Document YGEL9ayyxbxZGEojE8vDZEggy

i*M6--location--phonei S* G C o l l i n s " A 3 N D - 4-3860 date SUBJECT REFERENCE May 27, 1982 G. D. Ingenthron - A3NB T O : R. T. Berendt - E2ND J. R. Condray - G3WG Attached are updated versions of our Agent Orange Position Statements. Comments? :cm Attachments Sarah Gainer Collins 6Ud IV * I OCW Q ' T T \ Wr -- SUBJECT TO PROTECTIVE ORDER. C24772 AGENT ORANGE ... MONSANTO COMPANY POSITION We genuinely sympathize with the plight of our Vietnam Veterans. But we believe that the substantial amount of scientific and medical evidence available today suggests that there is no link between Agent Orange and human health problems of the magnitude claimed by the veterans. Monsanto was one of the companies asked to produce this herbicide mixture for the U.S. Government during the Vietnam War. Now, much to our regret, we find that we are both an object of the veterans' frustrations and a target of a class action suit filed by thousands of veterans against the producers. U H r U i k tAQ-Jfc 11 Cm < w - i iwipwii* iIn V i l l a .. Ml I ni I 11111'111 . m i <i h i h w 'M * ef ApMttu-fllT ili li H 1tMgwiilj fCAgent Orange, useddyy((inai VviietnamI^betwoen 1063 and 137(T, was supplied at the government's request, formulated to government specifications, applied by military personnel under the orders of the government, and used in war situations ... utterly b e y o n d the control of the manufacturers. J 0 - * ' k "** The c o n t r o v e r s y (s u r r o u n d i n g -A oire Qranpo<yRftg--<in t i i i m - to-- gxHB despite the lack of virtually any scientific evidence that this herbicide posed a danger to the veterans. To the c o n t r a r y ^ thaja is a ai amount of s c i e n t i fic/medical . . ind<c'evidence on the record^attached,)/trnat say there is no linx----- between Agent Orange and human health problems of the magnitude claimed by the veterans. Obviously, this con f l i c t is not of our making. However, having been drawn into it, we have no alternative but to defend ourselves. We are confident that good science will ultimately prevai l over thf e motions of the moment and exonerate the p r o d u c e r s of Agent Orange. At the same time, we sincerely hope that good science will also p r o v i d e m a n y of the answers .the veterans n o w seek regarding possible service-related health problems. -oOo- KS / une, 1982 For additional information, contact: Sarah Gainer Collins Environmental Communications Monsanto Company 800 N. Lindb e r g h Blvd. St. Louis, MO 63167 CONFIDENTIAL314-694-3860 SUBJECT TO PROTECTIVE ORDER. ry C24773 AGENT ORANGE -- MONSANTO COMPANY BACKGROUND Monsanto began producing the components of Agent Orange -- 2,4,5-T and 2,4-D-in the late 1940s. We continued the manufacture of these herbicides 'until 1970 when we decided to get out of the business for economic reasons. During the Vietnam War, Monsanto was one of the companies asked by the U.S. government to produce a special formulation of these herbicides for use in Vietnam. Consequently, today, we are a target of a class action suit filed by thousands of veterans against the producers. The suit seeks $40 billion "1 o' trust fund to compensate Vietnam veterans for cancer, miscarriages, and birth defects allegedly caused by the use of Agent Orange. We genuinely sympathize with the plight of our Vietnam :* Veterans. The unpopular war they fought has left inevitable scars and Agent Orange has become an outlet for accumulated frustrations. Also, in the past few years, a great deal of information has been gathered from health studies on human populations exposed to dioxin...a trace contaminant found in 2,4,5-T. One such study offers us a good insight into long-term or chronic h e a l t h effects of dioxin exposure. In 1949, there was an accident at one of M o n s a n t o 's plants during whi c h 121 employees w ere exposed to relatively high concentrations of dioxin. A standardized mortality analysis^s^ a study of the cause of wh of i dcEihennavv3tii3rhroxonwn^memwreeaennsTttaehalxrlaper HHocsee<eeanttaidltiltdlthvhyi/n*iaac^roltiifncldtr9AnnnuQeedciutnneQuuddnntyiei'yv3v7^e^enrrtrsrshi>j-MSititsyiyPnecunoiskla employees nduLitioliuiiurla. iuirfmndutiiutlmhu1ei1ajjnJliyojLouu&annndLa-dit u te -- f Ullt excess in dealh tl'UUT-- cancer 0Ir L U i d l U Vascular d i s e a s e / s-t ftttc tioa m alum- frem the total U.S. population. Mon s a n t o is confident that good science will u l t i m a t e l y prevail over the emotions of the moment and exonerate the producers of Agent Orange. At the same time, we sincerely hope that good science will provide answers to Vietnam veterans regarding their health problems. -oOo- June 1982 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C2477 ! o, AGENT ORANGE -- MONSANTO COMPANY BACKGROUND Monsanto began producing the components of Agent Orange-- 