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DATE SUBJECT TO D. R. Bishop - F3EE - 4-2891 October 27, 1983 cc J. F. Hussey - F3EA G. D. Ingenthron - F3EB J. T. Nolan - DIA M. C. Throdahl - DID R. T. Berendt - E2ND OCT 2 8 ^ 3 T. M. Bistline - E2ND W. D. Carpenter - G3WG W. G. HcCarville - G3WG G. Roush - G2WG As you may know, we have been offered the opportunity to provide a general article on dioxin for the Post-j)ispatch Special Supplement, now scheduled for Nov. 13R The only restraint is length -- we've been allotted up to 54 column inches which, by our calculations, equates to 8 pages double-spaced. Attached, for your prompt review and approval, is a draft done by Gerry Ingenthron from a longer first cut I gave him last week. The P-D deadline for this article is next Tuesday, Nov. 1. We need your cooperation in clearing this for publication. Please send or phone your comments/approval direct to Ingenthron as I may be out of the ofice Monday and/or Tuesday. One final point: if there are no objections from the legal department, we'd like to put Dr. McCarville's name on the article as the author. We need a name, and since Bill is a Ph.D. scientist and the chairman of our corporate dioxin task force, he seems to be appropriate. If anyone has any thoughts or problems with this, let Gerry know that, as well. Thanks D R B :ec Attachment IN 10 REV. 8 '7 7 > SUBJECT 1KJ PROTECTIVE ORDER. C2308y Draft: 10/27/83 Special to the St. Louis Post-Dispatch MONSANTO SAYS DIOXIN SCARE IS OVERREACTION by William J. McCarville, Ph.D. Director, Environmental Affairs Monsanto Company Since late in 1982, after public hearings focused attention on dioxin contamination in Missouri, there has been a continuing barrage of news stories about the chemical and i t s ^ '- dangers. ! Early in that period, stories labeled dioxin "one of the deadliest substances known" and reported that animal tests also showed it causes a variety of health problems. Those early stories said the same effects on humans were suspected, though "test results are inconclusive." In recent months, reports have been more scientifically thorough, qualified authorities on the subject have been relied upon more often, and known facts about dioxin have been more thoroughly reflected. But the fear generated in early public hearings, in the reactions of frightened citizens of contaminated areas, and reflected and reinforced in news reports, remains today. In light of extensive studies of the human experience with the toxic chemical, that level of fear and the reaction to dioxin is simply unwarranted. What is called for is now taking place: a careful scientific and medical assessment of the known hazards and risks of dioxin, a realistic program of protection against dangerous levels and disposal of dioxin-containing wastej; and a continuation of health studies to further broaden our knowledge about the chemical CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C2309O -2 - Dioxin is, indeed, a useless, unwanted toxic chemical. It exists only because it can be produced unintentionally as a contaminant during the manufacture of certain industrial chemicals and pesticides and as a by-product of certain non-industrial combustion processes. (While there are some 75 different dioxin T..V.S- compounds possible,ATCDD is the moxt toxic and is generally the chemical referred to in stories about ''dioxin." ) Contrary to some news reports, however, the scientific ^-"community knowsi^guite a lot about both short-term and long-term /> uman health effects of tllio(xtn^iexposure p h a s e d on documented evidence^. ' rffitn b d iM M ' Between 1949 and 1976 more than 800 industrial workers were exposed to dioxin in nine separate industrial accidents in (VMM* i various locations. Also, in a 1976 accident, thousands of people in Seveso, Italy, were exposed after an explosion when a ^chemical cloud containing dioxin^spread across that city. All of these incidents have been carefully studied by medical authorities. The health status of those exposed is being carefully monitored. Those exposed workers who have died in intervening years also have been identified -- their various causes of death determined and compared to expected death rate statistics from similar populations. ' Dioxin was also a contaminant in Agent Orange, the herbicide sprayed in Vietnam, and a careful analysis also is ^ ~UrO being conducted on a-- 1arge groupTHT formc rU .S . Air Force CXCjQi h> \J `-t jO iL -A jJ u fc f t personnel wbc handfled- and sprayea Agent Orange. </'s n }. These medical'and statistical studies show: iW 'No person is known to ever have died as a result of ^ ivV T(f-' exposure to dioxinCONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C230! -3- V I/X 4 A H known short-term health effects were non-permanent and gradually disappeared, once exposure