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t {) ROBERT L. METCALF ) 2002 Golfview Drive Urbana, Illinois 61801 April ij, 1969 Dr. W. R. Hiehard Organic Chemicals Division Monsanto Company 800 H. Lindbergh Boulevard St. Louis, Mo. 63166 . ' . Dear Bill; ' Thank you for your letter of March 31, which arrived today. I arn attaching a report of the visit to Industrial Bio-Xc3t which covers the information I received there and Includes some conclusions and recommendations which you may find of interest. I can only conclude from revaluing the data that there is a serious problem. As I indicated the Bio-Test Program in the main seems sensible. Ky overall impression is that some of the toxicology is more extensive than varan cod. I feel that the PCB problem wi11 have to be attacked by doing soiiething to prevent further environmental contamination rather than by defensive action. The latter in the cass of DDT has not done anything to still the public outcry. It seems clear that environmental contamination by such highjy stable lipid soluble substances is highly undesirable and must b'e corrected. I am personally quite interested in this problem and think it important to determine the extent of biodegradability'of the various typical PCB's. Perhaps we can look into this matter in our laboratory as this falls into the general purview of uy Ffasch Foundation and Public Health grants on environmental biodegradability. If you could provide small samples of the various typical Arochlors and in particular a low milligrams of known chlorinated biphenyl ..compounds, we shall plan to study their possible hydroxylation in the model Udenfriend system and if we can work out the methodology will look at one or*. two in our small experimental ecosystem test for biodegradability. I shall continue to follow this problem vith interest and will hope to discuss it with you early next month when I am in St. Louis. Meanwhile do not hesitate to call me if I'can be of help. Yours sincerely Robert L. Metcalf DSW 019737 STLCOPCB4007670 Robert L. Metcalf ; From the background data presented it appears that something of the order of 80 million pounds of polychlor biphenjO-s (PCB) are produced annually, These products contain from 3 to 9 chlorine atoms per molecule and become increasingly inert and stable to environmental oxidation with higher degree of chlorination. However, about, half the production is in the 3-chlorine atom variety (Aroclor.'.'12h2)^ At first thought it seems unlikely because of the major uses of PCB in capacitors, transformer oils, heat transfer fluids in closed systemt, that these materials could be the source of the substantial degree of environmental contamination reported. However, about I4O million pounds annually is stated to be used as plasticizers, hydraulic fluid, ' adhesives, and in carbon paper. From this amount a very substantial percentage must escape into the environment as waste. Because of the apparent high stability of PCB, amounts entering the environment would be degraded very slowly and it seems possible that at least lOmillion pounds annually may become environmental contaminants. Since the PCB's were introduced commercially in 1?2? there have been UO.-years of production. If this has averaged $0 million pounds per year, then about 2 x 10^ pounds have been 8 made and perhaps 2 x 10 pounds have entered the environment,. Because of the apparent stability of these compounds most of this amount may still be circulating in the global ecosystem and this is suggested by the levels reported by Holmes jst al. (1967) and Risebrough et al. (I968) in animal tissues which are quite comparable to those found for DDT, Both PCB DSW 019738 STLCOPCB4007671 o) and DDf are extremely stable and water insoluble and have been produced in roughly the same total amounts over ths past 30 years. i'hus it seems quite reasonable to conclude that the environmental contamination described for PCB is due to waste amounts of these compounds. Ms, coupled with the thorough evidence from mass spectometry strongly suggests that there is an important environmental quality problem involved In vrastes of PCB, This laboratory is highly experienced and seems quite competent to provide standard data required by PDA for evaluating the safety (or hazard) of agricultural or industrial chemicals. 1`he long term feeding studies on rats and dogs will doubtless serve to indicate the chronic toxicity hazards of chronic ingestion of the PCB at ppm levels and this vail almost certainly result in severe liver damage at some reasonable level, fhe chicken reproduction investigations at 0.01, 1, 10, and IDO ppm should be considerably more meaningful particularly in regard to studies of egg hatchability, shell thickness, etc.. While the fish toxicity investigations will be interesting, I cannot see that they are particularly relevant or necessary at thi3 time and I would think this data could be obtained from Pish and Wildlife investigations, etc,, and will undoubtedly be forthcoming, unsolicited, '' . '\ Conclusions and Suggestions..-- It seems to the writer that the evidence regarding PCB effects on environmental quality is sufficiently substantial, widespread, and alarming to require immediate corrective action on the part of Monsanto, The defensive measures presently inderway will do little if anything to DSN 019739 \ STLCOPCB4007672 _3_ ; refute the evidence already presented* I would suggest the following} 1*. A substantial analytical program to monitor air and water effluents . from Monsanto plants producing PCB and also those of major customers. 2, Prompt correction of effluent conditions where PGB can bs demonstrated.. . , 3, Serious consideration of curtailing sales of PCB far uses such as plasticisers* adhesives* and carbon paper where waste is certain to enter environment* . h. Review of disposal and recovery methods for PCB in capacitors, transformers, heat transfer fluids, and hydraulic fluids* -Emphasize to customers importance of preventing environmental contamination*. 5*. Thorough investigation of environmental fates of various PCB's including photochemical oxidations, chlorination in water systems, etc. ' 6*. Biochemical and electron microscopic study of levels of PCB ingestion which cause proliferation of endoplasmic reticulum and induction of multifunction oxidases in chichens and rats (perhaps these are partially included in present Industrial Biotest experiments), ' 7. Begin investigations of possible biodegradable substitutes for .... RGB's a3 plasticizers, adhesibes, fire resistant hydraulic fluids, etc., anticipating loss of these markets as a necessary corol&ary of environmental - problems*. Are, for example, chlorinated diphenyl oxides or diphenyl sulfides suitable for these uses. They should be Considerably more biodegradable,. DSW 0197*0 STLCOPCB4007673