2,4,5-T and 2,4-D-- in the late 1940's. We continued the manufacture of these herbicides until 1970 when we decided to get out of the business for economic reasons. During the Vietnam War, Monsanto was one of the companies asked by the U.S. government to produce a special formulation of these herbicides for use in Vietnam. Consequently, today, we are a target of a class action suit filed by thousands of veterans against the pro ducers. Th? gyiir "-- J +n vrtflT?T r,M Vqt ,, a * n f 1 L. 1 ' 11 We genuinely sympathize with the plight of our Vietnam Veterans. The unpopular war they fought has left inevitable scars and Agent Orange has become an outlet for accumulated frustrations. Also, in the past few years, a great deal of information has been gathered from health studies on human populations exposed to dioxin-- a trace contaminant found in 2,4,5-T. One such study offers us a good insight into long-term or chronic health effects of dioxin exposure. In 1949, there was an accident at one of Monsanto's plants during which " 121 employees were exposed to relatively high concentrations of dioxin. *J standardized mortality analysis-- a study of the cause of death-- was recently conducted by Monsanto and the Institute of Environmental Health at the University of Cincinnati on those employees who were exposed in 1949. The study found no apparent excess in death from cancer or cardiovascular disease among the study group as compared to the total U.S. population. Monsanto is confident that good science will ultimately prevail over the emotions of the moment and exonerate the producers of Agent Orange. At the same time, we sincerely hope that good science will provide answers to Vietnam veterans regarding their -health problems. 0O0 June 1982 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. 24775 M MONSANTO RESEARCH CORPORATION From location Monsanto Research Corporation/Dayton Laboratory oatc :22 February 1983 CT Analytical Capabilities in the Analysis of TCDD Iny/r^Offiee Correspondence Y, A w U> ~ r ~~ A ji /n \ ARIO CFCRCNCC T O sJ. R. Condry G3WdH;B 2 4 198? Attorney Work Product Attorney-Client Privilege This memo is a chronology of Monsanto's ability to analyze for tetrachlorodibenzo-p-dioxin (TCDD) in 2,4,5-T and TCP. The emphasis has been to evaluate whether the procedures used to analyze our products described in the documents provided to me by Townley and Updike were both adequate for the levels of TCDD present and comparable to state of the art techniques. To facilatate this chronology all references will give the tab number, the legal document page numbers and date in the documents provided to me by Townley and Updike. Notebook Tab Page 1 055386 3 055394 3 055397 3 055401 1 055409 \ 1 055301 4 055307 Date 4-2-65 4-10r65 4-14-65 4-21-65 5-7-65 7-26-65 8-4-65 Comment The analysis of 2,4,5-T acid was initially carried out by the Agricultural Chemicals Research Department on GC-flame ioni zation detector (FID) (see tab 12, page 055377) in accordance with the method specified by Dow. 1.1 ppm of TCDD is detected using this method which is close to the 1 ppm detection limit specified in the Dow Method* Using an additional concentration step a value of 0.4 ppm is reported which shows an ability to analyze TCDD below 1 ppm which could be interperted as exceeding "state of the art." A result is listed as "trace ( >>> 1 ppm)" again demonstrating the ability to detect TCDD at or below 1 ppm. A common problem occurs here in that maintaining "state of the art" is difficult and the analyst moves from the specified flame ionization detector (FID) to the less sensitive thermal conductivity (TO) detector. Some compensation for lost sensitivity is achieved by injecting larger sample volumes. Analyses in the 16 to 40 ppm range previously obtained using the FID are readily carried out using the TC. Based on the peak height for a sample at 11 ppm, a reasonable estimate of the detection limit for TCDD at this point in time is 2 to 4 ppm using the conditions listed. By injecting an even larger sample volume into the chromatogram a value of 4.2 ppm is reported. Therefore the detection limit for the GC-TC combination is below 4 ppm. IC-10 SUBJECT TO PROTECTIVE ORDER. C25U2i Monsnato Research Corporation/Dayton Laboratory fT? February 1983 Analytical Capabilities in the Analysis to TCDD J. R. Condry G3WG >age 2 Attorney Work Product Attorney-Client Privilege Notebook Tab Page Date Comment____ 4 055331 8-31-65 A value described as "trace" was stated to be equivalant to 2 ppm.. This would constitute a reasonable estimate of the detection limit which is a factor of two higher than the "state of the art". Note that a 2 ppm chromatographic peak for TCDD would only be 4 mm in height which is quite small. 