Document qkKYkrR3pBNKpMp0MjMdkgDDj

I :: lawuo Rem J i*i!" w. R, Richard - Research Center Mil MRAn NIlMMi TO : March 6, 1969 H. Bergen ,7. Springate AROCLOH WHJ3LIFE ACCUSATIOHS W. Schalk D. Olson R. Kelly J. Garrett E. Wheeler - EWHEE ,, . P. Hodges v- P. Park R. Keller E. Tucker HBERO JSPRX WSCHA DOLSO RKELL JGARR PHODO PPARK JFQ JFQ Hisebrough In a recent paper "Nature", Vol. 820, Dec. 14, 1968, ha attacked chlorinated biphenyls in three weyB: (1) a pollutant - widely Bpread by air-water; therefore an un control! able pollutant. (2) n toxic substance - with no permisolble allowable level causing extinction of peregrine falcon by induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. (?) a toxic substance endangering man himself; implying that the peregrine falcon is a leading Indicator of things to come. As outlined in gc-ience,Vcl. 163, Pg. 548, Environmental Defense Fund (EDF) is attempting to write new legal precedents in conservation law by hearings and court action. In the Wisconsin case, water quality standards are at issue. "A substance shall be regarded as a pollutant if its use results in public health problems or in acute or chromic (injury) to animal, plant or aquatic life". Wisconsin Is one of 7 states which now have federally approved water quality standards. According to Bern Wright-, acting chief of the Federal Water Pollution Control Administration's Water Quality Standards Branch, PDF would fit the definition of a pollutant upon a showing that it is harmful to aquatic life. ' These people in F.PF are saying we must not put stress on any living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim "enzyme inducer" activity is the real threat of DET and PCB's and are using theBe arguments to prove that very small amounts of chlorinated hydrocarbons are "harmful". Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations. Monsanto is preparing itself to identify trace ppb quantities of color.'a ted biphenyls in water samples, in concentrated collected air samples, and m animal tissues. We will know whether we have been falsely identified and accused or not. We will eventually know where any pollution is taking place and the extent of the pollution. MOWS 097231 DEFENDANT'S EXHIBIT MONSFQX00097200 WATER PCB-SD0000054925 E, Wheeler -2- March 6, 1969 (b) We arc not prepared to defend ourselves against the accusa- tlons made of enzyme and hormone activity, the isolation of enzymes or metabolic products, the Indirect accusation of cancer, or the splitting of genes, when this accusation is made. Whether we can defend this route or not needs further discussion. - (c) Through the Industrial Bio-Test program we are to establish the long term allowable limits of chlorinated blphenylB for certain blrdo-flsh-animals by feeding experiments, pathologi cal examination, and tissue analycis for chlorinated biphenyls. We may be able tD answer reproductive ability in some animals, DOT has been under attack for some years because of its chlorine content, itB persistent ability to be identified, and the wildlife problems attributed to it. We will still be .under the Bame attack by the mechanisms listed in (b) even though wc might establish safe operating limits for humans and certain animals, . Where does thlB leave us? Under identification and control of exposure - we will be able to Identify and analyze residues as well or batter than anyone In the __ world. We will probably find residues other than DDT and PCB's. ' We will probably wind up sharing the blame in the ppm to ppb con-, eentratlon level. We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can contlnua to set .up disposal and reclaim operations. We can work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize losses for large hydraulic users. But, we can't easily control hydraulic fluid losneB In small plants. It will be still more difficult to control other end uses such as cutting oils,-adhesives, plastics and NCR-paper. In these appli cations exposure to consumers Is 'greater and the disposal problem } becomeb complex.If chlorinated biphenyl Is shown to have some - long term enzyme or hormone activity in the ppm range, the appll- cations with consumer exposure would cause difficulty. Rlsebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted i or we will eventually have to withdraw product from end uses which , have exposure problems. Since Rlsebrough's paper in "Nature", Dee. 1968 has Just been published, it Is timely, perhaps Imperative, 1 that tills paper and its Implications be discussed with certain . customers. This Is a rough one because It could mean Iocs of | business on empty and falBe claims by Rlsebrough. - - * Well prepared discussions with lad, Bio-Test, Monsanto biochemists, the medical and legal deportments must take place now. The , HONS 097231 MONSFOX00097201 WATER PCB-SD0000054926 E. Wheeler -3- Mareh 6, 1969 position of DDT manufacturers should be determined as a guide. We are being accused of the same things attributed to DDT. I have written this memo to clarify some of the issues. May I please have comments, . Thanks, W. R. Richard ms Att. MOHS 097234 MONSFOX00097202 WATER PCB-SD0000054927