Document zdjkEypjqedYvv5oOz6Mgomv7

February 3, 1971 0riff1th E. Qulnby, M. D. Consulting Toxicologist Preventive Medicine Post Offlca Box 1313 Wenatchee, Washington 988OI Dear Dr. Qulnby1 Thank you for your letter of January 20, which arrived on the 27th, at which time X was out of town and Just returned. I appreciate very much your Interest In the polychlor inated biphenyls and am happy to reply serially to the questions raised In your letter concerning the "Monsanto Statement on PCS" printed In Environment, Vol. 12, No. 1. May I preface my answers with the comment that we take no responsibility for Dr. Rlsebrough1s statements In the publication and I am assuming that your questions relate to the Monsanto statement published therewith. Now, as to your questions* 1. The Monsanto statement supplied Environment Magaslne wss prepared with my collaboration and approval. My Interest In the toxicity of and occupational hasards Involved with the polychlorinated bi phenyls and terphenyls dates back to 1936. X recall vividly the first meeting held at Harvard under the sponsorship of Dr. Cedi Drinker to discuss the early results of research carried on under hla direction on the chlorinated blphenyle MONS 089553 Orlfflth B. Quinby, N. 0. February 3, 1971 Pag* Two and chlorinated napthalanea rtnt. 1. Ind. Hyg. Toxicol. 19, 300 (1937i/- You nay be aura that the Medical Department at Nonaanto haa been aware of all subsequent publloatIona relating to the toxicity of chlorinated blphenyla and terphenyla. The literature Indicate* that there waa a number of Incidents of lnduatrlal effects In the late 1930'a from the us* or a waxy material composed of chlorinated napthalenea, chlorinated blphenyla and chlorinated diphenyl ether. I submit, however, that there have been few Instances reported since 1940 concerning 111 effects in workers exposed to the chlorinated biphenyls or ohlorlnated terphenyls when uaed alone. In the rare cases that have been reported, the reecnended procedures for safe handling and usage have been Ignored. 2. Monsanto has been aware that In the early and mid1950's there was some us* of PCS'* as extenders for pesticides where the formulations were applied to field crops or. In the case of research sponsored In New York State not participated in by Monsanto, on forests for attempted control of elm tree disease. These experiments were based on research efforts of the USDA. As far as our records Indi cate these were abortive attempt* In using the PCB's In "broadcast applications'' on perhaps all kinds of crops. The facts as we know them ax** that uses never did develop where the PCB's were Incorporated In formulations for "broadcast appli cations" to agricultural arops such ae vegetables, animal feed, ootton, citrus, etc. I don't have exact figures but X would estimate that something less than 100,000 pounds of PCB's were ever used in experimental or semi-commercial applications. To me and to our company this does not represent "broadcast application" as the term Is generally uaed now and as It relates to the application of most common agricultural lnseotleldes. 3. Most of the possible uses of PCB's reon--ended as possibilities in our Technical Bulletin 0/PL-306 remained as possibilities. It la true that PCB's were used In specialty (industrial, corrosive resistant) paints; In specialty rubber for sealants (not automobile tires as has been alleged); In specialty adhesives ror many purposes. They were not widely used In lubricant* or cutting oils. I don't know what la meant by "carburetor fluids". MONi OrIff1th S. wulnby, N. 0. February 3, 1971 Fage Thraa Aa to whether or not auch uaaa could lead to the PCB'a getting Into the environment, I wonder If In late 1969 when we aupplled the atatement to "Envir onment" you would have predicted the current aituatlon aa regarda mercury. 4. We have not had any oaaee of occupational lllneea In our workers manufacturing PCB'a, with the one exception mentioned (page 307, J. Ind. Hyg. Toxicol, referred to above). As I have Indicated earlier, there were incidences of occupational Illness In the late 1930'a and per haps early 191*0'a. X believe the facts are as Indi cated above that these were from uses where the polychlorinated biphenyls ware used In conjunction with other chlorinated hydrocarbons. X would alao point out that the number of Instances may have been exaggerated since at that time one state health or labor department after another published bulletin after bulletin referring to the original cases. In this way there may have been aone magnification of the seriousness of the situation. I repeat again for emphasis that we know the cases that occurred did not Involve the use of polychlorinated blphenyla alone. In the mld-1950'a we sponsored work at Kettering Laboratory (see reprint enolosed) which X believe Is the most definitive in terns of potential occu pational hazards that has been done. Since the question of possibility of the PCB's getting Into the environment came to our attention we have under taken a number of reaeareh and other projects. These have been auch that X can honestly say that I aa proud of the way Monsanto has responded to the situation. We have, for example, undertaken chronic animal feeding studies such as would be required If we were to consider applying for a food additive petition with the FDA. As data have been forthcoming on an Interim basla from these studies, we have provided copies of the data to represen tatives of the Offloe of Science and Technology or the President, to the Food and Drug Adsdnlstration, the D. 3. Department of Agriculture, the Fish and Wildlife Service, the Federal Water Quality Agency and other toxlcologlsta MQNS 0B9555 Orlfflth K. Quinby, M. D. February 3# 1971 Pag* Pour In th* United Stat** and abroad. A statu* report on the** studle* ha* b**n accepted for presentation at th* 1971 meeting of th* Society of Toxicology. Briefly, I believe that all of th* toxlcologlata who hav* r*vl*w*d th* data concur that PCB'a are no more and proba bly l*as toxlo than DDT. This ha* b**n most reassuring to u* in term* of wh*th*r or not any PCB In th* envir onment la a threat to th* public health. Equally Important, we hav* c*a*d all sal** of th* poly chlorinated biphenyl* In thoa* applications where acap to th* environment cannot b* prevented. Us* In electrical transformers, on th* other hand, will continue but with provisions that th* fluid In th* transformers will b* returned to Monsanto for Incineration If It cannot b* reclaimed for reua*. In short, w* no longer sell poly chlorinated biphenyl* for uses which cannot b* controlled. I would hop* that you would agree that Monsanto has reacted In a most responsible fashion. I would hasten to add, however, that any action on th* part of ay com pany has been based on the development of sound data developed by ourselves and responsible scientists. It has not been reaction to pSlitlcal pressure nor th* more activist scientists and pseudo-solentlsts who, I know you appreciate as much as X, have becoew so prominent In today's emphasis on restoration and enhancement of th* environment. Pleas* understand X agree completely that there has been and continues to be deterioration of our environment. X am convinced, however, that steps for Improvement must be taken on a rational and objeatlv* basie. In conclusion X feel Monsanto has taken a realistic attitude towards the PCB's based on facts as they hav* developed. At no tins hav* w* mads efforts to ooneeal th* truths about PCB's. Should you hav* any faots In your possession that Indicate otherwise, X would be happy to receive them. Very truly yours, MOMS 089556 JUOCiJu R. Emmet Kelly, N. D. Medical Director Enclosure (Tox. of Vapors of Aroclors 1242, 1254; HOS on Chloro- b.c. V. B. Papageorge diphenyls)