Document dY16102oR74aEmyRQQDdbG0Qe

Ccoi co) RECEIVED f;r;r >; i isa;.: Interoffice Communication ROUTE TO: To: J. J. Hall COPIES TO: From: R. A. Klein FILE: Date: October 20, 1982 Subject: (1) LONZA USE OF BIODEGRATION WORK BY PONCA CITY (2) USE OF CONOCO'S FDA CERTIFICATION ON ALFOL 8 AND ALFOL 10 Attached is a memo from Victor Rincon to Mike Fortier on subject No. 1 above. My feeling is that we ought not to make biodegradability repre sentations to Lonza which Lonza intends to pass on to their customers. Could you please issue a policy statement concerning any potential liability we might incur by allowing Lonza to make biodegradability representations using Ponca City laboratory results. Secondly, could you contact Harris Halpert to review his discussions with Helena Chemical and R. J. Industries concerning the possible use by Helena of our FDA registration on ALFOL 8 and ALFOL 10 alcohols in a tobacco sucker control agent which Helena intends to manufacture and sell. R. A. Klein RAK:dkh cc: MJF, CFP, HH, DLM, NCF Attachment s VEV-245o5i conocoj Interoffice Communication To From M.J. Fortier V.A. Rincon V 1 c Date October 12, 1982 RECEIVED OCT 18 1982 CHEM. MKTG. Subject LONZA USE OF BIODEGRADATION WORK DONE BY PONCA CITY Late in 1981, Lonza submitted nine samples of various Lonza products for a biodegradability study to be done by our labs in Ponca City. This project has been completed and the results have been discussed with Lonza technical personnel. Lonza is very pleased by the results obtained in R.L. Huddleston's shop and now they would like to get guidelines from Conoco to deter mine to what extent they can use these results. In summary, the results indicate that eight items are highly biodegra dable and the last one is not. We need to tell Lonza how much they can lean bn the report when they convey the biodegradability message to Lonza customers. Lonza could use these approaches in ascending order of Conoco involvement: 1. Lonza salesmen can review biodegradability issue verbally. 2. Lonza can write a hand-out sheet paraphrasing the results. 3. Lonza can write a hand-out sheet quoting verbatim from the report. 4. 'Lonza can incorporate results in official product data sheets. 5. Lonza can use approaches 1 through 4 stating that Conoco did the work. I recommend that Lonza be allowed to use results as indicated in statements 1 through 4. Conoco then remains uninvolved until some one questions the results and Lonza may have to spell out details of the study. ATTENTION: Distribution Please comment so I can make appropriate response to Lonza. V.A. Rincon/cb ' cc: RAK, CFP, DRP, WJBV, PTH, OCK, RLH, AMN