Document jdNeN2OjQq0wDre0KxXovyop
Monsanto
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o t. of Medicine & Environmental Healthko\*--^1
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October 3, 1979 "S " G. E. Paget
Muff Dioxins in Chlorophenols
TO G. Roush
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1. Pentachlorophenal containing 3,000 to 10,000 ppm total dioxin primarily,-, octachloro dibenzo dioxin could cause chlsroacne in exposed workers and produced .a positive response in the chick edema factor study.
2. TCDD has not been found in Pentachlorophenol by either Monsanto or Dow.
3'. 2,3,7,8 TCDD and mixed hexachloro dibenzo dioxins at dietary concentrations of O.Sppb and 2.5ppb produced a positive chick edema response.
4. Orthochlorophenol, Parachlorophenol 2, 4-dichlorophenol pentachlorophenol feed stock and chlorophenol still residues at dietary concentrations of 1500 ppm were negative in the chick edema factor study in 1974. Some evidence of toxicity was observed with the still residue.
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5. Based upon these negative responses and the 2,3,7,8 TCDD re sponse, it was concluded that the tested chlorophenol materials contained less than 0.3ppm 2,3,7,8 TCDD activity.
. 6. The present total TCDD analysis in chlorophenol. from Dayton *.
( O.Sppra TCDD) are consistent with these negative responses ..
and with the reported lack of chloracne in the chlorophenol
workers. -
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7. The Nebraska report of 2.6ppm 2,3,7,8 TCDD in chlorophenol -' is not consistent with the biological assay or with- the Dayton results.
8. It has been recommended to MICC that chick edema studies be "conducted with the chlorophenol materials in question. These studies could detect 0.1 to 0.3ppm 2,3,7,8 TCDD activity, (attached)
9. If the Nebraska data are correct, then (1) the exposure to the chlorophenols must be much lower than those previously to penta chlorophenol (2) the previously bioassay results on chloro phenols must have been flawed, or the composition of that 1974 material was different, (3) the Dayton data must be grossly in error, and (4) previous MICC analysis (Jim Mieure) must have been in error.
Confidential-Subject t Protective Order
f ' C01094
Paul Xi. Wright
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p* X- Sample Extraction (Jar Method) O CAUTION: When using this method to analyze for 2,3,7,8-TCDD, all of the
following operations should be performed in a limited access laboratory with the analyst wearing full protective covering for all exposed skin surfaces- See Section IV for details on specific safety requirements.
In addition to the EPA Method 613 concerns, the analyst should note that finely divided dry s o ils contaminated with TCDD are particularly hazardous because of the potential for inhalation and ingestion of fine particulates containing TCDD. It is recommended that such samples be processed in a confined environment, such as a hood or glove box- Lab personnel handling these types of samples should also wear masks fitte d with charcoal adsorbent media to prevent inhalation of dust. Recommended field sampling safety procedures are given in Appendix C.
ST. LOUIS AREA DIOXIN SAMPLING SAFETY FRXEHMJR&ESst &0>
A. Personnel Safety
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1. Protective Equipment - All personnel on site will wear neoprene steel toed toots, coated lyvek or Saran disposable coveralls, and Buna-N or Nitrile gloves. In addition, anyone actually involved in taking a sarple will wear a full-face mask respirator with combination organic vapor and dust cartridges.
2. Decontamination - A decontamination area will be set up next to the sample packing station and all entry to and exit from the site will be through, this area. In the decontamination area will be a soap and water wash and water rinse for the boots and gloves. Also, a 55-gallon d n m will be placed in the area for disposal of overalls and gloves. In addition, an industrial first-aid kit will be located in the decontamination area.
3. Ccr-rrunication Equipment - Ctrmmication equipment on site will be a base station at the ccrrand post, one vehicle with a mobile radio and 5 walkie-talkies. Each sampling team will have a walkie-talkie for cormunication with the team leader.
B. Site Safety
1. Access - The extent of access for members of the news media has been
decided at this time. tor safety reasons, nonessential individuals shall
be kept away from the site durinj sampling. No participating personnel will be permitted inside the site without the permission of the CSC nor are they to wander off site without permission.
2. Physical Examinations - EPA, EfcE and TAT personnel who have not received a complete physical examination within the past year will not be
allowed inside the site during unpling.
3. Personal Hygiene - No one shall be permitted to eat, drink or wroke
within the site, and shall thoroughly wash hands and face with soap and
water before doing so outside the site. Individuals must wash hands with
soap and water before urinating. All footwear, once worn inside the site,
must remain on site until ccnpletioo of the field work. At the end of each day, disposable clothing shall be removed and disposed of in 55-
gallon setal dmas. Individuals are expected to thoroughly shower, as
soon as possible, after leaving the job site at the end of the day.
4. Personnel Exposure - In the event clothing is ripped or torn, work is to stop and the clothing Is to be removed and replaced as soon as possible. In the event of direct skin contact, the affected area is to be washed immediately with soap and water. Ihere will be a person stationed in the
decontamination area to assist in helping people on and off with the protective gear.
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5. Hospital One perron stationed outside the security area shall know the quickest route to medical facilities.
6. Decontamination - The 20 by 20 foot area located next to cornvand post
is provided as a decoot amination area. Individuals within the site shall remove all disposable clothing, at this point before exiting the area. # because of possible dust on disposable clothing, the decontamination nan shall wear protective clothing, gloves, and face mask while assisting - people in removal of exposed articles. All disposable items shall be placed in 5S-gallon metal drums with lids located within the fences. Items which cannot be disposed of will be given a preliminary decontamination wash, placed in plastic bags, and returned to the Reg!oral Laboratory for further decontamination, and be withheld from further use pending the anaytical results.
In an effort to reduce the volume of contaminated trash and rinse water, team members are to make a conscious effort to minimize the amount of eguiprient and supplies brought inside the site.
7. Disposal of Kash and Rinse Solution - All wash and rinse water will be disposed of at tire end of each working day on the working site. Rinse
solvents will be allowed to evaporate. Lids are to be put on all drvns
in the event of rain and at the close of each workday.
8. Site Security - Absolute security will be impossible because there are houses and residences on the sites. Djring actual daily cperatirr.*, sites will be posted with banner cord and team leaders will make an active ef fort to minimize general population exposures.