Document gZJz6ek9V1RQ500p4D7pagaJ

February 3, 1971 Griffith E. Quinby, M. D. Consulting Toxicologist Preventive Medicine Post Office Box 1313 Wenatchee, Washington 988OI Dear Dr. Qulnby1 Thank you for your letter of January 20, which arrived on the 27th, at which time I was out of town and just returned. I appreciate very much your interest in the polychlor inated biphenyls and am happy to reply serially to the questions raised in your letter concerning the "Monsanto Statement on PCS" printed in Environment, Vol. 12, No. 1. May I preface my answers with the comment that we take no responsibility for Dr. Rlsebrough's statements in the publication and I am assuming that your questions relate to the Monsanto statement published therewith. Now, as to your questions! 1. The Monsanto statesient supplied Environment Magaslne was prepared with my collaboration and approval. My interest in the toxicity of and occupational hasards Involved with the polychlorinated bi phenyls and terphenyls dates back to 1936. I recall vividly the first meeting held at Harvard under the sponsorship of Dr. Cecil Drinker to discuss the early results of reeearoh carried on under his direction on the chlorinated biphenyls DSW 019585 STLCOPCB4007518 Orlfftth 5. Quinby, M. D February 3* 1971 Pag* Two and chlorinated napthalanes ^fef. J. Ind. Hyg. Toxicol. 19, 300 (1937,27. You may be sura that tha Madical Department at Monsanto has bean aware of all subsequent publications relating to tha toxicity of chlorinated biphenyls and terphanyla. The literature indicates that there was a number of incidents of industrial effects in the late 1930's from the use of a waxy material composed of chlorinated napthalenes, chlorinated biphenyls and chlorinated diphenyl ether. I submit, however, that there have been few instances reported since 1940 concerning ill effects in workers exposed to the chlorinated biphenyls or chlorinated ter* phenyls when used alone. In the rare cases that have been reported, the recommended procedures for safe handling and usage have been ignored. 2. Monsanto has been aware that in the early and mld1950'a there was some use of PCB's as extenders for pesticides where the formulations were applied to field crops or, in the case of research sponsored in New York State not participated in by Monsanto, on forests for attesipted control of elm tires disease. These experiments were based on research efforts of the USDA. As far as our records lndl* cate these were abortive attempts in using the PCB's in "broadcast applications" on perhaps all kinds of crops. The facts as we know them are that uses never did develop where the PCB's were incorporated in formulations for "broadcast appll* cations" to agricultural crops such as vegetables, animal feed, ootton, citrus, eto. I don't have exaot figures but I would estimate that something less than 100,000 pounds of PCB's were ever used in experimental or semi-commercial applications. To me and to our oompany this does not represent "broadcast application" as the term la generally used now and as it relates to the application of most common agricultural Insecticides. \ 3. Most of the possible uses of PCB's reoommended as possibilities in our Technical Bulletin O/PL-306 remained as possibilities. It la true that PCB's were used in specialty (industrial, corrosive resistant) paints; in specialty rubber for sealants (not automobile tires as has been alleged); in specialty adhesives for many purposes. They were not widely used in lubricants or cutting oils. I don't know what is meant by "carburetor fluids". DSW 019586 STLCOPCB4007519 OrIff1th B. wulnby, M. 0, February 3, 1971 Page Three As to whether or not such usss could lead to th PCB's getting Into the environment, I wonder if In late 1969 when we supplied the statement to "Envir onment" you would have predicted the current situation as regards mercury. 4.we have not had any oases of occupational illness In our workers manufacturing PCB's, with the one exception mentioned (page 307* J. Ind. Hyg. Toxicol, referred to above). As I have Indicated earlier, there were Incidences of occupational illness in the late 1930's and per haps early 1940'a. Z believe the facts are as indi cated above that these were from uses where the polychlorinated biphenyls were used in conjunction with other chlorinated hydrocarbons. I would also point out that the number of instances may have been exaggerated since at that time one state health or labor department after another published bulletin after bulletin referring to the original cases. In this way there may have been some magnification of the seriousness of the situation. I repeat again for emphasis that we know the cases that occurred did not Involve the use of polyehlorlnated biphenyls alone. In the mid-1950's we sponsored work at Kettering Laboratory (see reprint enclosed) which I believe Is the most definitive in terms of potential occu pational hasards that has been done* Since the question of possibility of the PCB's getting Into the environment oastt to our attention we have under taken a number of research and other projects. These have been suoh that Z can honestly say that I am proud of the way Monsanto has responded to the situation. We have, for example, undertaken chronic animal feeding studies suoh as would be required if we were to oonslder applying for a food additive petition with the FDA. As data have been forthcoming on an interim basis from these studies, we have provided copies of the data to represen tatives of the Offloe of Science and Technology of the President, to the Food and Drug Administration, the U. S. Department of Agriculture, the Fish and Wildlife Service, the Federal Water Quality Agency and other toxloologlsta DSW 019587 STLCOPCB4007520 Oriffith B. Quinby, M. D February 3# 1971 Page Four in tha United States and abroad. A status rsport on these studies has bsen accepted for presentation at the 1971 meeting of the Society of Toxicology. Briefly, I believe that all of the toxicologists who have reviewed the data concur that PCB'a are no more and proba bly less toxic than DDT. This has been most reassuring to us In terms of whether or not any PCS In the envir onment Is a threat to the publio health. Squally important, we have ceased all sales of the poly chlorinated biphenyls in those applications where escape to the environment cannot be prevented. Use in electrical transformers, on the other hand, will continue but with provisions that the fluid in the transformers will be returned to Monsanto for incineration If It cannot be reclaimed for reuse. In short, we no longer sell poly chlorinated biphenyls for uses which cannot be controlled. I would hope that you would agree that Monsanto has reacted in a most responsible fashion. I would hasten to add, however, that any action on the part of my com pany has been based on the development of sound data developed by ourselves and responsible scientists. It has not been reaction to political pressure nor the more activist scientists and pseudo-scientists who, I know you appreciate as much as I, have become so prominent in today's emphasis on restoration and enhancement of the environment. Please understand I agree completely that there has been and continues to be deterioration of our environment. I am convinced, however, that steps for improvement must be taken on a rational and objective basis. In conclusion I feel Monsanto has taken a realistic attitude towards the PCB'a based on faots as they have developed. At no time have we made efforts to ooneeal the truths about PCB's. Should you have any faots in your possession that Indicate otherwise, I would be happy to receive them. Very truly yours. DSW 019588 RKKtJu R. Kmmet Kelly, M. D. Medical Director Enclosure (Tox. of Vapors of Aroclors 1242, 1254; HOS on Chloro- b.c. w. B. Papageorge diphenyls) STLCOPCB4007521