Document e0XoLx7v0dbo7Kgjrqp9OZvM

u (T~ -- <; fYC d1 February 23, 1973 Mr. Wilbur H. Speioher Administrator, Industrial Hygiene Meetinghouse Ileotrle Corpomtion 700 Braddock Avenue East Pittsburgh, Pennsylvania Dear Wilburt , Jack Qarrett and I have dlsousaed his conversation with you ~ sometime ago concerning the toxicity of chlorinated naphtha lenes. I thought I would confirm his coeawnts to you-by this letter. Monsanto has not had any experience in the manufacture or use of chlorinated naphthalenes. Our evaluation of their toxicity characteristics then is based on numerous reviews of the lit erature and from Involvement from time to time In Incidents where the chlorinated biphenyls were suspected of causing Industrial or environmental problema, and where subsequently, the chlorinated naphthalenes were found to be the culprits. I have enclosed Xerox copies of the discussion In Patty's textbook on the chlorinated naphthalenes. I believe this la a good review of the literature and an objective evaluation of hazards associated with those compounds. Obviously, this discussion relates principally to the Industrial hygiene as pects of the hazards and toxicity. X have also enolosed a copy of the united States Department of Agriculture Nemo distributed In 1953* discussing sn Incident where the chlorinated naphthalenes were proven to be a distinct environmental problem which I have been told coat the manu facturer of the product containing the chlorinated naphthalenes several millions of dollars. I am sure you are aware that the chlorinated hydrocarbons or askerel type fluids are under continuing surveillance and study by a number of U. S. agencies. Including the Food and Drug Administration, the Council of Environmental Quality, the Office of Science and Technology of the President, the National Bureau 0S\N 282851 STLCOPCB4064180 Wilbur H. Speicher 2 February 23, 1973 of Standards and several sub-agencies of the Environmental Protection Agency. It is no secret that a number of indivi duals within these agencies have proposed a complete ban on the use of PCBs, including the use in transformers and capa citors. Continued use of these applications is currently allowed under restrictions based primarily on action by Monsanto to prove that the current quality PCBs manufactured in the United States could be used, with appropriate precautions, without serious industrial hazards and with complete protection of the environment. I can think of no other action at this time which would intensify the efforts of a number of government agencies to effect a complete ban on the manufacture and use of askarel fluids than to change their composition by introducing other chlorinated hydrocarbons with questionable concurrent increase in hazards in the working environment or to our eco-system.- You are probably aware that the most important data which has lead the government agencies to permit the continued but restricted use of polychlorinated biphenyls are the extensive animal toxicity studies which we have completed in the last two years. These included two-year feeding studies in rats and dogs; a three-generation rat reproduction study; possible effects on poultry relating to egg production, hatchabillty and egg shell thickness; teratology and mutagenatic studies. Along with these feeding studies have been tissue residue analysis and a major effort on developing biodegradation data. As a matter of interest, the cost of these studies to Monsanto has been something more than a half million dollars. I am certain that government agencies ( and many of the public environmental protection groups ) would rightfully question a change in the askarel fluids which would introduce the chlori nated naphthalenes. I can hot find published data indicating the possible chronic effects of chlorinated naphthalenes - if it contaminates food or feed products or its possible effect if accidentally released to the environment* As a matter of fact, the published literature on the potential industrial hazards from inhalation is not as complete or current as It should be by today's standards. I know that for many years, you and your associates have established a system within your company of recommending necessary precautions In handling any materials purchased by you. The Medical Department of Monsanto has a similar program. In addition, we are in the position of essentially "banning" the production or use of any chemical where we' think the hazards or risks make that step desirable or necessary. With the data presently at hand, we would not permit the manufacture or use of chlorinated naphthalenes intentionally nor as a significant component or by-product of any product within our company. DSW 282852 STLCOPCB4064181 VI1bur Speloher -3- February 23, 1973 1 don't believe I've talked to you since the last meeting of the AIHA, so aay I take this opportunity to congratulate you on being elected to honorary aeatberSlp. Best personal regards. Sincerely, EFV/alb Enclosure SlsMtr p. Wieeler Manager, Environmental Health be: P. B. Benlgnua - B2SC T. L. Oossage - B2SL C. Paton - B2SC DSW 282853 STLCOPCB4064182