UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION WILLIAM R.

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UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 56138 / July 26, 2007 ACCOUNTING AND AUDITING ENFORCEMENT Release No. 2658 / July 26, 2007 ADMINISTRATIVE PROCEEDING File No. 3-12712 In the Matter of DELTA & PINE LAND COMPANY and TURK DELTAPINE, INC., Respondents.I.

) Monsanto A .

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI - EASTERN DIVISION x VOLUME I WILLIAM R.

1930s -- Chloracne, a dermatitis characterized by blackheads similar to teen-age acne but often more severe, was noted among workers dealing with chlorinated aromatic hydrocarbons (chloracnegens). 1941 -- 2,4-D and 2,4,5-T first synthesized, 1944 -- 2,4-D and 2,4,5-T reported as herbicides and marketed by Amchem Products. 1947 -- Effectiveness of 2,4,5-T and derivatives against woody plants resistant to 2,4-D established by Dow, 1948 -- 2,4,5-T registered for control of weeds on rangelands, fence rows and rights of way, 1949 Explosion in Monsanto's 2,4,5-trichlorophenol (TCP) unit at Nitro, W.Va. exposed 250 workers to reaction mass causing 122 cases of chloracne, some very severe.

IN THE CIRCUIT COURT TWENTIETH JUDICIAL CIRCUIT OF ILLINOIS ST.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OE MISSOURI EASTERN DIVISION WILLIAM R.

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TABLE 1: Summary of Industrial Incidents Resulting in Possible Exposure to 2,3,7,8-TCDD Date of Incident Manufacturer 1936 1937 Lumber Company (user, not a manu- facturer) Dow Chemical Co. 1949 Monsanto Company 1949 N.A. 1952 N.A. 1952-53 Boehringer Plant Locations Product Process Used3 Mississippi/ United States Use of Dowicide H Treating lumber Midland, Michigan/ United States 2-(2-chlorophenyl) phenol; tetrachlorophenol Nitro, West Virginia/ United States TCP; 2,4,5-T Nordrhein, Westfallen/ West Germany PCP; TCP Nordrhein, Westfallen/ West Germany TCP N.A.C A N.A.

M_P{ e- 's't px 2/fV J : 698 TOWNSEND IT Al* Ta ils 1 rophenol or pentachlorophenol processes.

STATE OF MICHIGAN \ # *> James J.

77 ri EASTERN DIVISION WILLIAM R.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION WILLIAM R.