealed to unauthorized persons, or sent outside the company without proper authorization. Either retain in the operating department or return to the standard documents department." Thank you. This is again Krummrich plant operating instructions department 246, and its still operator, is that right? The next group? .43 Volume 37 Page 147 WATER_PCB-SD0000059067 I 1 A. I 2 0* I3 I 5 I 6 A. 7 Q1 8 1 9 A. 10 Q. ( i 11 A. I 12 0. L 3 ! 14 A. \ '5 i 16 Q. :i `1 1 '7 18 A. *1 l 19 Q. 5 ; 1 20 5 21 A. r1 22 0. i 23 j: 24 : i 25 i 144 i That is right. I was going to ask you to read this paragraph, but it looks like one that you've just read a short tine ago, is it not, as to Aroclors. In fact, the one you just read a short time ago? Yes. It does appear to be so. This is again for the Krummrich. plant operating instructions department 246? ' Yes . And the date of this is June 1976. Yes. And the next set is from Krumrnrich, operating instructions department 246, and what's this for? It's an abbreviation, PREM.OP. That's premium operator, that is the top worker assigned within that department. And the next is standard manufacturing process, Aroclors, Department 246, and that's dated 1972? There's a written notation on it. It says 1972. It also says before that, do not loan. Is that something that typically would have been written on it? I don't know that it's typical, but it's not surprising. On the last page of this, Mr. Papageorge, under paragraph G, there's Aroclor - a reference to that. And it says, in parenthesis, see hygenic guide, series on chlorodiphenvls, right? Volume 37 Page 148 WATER PCB-SD0000059068 < A. Yes. I 0- Looking earlier in this particular process, it will state something, for example, it says "chlorine, and it has a description and formula, and contents, toxic hazard 1 rating, toxicology information. I 6 A. Uh-huh. ' Q- And it has the same on hydrochloride off-gas? I S A. Yes . T 9 0. And it has the same thing previous on biphenyls. But when 10 we get to Aroclors, it says to refer to the hygienic guide 1 i > series. What's the hygienic guide series? 12 A. That was a publication that addressed the safety and I 12 industrial hygiene of, in this case, chlorodipnenyIs. r 14 ' Q. And would that then be incorporated into the manual, so i '5 to say? 15 A. Yes. A copy was attached and inserted in the manual. i ;7 Q. And who published that or where did it come from? 13 A. I don't recall the exact name of the group, but this was 19 a group of professional industrial hygienists that put ,i 20 this information together for many products. 21 Q. The next set looks almost like a duplicate of the previous 22 set. Again, we have a standard manufacturing process, i 23 |! Aroclors, department 246, and then in handwriting, do not ii 24 loan, 1972. 25 A. That's what it says. L45 Volume 37 Page 149 WATER_PCB-SD0000059069 Q. And when we get to the last page, again for the reference on Aroclor, it says see the hygienic guide series on chloridiphenyls? A. Yes. c Q. That would be the same one we just talked about? 6 A. That is correct. Q. Now we have another one, another publication or a set 3 of instructions, process description for the manufacturer o of Aroclors in Department 246, is that correct? 1C A. That is correct. i: Q. And I took that 66 there to mean 1966, would that be 12 reasonable? In fact, I'm sorry... A. It seems to be reasonable, yes. Q. It has a date written in, 1966 , does it not? A. Y'es. Yes. rj Q. And did you know these gentlemenhere, by the way, that 17 signed this, that approved it? ' Q A. Yes. Q. Mr. Harris and the other gentlemen? 20 A. Yes. Mr. Heisler, yes. Mr. Gibbs and Mr. Carder,, yes. 2i Q. And this has the same caveat, so to say, this process is 22 the property of Monsanto Company? 22 A. That is a standard statement that appeared on all of 24 Monsanto's instructions. 25 Q. Now this manufacturing process from 1966, if I can direct Volume 37 Page 150 WATER PCB-SD0000059070 I 1 I J I i t 1 1 1 I 47 i i J 1 A. 5 6 7 3 9 Q. 10 A. 1I 12 " 9 o. 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 Q. 21 il 22 A.- 0. 