Document y3O5j7j8jj621pGwpoERQQ3D

.'..'"SImO I.'.'L'tfCTitfAL CiEMICALS CO. .... R. H. Munch - S. Second St. - St. Louis March 9, 1972 P. G. Benignus - GO ^-W. R. Richard - GO ,W. B. Papageorge TO 'General Offices B2NK w<* ^ You have ashed for ray comments on the latest draft of ANSI Committee C-107 proposed guidelines for handling a3karels in the manufacture of capacitors. They are as follows: 1. The proposed guidelines represent a very great step forward because they show that the capacitor industry is beginning to understand the problem and is beginning to think about how to try to solve it. 2. The great problem is not what you or I or others connected with production and use of askarels think but whether or not we can secure agreement from environmentalists and government agencies that the guidelines are adequate to protect the public - present and future. '' They will not be convinced unless we supply supporting data. The data needed are: a) Proof that the lower PCB's do degrade more rapidly than the higher ones. -------- b) The best possible data on rates of degradation by ail mechanisms - photo, bio, oxidative or others. c) Data on toxicity. d) Data on migration of PCBs through soil. e) Data showing how much the already accomplished industry actions will reduce PCB input, particularly higher PCB Input, to the environment. Were these guidelines approved by the whole committee - including members who represent the government and environmental viewpoint or only by Industry representa tives? 5-. I am returning parts of the draft with minor errors which you will want to correct marked. 6. We need a similar document for the transformer industry. I think that if we supply supporting data and get a guideline for the transformer Industry too, we should be able to win. db Vw m 1 R. H. Munch MOWS U99453 iv (. -.A_ \j^-c5bjj[ju l\Mx--j{& 6-v^ <Sr' a 5 ..,-<>\ S' t\r u<rv~ 5? v'SCWu-C ' ` |^a^jz/o a^L^tuu^w4c Qk4 c, k^-cl c>-^ <JCrW/VV'-0-^ t >J <:atX-C_ wu^yvir^-rv~ kxjrt-'k k~. ^rZ^CjTjiao. Cf ^){eS' ^viWrv_ -- Cu-ixJl A^.a^u\" o^-<Lc^. &d/\Jke*4JU.d 4-tfw <k-tur* C <^ru '* (Q. JlUutdl M OuxLO. '^L*i Urtrd^ , gX^Jm^ O-^ C&JL <C' ft.A MONi 099454