Document bawmz7E47EdXNxwDeZLDZZ5p3

R. C. Isham - BIRD - 2621 February 21, 1979 Toxicological Significance J. R. Foehr - B2SA J. S. Metcalf - B2NK T O C. F. Callis - B2SA As we've discussed, analysis of our products for TCDD is giving us a white knuckle atmosphere around here. I'm beginning to wonder if we aren't our own worst enemies on our testing proce dures. Your people can measure TCDD in amounts even smaller than .010 ppm. "Somebody" has determined that .010 ppm is the level of "toxicological significance," and we duly reported our OCR reserve sample had TCDD at an average amount .037 pom to the EPA. My question is, who is the "somebody" that said .010 ppm has "toxicological significance"! Why isn'u the level of signifi cance 0.1 ppm? Is there any indication that lower concentra tions arc hazards? I'm not a chemist, but neither are most reporters. Jim Mieure helped me figure out that our trace TCDD contamination in the Sturgeon car works out to 1/8 ounce in 207,000 pounds of material. I don't know if that's hazardous or not, but I do know we reported our findings and we're greeted with both regional and political concern. Could we have said, "We examined the reserve sample and found no TCDD at the level of toxicological significance which is 0.1 ppm"? I also note that Federal pesticide regulations set an upper limit of 0.1 ppm of 2,3,7,8 TCDD in 2,4,5-T pesticide. If that parameter is okay for Uncle, why are we asking our people to search for smaller concentrations in our products? R C I :j t R. C. Isham COO 45 0