23 24 A. 25 ; o- your attention to Aroclor- on page 39. On page 40, going to Aroclor, and would you please read what the other hazards are in relation to Aroclors? It reads under other hazards: "This material can cause dermatitis, systemic poisoning from the fumes and yellow atrophy of the liver. There are skin, mucous membranes and eye hazards encountered in handling this material." And what is systemic poisoning? I have an understanding. I don't know if it's accurate. But this, is a reaction bv the body to a foreign material, and it's in the system - in the body's system. It's a poison to the body, in other words. That's one way to look at it, yes. And this looks like a repeat of the previous one? Yes . Back here, Mr. Papageorge, I put a question mark on that because it says old SMP Aroclors? It does say that, yes. What would SMP mean? Standard manufacturing process. Okay. We have a - there's a first sentence, I think, to that other paragraph that you couldn't read before. I see. Would you read that, please? Just that first paragraph? Volume 37 Page 151 WATER PCB-SD0000059071 1 A. It says: "Diphenyl and Aroclor are toxic materials. To prevent toxicity... 4 End of statement. 5 Q. Okay. And then go to the next page. 6 A. 7 "Clean change of clothes is furnished daily to each employee and time is alloted at the 3 end of each shift for bathing. In addition, one 9 should wash his hands and face before eating." 10 But I don't know if the two are necessarily related. 11 Q. I^ Okay. Would the reason for recommending to the employees to wash their hands and face before eating is so they :J 1 4 A. wouldn't ingest this material? Yes. That a - this is a fairly common statement for a 16 Q. i 7 A. i Q. chemical manufacturer. To protect the health and safety of your workers? That is right. Would you read this paragraph, please, under the hazards 19 V , A. and means to safeguard material? "There are many accidents that can occur that 2 1 may be classed as safety and health hazards. These 22 accidents may result from such things as broken 23 process lines, gas leaks, acid leaks, steam burns, 24 etcetera. The following safety equipment is provided to each employee: One pair of rubber overall, goggles, Volume 37 Page 152 WATER PCB-SD0000059072 one pair spectacles, one pair rubber shoes, one pair rubber-covered gloves, one pair of canvas gloves, and one fume respirator. And for the department use, one gas mask, one clean change of clothes, four safety showers, and one stretcher." Okay. Thank you. And this, again, appears to be a duplicate of the prior one, OMP Aroclors? It looks the same, yes. And we have that same sentence beainning? Right. And would you read just from the very last page, then, the hazards paragraph? Just the first paragraph of the hazards ? "The fumes from Aroclor 1254 are quite obnoxious and are, when inhaled excessively, dangerous and hazardous. When handling this material in relatively closed areas, ample ventilation (hoods in extreme cases) should be provided for removal of the fumes from the working area. If fumes attack the mucous membrane of the nasal passages and irritation of the membranes and slight lung congestion may result from excessive inhalation of the fumes . " Thank you. THE COURT: In light of the hour, members of the Volume 37 Page 153 WATER PCB-SD0000059073 1 WrtV^ J April 8, 1970 Dr. Herbert Blumenthal Chief, Petitions Review Branch Bureau of Foods, Pesticides and Product Safety U. S. Food and Drug Administration 200 C Street, Southwest _ Washington, D. C. 20204 * Dear Herb: I thought you would be interested in knowing that Monsanto is committed to a program which will allow the future use of our Arodors only in those applications where escape to the environ ment can be prevented. Secondly, we have essentially a crash program under way to find non-persistent, non-chlorinated substitute products. Already, we have two large users switching to substitutes of this type. Obviously, Kerb, you can recognir.e the competitive aspects of developing and phasing into sales such type of substitutes so, at present, we are not making any widespread announcement. On the other hand, if the publicity gets as red hot as it did in the case of DDT, we may be forced to make such an announce ment at any time. Cordially, BEK/In R. Emmet Kelly, M. D. .Medical Director A 3462 V. WATER PCB-SD0000059074