Document nmbBOyyrNr8Gv4XMK85Y7B0N6

6/2/76 Mrs. Hillis L. Howie Dear Mrs. Howie: Mr. Hanley has asked me to respond to your thoughtful letter of May 22 since X am the General Manager of the Specialty Chemicals Division of Monsanto and therefore dinactly responsible fot> the manufacture and sale of flftl.s. ltmsanto feels very keenly<'Hbout the toxicological and environmental impact of the products we manufacture and I would like to give you two' examples of that concerning the very product under consideration here. Prior to 1970 Monsanto manufactured and distributed PCB's for a wide variety of uses in the United States including carbonless carbon paper, jj \*no hydraulic fluids, plasticizers, etc.^ When the first scientific investigations confirmed the continuing presence of PCB's in the environment i-t-fce~Hn4ted fitnru-waL jn.7ClZjx, and long before information regarding the potential impact tirhi "t-O'wVtuateatsten was determined, Monsanto unilaterally and voluntarily began its program of terminating sales of PCB's to all applications other than those of the/|Capa^ti&I_find~i&af*rmer industry where we believed losses to the environment were minimal. The reason we continued marketing to even these industries was the fact that the PCB fluids we manufactured had characteristics, including high fire resistants, that could not be duplicated by other products and that these fluids were used in so-called closed or sealed systems. The import of that latter remark being that they would not escape into the environment. I might add parenthetically that even today as we are phasing out of the manufacture of PCB's for even electrical industry uses there is no replacement 0207766 PCB-ARCH0743867 fluid possessing comparable fire resistant characteristics. A Becond step which we took again when we understood the nature of the problem was to literally build a "concrete bath tub" around our PCB manufacturing facility in order to restrict losses to the absolute minimum. Today cu effluent-amounts-to-no-morc than ._ans_to..two partg^^ier.triHlrm i>GBLs ^i'y^^)^ tfre-Mlaklsailppl River.at average flo_rate.s. cird There are many other factors connected with the history of TcCiBTtme:an..u.facture and our handling of it and I am teldng -tinr-llbei'Ly of 'attaching a statement which we have prepared to outline the problem which we have faced. Thi eeepeialioo is currently in the process of phasing out of all manufacture and'distribution of PCB's. We have gone on public record as stating that we not only want to but are going to discontinue such a business as quickly as the electrical industry can convert to environmentally safe and acceptable alternate dielectric fluids. We have made available to our customers, all of whom we believe to be competent, technically sound and responsible companies, the information we have on the protection of manufacturing facilities and even offer our own incineration facilities at our plant outside of St. Louis to help them dispose of waste should they not have an internal facility. We do not, however, nor do we feel we can "police" the specific handling of our end product by each customer. Your mention of the Toxic Substances legislation is another timely issue. The Manufacturing Chemists' Association, s comprised of the major chemical companies and of which Monsanto is a pxdaaipai member, has been instrumental 030776? PCB-ARCH0743868 3 In working with key members of Congress to develop a practical, but yet effective, version of Toxic Substances legislation and we believe a suitable Bill will shortly be sent to the full Congress for their consideration. We believe this type of Joint government-industry emphasis on khX controlling potential pollutants will help over the long term to prevent the most distressing type -of problem which your community is currently facing. J hapa-ay-tetter-ls 020776 PCB-ARCH0743869