ceased. Long-term human exposure has been scientifically linked to only one health problem -- a skin condition called chioracne. This skin condition is considered an important marker. Chloracne is widely regarded by medical experts as the hallmark, I or first visible symptom, of toxic exposure to dioxin. It manifests itself shortly after exposure (usually within two to three months) and in most cases clears up fairly rapidly. In a few instances, chloracne has been found to persist for up to 30 years. The overwhelming weight of medical evidence published in scientific literature to date indicates that a person who ^ does not get chloracne has not been exposed to a toxic or harmful level of dioxin, Q n 1 f-ir^brr flint nhlnrai^nn ir thr" -inly N ot documented long-term health e ffeot^ovor/observed-rn humans. ^ /Tke literature further indicates that there is no documented C\jLl Lb-W- I t ' p 4 ^ e v i d e n c e of any other long-term health effect to humans. Otf/-* ^ This opinion is shared by scientific groups including the American Medical Association and the British Advisory yMj-, (as, Committee on Pesticides. Others who have studied the evidence ic. and concur include a host of independent medical experts as ^` well as the Veterans' Administration and the U.S. Air Force. Every population includes many people who are ill. Certainly there are Vietnam veterans, some former residents of Times Beach and some chemical plant workers who are truly ill -- CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C23092 4 no doubt suffering a wide range of very real health problems, dic't'V*' which they may have concluded are linked toA exposure. Others who were exposed or fear they may have been exposed to dioxin are no doubt suffering mental anguish. S t i l A others may well be experiencing very real symptoms but from f psychosomatic illness. And, finally, some may well have become ill and depressed as they have watched their property values plunge and ..their life savings disappear. There is no scientific evidence linking exposure to dioxin with serious long-term health effects, and there is no evidence that the health of those who may have been exposed to dioxin is any different from^ those wittjno exposure. The Source of Fear) What are the factors that contributed to the current state of public fear? There are many. First is animal data. Dioxin is very toxic when fed to some species of laboratory animals. The guinea pig is by far the most sensitive.)^More than half the guinea pigs tested were^|//v^ almost instantly killed by a single oral dose of dioxin, in the\ billionth of an ounce rangej However, other test animals are far less sensitive and can tolerate doses ranging from 100 to ' 11*-1 ' 7,000 times greater than those of the guinea pig. It is on the basis of the extreme toxicity to guinea pigs that dioxin has been called "one of the most toxic substances jj ii t known to man." (Coincidentally, the guinea pig is also extremely^y/J^ sensitive to many highly beneficial chemicals as well, including / the penicillins.) ' CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C23093 When scientists do not have human data to rely on, they are forced to use animal tests to make human risk assessments. But the scientific community readily admits that it does not know how to accurately extrapolate animal data to humans. This I ,\?v: problem was at the root of the saccharin controversy a few A years ago, and i.t"saV still unresolved. However, it*'clear from the accumulated human data ,that we are not nearly as sensitive to dioxin & -- -- -------------- --- -------- y or probably any other laboratory animal. For on projections of lethal toxicity from animal as the guinea pig instance,I b^tsea studies, the ,, r: pf ,A<1,/jU accidental release of dioxin in Seveso, Italy, would-have killed ux fixctr every human being within miles of the incident; rVctnn?tAiy nn one died. In fact, the only documented health effect observed to date from this exposure has been some cases of chloracne. Another factor in the fear was the increased attention and public concern focused on dioxin when the Agent Orange controversy spread across the national scene in the late '70s. Sympathetic television reports first informed the public that Vietnam veterans were suffering from diseases and were fathering . deformed children -- both at "unusually large" rates. In fact, NI A, > , ... ' y ^ there was and still is no scientific evidence to support these ^ 1^ \ ^allegations. I Only three-thousandths of one percent (.003%) o f t - -A y 1 .Vtiie veterans thus far have been f o u n d t o be suffering any kind 0^ tfJ- J \C V / of health proble^m^ f h i k U W r . d LA*-*--- " Many Americans already sympathetic to problems the 'Vietnam veterans face, reacted with shock to the claims. Agent ^ Orange became a rallying point for some