Document YD1rRV08RQ0NbJKMJ2DRL8an0

l.:oi32r.io IbOW iKiMI h W>c*. ICKI W. R. Richard - Research Center 0*11 eur>;i 't *1 1 1 W| *C 1 TO : March 6, 1969 '\ $rR0l}DR WILDLIFE ACCUSATIONS ( ^^-------- V ^^ // E. Wheeler - EVfHEE Ecrtfcn J.,^fiprlngato jr * Schalk /D, Olson R. Kelly J. Garrett P. Hodges P. Park R. Keller E. Tucker IIIiLIC JSPPiI WSCHA DOLSO RKELI. JGARR PHODG PPARK JFQ JFQ Risebrough in a recent paper "Nature", Vol. 220, Dec. I1}, 196R, has attacJced chlorinated biphenyls in three ways: (1) a pollutant - widely spread by air-water; therefore an un controllable pollutant. (2) a toxic substance - with no permissible allowable levels causing extinction of peregrine falcon by induced hepatic' enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. (3) a toxic substance endangering man himself; implying that theperegrine falcon is a leading indicator of things to come. As outlined in Science,Vol. l63, Pg. Environmental Defense Fund (EDP) is attempting to write new legal precedents in conservation law by hearings and court action. In the Wisconsin case, water quality standards are at issue. "A substance shall be regarded as a pollutant if its use results in public health problems or in acute or chromic (injury) to animal, plant or aquatic life". V.'isconsin is one of T states which now have federally approved water quality standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Water.Quality Standards Branch, DDT would fit the definition of a pollutant upon a showing that it is harmful to aquatic life. ' These people in KDF are saying we must not put strecr, on any living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim "enzyme inducer" activity is the real threat of DDT and PCB's and are using these arguments to prove that very small .amounts of chlorinated hydrocarbons are "harmful". - Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations. (a) Monsanto is preparing itself to identify trace ppb quantities of chlorinated biphenyls in water samples, in concentrated collected air samples, and in animal tissues,. We will know whether we have been falsely identified and accused or net. We will eventually know where any pollution is taking place and the extent of the pollution. a >1 ** EXHIBIT^O^----- H'lZ-47 N. KUNCAITIS MAE 053006 TOWOLDMONOQ51097 E. Wheeler -2 - March 6, 1569 (b) We are not prepared to defend ourselves against the accusa- ' tions made of enzyme and hormone activity, the Isolation of enzymes or metabolic products, the indirect accusation of cancer, or the splitting of genes, when this accusation is i made, V/hother we can defend this route or not needs further I discussion.------- -- " ~--------- ----------- - (c) Through the Industrial Bio-Test program wo are to establish the long term allowable limits of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. V/e may be able to answer reproductive ability in come animals, DDT has been under attack for some years because of its chlorine content, its persistent ability to be identified, and the v;i3dlife problems attributed to it. We will still be under the same attack by the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where doos this leave us? Under identification and control of exposure - we will be able to identify and analyze residues as well or better than anyone in the world. V/e will probably find residues other than DDT and PCB's. We will probably wind up sharing the blame in the ppm to ppb con centration level. ' " We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, wc can continue to set up disposal and reclaim operations. We can work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users. But, we can't easily control hydraulic fluid losses in small plants. It will be still more difficult to control other end uses such as cutting oils, adhesives, plastics and NCR paper. In these appli cations exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl is shewn to have some long terra enzyme or hormone activity in the ppm range, the aoolications-with consumer exposure would cause difficulty. Risebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which have exposure problems. Since Risebrough's paper in "Nature", Dec. 1968 has Just been published, it is timely, perhaps imperative, that this paper and its Implications be discussed with certain customers. This Is a rough one because it could mean Iocs of business on empty and false claims by Risebrough. Well prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical and legal departments must take place now. The MAE 053007 TOWOLDMONOQ51098 E. Wheeler 2- - March 6, 1969 position of DDT manufacturers should be determined as a guide. VJe are being accused of the same things attributed to DOT. I have written this memo to clarify some of the issues. May I please have comments. Thanks, ms Att, W, R. Richard 4 MAE 053008 TOWOLDMONOQ51099