Document ZBjen3y7dQZw8dOjOaam9rzyO
DISCONTINUATION OP THERMINOli FR SALES
* Would go to Vice Presidents only plus Specialty Products Group/ Regional Managers
1. ft, *Why has Monsanto decided to discontinue Thermlnol FR heat transfer fluid sales?
A. We have previously written to all Thermlnol FR heat transfer fluid customers alerting them to the precautions necessary In I handling and using these PCB-contalnlng products. Earlier this year we stopped selling Thermlnol FR fluids for new heat trans fer fluid systems. We also discontinued sales of make-up Thermlnol FR fluid to food-related applications and worked with these customers in converting FR fluid to non-PCB heat transfer liquids (e.g., Thermlnol 55 and Thermlnol 66). We have now de cided to discontinue all Thermlnol FR heat transfer fluid sales In the U.S.A. and Canada because there are serious problems associated with the possibility of accidental leakage of PCB from heat transfer systems.
2. ft.* Who within Monsanto decided to discontinue Thermlnol FR heat transfer fluid sales?
A, This decision was made by Monsanto's corporate management and affirmed by Its Board of Directors at their monthly meeting in December, 1971.
3. ft.* Does this action mean Monsanto Is getting out of the heat transfer business?
A. No. The sales ban applies only to the FR series of fluids (Thermlnol FR-Lo Temp, Thermlnol FR-0 and Thermlnol FR-1). The FR series is the only one that contains PCBs. All other Thermlnol heat trans-
MONS 095904
-2-
fer fluids (Thermlnol 55* 66, 77 and 88) are PCB-free.
4. Q.* Are you banning sales of all Thermlnol fluids? A. No. Not all Thermlnol fluids contain PCBs. Thermlnol FR series (l.e., FR-Lo Temp, FR-0 and FR-l) are the only ones containing PCBs. All other Thermlnol fluids (l.e., Thermlnol 55, 66, 77 and 88) are PCB-free.
5. Q, What replacements are available from Monsanto for Thermlnol FR fluids?
A. The most likely Monsanto replacements are Thermlnol 55 or 66. We must advise you that none of Monsanto'3 remaining Thermlnol heat transfer fluids are fire resistant. We suggest you work closely with your Insurance company In converting from Thermlnol FR fluids so that you make a carefully considered Informed de cision, As stated In our letter of December 15, 1971, Monsanto has a team of engineers available to be of assistance to you In making your decision. They may be contacted by telephone at
. (314) 694-2514 or by writing Dr. Cummlng Paton, Monsanto Company, P.0. Box 14617, St. Louis, Missouri 63178.
6. Q,* What other fire resistant heat transfer fluids are available from Monsanto?
A. Unfortunately we have none available and will not have one availa ble in the foreseeable future.
7. Q.* What other fire-resistant heat transfer fluids are available in the U.S.A. or Canada?
MGNS 095905
-3-
A. The only fire resistant heat transfer media we know of are high pressure water and molten salts. Both of these systems have dis advantages which may rule them out as replacements for many existing Thermlnol FR systems,
8. Q. *Could I obtain PCB fluids outside the U.S.A. or Canada? A. PCBs are manufactured in France, West Germany, Italy and Japan. The decision on imports 13 yours to make. We would suggest, however, you consider such a course of action very carefully.
9, Q. V/ill Monsanto'3 ban on PCBs for sale in heat transfer systems apply world-wide?
A. Yes, as soon as the decision can be Implemented.
... Q. Will a world-wide ban on Thermlnol FR sales go into effect immediately?
A. As promptly as it can be Implemented.
11. Q. Have any of your competitors in PCB manufacture announced a similar
ban?
.
A. Not to our knowledge. However, we believe they are considering
restrictions on PCB sales. Bayer has already made an announcement
to this effect. Furthermore, certain European countries (e.g.,
Sweden) have taken action limiting the imports of PCBs. Other
countries could well follow suit,
12. Q. *Why has Monsanto acted so precipitately on Thermlnol FR sales? A. We do not consider our action precipitous.
MONS 095906
-4-
-J. . Why is Monsanto giving overseas customers longer to convert than its U.S.A. and Canadian customers?
A. Implementing a decision of this kind on an international basis takes time.
14. Q. This latest policy on Therminol FR sales is not consistent with Monsanto's previous differentiation between "open" and "ciised" PCB systems. Why is Monsanto changing its policy.
A. We are concerned about accidental leakage over which we have no control. Our policy has not changed.
15. Q. By banning Therminol FR 3ales, 13 Monsanto admitting that PCBs are the toxic, dangerous chemicals that many scientists, ecologists ami writers haveNbeen suggesting for over two years?
A. The extent to which PCBs are toxic and dangerous is a relative and comolex matter. We believe this action and our previous actions concerning PCBs have been reasonable and rational. We believe we have acted a3 reasonably as any manufacturer could on learning an increasing amount of previously unknown information about one of its products.
16. Q. The FDA recently stated (FDA Pres3 Conference September 29, 1971) that the alarm over PCBs is greater than the facts justify. FDA also rejected an outright ban on PCBs as some critics have called for. The FDA does not believe PCB3are an Imminent hazard. In view of these FDA statements why has Monsanto acted so precipitately in apparent contradiction of FDA?