veterans, and its emotional appeal was magnified by television news coverage. J^But despite nearly five years of heavy publicity, of the 2.4 million CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. C23094 -6 - P tu American military personnel who served in Vietnam, than 10,000 have joined in the class action l a w s u i t ^ More recently, local and national news coverage has focused on the contamination of Times Beach, the Miny!er -Stout sites and other Missouri locations. News reports also were fueled by local hearings, by the Federal EPA resignations, congressional hearings and the Christmas Eve, 1982, pronouncement by an official of the Centers for Disease Control (CDC) urging the residents of Times Beach to evacuate immediately due to the "imminent threat'1 posed by the dioxin-tainted soil there. Together, these events led up to the EPA buy-out at a cost to taxpayers of about $33 million. Yet, not one resident of Times Beach or any other Missouri dioxin site has ever had chloracne. The CDC evacuation recommendation was made on the basis of a dioxin risk assessment which concluded that the presence of dioxin in the soil at levels above 1 part per billion (ppb) "constituted an unacceptable risk." The CDC's so-called "safe level" guideline of 1 ppb first assumes that humans are as sensitive to dioxin as laboratory animals and that dioxin is a human cancer-causing agent. Next it assumes that a small child may eat one gram of dioxin- contaminated soil every day for several years, while being further exposed to another gram every day through direct skin contact. CDC then added a safety factor of 1,000. Using this basis, CDC then projected that a child, so exposed for 6H years, would accumulate a large enough dose of dioxin to raise his/her risk of cancer by one additional chance in a million. It's CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. 023095 7- interesting to note that according to the EPA, smoking four cigarettes also increases the risk of cancer by one in a million. On this basis, the citizens of Times Beach were urged to evacuate immediately on Christmas Eve. (In October, 1983, the Federal CDC said tests on people exposed to dioxin in Eastern Missouri showed no "meaningful ill-health effects," though many frightened residents remain skeptical.) Industry critics including Samuel Epstein and E P A 's / Hugh Kaufman have used the dioxin issue to gain press and TV! coverage for their viewpoints. L' ^Dioxin also has become a potential source of huge cash rewards for a few attorneys of the plaintiffs' bar and some of the alleged victims of alleged dioxin exposure.^ Damage awards in a recent trial in Madison County, 111. -- while still on appeal -- could make millionaires out of some railroad workers and their lawyers. In that case, no evidence of the existence of dioxin or exposure to it was presented; the mere possibility of exposure was enough to convince a jury to find for the plaintiffs. The plaintiffs' bar recently formed a dioxin task force to share information about cases and coordinate future dioxin- related litigation. The costs of the fear and hysteria resulting from these factors are already staggering -- e.g., the Federal government's $33 million buy out of Times Beach, the mental anguish of many cconfused citizens, Ann-m-i n iqtv. CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. -8 These examples will be only a prelude unless reason and knowledge are brought to bear on socie^ai-guestions^pf this kind. Fear, hysteria, political on^legal exploitation a11 poor substitutes for reasoned decision-making-on public issues affecting the health, safety and livelihood of millions of Americans. It is clear that dioxin is not wanted in our environment. However, once it becomes bound to soil, it does not pose much potential for exposure. is toxic and/tfreat care should be taken in ensuring that dioxin-containing waste is disposed of properly and safely. Success in curtailing the amount formed from industrial and non-industrial sources should be and is being pursued with vigilance. Additional research should go forward to help scientists better understand this puzzling compound and its ultimate fate in the environment./-Health studies should continue until even L / n**.. the most cynical critic is finally convinced that dioxin is no ' Lit4*' a major health threatT) The best way of coping with the increasingly complex and costly decisions we face with dioxin is through objective, IfJ ^ '. i/6' reasoned evaluation of the true risk to mankind, and that risk should be based on good science -- not political expediency. Who pays the bills? We all do, of course. So it behooves those who make the judgments concerning risks and costs to make them carefully, unswayed by the hysteria of the moment. -0O0- CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. 023097