6 24196 7-18-66 The method for the analysis of 2,4,5-T for TCDD is sent to Nitro where it is set up again using a GC-TC combination comparable to that used since 5-7-65 by the Agricultural Chemicals Research Department. 6 24197 7-21-66 The newly established method at Nitro analyzed a series of 2,4,5-T samples for TCDD. Values range from 3.5 ppm to 28 ppm. This suggests that the detection limit was below 3.5 ppm which corresponds to the 2 ppm detection limit estimated from the results of 8-31-65. 6 001487 7-22-66 A memo from F. L. Rupel states that typical TCDD values in 2,4,5-T range from 5 to 18 ppm and that a problem occurs when values are above this range. As an analytical chemist with a method able to detect TCDD approximately one order of magnitude lower than the value considered to be a problem, I would have considered the method adequate while not necessarily being "state of the art". 6 24217 2-17-67 The analysis report lists a TCDD value as 1 ppm and other values as "trace" and "nil". This implies an ability to detect less than 1 ppm which could be interpreted as "state of the art". No obvious reason is given for the improved sensitivity. 6 001430 10-17-66 The analyses of TCDD from February to October have ranged from 1-26 ppm indicating the method was adequate in its ability to analyze for TCDD since there were no "none detected" values reported. However, the memo issued on this day indicates TCDD as "less than 5 ppm" which could indicate some degree of ra'ising of the detection limit. This problem is quickly corrected and by 11-17-67 (Tab 6, page 001437) results of 3 ppm axe again being reported. 2 85303 9-24-68 The analysts back at the Agricultural Cheniical Research Department state the TCDD method was updated to allow assays of TCDD at 1 ppm or less. By 11-27-68 this goal was achieved in reporting TCDD values of <.l ppm (Tab 7, page 57707) using a GC-FID combination. This would be state of the art analysis for TCDD at this time. J CONFIDENT! 4L SUBJECT TO PROTECTIVE ORDER. C2 4 (Monsanto Research Corporation/Dayton Laboratory 5 February 1983 Analytical Capabilities in the Analysis to TCDD J. R. Condry G3WG Page 3 , .Attorney Work Product Attorney-Client Privilege Notebook Tab Page Date Comment 6 001629 12-9-68 The TCDD analyses being conducted at Nitro are listed in this report as "trace" levels. By inference from the results given on 7-25--68 (Tab 6, page 001443) this trace level is less than 3 ppm. The levels of TCDD in 2,4,5-T have been lowered to an extent that the method is now just adequate. 6 23464 3-6-70 At this time the analyses at Nitro are apparently moved to a GC with an FID detector and results are now being reported to 0.3 ppm. This action may have been in response to Dow's specification of 0.1 ppm TCDD content in 2,4,5-T acid on February 12, 1970 and the fact that the levels of TCDD in 2,4,5-T have been low since 2-22-68 (Tab 6, page 001440). 12 50180 1970 A Monsanto method is described using election capture (DC) detection in combination with a gas chromatograph for the analysis of TCDD in chloropenols. The use of GC-EC for the TCDD analysis was first mentioned by Higginbottom in 1964 (J.A.O.A.C. vol. 47, pages 772-776, 1964). The Monsanto GC-EC method could quantitate "chlorodioxins" at a few tenths of a ppm to a few ppm depending on the particular chlorinated dibenzo-p-dioxin was being examined. Note that the Agricultural Chemicals Research Department was analyzing for TCDD at 0.1 since 11-27-68 (Talx 7, page 57707). 10 058370 12-7-70 Analyses performed at Agricultural Chemicals Research Departmen on unknown instrumentation give TCDD results to 0.072 ppm but the matrix being analyzed is not clear. Concentrated sulfuric acid washes are being used in sample preparation indicating an awareness of the FDA's chick edema work (Tab 12, page 057305). 11 058377 12-16-70 Mention is made of a USDA method for TCDD without giving any details. Also a detection limit of 0.3 ppm is given for the analysis of what appears to be an eluant from 2,4,5-T which had been cleaned up by treatment with carbon. In general the TCDD analysis capability within Monsanto during its production of 2,4,5-T at various times approached and may have exceeded state of the art but was adequate at >all times. There were very few instances in which a series of analyses went with no TCDD being detected. Results of no TCDD being detected might delude one into thinking that the products were clean when the real problem was analytical sensitivity. For most of the Monsanto products the TCDD level was most often a factor of two to a factor ten greater than the estimated detection limit. Thus the analyses for TCDD (particularly those going on at Nitro) were adequate while not necessarily being state of the art. I hope this review and comments have been of use to you. If I can answer any of your questions please contact me. CONFIDENTS W4 Fred Hileman SUBJECT TO PROTECTIVE O R D E R / * ' G2502o