MGNS 095907
-5-
A. We respect the opinion of PDA and are aware of it. The FDA, however, is not a corporation engaged in the manufacture and sale of products, and its opinion on this subject does not govern our decision. Again, we do not feel we have acted precipitously.
17* Q.# We do not dispute Monsanto's reason for its decision on Therminol FR fluids; our strong criticism of Monsanto con cerns the lack of warning by Monsanto that they were going to ban Therminol FR sale3. Why were we given no warning.
A. Our previous communications should have alerted you to the possibility of this decision on our part. We believe warnings were given. We communicated our decision that no new heat transfer systems would be sold Therminol FR, Sale of Therminol FR to food-related applications v/as discontinued. In addition, we have encouraged remaining customers to consider converting to a non-Thermlnol FR fluid either before or at the time for the next "make-up".
18. Q.* We believe it is impossible to convert all Therminol FR systems in the U.S.A. and Canada on the day your decision was received. That means heat transfer systems are still operating on FR fluid; why can't we have another drum or two to last until such time as we can 3hut down our plant for conversion?
HONS 095908
-6-
A. Monsanto believes that lee-way in the matter of filling Therminol FR orders after Its decision was communicated could lead to stock piling, which we believe Is unwise under the present circumstances. One of the key reasons for establishing a team of engineers at Monsanto la to give advice and assistance to aid customers in arriving at informed decisions on how to handle such situations. Assistance may be obtained by calling (314) 694-2514 at Monsanto's St. Louis headquarters.
19. Q. From recent PCB production figures given out by Monsanto, there are other applications besides heat transfer for PCBs. What action has Monsanto taken on PCBs In these other applications?
A. Simply enumerate the actions.
20. Q. We see that dielectric applications are by far the biggest user of PCBs. Shouldn't they be the ones to be shut down?
A. Based on the information available to us at this time we believe the risk of accidental escape from this use is slight. Our opinion on this may change. .
.
21. Q, I buy PCB for both dielectric and heat transfer use3. Why can I get one but not the other?
A. Because, in our opinion, the risk of accidental leakage and possi ble resulting contamination is less in one use than in the other.
MOWS 095909
-722. Q,* How long will the engineering team be available to help on con
versions? A. We would hope most customers will have converted to non-PR
fluids In the first four months of 1972. However, the engineer ing team supplements the ongoing team or Monsanto heat transfer fluid specialists. Monsanto's heat transfer fluid specialists are always available for reasonable periods to assist customers.
23. Q. Is there any possibility Monsanto's replacement heat transfer fluids may be discontinued as abruptly as Thermlnol PR?
A. We do not consider our decision abrupt. We have no present plans for discontinuing sales of replacement fluids, but our customers should anticipate that we will react responsibly to new Information about our products a3 i*e have with PCBs.
24. Q.* What evidence do you have that Thermlnol 55 and 66 will not give
/ ''
similar problems to the ones that have arisen with Thermlnol FR? A. We will send you bulletins on Thermlnol 55 or 66 which contain
relevant data on this subject. 25. Q, What is the attitude of FDA and USDA on Thermlnol 55 and 66 as
replacements for Thermlnol PR? A.
MOWS 095910
-826. Q.* your letter of December 15. 1971 states that refunds on returned
Thermlnol FR fluids will not be given after March 1, 1972, Does this mean I must convert to another fluid by then? A. The decision on when and to what to convert Is your3. The re fund policy applies only to unopened drums of Thermlnol PR you may be carrying as inventory In your warehouse. 27. Q, X Just filled my ThermlnolFR system in early 1971. The fluid is in excellent condition and could probably be reclaimed by Plndett to be as good as new. Will you allow me credit lr I return the drained fluid by March 1, 1972? A. No. 28. Q. Are you banning Thermino^FR fluids because Monsanto admits liability in the HollyFarms lawsuit? A, We admit no liability .in the Holly Farms lawsuit. We point out that Holly Farms sued the user of PCB heat transfer fluid as well as Monsanto. 29. Q. I have read of the Holly Farms lawsuit against Monsanto. Have you other lawsuits pending on PCBs. If any, what are they about? A. Questions concerning lawsuits should be directed to our Law Dept.
MOMS 095911
-9-
3jl. Q. What should I tell my employees If they ask why we are switching from Therminol FR to a more hazardous fluid as far as fire safety is concerned?
A. The decision is yours. Perhaps you might indicate that the material is no longer available.
32. Q. Does Monsanto consider PCB to be a toxic and dangerous substance to human3 and wildlife?
A. The question is not susceptible of a simple yes or no answer. We can refer you to scientific information from which you may draw your own conclusions.
33. <5, Monsanto has made great play in its press statements on the safety aspects of PCBs with respect to their use in dielectrics. In heat transfer, we chose Therminol FR solely on the grounds of safety where we could protect the lives of our employees, neighboring citizens and valuable property. Why does Monsanto discriminate on safety? Why use safety as an excuse for continued PCB sales in one area and not in another?
A. Because, in our opinion, the risk of accidental leakage and possible resulting contamination 13 less in one use than in the other.
34. Q. Was any pressure put on Monsanto by government agencies, environ mental groups or other quasi-official groups to ban Therminol sales?
A. The decision was the independent internal decision of the top management of this company.
MONS 095912